ML19321B142
| ML19321B142 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 06/23/1980 |
| From: | Widner W GEORGIA POWER CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML19321B141 | List: |
| References | |
| NUDOCS 8007280128 | |
| Download: ML19321B142 (42) | |
Text
_ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _.
f g?
7(
4 5
[,Y,',I,b.
[J b.
w w,om,
June 23, 1980 L
g rgia Power United States Nuclear Regulatory Commission Office of Inspection and Enforcement Region II - Suite 3100
REFERENCE:
101 Marietta Street, NW RII: WHM Atlanta, Georgia 30303 50-321/80-02 50-366/80-02 ATTENTION:
Mr. James P. O'Reilly Gentlemen:
to the NRC letter dated AprilGeorgia Power Company hereby submits 11, 1980, concerning the engineering evaluatior response of the approved fire protection modifications at Plant Edwin I
. Hatch:
Deviation A states in part that " documentation is not available modifications required by the Fire Protection Saf (FPSER) and the Hatch Fire Protection Program Evaluation (F eport C of Appendix A to the NRC's Branch Technical were (BTP9.5-1)."
n In order to provide reasonable assurance that the fire protection modifications were made in accordance with design sp drawings, etc., an evalation was conduced in two (2) phases j
- ons, conducted by our Fire Protection Consultant, Professional Loss Co Phase I was j
Inc., Oak Ridge, Tennessee.
the fire protection systems modifications or installations madP sult of commitments referenced in Table 3 of the H e as a re-Evaluation.
as it affects the Plant Hatch Fire Protection Progra program of this review was submitted to representatives of the NRC (A draft copy in Atlanta, Georgia on June 2,1980.
draft has been enclosed for your infonnation).An additional copy of the review that future installation and modifications will be m 1
re of the 10 criteria.
e application As a result of this review, eleven (11) recomendations were made fire protection consultant (pages 23 through 32 of the Qualit y the Engineering Review).
and components as "Q",referencing them in the Equipment Loca y Assurance as "Q",
and a review of inquiries or specifications for proc already been initiated to insure that future modifications will be urement have in accordance with the 10 QA Criteria for Fire Protection e
Also during this 8007egok N
l GeorgiaIbwer A United States Nuclear Regulatory Commission Office of Inspection and Enforcement j
Region II - Suite 3100 June 23, 1980 Page Two
~
engineering review, the fire protection consultant along with Georgia Power Company site and corporate personnel, Southern Company Services, Inc.
engineering and fire protection personnel and Bechtel Power Corporation engineering personnel met to develop and define a " Fire Protection Philosophy" for each safety-related and non-safety-related area of the plant. The purpose of these philosophies is to " establish the fire pro-tection needs for each plant area and document the basic approach to be taken to meet the philosophy". This step was taken to insure that "all quality assurance for plant fire protection systems and equipment will have to be directed toward the satisfaction of these basic philosophies.
Any deviation from these philosophies will require sufficient documenta-tion to justify the change". These philosophies will become a permanent part of the Hatch Fire Protection Program Evaluation.
Phase II of this engineering evaluation included a Quality Control inspection of not less than 10% of the material or components installed per commitments in Table 3 of the Hatch Fire Protection Evaluation.
In some cases we were able to trace back to construction documentation and inspection records, letters of certification, maintenance requests, etc.
generated during the system modification in tiiose areas where records are apparently sufficient to support the installation and operation of a system or component to QA criteria.
A breakdown of the review of each modification or installation made, the method of review, and the results of that review is listed below.
1.
Sprinklers - The total amount of piping of each size was calculated and 10% of that total was either ultrasonically tested or visually verified to be the size and schedule as specified on the system drawings,10% of the total number of hangers, fittings and spray heads were visually inspected to insure they were of the proper size, material or temperature rating as specified on system drawings.
Only one discrepancy was found during this inspection. The Intake 0
Structure drawing specified 135 F spray heads. The spray heads used were 1750F rating. These were used because of the high ambient temperature within the intake structure during warm weather months.
Specifications will be changed to correct this discrepancy.
2.
Fire Doors and Fire Walls Control Room - Fire doors were visually inspected to verify their rating is consnensurate with that of the walls and that the door frames are UL labeled.
Integrity of the fire walls was verified by a visual inspection and documented on a maintenace request at the time the walls were modified. This documentation is filed on site and is available for review.
m
a Georgia Pbwer A e
. United States Nuclear Regulatory Commission
~0ffice of Inspection and Enforcement Region II - Suite 3100 June 23, 1980 Page Three Fire Pump House - Fire doors were visually inspected to verify their rating is comensurate with that of the walls and they were installed per manufacturer's recommendations.
Fire walls were visually inspected during initial installation. The inspection was documented on i
a maintenance request which is filed on site and is available for review.
I i
One discrepancy was identified during the inspection:
it was noted that fusible link placement on the fire pump house roll-up doors was not in accordance with the criteria established in NFPA 80. A design change request (DCR 80-30) has been written to add additional ceiling level fusible links.
3.
Oil Collecting Curbs - Integrity of the oil collection curbs for both the Recirc MG set rooms (Units 1 and 2) and the RHR service water pumps (Units 1 and 2) was visually verified.
Volumetric storage capacity of each of these areas has been calculated and the results 4
indicate that the curbed areas are capable of containing 3 to 7 times the capacity of oil contained in the pump lubrication systems. These calculations are filed on site and are available for review.
j 4.
Fire Pump Annunciators - Documentation in the form of red-lined prints, a maintenance request for installation and functional test for verification of operability are filed on site and are available
+
'or review. This documentation should substantiate the use of QA criteria for installation of the annunciators.
i 5.
Fire Dampers - Documentation in the form of materials receipt inspections, a maintenance request for installation, installation inspection reports and a functional test to verify operability of electro-thermal links is filed on site and is available for review.
This ' documentation should substantiate the use of QA criteria for installation of the fire dampers.
6..
Penetration Seals - Documentation in the form of maintenance requests,
.a vendor QA manual, vendor QC inspection reports, penetration seal material certification, etc. is filed on site and is available for review. This documentation should substantiate the use of QA criteria for installation of penetration seals.
f 7.
Reactor Recirc MG Set Room Structural Steel Coating - A visual inspection of all structural steel coating within these rooms was performed with no discrepancies
{
, _ _ _.. _ ~..
,,m_
,--,..,,_.,,m.
Georgia Power d United States Nuclear Regulatory Commission Office of Inspection and Enforcement Region II - Suite 3100 June 23, 1980 Page Four identified. QC documentation was generated during preparation activities and application of the coating. A search for the documentation is being conducted by site personnel and the con-tractor that made the application.
If records cannot be located within the next 30 days a sample of the coating will be analyzed to determine its composition which, in turn, will disclose the man-ufacturers' recomenoud coating thickness.
Once this has been determined, test will be conducted to verify coating thickness.
8.
Kaowool - The inspection included approximately 10% of the installed linear footage of Kaowool for area tray coverage. After the Kaowool was installed design engineers from the Bechtel Power Corporation reviewed the on-site installations made by Georgia Power Company for the purposes of issuing of as-built notices and to identify any deficiencies. Two proposed design change request (B2E-087 and B2E-089) were issued and as-builts for the East Cableway were issued which showed the necessary installations to meet commitments ar,d to provide good fire protection practices (Ref. DCRs79-299 and 79-373). This documentation is filed on site and is available for review.
During the 10% inspection no discrepancies were identified. Some Kaowool was being replaced due to maintenance activities.
9.
Detectors - 10% of the total number of detectors installed per commitments were inspected for location as specified on drawings.
The only exception to this was the HVAC room on the 164' elev.
of Unit 1.
This area was not checked due to airborne contamination problems.
