ML20024G397
| ML20024G397 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 06/30/1978 |
| From: | Ippolito T Office of Nuclear Reactor Regulation |
| To: | Mayer L NORTHERN STATES POWER CO. |
| References | |
| NUDOCS 9102110423 | |
| Download: ML20024G397 (14) | |
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JUNE 8 0 1978 OI&E(3)
Attorney, OELD Northem States Power Cos54ror r
hy ATTH: Mr. L. O. Mayer. Manager JRBuchanan Nuclear Support Services 414 Nicollet Mall - 8th Floor ACRS(16)
Hinneapolis,tiinnesota 55401 Gentlemen:
We have completed our initial review of the Nanticelle fire pewtection j
program.
Additional infomation needed to continue the review is identified in Enclosure 1 to this letter.
M the interest of resolving certairi issues, we have tden certain positions that are identified in Enclosure 2.
Please provide responses to these questions and positions prior to our fire protection site visit, now scheduled for August 5,1978, l
and be prepared to discuss any unresolved issues at the time of the site visit.
Sincerely,
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Otid nal 54 " d U Thomas A. Ippolito, Chief Operating Reactors Branch f3 Division of Operating Reactors
Enclosure:
Rcqucst for Additional Infomation cc w/ enclosure:
See page 2 C
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June 30, 1978 cc Gerald Charnoff, Esquire The Environmental Conservation Libr.ry Shaw, Pittman, Potts and Minneapolis Public Library Trowbridae 300 Nicollet Mall 1800 M Street, N. W.
Minneapolis, Minnesota 55401 Washington, D. C.
20036 Arthur Renquist, Esquire l
Vice President - Law l
Northern States Power Company 414 Nicollet Mall Minneapolis, Minnesota 55401 Mr. L. R. Eliason Plant Manager Monticello Nuclear Generating Plant Northern States Power Company
)
Monticello, liinnesota 55362 Russell J. Hatling, Chairr.ar, Minnesota Environmental Control Citizens Association (MECCA)
Energy Task Force 144 Melbourne Avenue, S. E.
Minneapolis, Minnesota 55414 Mr. Kenneth Dzugan Environmental Planning Consultant Of fice of City Planner Grace Building 421 Wabasha Street St. Paul, Minnesote 55102 Sandra S. Gardebring Executive Director Minnesota Pollution Control Agency l
1935 W. County Road B2 Roseville, Minnesota 55112 Mr. Steve Gadler 1
2120 Carter Avenue St. Paul, Minnesota 55109 Anthcr.; 2. Roisran Natural Resources Defense Council 91715th Street, i;. F.
L'ashington, D. C.
20005
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ENCLOSURE 1 RE00EST FOR ADDlTIONAL INFORMA
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MONTICELLO NUCLEAR GENERATING PL' hit 1.
Combined Fire and Security Emergency (A.1)*
Describe the responsibilities of key plant personnel in the event of a combincu fire and security emergency, 2.
Equipment Recuired For Safe Shutdown ( A.2)
The information provided in the Fire Hazards Analysis is not sufficiently detailed. The information does not indicate which equipment within the individual fire zones are shfety related or required for safe shut down.
For each fire area, provide a list of the equlpment (in-cluding cable runs) located in the area that can be used to perfom functions required for safe shutdown. Where redundant trains of safety related ecuipment are located in the same fire area, describe the barriers or distance which separates them.
For each item on the list, indicate whether its function can be per-fomed by equipment located in another fire area and identify the area.
In preparing the list for each fire area, the following func-tions snould be considered to be required for safe shutdown:
a.
Placing the reactor in a subcritical condition and maintaining the reactor subcritical indefinitely, b.
Bringing the reactor to hot shutdown conditions and maintaining it at hot shutdown for an extended period of time (i.e., longer than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) using only nomal sources of cooling water.
c.
Maintaining the reactor coolant system inventory indefinitely using only normal sources of makeup water.
d.
Bringing the reactor to cold shutdown conditions within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
If all the redundant equipment available to perfom any of the above functions (assuming a loss of offsite electrical power) is located in a single fire area, identify the specific separation that exists and any combustible material between the redundant equipment.
