ML20050B797
| ML20050B797 | |
| Person / Time | |
|---|---|
| Issue date: | 04/02/1982 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-1078, NUDOCS 8204070425 | |
| Download: ML20050B797 (37) | |
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1 UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS
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4 264th GENERAL MEETING S
6 Nuclear Regulatory Commission 1717 H Street, N.W.
7 Washington, D.C.
8 Friday, April 2, 1982 9
The 264th meeting of the Advisory Committee on 10 Reactor Safeguards was reconvened at 9 05 a.m.
11 PRESENT FOR TH'E ACRS:
12 P J.
SHEWMON, Chairman J.J. RAY, Vice Chairman 13 J.C.
MARK, Member O
M.S.
PLESSET, Member 14 C.P. SIESS, Member R.C. AXTMANN, Member 15 M.
BENDER, Member W. KERR, Member 16 M.W. CARBON, Member H. ETHERINGTON, Member 17 W.M.
MATHIS, Member D.A. WARD, Member 18 D.W.
MOELLER, Member J.C.
EBERSOLE, Member 19 D. OKRENT, Member H.W.
LEWIS, Member 20 DESIGNATED FEDERAL REPRESENTATIVE:
21 R.
F.
FRALEY, Executive Director 22 23 24 25 O
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2 MR. SHEWMON Are we ready to proceed wi th the 3 next item on the agenda, then?
It is not clear that any O
4 members has vouched for what comes next on the agenda, 5 but apparently we are having something on the fire 8 protection program.
7 Mike, did you bring this to us?
8 MR. BENDERS I am not sure who brought it to 9 us, but I am aware of what is there.
I can talk about to it.
11 MR. SHEWMONs Would you please introduce it?
12 MR. BENDER:
There are a number of questions 13 that have been raised in the last few months about fire
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14 protection and its impact on the safety of the plant, 15 and among the questions that have been raised, they have 18 to do with how well we understand how the fire 17 protection devices themselves may be protecting the 18 plant in view of their potential f or causing damage, 19 particularly questions like fire hoses and sprays and 20 things of that sort.
21 So one of the things that we anticipated we 22 would hear today would be something about how mach 23 thought is being given to that subject.
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24 The second point that has been of interest to 25 the Committee is the fact that some of these systems are O
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i==1 tea er auttiao ia tire a per the tateat deiao 2 that if you turn off the air supply to some of these 3 systems you can limit the spread of the fire.
The 4 reliability of fire dampers is not all that well known 5 at the moment.
So the philosophy of their effectiveness 6 is of interest.
7 The third point that has been of interest to 8 me specifically is that since Appendix R has been 9 imposed the Staff has developed a long list of to exceptions that have had to be considered and I tho ugh t 11 it would be a good idea to have ourselves updated on 12 what the significance of those exceptions were and how 13 they were being dealt with.
14 I understand that the Staff is here from the 15 Chemical Engineering Branch to give us an update on the 16 subject.
17 MR. SHEWMON:
Please introduce yourselves and 18 proceed.
19 MR. FERGUSON:
I am Bob Ferguson, Section 20 Leader, Fire Protection, in the Chemical Engineering 21 Branch in the' Division of Engineering, NRR.
We did 22 receive a brief note f rom the Committee, from one of the 23 staff members, which identified the five questions which 24 M r. Bender just enumerated.
25 Tuesday or Wednesday we sent down a brief two O
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1 or three-page report which gave our remarks to that.
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2 did not answer all of the specific questions that were 3 in Mr. Bender's presentation.
We can do that in O
4 discusssion.
If the Committee has had a chance to read 5 that, I would just briefly summarize what I said and get 6 on to any specific questions you have.
If not, I will 7 go through and spend a little more time on it.
8 MR. BENDER:
Why don't you summarize?
9 MR. FERGUSON:
Okay.