The following discrepancies were identified during the inspection:
o Control Room Peripheral Rooms - 2 detectors were checked and 1 was off horizontally by 2 feet.
e Cable Spread Room - 4 detectors were checked and all were within specs horizontally but were located 3 feet from the ceilir.g which is not within specs.
All other detectors in other areas appeared to be mounted and located properly. Steps have already been taken to review all areas of the plant to identify other discrepancies. Design changes will be made as necessary to correct any problems.
Functional test, vendor certification of the systems, c,d construction daily inspection for installation of wiring is filed on site and available for review.
l
- - ~
e Georgia Power d United States Nuclear Regulatory Commission Office of Inspection and Enforcement Region II - Suite 3100 June 23, 1980 Page Five A plant inspection has been conducted for almost all areas containing fire protection components or systems. Georgia Power's Fire Protection Consultant has identified any problem areas and has noted them in the
" Fire Protection Philosophy". As a result of the deficiencies noted by the Consultant, the NRC inspection of January 1980, and the 10% inspection, modifications will be made to all systems as needed to bring them into compliance with codes where possible and into compliance with good fire protection engineering practices where it is not possible or practical to meet fire codes. All modifications are expected to be complete by January 1981, where possible, and for those areas which may require a plant or unit outage in order to conduct modification activities, the modifications are expected to be complete by May 1, 1981.
If you have any questions in this regard, please contact this office.
Sincerely, J. a.. W(k (Jek'l
/
W. A. Widner 9'.a JAE/BEB/mb Enclosure
_PL C "+"i ""! "" cc""< !"c-l ENGINEERING REVIEW Of The QA PROGRAM As It Affects The PLANT HATCH FIRE PROTECTION PROGRAM May 1980
/
l 1
l I
P. O. Box 446 e Oak Ridge, Tennessee 37830 * (615) 482 3541
e TABLE OF CONTENTS Page Foreward............................
1 In+-
ction..........................
3 Summary of Findings 4
Design Control and Procurement Document Control......
6 Instructions, Procedures, and Drawing...........
8 Control of Purchased Material, Equipment, and Services 8
Inspection 9
Tes t and Tes t Control................... 9 e
l Inspection, Test, and Operating Status 9
Nonconforming Items and Corrective Action........
10 1
)
Records.........................
10 j
-1 Audi ts 10 Plant Hatch Fire Protection Philosophies......
..... 11 Areas Wi th Impact on Plant Safety............
12 Non-Safety Related Areas 19 Recommendations
.......................28 Detailed Inquiry Review Appendix A
FOREWARD The preparation of this report required the compilation of extensive information relating to the quality assurance program for the fire protection program of Plant Hatch.
Appropriate portions of the Hatch Nuclear Plant Quality Assurance Manual (HNP-QAM), Southern Company Services, Inc., Plant Hatch Operational Support Policies and Proce-dures, and S'outhern Services, Inc., Engineering Policies and Procedures were surveyed as a part of this informal engineering review.
In addi-tion, specific personnel involved in the program were interviewed.
Because of Georgia Power Company's limited involvement in the design of past fire protection systems corporate procedures were not evaluated.
For their part in providing the information, we gratefully acknowledge the cooperation of the following individuals: Mr. W. A. Widner, Mr. J. C. Beckham, Jr., Mr. D. W. Howell, Mr. M. Manry, Mr. J. R.
Jordan, Mr. D. McCusker, Mr. C. Belflower, Mr. C. R. Miles, Mr. K.
Kraven, and the Hatch Plant Review Board (PRB) from Georgia Power Company; Mr. W. F. Garner, Mr. J. C. Vance, Mr. D. Bush, Mr. J.
Ni chols, and Mr. J. Clark of Southern Company Services, Inc.
A special thanks is extended to Mr. R. H. Taylor and Mr. B. E. Brown for their help and patience during this project.
1
+ +,..,++** w *+--
m
y--
4 l
This survey was performed by Mr. M. E. Mowrer, P.
E., Senior Fire Protection Engineer, Professional Loss Control, Inc. (PLC). Tech-nical support was provided by Mr. D. S. Mowrer, P. E., Senior Fire Protection Engineer, PLC.
Overall supervision and review was pro-vided by Mr. K. W. Dungan, P. E., President, PLC.
Mr. M. E. Mowrer, Mr. D. S. Mowrer, and Mr. K. W. Dungan exceed the qualifics ons defined in Reg. Guide 1.120 and have extensive fire protection experience in the nuclear utility industry.
2
INTRODUCTION In February,1978, Plant Hatch committed to the Nuclear Regulatory
- Commission to provide the quality assurance program outlined in Attachment No. 6 to the Supplementary Guidance for the NRC Nu: lear
' Plant Fire Protection Functional Responsibilities, Administrative Controls and. Quality Assurance.
Up to the present time, however, installations of, and modifications to fire protection systems and equipment have generally received little formal quality assurance.
Certain elements have received fairly stringent quality assurance and control such as cable penetration seals, fire dampers, and to a lesser tatent fire detection systens, but these have been the excep-tion rather than the rule.
The purpose of this informal engineering review of the fire protection quality assurance program was to determine its adequacy and complete-ness with respect to future installations and modifications and will not address past problems.
3
SUMMARY
OF FINDINGS The engineering review of the fire protection quality assurance (QA) program indicated that while all parties involved have necessary QA procedures available to them, the procedures are not required to be utilized.
For example, no quality control is applied at the plant site for non-Q items while detailed procedures for quality assurance and quality control are already previded for Q listed items.
(Fire protection is considered r.on-Q with the exception of cable penetration seals, fire dampers, and at least pieces of the fire de-tectionsystems.)
In order to ensure that adequate controls are provided to meet the previous commitment to the NRC, fire protection systems and equip-ment must receive a similar level of control to that presently pro-vided for Q items.
It should be emphasized that the 10 items committed to for fire protection address 16 of the 18 criteria outlined in 10 CFR Part 50, Appendix B, but in a reorganized format.
Only items XII and XIII (Cor.;rol of Measuring and Test Equipment, Handling, Storage, and Shipping) are not specifically discussed in the 10 fire protection criteria, so there is no obvious reason for not including fire protection in the existing plant QA program for Q items which is already available and fully operational. Another advantage to 4
considering fire protection Q is that if it is included under 10 CFR Part 50, Appendix B, then a detailed description of the specific fire protection QA plan does not need to be submitted for review by the NRC. This approach seems the most straightforward and workable in ensuring that the required controls are provided.
In fact, con-sidering fire protection as Q seems to be the only mechanism presently available to Georgia Power to trigger the necessary controls.
SCSI can reportedly, however, initiate the appropriate procedures at the discretion of the SCSI supervisor without necessarily calling an item Q.
The overall Plant Hatch fire protection QA program appears to be adequately organized to satisfy the requirements of the NRC. The responsibilities for the actual fire protection program, however, are fragmented and seem to. lack the overall coordination required to ensure effective implementation. This organization will be discussed in detail as a part of the report on the engineering review of the Administrative Control program which is now in process.
5
-ummem y
- a goe e
-=
w.
- =e op._
g me
=+
- =-ag.
a e
9 Design Control and Procurement Document Control Each design of, or modification to plant fire protection systems or equipment is reviewed by the PRB and Plant Engin'eers to ensure compliance with NRC commitments. The FSAR is used as one of the primary bases of determining compliance.
The paper route taken by the DCR (the Design Change Request is generateu to accomplish the work) varies depending upon whether or not the design package is developed on site.
HNP-809 does not appear to reflect these differences.
In addition, qualified fire protection personnel do not review gli DCR's for their impact from a fire protection standpoint.
DCR's specifically related to fire protection systems and equipment may, however, be adequately reviewed during design depending upon the design organization involved.