3.
Fire Induced Sourious Ecuipment Operation (A.2)
Identify any equipment required for safe shutdown (see item 2 above) that is subject-to spurious operation as a result of a fire.
Parti-cular attention is directed to valves and valve position indicators.
Discuss the effects on safe shutdown of such spurious operation.
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InstrumentandStationAirSystem(AJ)
Describe the function of the instrument and station air system in achieving and maintaining both hot shutdown and cold shutdown condi-tions.
Identify any fire areas which contain components or piping
- Referenceo section in Appencix A to BTP 9.5-i
. of the air system and air operated valves whose position must change for shutdown.
Verify that the loss of the air system will not prevent shutdown operations.
5.
Safe Shutdown Systems-Valves (A.2) a.
Provide a list of remotely-operated valves, with their fail positions, in safe shutd'.wn systems identified in item 2 above.
b.
Describe the provision and accessibility to manually operate these valves, if necessary, during the shutdown operations following fires which prevent remote operation of the valves.
6.
Failure Analysis (A.4)
Provide a failure anal.ysis which verifies that a single failure
- does not impair the primary and backup fire suppression capa-bilities.
The analysis should include consideration of failures in the suppression system, the fire detection system or the power sources for such systems.
7-. -Lightning Effects (A.5)
Describe the means provided to prevent lightning from initiating fires which could damage safety-related equipment.
Describe the means provided to prevent lightning from damaging the fire pro-tection system.
8.
Effects of Extinguishinc Agents (A.5)
Provide the results of an analysis which shows that rupture or inadvertant operation of a fire fighting system will not sub-tequently cause damage or failure of safety-related equipment required 'or safe shutdown.
9.
Safety-related Systems Interlocked with Fire Fighting Systems (A.5)
Identify any safety-related systems or their auxiliaries which are interlocked to and could be disabled by operation of a fire fighting system.
10.
Fire Brigade Eauioment (B.3)
Describe the ecuipment provided for the fire brigade.
Describe means that will be used to either override door locking mechanisms or breach a barrier to provide fire brigade access and personnel egress in the event of a locking mechanism failure.
Describe tne training and tools provided for this purpose.
. 11.
Shared Emergency Ecuipment (B.3)
List the emergency equipment that is shared or proposed to be used by both the fire brigade and the security team.
12.
Supplemental Fire Department (B.4)
Describe the procedures and required authorization for entry, command and supervision of off-site fire department.
j 13.
Fire Brioade Organizational Chart (B.5)
Provide an organizational chart of the fire brigade for each shift which shows the brigade size, composition and chain of command and which designates the normal duty position of the brigade leader, i.e., operator, electrician, maintcnance man, etc.
14.
Fire Brigade Physical Examination (B.5) l l
Confirm that all fire brigade members are provided with a periodic j
physical examination to screen out personnel with heart or respira-tory disorders, or provide justification for any exceptions.
15.
Fire Protection Orcanization (B.5) a.
Identify the onsite positions responsible for sections 1.0 d (1) and d(3) requirements of Attachment No.1 to " Nuclear Plant Fire Protection Functional Responsibilit-Administrative Controls and Quality Assurance",
b.
Provide the implementation dates for procedures, currently under development, to comply with sections 1.0 f(l) and f(3) of Attachment No.1 to " Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls and Quality Assurance",
c.
Confirm that contractor personnel are indoctrinated in the appropriate procedures which implement the fire protection program such as tne control of combustibles and ignition sources.
16.
Fire Bricade Trainina (B.5) a.
Confirm that:
(1 )
Fire brigade training includes suppression of: electrical fires in cables and cable trays, hydrogen fires, flammable liquids, waste / debris fires, and record file fires.
. (2)
Practice sessions provide fire brigade members with experience in actual fire extinguishment and use of emergency breathing apparatus under strenuous conditions.
(3) The area and type of fires chosen for fire drills are varied such that brigade members are trained in fighting fires in all safety related areas containing significant fire hazards.