10 Basically we went back to the October ACRS 11 meeting where some similar questions were raised during 12 the f ull Committee and at that time the Staff was 13 requested to come back and give additional information
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14 to the Committee on fire protection, which included how 15 the requirements got to where they are, wh e the r 16 exemptions are being granted on the fire protection 17 requirements, what about fires in particularly critical 18 areas, the reliability of fire barriers and the effect 19 o f fire suppressants on safety equipment.
20 With regard to the fire protection 21 requirements, on April 27, 1981 the Commission required 22 tha t operating licenses af ter January 1, 1979 contain a 23 condition requiring compliance with the commitments made
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24 b y the applicant and agreed to by the Staff.
This is 25 documented in a SECY paper, SECY-80-546 and O
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1 SECY-81-114.
2 Tne guidelines for the fire protection 3 programs being used in current reviews, that is, after 4 January 1,
1982, are set forth in NUREG-0800, fire 5 protection trogram, issued July 1981.
The guidelines-6 contained in this document are the most recent 7 consolidation of all previous fire protection guidance.
8 They include the technical requirements set forth in 9 Appendix R.
10 For plants revie'wed prior to January 1,
- 1982, 11 the guidelines used for the review are set forth in 12 earlier issues of the standard review plan and in 10 CFR 13 Part 50.
These guidelines are in accordance with the 14 Commission's memorandum and order in the matter of the 15 petition for emergency and remedial action dated May 23, 16 1980.
17 The Commission's order indicated that on April 18 23, 1980, the Commission approved the proposed rule 19 concerning fire protection and that the combination of 20 guidance contained in Appendix A to BTP 95-1 and the 21 requirements set forth in the proposed rule define the 22 essential elements for an acceptable fire protection 23 program at nuclear power plants docketed for
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24 construction permit prior to July 1,
1976, for 25 demonstration of the plants with GDC-3 of Appendix A to O
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-With regard to exemptions that we are granting 3 from fire protection, the majority of exemption requests O
4 that we have received to date with regard to protection 5 of safe shutdown are concerned with about five or six 6 a reas.
One is fixed fire barriers which define the fire 7 areas for which Appendix R would require a three-hour 8 barrier and which we may grant something lesser than 9 that, down to about one hour, depending on what the fire 60 load is on either side of the barrier.
11 In other words, if the fire load in the plant 12 actually was only a 30-minute fire, we may grant an 13 exemption for a one-hour barrier.. If it is a one-hour
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14 fire it might be a two-hour barrier.
15 The second would be fire barriers protecting 16 saf e shutdown cables without an automatic fire 17 sup pression.
In other words, within a fire area if it 18 contains redundant systems, Appendix R now requires if 19 the thing -- if the components are within 20 feet of 20 each other that they would have a one-hour fire barrier 21 plus an automatic suppression system.
l 22 In some cases the configuration may be such 23 tha t an exemption would be requested for simply the fire
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24 barrier without the suppression system.
In other cases
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25 it might be the suppression system without the fire l
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Another class is most of the operating plants 3 took some effort to apply modifications which would O
4 re ta rd the propagation of cable fi re s, such as cable 5 coatings -- that sort of thing -- enclosing the cables 6 in cable metal covers, Kaowool blankets, any kind of 7 non-combustible asterial that would break up the spread 8 of the hot gas and slow down propaga tion f rom one cable 9 tray to another.
So we expect exemption requests for 10 something less than 20-foot separation with some sort of 11 fire nuppressant in there and an automatic suppression 12 system.
13 Another class would be a large area almost
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14 lik e a fire outside that the area would so big, with few 15 in situ combustibles and no automatic suppression 16 sys tem, with separation of redundant things similar to 17 what was described previously.
18 One has no fixed suppression system in the 19 control room.
Appendix B requires for any area that is 20 so congested that you require an alternate or dedicated 21 shutdown that you would put a fixed suppression system 22 in the ares around which you are concerned.
One of 23 those happened to be the control room.