In order to evaluate the fire protec+ ion system procurement process, we have reviewed the inquiry number SS-6916-7 for Intake Structure Fire Protection Sprinkler System for Georgia Power's Hatch Nuclear Plant Units 1 and 2 dated December 8,1977.
In general, the speci-fication was found to be not specific enough.
Of the 49 pages included, only 18 pages directly influenced design while the remaining 31 pages of " boiler plate" added to the difficulty of determining exactly what 6
m
- mem- +
+
was required. Specific details concerning system design criteria and function were omitted entirely.
The piecing togethe of several related documents 1,n the inquiry has resulted in some paragraphs which are confusing and others which are conflicting.
The final document results in a specification which can be bid on by qualified vendors, but the design is left to the discretion of the vendor. This can result in serious problems since many sprinkler system vendors are not familiar with the unusual characteristics of modern power plants that can affect system. design.
Since the speci-fication was so vague, it would be difficult, if not impossible, to determine lack of compliance with it from a site QC standpoint.
Several of the existing SCS Engineering Policies and Procedures provide excellent means of providing the necessary QA control du ~.ig the design and procurement stages if carefully adhered to.
For example, Section 7.3.3.2.a establishes a good point of requiring documentation for any deviations from the design bases.
Section 7.3.4.2 requires the review and approval of the vendors' QA program.
Section 7.3.4.3 routes a copy of the inquiry to the operating company for review and comment prior to issuance which is a very important feature.
7 n
v
Instruction, Procedures, and Drawing The necessary programs and procedures are now available and, if fire protection is considered a Q item by the plant, appropriate mechanisms
.are in place to ensure compliance with the QA commitments.
Control of Purchased Material, Equipment, and Services Selection of appropriate procedures to control the work done by vendors is now at the discretion of the SCSI personnel involved.
This process should be adequate when SCSI personnel are informed of the level of
~
QA required for fire protection in the future.
(Only SCSI is discussed because of their primary involvement in the design of fire protection.)
Unless material is considered to be Q no inspection is made of equip-ment received at the site.
For Q items, a Material Inspection Request (MIR) is automatically triggered which will require that incoming materials be inspected.
In order for the on-site QC personnel to provide the inspections required, it will be necessary to provide them with a copy of the inquiry, a bill of materials, and appropriate acceptance and rejection criteria for the system.
8 e
Inspection QC personnel are available to perform and/or review the inspection functions committed to but are not presently provided with sufficient information to audit against in many cases.
Since the on-site QC personnel have no particular expertise in fire protection, it will be necessary to provide them with specific acceptance and rejection criteria for each item to be inspected.
Test and Test Control Personnel who perform, observe, or review tests of fire protection systems during their original installation or for routine surveillance tests (such as those required by Tech Specs) have not necessarily received any particular training to qualify them for these tasks.
Inspection, Test and Operating Status Specific pieces of fire protection equipnent are not identified by any temporary marking to show whether they satisfactorily passed the required tests.
(Fire extinguishers are an exception to this general-ization.)
For example, fire hoses are hydrostatically tested per Tech Spec requirements, but the hoses themselves are not marked 9
l i
when tested so there is no way to verify that the hose located at a specific standpipe was actually tested. Hose houses offer a similar problem.
Nonconforming Items and Corrective Action Appropriate measures are provided to document and control items which do not perform as required and to correct the problems identified.
Records l
1 All records relating to fire protection are kept by Documentation 1
where they are identifiable and retrievable.
Audits QA personnel perform periodic (at least annual) audits of the fire protection program requirements. This frequency is considered to be adequate.
10
.e
PLANT HATCH FIRE PROTECTION PHILOSOPHIES In order to audit the design of fire protection for any plant area it is necessary to understand the philosophy established for that area. The tables which follow were generated in an attempt to establish the fire protection needs for each plant area and document the basic approach to be taken to meet the philosophy.
All quality assurance for plant fire protection systems and equipment will have to be directed toward the satisfaction of these basic philosophies.
Any deviation from these philosophies will require sufficient documentation to justify the change.
These philosophies were generated by a committee with representatives from the following grcups attending all meetings:
Professional Loss Control, Inc., Georgia Power Company, Plant Hatch, Bechtel, and Southern Company Services, Inc.
For convenience the philosophies are divided into two groups depending upon their impact on plant safety.
i 11
V '
O PLANT HATCH FIRE PROTECTION PHILOSOPHIES FOR AREAS WITH IMPACT ON PLANT SAFETY O
4 O
-=
rtant ran PLANT HATCH l
~
AREA HAZARD FIRE PROTECTION PHILOSOPHY HOW ACCOMPLISHED FIELD NOTES Control Room cabling and ordinary Reduce damage to the control General area detection above Detector spacing and loc (164' EL) combustibles such as room even though remote shut-and below the op?n grid ceil-tions will comply with il (Hatch Fire Pro-bocks and papers down does not require the ing is provided ior early 72E requirements.
gram Evaluation, area.
warning.
Page 8)
Peripheral Kooms ordinary combustibles Prevent a fire from spread-Early warning detection and Detector spacing and loc (not safety re-and cooking in the ing to the control room.
physical barriers are tions will comply with N lated) (164' EL) kitchen provi ded.
72E requirements.
(Hatch Fire Pro-gram Evaluation, Page 8b)
Cable Spread extensive cabling Prevent a large fire and Early ware.
- detection, The location of the cros (147' EL) limit potential for spread ceiling level pre-action zoned early warning detG (Hatch Fire 'ro-between Units 1 and 2 even sprinklers to spray at least tors will meet the requi graq Evaluation, though remote shutdown is in-one side of each cable tray ments of NFPA 72E. The Page9) dependtnt of this area.
(where practical), physical ceiling level pre-action barriers for redundant trays sprinkler system will be in close proximity, some generally designed per N; cable covering and a manual 13 requirements but not <
C0 suppression system are head locations can comp 1; 7
- provided, because of obstructions.
Existing heads will genei ally be elevated and some additional heads provide <
East Cableways cabling and transient Prevent damage to redundant Physical fire barriers have Detector spacing and loc.
(130' EL) combus tibles cabling (north' end of Unit 2 been provided for redundant tions will comply with fu Hatch Fire Pro-and south end of Unit I cables in close proximity, 72E requirements.
The si gram Evaluation, cableway.)
early warning detection and kler system will be desit Page 10) ceiling level sprinklers, and installed in accordar with NFPA 13 requirements Z
PLM t t1Rt PLANT HATCH AREA HAZARD FIRE PROTECTION PHILOSOPHY HOW ACCOMPLISHED FIELD NOTES RPS and Vertical cabling (sir.gle div-Prevent fire spread to cable Fire barrier and penetration Detector spacing and la Cable Chase Rooms ision for both units spread area above.
seal have been provided.
tions will comply with (130' EL)
(Early warning detection and 72E requirements. The (Hatch Fire Pro-pre-action water suppression kler system will be det gram Evaluation, are provided for economic and installed in accor<
Page 10a) reasons.)
with NFPA 13 requireme, except for head locatii Sprinkler heads shoulf replaced with those 09 lower temperature ratil heat collectors should provided to speed opes Annunciator Rooms limited cabling Prevent fire spread to impor-Early warning detection is Detector spacing and li (130' EL) tant areas.
provided.
tiens will comply with (Hatch Fire Pro-72E requirements.
gram Evaluation, Page 11)
Switchgear Rooms cabling for one div-Confine the fire to the room. Physical barriers and early Detector spacirg and li (130' EL) ision and askarel-warning detectors are pro-tions will comply with (Hatch Fire Pro-filled transformer vided.
72E requirements.
i gram Evaluation, Page 11)
Switchgear Trans-limited cabling and Confine the fire to the room, Physical barriers and early Detector spacing and li former Rooms askarel-filled trans-warning detectors are pro-tions will comply with (130' ELl former vided 72E requirements.