The situation selected should simulate the size and arrangement of a fire which could reasonably r
occur in the area selected, allowing for fire development due to time required to respond,'to obtain equipment, and organize for the fire, assuming loss of automatic suppression capability.
(4) Fire drills will be critiqued to determine how well the-training objectives have been met.
17.
Control of Combustibles and Ignition Sources W.5) a.
Provide the implementation date for the administrative controls under development for the control of combustibles and ignition sources; b.. Confirm that the administrative controls for combustibles and ignition sources will comply with all the requirements of Attachment No. 3 and No. 4 and especially subsections-2a; 2b(1); 2b(2); 2b(4), and 20 to " Nuclear Plant Fire Protection Functional Responsibilities, Administrative Control and Quality Assurance".
1 c.
Clarify whether "No Smoking" signs will be used in all safety related areas, and in areas containing flammable or potentially explosive materials or atmospheres that present a hazard to safety-related equipment.
18.
Fire Fightino procedures (B.5) a.
Provide the implementation date for the fire fiohting procedures currently under development.
b.
Confirm that fire fighting procedures will comply with all the
. requirements of Attachment No. 5 to " Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls and Quality Assurance", or provide justification for any exceptions.
In dddition, Clarify your response to section "a" through "g" of Attachment No. 5 to eliminate phrases such as "if appropriate",
"when needed", "if necessary" to thereby provide a more positive description of your program.
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- 19.
Quality Assurance (C.)
l Confirm the following:
a.
The QA program for fire protection will be under the management control of the QA organization.
b.
NSP operational QA program under 10 CFR= Part 50 Appendix. B will be implemented to comply with all the requiremehts of Appendix A to BTP9.5-1 or_ Regulatory Guide 1.120.
- 20. Removal from Service Procedure (C.6)
Provide a summary of the procedures established to centrol the dis-arming of any-automatic or manually actuated fire protection system.
Identify the management. position responsible for authorizing the disarmament and the means used to assure the system is returned to normal.
21.. Fire Barrier (D.1)
Identify the fire barriem, enclosing separate fire areas, that do not have a minimum. fire rating of th ee hours.
For those barriers, describe the fire rating of the associated doort, ventilation dampers and seais for cable, pipe and ventilation duct ?enetrations.
- 22. Steal Structures (D.1)
Describe the type of fire protection, if any, applied to steel struc-tures.
Evaluate the possibility of fire damage to protected and unoro-tected steel structures and the effect of such damage on the safe shutdown capability.
- 23. Drains (D.1) a.
Provide the results of an analysis which shows that drains have sufficient capacity, and/or equipment pedestals have sufficient height to prevent standing water from sprinklers and fire hoses from damaging safety-related equipment or supporting systems nec-essary for safe shutdown of the plant.
As an alternate, show that the standing water does not damage such equipment.
b.
Identify the areas containing safe shutdown equipment that are not provided with floor drains.
Describe the drainage path for those areas without drains, 1
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c.
Identify the areas containing combustible liquids that are not provided with floor drains.
Describe the drainage path and provisions for containing or a1verting the combustible liquid"in those areas without drains.
In those areas with drains, state the capacity and location of the drain reservoirs and describe the provisions to prevent the spread of flamable liquid fires via the drain system to safety-related areas or to other areas con-taininrcombustible liquids.
- 24. Curbed Areas (D.1) provide the results of an analysis that shows that curbed areas surrounding combustible liquid tanks have sufficient capacity to contain the full contents of the tanks plus the quantity of water required for extinguishment of a fire involving the combustible i
liquid.
- 25. Pipe and Ventilation Duct Penetrations (0.1)
Provide the results of an analysis wnich shows that the existing or proposed fire barrier penetration seals for pipe and ventilation duct penetrations are adequate to prevent the spread of smoke and fire through the barrier considering the combustible loading and possible air pressure differential.
- 25. pioing Containing Combustibles (0.2)
Identify all piping containino flammable gas or combustible liquid which is routed through areas containing sa#ety-related equipment, safety-related cables or through which personnel must pass to reach safety-related equipment for local operation.