However, in
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24 general we a re permitting exemptions for not having a 25 fixed suppression in the control room, since it is O
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2 The next category would be some a rea in the 3 plant where there are not a lot of in situ combustibles O
4 and it was just a matter of moving a cable or installing 5 another cable to provide an alternate shutdown means 6 around tha t area, if there is not a large concentration 7 of in situ combustibles.
Therefore, we would not 8 require a fixed suppression system in that area either.
9 The next topic I wanted to discuss was fires 10 in critical areas.
Most of the questions raised in the 11 October meeting were concerned with control room fires 12 or areas termed as areas of convergences, that is, areas 13 where redundant things cas.e together in the same fire
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14 area where you stand a chance or losing all of your 15 shutdown systems or safety 1:ystems and so forth.
16 For the, purposes cf this discussion, critic,1 17 areas are those areas where redundant systems necessary 18 for plant operation are in close proximity and, 19 therefore, a fire and/or fire suppression system may 20 threaten both systems, for example, the control room, 21 cable spreading room, relay rooms and switch gear 22 rooms.
23 For these critical areas, our guidelines
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24 accept three methods of fire protection.
Passive 25 three-hour barriers should be used where possible.
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314 1 Where a fixed barrier cannot be installed, an automatic
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2 suppression systes, in combination with a fire barrier 3 -- a separation distance free of combustibles -- is used O
4 if the configuration of systems to be pro tected and in 5 situ combustibles are such that there is reasonable 6 assurance that the protected systems will survive.
7 If the latter condition is not met, an 8 alternative shutdown capability is required.
And in the 9 area for which you provide such things we require a 10 fixed suppression system if it contains a large 11 concentration of cables.
12 It is essential to remember that these three 13 alternative requirements are not deemed to be 14 equivalent.
However, they provide adequate protection 15 for those configurations in which they are accepted.
In 16 addition, we accept other alternative configurations if 17 they are justified by a fire hazards analysis.
18 Where alternative shutdown capability is 19 provided, it must meet the minimum criteria set forth in 20 section 3.L of Appendix R.
The alternative must assure 21 tha t one train of equipment necessary to achieve hot 22 shutdown from either the control room or emergency 23 control station is free of fire damage.
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24 In addition, the alternative must assure that 25 the fire damage to at least one train of equipment O
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1 necessary to achieve cold shutdown is limited such that 2 it can be repaired within a reasonable time.
That is, j
3 it should be limited to minor repairs and the components j
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4 for such repairs stored on-site.
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With regard to the fire barriers, the fire 6 areas are usually defined LI walls, ceilings and floors 7 which act as fire barriers to confine the effects of the 8 fires.
These assemblies may be penetrated by piping, 9 conduit, vintilation ducts, doorways and access 10 entrances.
Normally the openings are closed by 11 penetration seals, fire doors and fire dampers.
12 Fire dampers are usually open and should close 13 when a fire occurs.
Some fire doors operate in a 14 similar manner.- However, in most cases fire doors are 15 normally closed.
Penetration seals, access hatches are 16 usually in place.
However, during repair or maintenance 17 procedures they may be open.
Because any of these 18 openings may be open at the time of the fire, part of 19 the* firefighting strategy should be to assure that these 20 openings are closed and that compensating measures are 21 taken to con tain the fire.
22 With regard to the ef f ects o# fire 23 suppressants, the effects of fire suppressants on
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24 components and equipment should be taken into account in 25 all fire areas, as stated in Appendix R, section 3.G.3.
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1 For example, the zone of influence of a fire hose is as
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2 oreat or sometimes greater than the fire itself.
3 That ends the remarks I would propose to say, O
4 and if there are any specific aspects of it, I would be 5 happy to answer questions.
6 MR. OKRENT I do not understand what you mean 7 when you say the effects of fire suppressants should be 8 taken into account.
What do you mean by "taken into 9 account"?
10 MR. FERGUSON:
If you have a room which, let 11 us say, is a concrete room and the thing of concern is 12 strictly cables passing through the room, the cables 13 themselves can withstsnd being sprayed with water.