(Hatch Fire Pro-gram Evaluation, Page 11)
Control Building cabling of both div-Prevent an exposure fire Early warning detection and Detector spacing and if Corridor (130' isions, transient from damaging safety related sprinklers are provided.
tions will comply with EL) (Hatch Fire combus tibles cabinets or both divisions llater will be prevented from 72E requirements. The Program Evalua-of cable and prevent a prop-entering safety-related sprinkler system will tion, Page 12) agating cable fire occurring cabinets.
designed in accordance in Unit 1 (not all IEEE 383 NFPA 13 requirements a qualified cable).
ceiling. Because of obstructions to good wl
PLANT FIRE PLANT HATCH AREA HAZARD FIRE PROTECTION PHILOSOPHY HOW ACCOMPLISHED FIELD NOTES i
Control Building distribution from the Corridor continue 1 ceiling, sprinklers wi 3
also be provided below i
cable trays to protecG an exposure fire. Th9 supplementary sprinklg heads will be provided heat collectors since will be installed furG:
from the ceiling than fied by the code. Sp?
will be installed aboe i
the gas storage cabine
! Control Building cabling of one divi-Limit the fire to the general Early warning and physical Detector spacing and 1
! Corridor and Work sion, air compressors area.
barriers are provided.
tions will comply with Area (112' EL) and transient com-(Water suppression is pro-72E requirements. Thg
- (Hatch Fire Pro-bustibles vided for vertical cable kler system will be di i gram Evaluation, concentration for econorr.ic and installed in acco7 i Page 13) reasons only.)
with NFPA 13 requireme Doors to Battery Room not labeled fire doors
! Battery Rooms limited cable and H Confine damage to a single Physical barriers and early Detector spacing and 1 2
(112' EL) from batteries battery room, warning detection are tions will comply with (Hatch Fire Pro-provi ded.
72E requirements.
Doo gram Evaluation, the room are not label' Page 13) fire doors and no loss ventilation alarm is p I Diesel Generator lube oil, cable and Contain a fire to a single Physical barriers, dike and The CO system will ae 2
Diesel Rooms diesel fuel diesel generator cell.
automatic, total flooding, signed and installed t (Hatch Fire Pro-C0 system are provided.
the requirements of NF 2
gram Evaluation, Page 18) 1 5
PLANI FIRE PLANT HATCH AREA HAZARD FIRE PROTfCT, ION PHILOSOPHY HOW ACCOMPLISHED FIELD NOTES l
Diesel Fuel Oil bulk fuel oil Contain a fire to a single Physi::al barriers, dike and The C0 system will be 2
Rooms (Hatch diesel generator cell.
automatic, total flooding CO signed and installed to 2
Fire Program Eval system are provided.
the requirements of NFF uation, Page 18)
Diesel Switchgear cabling and switch-Contain a fire to a single Early warning detection and Detector spacing and lal Rooms (Hatch gear switchgear room.
physical barriers are pro-tions will comply with {
Fire Program Eval <
vi ded.
72E requirements.
uation, Page 18a)
Diesel Battery cable and H from Contain a fire to the battery Early warning detection and Detector spacing and lal 2
Rooms (Hatch batteries room.
physical barriers are pro-tions will comply with !
Fire Program Eval vided.
72E requirements. No uation, Page 19) of ventilation alarm i provided.
i River Intake cables, oil and Prevent a fire from damaging Closed nozzle water suppres-The sprinkler system wt Structure transient combusti-both divisions of either the sion systems are provided for be designed and install quirementsexceptforg accordance with NFPA I (Hatch Fire Pro-bles service water or RHR pumps.
each pump and barriers are gram Evaluation, provided to prevent water Page 19) damage to adjacent pumps and kler head locations.
MCC's. A general early kler heads will be ins i warning detection system is -
at lower elevations th.
also provided.. Passive pro-specified by the code f I
tection is provided for cable order to prevent spray 1 trays with close divisional adjacent redundant pum interaction.
Curbs are pro-Dikes must be revised i vided around the P.HR pumps.
vent water systems on G RHR pumps from operatiq from a single fire and i curbs' could be provider tween service water pd to prevent oil spread. !
J
PLntt i r1HL PLANT HATCH AREA HAZARD FIRE PROTECTION PHILOSOPHY HOW ACCOMPLISHED FIELD NOTES R actor Building oil and cable Contain a fire to the room.
Sprinklers are provided for The sprinkler system wii HPCI Room (87' floor level protection.
designed and installed C EL) (Hatch Fire Physical barriers are also accordance with NFPA 13 Program Evalua-provided in Unit 2.
Unit 1 quirements except for sp tion, Page 21) uses a water curtain to con-kler head locations. Be trol exposure to adjacent cause of obstructions, s areas.
klers may have to be loc at a lower level than sp fled by the ce'e.
These heads and tho:e used for water curtain will be pq vided with heat collecto Reactor Building oil and cable Limit the damage caused by Wet pipe sprinklers are pro-The sprinkler system wil RCIC Room (87' a fire.
vided for floor level protec-designed and installed i EL) (Hatch Fire tion.
accordance with NFPA 13 Program Evalua-quirements except for sg tion, Page 21) kler head locations. B3 cause of obstructions, s klers may Save to be loc at a lower level than sp.
fied by the code. ThesG heads will be provided c heat collectors.
Reactor Building oil and cable Limit fire damage to equip-Wide spatial separation of Because a single fire co.
RHR Corner Rooms ment and cabling within the redundant systems and partial cause loss of 3 of the 4 (87' EL) (Hatch
- room, physical barriers are pro-pumps, early warning,spr Program Evalua-
- vided, klers for the oil hazard tion, Page 22) for divisional interactir should be considered for economic reasons only.
one RHR pump is required Torus Area -
limited cable This cabling is not required Horth & South for safe shutdown and does (87' EL) (Hatch not expose any so no protec-Program Evalua-tion is required.
tion, Page 23)
M
PLANT FIRE PLANT HATCH AREA HAZARD FIRE PROTECTION PHILOSOPHY HOW ACCOMPLISHED FIELD NOTES Reactor Building cable and limited Prevent a fire from damaging one division of cabling Detector spacing and lo<
Unit 1 Northwest transient combusti-cabling for redundant divi-is provided in each of these tions will comply with I and Southwest bles sions in adjacent areas.
areas.
Early warning detec-72E requirements.
Cable Areas (130' tion and access to the over-EL) (Hatch Fire head cables is provided to Program Evalua-facilitate manual firefight-tion, Page 24) ing operations.
Unit 2 Reactor cable and limited Keep a fire from damaging Early wa.rning detection is Detector spacing and lo Building-North-transient combusti-cabling for both divisions.
provided as well as access to tions will comply with I west & Southwest bles the overhead cables to facil-72E requirements.
Cable Areas (130' itate manual firefighting EL)
(Hatch Fire operations.
Cables with Program Evalua-close division interactions tion, Page 24) are wrapped with Kaowool.
Area, Accumulator CRD cable and limited Keep a fire from damaging Early warning detection and Detector spacing and lo' s (130' EL) transient combusti-cabling for both divisions.
access to the overhead cables tions will comply with I (Hatch Fire Pro-bles is provided to facilitate 72E. requi rements, gram Evaluation, manual firefighting.
Divi-Page 25) sional interactions are sep-arated by a wrapped cable tray as a minimum.
Unit 1 HVAC Room cabling, charcoal Limit a fire occurring with-A deluge system is provided Detector spacing and loi (158' EL) (Hatch filters, and transi-in a charcoal filter to that for the charcoal filters and tions will comply with I Fire Program ent combustibles unit and prevent an exposure general erly warning detec-72E requirements. The Evaluation, Page fire from damaging redundant tion is provided for the roort ceiling level sprinkler 26) cabling.
as well.