Provide an analysis to show that a fire involvino the liquid or gas will not prevent safe shutdown or result in the loss of function of a safety-related system.
Describe the provisions, if any, to piping systems which would reduce the likelihood or magriitude of a flamable gas or com-bustible liquid fire.
- 27. Diesel Fuel Transfer Shut-off (D.2)
Describe the means provided to automatically and/or manually stop the transfer of diesel oil from the storage tanks to the diesel generator day tanks in the event of a fire in the area housing the day tank, or through which the fuel oil transfer piping i, routed.
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, 28. Separation Criteria (0.3)
Describe the separation criteria used for the routing of electrical cables.
Certain cables electrically connected to equipment necessary for safe shutdown may be used for functions designated as non-safety-related and therefore classified as non-safety-related.
Examples of these might be remote indicating lights for valves, breakers, etc.
Describe whether such cables are kept with the safety division to which they were originally connected and if not, describe the effects on the safe shutdown equipment due to shorts to these cables as a result of fire.
Describe the minimum physical separation between re-dundant, electrical cables ur systems required for hot and cold shut-down where they are reiter. in the same fire area.
2g. Fire Stops (0.3)
Provide a detailed description of existing and proposed fire breaks and fire stops.
Include sketches, identification of materials of construction, and description of test results which demonstrate the effectiveness of fire steps used on electrical cubicles and vertical cable trays; and for intersection between horizontai and vertical cable runs.
Provide the criteria that were used in the design of the fire breaks and fire stops,
- 30. Cable Insulation Materials (D.3)
Identify all types of cable used in all areas of the cable tray system.
For each type of cable, identify the materials used for insulation and jacketing.
State the combustion and toxic charac-teristics of each type of material.
Identify whether flame tests were performed on single and jacketed assemblies.
Provide the accept-ance criteria and results of the flame tests.
Identify the flame temperature used, the exposed area, and the heat rate.
Provide a comparison between these test procedures and the IEEE 383 flame test procedures.
31 Method of Heat and Smoke Ventino (D.4)
In all the areas where manual fire fighting is proposed as either primary or backup means of suppression, describe the methods whicn would be used for heat and smoke removal using either fixed or portable air handling equipment.
If the plant HVAC systems are proposed for such service, provide design data to show that these systems are rated for the conditions (temperature and capacity) recuired when used for this service.
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32.
Prevention of Fire and Smoke Scread (D.4)
Describe the manner in which fire and smoke are prevented from spreading from area to area via the normal and emergency ventila-tion systems in all parts of the plant areas.
Describe the loca-tion, actuation method and fire rating of dampers used for fire and smoke control in both air supply and return air systems.
Describe the details of interlocks for ventilation system shutdown or mode j
change that can be utilized for fire and smoke control.
33.
Ventilation System Power and Control (D.4)
Identify all areas where ventilation systems power supply or controls are located within the area they serve.
Provide the basis for leaving ventilation systems power and control cables within the area they serve.
34 Preventina Recirculation of Ventilation Air (0.4)
Describe the separation between the air intakes and exhausts for normal and emergency ventilation systems and the current and pro-posed provisions which prevent smoke from being drawn back into the plant.
35.
Operation of Fire Damoers (D.4)
Discuss the provision for remotely re-opening fire dampers (including dampers actuated by caroon dioxide suppression system operation) for post-fire smoke venting.
36.
Combustible Filters (D.4)
Identify the location of all combustible filters used at the plant and discuss the potential fire hazard involved at each location.
Describe the fire detection and suppression capability and fire prevention measures for all such combustible filters.
Provide the results of an anaiysis on the effects of combustion of the filters in terms of heat, smoke generation, radiation release, and damage to safety-related ecuipment.
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- 37. proximity of Regular and Emergency Lighting Wirino (0.5)
Provide the results of an evaluation of the potential for a fire in a safe'ty-related area to cause dan. age to electrical wiring which would result in the loss of both regular and energency light-ing to areas providing access to the fire or egress from the area.
