ML20002A475
| ML20002A475 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 08/22/1978 |
| From: | Moody D YANKEE ATOMIC ELECTRIC CO. |
| To: | Ziemann D Office of Nuclear Reactor Regulation |
| References | |
| WYR-78-76, NUDOCS 8011170321 | |
| Download: ML20002A475 (4) | |
Text
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+e Tci: phone 617 366-90\\1 r-x 710-390 0739
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YANKEE ATOMIC ELECTRIC COMPANY db 20 Turnpike Road Westborough, Massachusetts 01581
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August 22, 1978
^ ;i United States Nuclear Regulatory Commission Washington, D.C.
20555
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Attention:
Office of Nuclear Reactor Regulation Dennis L. Ziemann, Chief Operating Reactors Branch #2 Division of Operating Reactors
References:
(a) License No. DPR-3 (Docket No. 50-29)
(b) USNRC letter from D. L. Ziemann to R. H. Groce, dated June 29, 1978
Dear Sir:
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Subject:
Staff Positions on Fire Protection Reference (b) above transmitted four Staff Positions dealing with fire protection at Yankee Rowe. We have reviewed these positions and our comments follow here.
PF-1 Fire Door Supervision Fire doors to safety-related areas or areas posing a fire hazard to safety-related areas should be normally closed and locked or electrically supervised with delayed alarm and annunciation in the control room.
Response PF-1 We accept the position for areas containing equipment required for safe shutdown.
PF-2 Electrical Cable Penetration Qualitication The cable penetration fire barriers should be tested to demonstrate a three-hour rating.
The test should be performed or witnessed by a representative of a qualified independent testing laboratory, and should include the followi ns,:
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c U.S. Nuclear Regulatory Commission August 22, 1978 Att: Of fice of Nuclear Reactor Regulation.
Page 2
'(1) The tests should be performed in accordance with ASTM E-119
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and the following conditions.
(2) The cables used in the test should include the cable insulation materials used in the facility.
(3) The test sample should be representative of the worst case configuration of cable loading, cable tray arrangement, anchoring and penetration fire barrier size and design. The test sample should also be representative of the cable sizes in the facility.
Testing of rie penetration fire barrier in the floor configuration vill qualify the fire stop for use in the wall configuration also.
(4) Cables penetrating the fire barrier should extend at least three feet on the unexposed side and at least one foot on the exposed side.
(5) The fire barrier should be tested in both directions unless the fire barrier is symmetrical.
(6) The fire barrier should be tested with a pressure differential across it that is equivalent to the maximum pressure differential a fire barrier in the plant is expected to experience.
(7) The temperature levels of the cable insulation, cable conductor, cable tray, conduit, and fire stop material should be recorded for the unexposed side of the fire barrier.
(8) Acceptance Criteria - The test is successful if:
(a) The cable penetration fire barrier has withstood the fire endurance test without passage of flame or ignition of cables on the unexposed side for a period of three hours, and (b) The temperature levels recorded for the unexposed side are analyzed and demonstrate that the maximum temperature is suf ficiently below the cable insulation ignition temperature, and (c) The fire barrier remainr intact and does not allow projection of water beyond the unexposed surface during the hose stream test.
If' previous tests can be shown to meet the above position, the
U.S.. Nuclear Regulatory Commission August 22, 1978 Att': Of fice of Nuclear Reactor Regulation Page 3 licensee should provide the results of the tests to show that the above position is met.
, Response PF-2 We do not intend to c.eet this position. Yankee Rowe will be sealing allicable penetrations through fire barriers with a system that will have been thoroughly tested to demonstrate a rating of three hours using the ASTM E-119 test.
While none of the tests will have used the exact Yankee Rowe cable construction or concentrations, we feel that enough tests have been done using different types of thermoplastic insulations and jackets to know that the cable penetration seal that we plan to use will work. The cable penetration fire barriers to be installed.will have been tested previously by the supplier with penetration' configurations similar to those at Yankee Rowe. They will be installed to provide a rating of three hours or the rating of the barrier, whichever is smaller. However, we do not intend to re-test the system using Yankee Rowe cables and loadings.
PF-3 Smoke Detection Systems Tests In situ tests should be conducted with a suitable smoke generation device to verify that the products of combustion from a fire would be promptly detected by installed smoke detectors and that ventilation air flow pattern in the area do not significantly reduce or prevent detection response.
Bench tests should be conducted'to verify that smoke detectors will provide prompt response and have adequate sensitivity to the products of combustion for the combustibles in the area where smoke detectors are installed.
If any fire detection systems are found to be inadequate, appropriate modifications should be made to provide adequate detection system performance.
Response PF-3 As was discussed and made evident to all at a meeting held on July 28, 1978 with the NRC, suitable smoke generation materials for conducting in-situ test of installed smoke detectors do not exist at this time. Until such methods and materials are developed, Yankee Rowe cannot conduct such a test. The design and installation specifications for new smoke detectors or detection systems in the plant will require ben'h testing of those detectors to verify prompt response and adequate' sensitivity to the combustibles in the area where such detectors are to be inscalled.
Please review our submittal of January 31, 1977 to see where such modifications are to be made.
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~w U.S. Nuclear; Regulatory' Commission August'22, 1978
' Att: Office ~of Nuclear Re' actor Regulation Page 4
. PF-4 i
Battery Room Ventilation Air. Flow Monitor If'not presently provided, a. ventilation air flow monitor should 1
be installed in each of the station, battery rooms to alarm and
' annunciate, in the-control room, the loss of. ventilation ~ air flow.
Response PF-4' As noted. in our ' January 31,1977 submittal to you,.the two battery rooms presently exhaust via a _ fan through dampers equipped with fusible' links.-'This area was reviewed by~our~ fire protection-consultants, and they' felt at that time there was no need for air flow monitors. We have reviewed the situation and arrangement of
'the fan; and damper,. and feel there is no need for a monitor.
l Therefore, we do not intend to add any.
r-It should be noted that.your four positions were based upon your initia1' review of'our Fire Hazard Analysis, without the benefit of a site visit. It would seem to us to be more effectivefif further positions are
- held until a site visit has confirmed the need for the issuance of these j
positions.
In.that manner, we.could avoid a constant flow of paper back and forth between us.
We trust that the above meets with your approval.
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-Very truly yours, YANKEE ATOMIC ELECTRIC COMPANY b
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D.
E.~ Moody Manager of Operations-9 1
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REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
DISTRIBUTION FOR INCOMING MATERIAL 50-029 REC: ZIEMANN D L ORG: MOODY D E DOCDATE: 08/22/78 NRC YANKEE ATOMIC ELEC DATE RCVD: 08/28/78 DOCTYPE: LETTER NOTARIZED: NO COPIES RECEIVED 3UBJECT:
LTR 3 ENCL 40 I
LTR CONCERNING STAFF POSITIONS DEALING WITH FIRE PROTECTION af $ 1ECT FACILITY.
PLANT NAME: YANKEE ROWE REVIEWER INITIAL:
XJM DIGTRIBUTOR INITI AL:
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FIRE PROTECTION INFORMATION (AFTER IGSUANCE OF OL).
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