Sprinklers are pro-tem will be designed ani vided to spray the floor installed in accordance level exposure fire to pro-the requirements of NFP; tect the cables.
For econo-Where adequate floor le' mic reasons, sprinklers will protection is not provii spray the ' ables from above by this system alone, ai c
as well because of the cable tional sprinkler heads i type present.
heat collectors will be vided at a lower level 1 specified by the code.
charcoal filter deluge s tem will not necessarilj l-*,
com{ywithNFPA15 req
PLANT FIRE PLANT HATCH AREA HAZARD FIRE PROTECTION PHILOSOPHY HOW ACCOMPLISHED FIELD NOTES Unit 2 HVAC cabling and transi-Prevent damage to redundant Early warning detection and Detector spacing and lo (chiller) Room ent combustibles safety-related cables and sprinklers are provided. The tions will comply with (158' EL)
(Hatch MCCs.
sprinklers protect the cable 72E requirements. The Fire Program from an exposure fire at the kler system will be des Evaluation, Page floor level.
Spray shields and installed in accord 26) will prevent spray of the with NFPA 13 requiremen MCCs by the sprinklers.
This single ceiling lev sprinkler installation t
should be able to spray the cable and the floor MG Set Rooms oil and cable (non-Contain a fire to the room Physical barriers, oil curb The sprinkler system wi (Hatch Fire Pro-safety-related) of origin.
and automatic sprinklers are designed and installed gram Evaluation, provided.
accordance with NFPA 13 Page 27) quirements.
Unit 1 Reactor oil in the recire Prevent a fire from damaging Good spatial separation is Inerting is not availab Building Drywell pumps and cables for cabling for both divisions.
provided between divisions during the fir:t 24 hou (Hatch Fire Pro-both divisions and the area is inerted with of startup and shutdown gram Evaluation, Nitrogen during operation.
Page 34)
Unit 2 Reactor oil in the recirc Prevent a fire from damaging Good spatial separation is No inerting is now proc Building Drywell pumps and cables for cabling for both divisions.
provided between divisions, for this unit.
(Hatch Fire Pro-both divisions thermal fire <!stectors are gram Evaluation, provided for the cable trays Page 34) and the trays are wrapped with Kaowool. The recirc pumps are curbed, provided with thermal detection and manual water suppression.
M
PLANT HATCH FIRE PROTECTION PHILOSOPHIES FOR NON-SAFETY-RELATED AREAS
~
e S
=
e Op 9
PLANI FIRE PLANT HATCH
~
AREA HAZARD FIRE PROTECTION PHILOSOPHY HOW ACCOMPLISHED FIELD NOTES Control Room limited cable, char-This area does not impact A nanually operated deluge The deluge system for I Roof (180' EL) coal filters, ' MCCs safe shutdown because of the
- ,ystem is provided for the charcoal filters will r (Hatch Fire Pro-remote shutdown capability charcoal dlters to improve necessarily comply witt gram Evaluation, so no protection is required, tentability of control rcoin.
requirements of NFPA I!
Page 8)
Computer Room cabling and paper Prevent a fire in this area Ceiling level early warning Detection should be cor (not safety re-from exposing adjacent detection and physical bar-ered for above ceiling lated) (147' EL) safety-related areas.
riers are provided. A manual beneath raised floor.
(Hatch Fire Pro-C0., suppression system is gram Evaluation, pr8vided for economic rea-Page9a) sons.
Laboratory (Hatchchemicals, paper Prevent a fire from spread-Early warning and physical (130' EL) and transient com-ing to the cable spread barriers to the floor above.
Fire Program area above.
Evaluation, Page 10)-
Oil Reservoir turbine lube oil Confine a fire to this area.
A dike, physical barriers, Detector spacing and 1.
and Conditioner and an automatic water sup-tions will comply with Rooms (130' EL) pression system are provided. 72E requirements in Unf (Hatch Fire Pro-The Sprinkler system wi gram Evaluation, designed and installed Page 12) accordance with NFPA Il quirements.
011 Storage Rooms lube oil Confine the fire to the room Water suppression, a dike, The physical barriers k (112' EL) (Hatch and physical barriers have breached by the hoses y Fire Program been provided.
portable oil filters wh Evaluation. Page should be permanentl 13) inside the oil room.
tor spacing and locatif will comply with NFPA $
requiremen ts. The spr$
systemwillbedesigne(
installed in accordanc@
NFPA 13 requirements. !
M
PLANT FIRE PLANT HATCH AREA HAZARD FIRE PROTECTI.0N PHILOSOPHY HOW ACCOMPLISHED FIELD NOTES RPS Battery Room limited cable and Confine damage to a single Physical barriers and early Detector spacing and lo-(non-safety-re-H from batteries battery room.
warning detection are pro-tions will comply with '
2 lated) (112' EL) vided.
72E requirements. No 1; (Hatch Fire Pro-of ventilation alarm is gram Evaluation, provided.
Page 14)
AC Current In-limited cabling and Confine damage to a single Physical barriers and early Detector spacing and lo verter Roons (non-H from batteries battery room.
warning detection are pro-tions will comply with I 2
safety-related) vided.
72E requirements. No Ic (112' EL) (Hatch of ventilation alarm 'is Fire Program provided.
Evaluation, Page 14)
Turbine Building lube oil spill and No safety-related equipment Water suppression and floor The sprinkler system wi' Oil. Spill Protec-cabling or cabling is in the area, drainage are provided for designed and installed -
tionZone(112' and it exposes none.
economic reasons.
accordance with NFPA 13 EL) (Hatch Fire quirements. Sprinkler i Program Evalua-tection is incomplete.
tion, Page 15)
Turbine Building cabling No safety-related equipment Physical barriers are pro-The sprinkler system wil West Cableway or cabling is in the area, vided as well as sprinklers designed and installed I (112' EL) (Hatch and it exposes none.
for economic reasons.
accordance with NFPA 13 Fire Program qui rements.
Evaluation, Page 15)
Service Building cabling No safety-related equipment Corridor (112' or cabling is in the area, EL) (Hatch Fire and it exposes none so no Program Evalua-fire protection is needed.
tion, Page 15) 1 O
l
AREA HA MD FIREPROTNTk0blLOSOPHY HOW ACCOMPLISHED FIELD NOTES Other Areas of cabling and limited No safety-related equipment Turbine Building oil or cabling is in the area, (112' EL) (Hatch and it exposes none so no Fire Program Eval-fire protection is needed.
ation, Page 15)
Turbine Building lube oil spill and Limit economic impact of a Water suppression.and floor The sprinkler system wi' 011 Spill Protec-cabling fi re.
drainage are provided.
designed and installed accordance with NFPA 13 tion (130' EL) requi rements. Sprinkle (Hatch Fire Pro-protection is incomplet)r gram Evaluation, Page 16)
Electrical Switch-cable and switch-No safety-related equipment Early warning detection is Detector spacing and los gzar Area (130' gear or cabling is in the area, provided for economic consi-tions will comply with t EL) (Hatch Fire and it exposes none so no derations only.
7T requirements.-
Program Evaluation, fire protection is needed.
Page 16)
Generator Seal Oil hydrogen seal oil No safety-related equipment A dike and automatic, open The water spray system v Unit (130' EL) or cabling is in the area, head, deluge system are pro-be designed and install.
(Hatch Fire Pro-and it exposes none.
vided to limit the fire in accordance with NFPA gram Evaluation, potential in the area for requi rements. The pres' Page 16) econo,'ic reasons only.
system does not protect entire diked area.
Electrical Switch-cable and switch-No safety-related equipment Early warning detection is Detector spacing and lo g:ar Area (147' gear or cabling is in the area, provided for economic consi-tions will comply with EL) (Hatch Fire and it exposes none.
derations only.
72E requirements.