State the number of portable lights designated for emergency use at a central location.
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- 38. Communication Systems (D.5)
Verify that emergency communications can be maintained for any fire area by using equipment located onsite that is not subject to damage from a fire in the area.
29.
Fire Cetection System Design (E.1)
Provide design data for the automatic fire detection system in each fire area, including such items as type, number and location of the detectors; and signaling, power supply and supervision of the syst em.
Identify any deviation (s) from NFPA 720.
40.
Fire Sucoression System Design (E.3)
Provide the design data for all automatic suppression systems (both existing and proposed) including such items as design densities, soak times, power supplies, and associated alarms.
Identify areas of non-compliance with appropriate NFPA Standards.
41,
Reouirements for Manual Hose Stations (E.3)
Provide the results of a study which verifies that the manual hose stations conform to all the requirements of NFPA 14 Demonstrate that all points of safety-related areas and areas with major fire hazard can be reached with the hose line stored at the manual hose stations.
Describe the caoability of interior hose nozzles-wnicn are describec as electrically safe type in fighting non-electrical fires.
42.
Remote Shutdown panels (F.6)
Provide an analysis to demonstrate that no fire which could impair control from the control room could also prevent control from remote shutdown panels.
Icentify any interconnections between the remote shutdown pane', and the control room and discuss the means of isolating the two control stations in the event of a fire.
43, Radiological Consecuences of a Fire (F.14)
Evaluate the radiological consequences of a fire in radwaste areas and areas containing contaminated materials sucn as filter cartridge, spent resin, etc.
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ENCLOSURE 2 STATEMENTS OF STAFF POSITION tiONTICELLO NUCLEAR GENERATING PLANT PF-1 Fire Bricade Trainino (B.5)*
a.
Regularly planned meetings should be held every 3 months to repeat the initial classroom instruction programs over a two year interval.
b.
During fire drills, an evaluation should be made of each fire brigade member's proficiency in the use of fire fighting procedures.
c,
. Fire drills should be critiqued at three year intervals by individuals independent of the utility's staff.
PF-2 Fire Door Supervision (0.1)
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.
PF-3 Electrical Cable Penetration Qualification (D.3)
The cable penetration fire barriers sho
be tested to demon-strate a three-hour rating, as is reau for fire barriers.
The test should be performed or witne!
by a representative of a qualified independent testing labor.
, and should include the following:
1 1.
The tests should be performed in acccrdance with ASTM E-119 and the following conditions:
2.
The cables used in the test should include the cable insula-tion 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 the penetration fire barrier in the floor configuration will cualify the fire stop for use in the wall configuration also.
"Referenceo section in Apoenc1x A to BTP 9.5-1
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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 differen-tial a fire barrier in the plant is expected to experience.
7.
The temperature levels of the_ cable insulation, cable con-ductor, cable tray, conduit, and fire stop material thould 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 sufficiently below the cable insulation ignition tem-perature, and c.
The fire barrier remains intact and does not allow projec-tion of water beyond the unexposed surface during the hose stream test.
If previous tests can be shown to meet the above position, the licensee shoulo provide the results of the tests to show that the above position is met, pF-4 Smoke Detection Systems Tests (E.1)
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 promet resconse and have adecuate sensitivity to the products of combus-tion for the combustibles in the area where smoke detectors are installed.
If any fire d2tection systems are found to be inade-quate, appropriate modifications should be made to provide acequate detection system performance.
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3 PF-5 Battery Room Ventilation Air Flow Monitor If not presently provided, a ventilation air flow monitor should be installed in each of the station battery rooms to alarm and annun-ciate, in the control room, the loss of ventilation air flow.
PF-6 Air Breathing Apparatus The air breathing apparatus used by the fire brigade and emergency control personnel (i.e., the complement of air breathing apparatus, spare bottles, and recharge capability), should be sufficient to meet the needs of ten people for a period of six hours at a usage rate of three air bottles per hour per person.
PF-7 Diesel Generator Rooms Fire Detectors Early warning-type fire detectors should be provided in the diesel generator rooms.
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