Program Evaluation, Page 17)
R: actor Feed Pump cabling and oil No safety-related equipment Drainage and an automatic, The water spray system Turbine Rooms or cabling is in the area, open head deluge system are be designed and install' (164' EL) (Hatch and it exposes none.
provided to limit the fire in accordance with NFPS Fire Program Eval-potential in the area for requi rements.
uation Page 17) economic reasons.
.,u.
.4,u.
PLANI HAICH AREA HAZARD FIRE PROTECTION PHILOSOPHY HOW ACCOMPLISHED FIELD NOTES Reactor Feed Pump cabling and oil No safety-related equipment
.i<e and automatic, open The water spray system Turbine Oil Condi-or cabling is in the area, head deluge system are pro-be designed and instal 0 tiener (164' EL) viced to limit the fire accordance with NFPA 15 (Hatch Fire Pro-potential in the area for requi rements.
gram Evaluation, economic reasons only.
Page 17)
Turbine Bearings oil No safety-related equipment Thermal detection and manual The water spray system (164' EL) or cabling is in the area, water spray are provided for located only outside th and it exposes none.
economic considerations only. the housing and must bs located. The system wi not necessarily comply 1 any codes.
R: actor Building limited oil and No safety-related equipment To further facilitate m.
CRD Corner Rooms cable or cabling is in the area, firefighting, early wari (87' Fire,EL) (Hatch and it exposes none so no detection should be Program Eval-protection is required.
considered.
tion, Page 23)
Main Steam Pipe negligible combus-This area does not impact Chase and Pipe tibles safe shutdown and uffers no Penetration Rooms fire exposure to safety-(130' EL) (Hatch related areas so no protec-Fire Program Eval-tion is required.
tion, Page 25)
Clean-up Phase negligible combus-This area does not impact Separator Rooms tibles safe shutdown and offers no (Hatch Fire Pro-fire exposure to safety-gram Evaluation, related areas so no fire Page 26) protection is needed.
l Rractor Clean-up negligible combus-This area does not impact Pump Rooms tibles safe shutdown and offers no (Hatch Fire Pro-fire exposure to safety-gram Evaluation,)
related areas so no fire pro-Pages 26 and 26a tection is needed.
i N
PLANI FIRE PLANT HATCH AREA HAZARD FIRE PROTECTION PHILOSOPHY
~
HOW ACCOMPLISHED FIELD NOTES Unit 1 Standby charcoal filters, Prevent fire spread to adja-Deluge protection is provided The deluge system for tt Treatment Rooms A cable and transient cent areas.
for the filters.
Early warn-charcoal filters will nc and B (158' EL) combustibles such ing and sprinkler protection necessarily comply with (Hatch Fire Pro-replacement filters for adjacent areas will pre-requirements of NFPA 15 gram Evaluation, vent damage into those areas.
Pages 27 and 28)
Reactor Water cables in Unit 2, This area does not impact Clean-up - Regen-negligible combus-safe shutdown and offers no erative Heat Ex-tibles in Unit 1 fire exposure to safety-changers (Hatch related areas so no fire Fire Program Eval-protection is needed.
uation, Page 23)
(
Equipment and cables No safety-related equipment Decant Pump Room or cabling is in the area, (Hatch Fire Pro-and it exposes none so no gram Evaluation, fire protection is needed.
Page 28)
Reactor Building cable This area does not impact Working Floor safe shutdown and offers no (158' EL) (Hatch fire exposure to safety-Fire Program Eval-related areas so no fire uation, Page 29) protection is needed.
Reactor Building cable, transient This area does not impact Working Floor combustibles and safe shutdown and offers no (185' EL) (Hatch MG Set Coast Down fire exposure to safety-Fire Program Eval-Breakers (not re-related areas so no fire uation, Page 29) quired for safe ps tection is needed. -
shutdown)
E!
e t n...
ranc I
PLANI HATCH AREA HAZARD FIRE PROTECTION PHILOSOPHY HOW ACCOMPLISHED FIELO NOTES Unit 2 Standby charcoal filters This area does not impact Deluge protection is provided The deluge system for tl Gas Treatment Sys-and cables safe shutdown and offers no for the charcoal filters.
charcoal filters will nr tem Roons A and B fire exposure to safety-re-necessarily comply with (Hatch Fire Pro-lated areas so no fire pro-requirements of NFPA 15.
grca Evaluation, tection is needed except for Pages 29 and 30) the charcoal filters themselves.
Unit 2 HVAC Room charcoal filters, This area does not impact Deluge protection is proviu The deluge system for th a
(185' EL) (Hatch minimal cable, and safe shutdown and offers no for the charcoal filters.
cha" ~ al filters will no Fire Program Eval-potential transient fire exposure to safety-necer < -ily comply with uation, Page 30) combustibles related areas so no fire pro-re luiraments of NFPA 15.
tection is needed except for the charcoas filters themselves.
RWCU. Equipment and cabling and minor This area does not impact Sample Systems transient combus-safe shutdown and offers no (Hatch Fire Pro-tibles fire exposure to safety-gram Evaluation, related areas so no fire Page 31) protection is needed.
Unit 1 Filter charcoal filters This area does not impact Deluge protection is provided The deluge system for ti Train (Hatch Fire and cables safe shutdown and offers no for th' charcoal filters.
charcoal filters will no, Program Evaluation fire exposure to safety-necessarily comply with Page 31) related areas so no fire requirements of NFPA 15.
protection is needed except for the charcoal filters themselves.
Unit 2 HVAC Room charcoal filters This area does not impact Deluge protection is provided The deluge system for th (203' EL) (Hatch and cables safe shutdown and offers no for the charcoal filters.
charcoal filters will nq Fire Program Eval-fire exposure to safety-necessarily comply with uation, Page 31) related areas so no fire requirements of NFPA 15.
protection is needed except for the charcoal filters themselves.
PLANT FIRE PLANT HATCH AREA HAZARD FIRE PROT,ECTION PHILOSOPHY HOW ACCOMPLISHED FIELD NOTES Reactor Building cable This area does not impact Working Area (203' safe shutdown and offers no EL)(Hatch Fire fire exposure to safety-Program Evaluation related areas so no fire Page 31) protection is needed.
Standby Liquid cable This area does not impact Control Rack Area safe shutdown and offers no (203' EL) (Hatch fire exposure to safety-Fire Program Eval-related areas so no fire uation, Page 32) protection is needed.
New Fuel Storage cable This area does not impact (228' EL) (Hatch safe shutdown and offers no Fire Program Eval-fire exposure to safety-uation, Page 32) related areas so no fire protection is needed.
Reactor Building cables and trans-This area does not impact Laydown and Work-ient combustibles safe shutdown and offers no ing Area (228' EL) fire exposure to safety-(Hatch Fire Pro-related areas so no fire gram Evaluation, protection is needed.
Page 33)
Dryer Separator cables and trans-This area does not impact Pool (228' EL) ient combustibles safe shutdown and offers no (Hatch Fire Pro-such as crates fire exposure to safety-gram Evaluation, related areas so no fire Page 33) protection is needed.
Unit 1 Radwaste cables and limited This area does not impact (108' EL) (Hatch transient combus-safe shutdown and offers no Fire Program Eval-tibles fi re exposure to safety-uation, Page 35) related areas so no fire protection is needed.
^
PLANT FIRE PLANT HATCH AREA HAZARD FIRE PROTECTION PHILC30PHY HOW ACCOMPLISHED FIELD NOTES Unit 1 Radwaste cable, trash com-This area does not impact Early warning detection is Detector spacing and los Csntrol Room and pactor and health safe shutdown and offers no provided for the Radwaste tions will comply with M Floor (132' EL) physics materials fire exposure to safety-re-Control Room and sprinklers 72E requirements. The 9 (Hatch Fire Pro-concentration lated areas so no fire pro-for the concentratians of kler system will be dest gram Evaluation, tection is needed.
health physics materials.
and installed in accord?
Page 35) with NFPA 13 requiremenk in the small area protes Unit 1 Radwaste cil 2 and charcoal This area does not impact Deluge ' protection is provided The deluge system for (144' EL) (Hatch fil ters safe shutdown and offers no for the charcoal filters.
charcoal filters will na Fire Program Eval-fire exposure to safety-re-necessarily comply with uation, Page 35) lated areas so no fire pro-requirements of NFPA 15c tection is needed.
Unit 1 Radwaste cable This area does not impact Addition (108' EL) safe shutdown and offers no (Hatch Fire Pro-fire exposure to safety-re-gram Evaluation, lated areas so no fire pro-Page 37) tection is needed.
Unit 1 Radwaste cable This area does not impact Addition (132' EL) safe shutdown and offers no (Hatch Fire Pro-fire exposure to safety-re-gram Evaluation, lated areas so no fire pro-Page 37) tection is needed.
Unit 1 Radwaste cable and charcoal This area does not impact Deluge protection is provided The deluge system for tt Addition (150' EL) filters safe shutdown and offers no for the charcoal filters.
charcoal filters will nc (Hatch Fire Pro-fire exposure to safety-re-necessarily comply with gram Evaluation, lated areas so no fire pro-requirements of NFPA 15.
Page 37) tection is needed.
Unit 2 Radwaste cable and minimal This area does not impact (103' EL) health physics safe shutdown and offers no (Hatch Fire Pro-materials fire exposure to safety-re-gram Evaluation, lated creas so no fire pro-Page 39) tection is needed.
1 N
?LANI FIRL PLANT HATCH AREA HAZARD FIRE PROTECTION PHILOSOPHY HOW ACCOMPLISHED FIELD NOTES Unit 2 Radwaste cable, charcoal fil-This area does not impact Deluge protection is provided The deluge system for tt HVAC Room (132' EL) ters and spare safe shutdown and offers no for the charcoal filters.
charcoal filters will nt (Hatch Fire Pro-filters fire exposure to safety-re-necessarily comply with gram Evaluation, lated areas so no fire pro-requirements of NFPA 15 Page 39) tection is needed.
Sprinklers should be co' Unit 2 Radwaste cable, trash com-This area does not impact (132' El except
. pactor, health phy-safe shutdown and offers no ered to protect the com.
f@r HVAC) (Hatch sics material con-fire exposure to safety-re-or, oil separator, and <
Fire Program Eval-centration and oil lated areas so no fire pro-centration of combustib uation, Page 39) from oil separator tection is needed.
as proviaed in Unit 1.
Unit 2 Radwaste cable This area does not impact (148' EL) (Hatch safe shutdown and offers no Fire Program Eval-fire exposure to safety-re-uation, Page 40) lated areas so no fire pro-tection is needed.
Unit 2 Radwaste cable This area does not impact Early warning detection is Detector spacing and 10 Control Room (164' safe shutdown and offers no provided.
tions will comply with EL) (Hatch Fire fire exposure to safety-re-72E requirements.
Program Evaluation lated areas so no fire pro-Page40) tection is needed.
Off-Gas Recombiner cable and potential No safety-related equipment H detection is provided in 9
Building (140' and H from any leak or cabling is in the area, the piping beyond the recom-2 152' EL) (Hatch and it exposes none so no biners.
A gas leak before Fire Program Eval-fire protection is needed.
the recombiners would be de-untion, Page 41) tected by radiation detection Waste Gas Treatmeni cable No safety-related equipment Building (106' &
or cabling is in the area, 124' EL) (Hatch and it exposes none so no Fire Program Eval-fire protection is needed.
uation, Page 42)
U
I RECOMMENDATIONS 1.
The plant " Equipment Location List" should show all fire protec-tion systems and equipment (such as detection systems, fire dampers, sprinkler and water spray systems, CO systems, pene-2 tration seals, etc.) as Q items according to the appropriate MPL number.
Fire doors will have to be assigned an MPL number.
2.
All appropriate personnel should be informed that all fire pro-tection systems and equipment require the same controls as Q items.
SCSI will have to.evise the Hatch Operational Policies and Pro-cedures accordingly.
In addition, all fire protection items must be specified under the appropriate plant Equipment Location List item to prevent purchasing under other designations.
For example, a fire door replacement should be shown as a fire protection item rather then the general architectural door designation which would not normally be considered a Q item.
3.
HNP-809 should be revised to reflect the paper path taken for DCR's which are designed both on-site and off.
In addition, it is essen-tial that all DCR's be reviewed by qualified fire protection person-nel for their impact on overall plant fire protection and/or to ensure proper fire protection design if related directly to fire protection systems or equipment. The following fonn might be used 28
.m..,o..e-o
-,,,e
.en,.+
m.
c
FIRE HAZARDS ANAL.YSIS DCR No.
Originator Date A.
Will the proposed work introduce special hazards such as cutting, welding, spray painting, etc.?
YES NO If yes, explain:
B.
Will the proposed work introduce transient combustibles?
YES NO If yes, identify:
C.
Will the proposed work require penetrating a rated fire barrier?
YES NO If yes, explain:
Action Required D.
Will the proposed work involve fire protection tech specs?
YES NO If yes, identify:
Action Required l
29
...-.--......_N__...
. _ _,.. n...._.....,.. __ c
FIRE HAZARDS ANALYSIS continued E.
Will completion of work result in additional fire loading?
YES NO If yes, complete Item F F.
Is there adequate separation (clear space, fire barrier, etc.)
between hazard and nuclear safety-related equipment, system, or cables?
YES NO If no, explain:
G.
Is the installed fire detection equipment adequate? Consider both temocrary and permanent hazard (s).
YES NO If no, list deficiency:
~
H.
Is installed fire suppression equipment -- including both auto and manual -- adequate for the hazard (s)? Consider both temporary and permanenthazard(s).
YES NO If no, list deficiency:
)
I.
Will the completed work result in any potential interference to existing fixed detection or fire suppression systems?
YES NO If yes, list deficiency:
4 30
~
4 to identify some of the impact a plant modification might have from a fire protection standpoint.
(Review of a DCR directly relating to fire protection systems or equipment would require a different analysis.
Fire protection DCR's designed off-site have a mechanism to handle this review, but hose handled by Georgia Power, themselves, do not.)
4.
A procedure should be established for the handling of PDCR's.
5.
Vendors should. be required to provide appropriate, documented, quality assurance for their work and materials.
6.
Readily available documentation should be developed to discuss l
the levels of QA provided for fire protection systems and equip-ment in the following time periods:
a) before February,1978 J
(none committed to), b) from February,1978, to May,1980
\\
(criteria committed to but not instituted, verified by a QC sampling of 10% of the items installed during this time period),
i and c) from May,1980, on (full QA program in place and operational).
7.
- If Georgia Power, Bechtel, or others are to be involved in future fire protection system or equipment design, then they must provide equivaient QA control to that discussed for Plant Hatch and SCSI.
31
8.
In order for QC at the plant to know what is required of them, inspection procedures, instructions and check lic's must be provided for the following:
a)
Identification of what is to be inspected, b)
Identification of the individuals or groups responsible for performing the inspection operation, and c)
Detailed acceptance and rejection criteria for the inspec-tion.
In order for the program to be capable of being audited, these criteria become especially important.
9.
Personnel who conduct insta11ation tests and periodic surveillance tests of fire protection systems and equipment should receive specific training to qualify them to conduct such inspections.
In addition, their reports should be reviewed by a qualified person.
10.
A system should be developed so that rome means of tempory identi-fication is provided to indicate that specific pieces of fire protection equipment have satisfactorily passed the required inspection (s).
l 11.
Inquiries or specifications for procurement should include much more detail so that not so much reliance is placed on the vendor.
The area design philosophy and basic design criteria should be included, applicable portions of appropriate codes should be i
32 t
i
referenced, and justification of deviations from the code or design philor,ophy should be required, functional tests should be specified, tolerances'should be included, acceptance and rejection criteria outlined, etc., so that QC personnel have i
sufficient information to audit against.
(See Appendix A for additional specific coments on the inquiry.)
i 1
d t
4 e
1 33 4
.~
m,r e
h e
APPEf1 DIX A DETAILED IfiQUIRY REVIEW _
l h
e a
w O
-,r
A d; tailed r; view of inquiry number SS-6916-7 for the Intake Structure Fire Protection Sprinkler System for Georgia Power's Hatch Nuclear Plant, Units 1 and 2, dated Dacember 8,1977, follows:
A.
Page 1 of Inquiry Item 4 of the Spec requires that "Each bidder shall submit with each proposal complete specifications, description of equipment, and draw-ings and/or illustrations showing the equipment or materials he pro-poses to furnish together with outline dimensions and clearances for his equipment." It is impractical to ask bidder to write specs and completa drawings for all items of equipment he plans te furnish as a part,of the proposal. However, the Spec should call for a list of equipment to be furnished including the manufacturer /model number / cut sheets, etc., on all items.
B.
Georgia Pover General Provisions (dated August 1,1966)
Page GP-5, Item 19, asks for materials of "only the kind, make and quali ty. " New, unused materials should be required by the Spec.
C.
Sprinkler System Spec (dated December 8,1977) 1.
Page 1 - Hose station equipment is included as a part of this Spec.
This is acceptable but ordinarily not desirable. Normally, hose station equipment should be purchased under a separate P. O. with an equipment supplier similar to other hardware items such as fire ex-tinguishers even if installed by the sprinkler contractor.
34
+p.
wee 4
2.
Section -1.3.1 requires underground pipe to be "WWP-421-(c) Class 250 Mechanical Joint." However, the codes referenced in 2.1.1 on pages 2 and 3 are for welded and flanged fittings only.
3.
Section 2.1.1 references the 1977 edition of NFPA Pamphlets 13 (Sprinkler Systems),15 (Water Spray Systems), and 70 (National Electrical Code). The 16 volume set of NFPA Standards is published annually. However, individual pamphlets are not revised on a yearly basis. Specific editions of each pamphlet should have been refe'renced as follows:
NFPA 13-1976, " Sprinkler Systems" NFPA 15-1977, " Water Spray Systems" NFPA 70-1975, " National Electrical Code" Since some underground piping was involved NFPA 24-1977, "Outside Protection," should also have been referenced.
4.
Page 3, Section 3.4.1 required "... listed or approved..." equipment.
This should be revised to read " listed by Underwriters' Laboratories and/or approved by Factory Mutual for fire service use."
5.
Page 4, Section 3.4.3 requires the " Manufacturer" to provide elec-trical valve mon ~.toring switches for Purchaser supplied gate valves. The term " Manufacturer" should be replaced with " Contractor."
" Manufacturer" is not defined in the Spec.
Also, we suggest the Contractor supply all OS & Y gate valves instead of the Purchaser.
6.
Page 4, Section 3.4.4. requires submittal of calculations in accordance with " paragraph 8.3.". Paragraph 8.3 of the Spec concerns correspondence 35 i
?
not hydraulic calculations.
Reference should be made to Chapter 7 of NFPA 13 entitled, " Hydraulically Designed Sprinkler Systems."
7.
Page 5, Section 6 entitled, Acceptance Criteria, specifically requires a hydrostati: test of all piping but does not mention flushing tests specifically.
Paragraph 6.1.1 requires submittal of a " Contractor's Material and Test Certificate." Again, this is not defined.
Reference should be made to Section 1-12 of NFPA 13 for the details of the Certificate and should discuss pneumatic test requirements when applicable.
8.
Pages 6 'and 7, Section 8, refers to " Manufacturer" which has not been defined. The term should probably be changed to " Contractor."
9.
Page 5, Section 6.1.2 requires system to be in accordance with the requirements of both NFPA 13 and NFPA 15. There are many conflicts between these two standards such as the following:
NFPA 13 NFPA 15 Piping black steel galvanized pipe required j
Strainers not always required strainers required Design Criteria general area specific spray protection protection pipe schedule hydraulic calculations allowed required for pipe sizing j
Tests no flow test requires full flow test requi red 10.
Page 8, Section 11.2.5 does not specifically state whether or not system piping is tc be painted.
l 36 m,
m n
a e
oes ma
6 D.
Data Sheet FPS-1 1.
Item 4 under Design Requirements states that " Adequate water is available at 120 psi."
This may be true from a practical stand-point but implies a flat curve of 120 psi available. Where "large" flows are required,120 psi will not be available. A water supply graph should be included as design data. This graph should show available pressure as a function of flow.
In addition, a specific elevation point must be included as a point of reference, since 120 psi is obviously not available at all points of elevation.
2.
Of utmost importance, this specification does not provide sufficient system design criteria in the form of water density (gpm/sq. ft.)
over the projected surface area of each pump.
In addition, pro-vision must be made for simultaneous manual hose stream allowance (generally 750 gpm per NRC requirements). These two items are cri tical.
~
3.
Item B, FPS-1 requires all welded piping. This may be overly restrictive as most sprinkler companies now comonly install com-bination welded / roll grooved coupling systems.
In addi tion, for seismic considerations where pipe passes through walls and floors, NFPA 13 requires use of mechanical groove couplings.
4.
Item C, FPS-1 requires four normally open contacts for fire alarm but does not specify the type of alarm device (retard chamber, flow switch, pressure switch, etc.).
5.
The Pipe Specification Sheet is acceptable but should go farther to specify valves also.
37
t 6.
Vendor Document Submittal Schedule, Page 1 of 3 should also require shop detail drawings (item 7).
E.
Additional Items 1.
The inquiry or Spec should include details of specific equipment items required such as manufacturer /model number and orifice size of nozzles required, details on the monitor switch manufac-turer/model number, and specific details on hose cabinets such as type and. length of hose, nozzle type, pressure reducing valve settings, etc.
2.
The Spec should indicate the method of actuation of closed. nozzles for sprinkler system. Assuming some thermal actuation device is required, the specification should detail the operating tempera-0 U
ture desired (135 F,186 F, 212 F, etc.).
In addition, where closed nozzles are located excessive distances from the ceiling, heat collectors may need to be provided to ensure timely actuation.
3.
The inquiry should specify detailed design criteria such as minimum end head pressure, maximum velocity allowed in system piping, and Hazen-Williams "C" factor to be used to determine friction loss in the piping.
4.
The inquiry should specify requirements for all standard valve trim such as pressure gauges, alarm test valve, drain valve, standard signs, etc.
l 38 e -
.vm a--
nm.-w.~,,
r I
5.
The Spec should indicate the method of supporting spray nozzles.
It is probable that some sort of support structure will have to be provided. The Spec should also include this as a responsibility of the Contractor.
6.
The Spec should call for a full water flow test to verify adequate coverage of each pump prior to installation of the closed nozzles when such a test is practical to conduct.
7.
The inquiry should indicate maximum pressures anticipated on the system; normally, this will be in the range of 150 psig to 175 psig.
8.
The Spec should specify guards for nozzles subject to mechanical inj ury.
o F.
General This specification (SS-6916-7) covered a single sprinkler system to protect a single hazard type.
During the following two months, change orders were issued to cover thirteen (13) additional systems. The protection requirements for these additional systems varied widely.
Some hazards required specific water spray application, others general area protection from ordinary wet pipe sprinklers, and some were pre-action type sprinkler systems.
Separate specific design criteria should have been developed for each system.
e
]
,