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14 The ref ore, if you have a fire and you expect somebody to 15 come in with a fire hose and put it out, the drif t of 16 spray on the cables, which are not on fire, should have 17 no effect on the operation of that particular system.
18 On the other hand, if you had pieces of 19 electrical equipment, let's say switch gear or so forth, i
20 which was separated by five feet or so, and you were i
l 21 concerned with coming in the room and spraying hoses on 22 one piece of switch gear and not having water from a 23 nozzle drif t into the other piece of switch gear and l ()
24 cause shorting and tha t sort of thing you would have to 25 do something else.
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1 MR. OKRENT:
How do-you take that into 2 account?
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MR. FEROUSON:
Well, you consider the room, O
4 wha t is in the room, how susceptible it is to either 5 heat, smoke or suppressant damage.
If you have a fire 6 in the room, is it separated enough so that you are not 7 concerned with the action of fighting the fire on one 8 side of the room affecting the other.
9 For instance, if the room was 50 feet wide and 10 a small amount of combustibles on one sid-e, you can 11 assure that you do not think tha t water is going to get 12 to the other side.
On the other hand, if they are five 13 f ee t separa ted, it would be pretty hard to say you would 14 spray one thing with your nozzle and not get water in 15 the other.
16 HR. OKRENT:
But are you suggesting that 17 things are currently installed in such a way that, for 18 example, water will not have adverse effects because 19 this has been taken into account.
20 MR. FERGUSON:
When the modifications are 21 done, that should be true.
In the older plants it is 22 not true.
It was not true when we started the review.
23 The licensees are aware of these kinds of
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24 problems and they are taking care of them, to the best I 25 k no w.
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1 ER. OKRENT So it is your expectation that 2 spray systems, where they exist after your review is g
3 complete, will not be able to cause adverse effects?
(O 4 They will only in other words --
5 MR. FERGUSON:
What I am saying is, if we have 6 an area where, let's suppose, it is sufficiently the fire itself would 7 separated that if one thing 8 take out one piece of redundant cable, va are concerned 9 then that t'c fire suppression activity would have a 10 wider scope and may in f act take out another piece of 11 equipment which damages the redundant system.
12 In that case, it does not meet the 13 requirements of the regulation.
The fire and the fire 14 suppressants acting together will take out both 15 red unda n t things in that area.
We know of no way to 16 protect it.
Therefore, he should have an alternative 17 system around that area which meets the minimum 18 requirements of 3.L.
19 HR. OKRENT:
Let us see.
I think there have 20 been some LER3 recently where safety equipment was 21 adversely af fected by the opera tion of sprays.
Are you 22 telling me these plants do not meet the regulations or 23 w ha t ?
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24 HR. FERGUSON:
There is a difference in safety 25 and shutdown equipment.
Th e regulation, as I quoted, O
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I was toward shutdown equipment and the particula r -- in a 2 number of instances, let us just take one where they 3 made the modifications and in checking out the O
4 modifications pushed the test button to test the 5 lights.
The system was not designed properly.
That 6 tripped a breaker.
When the breaker was closed back in, 7 everything was in the energized position and four or 8 five spray systems went off at different locations in 9 the plant.
10 That design did not meet the requirements.
11 But I cannot say whether there are more or there are 12 other plants out there that have that kind of condition 13 or not.
It should have been taken into account.
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14 MR. KERRs I have seen two cases recently in 15 which smoke detectors detected in one case a welder's 16 torch and in the other case I think somebody was smoking 17 and automatically triggered a spray system.
18 Have you thought about whether in light of 19 f uture probability of this sort of thing that the 20 actuation should really be automatic or perhaps it 21 should be manual or delayed?
I do not know the answer 22 to it, but it seems to me that would give one some 23 pause.
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24 MB. FERGUSON:
Well, I think the individual 25 designing the system should give that very careful O
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2 MR. KERR:
But if you require tha t it be i
3 automatic, does he have a choice?
4 HR. FER GUSON :
We do not require it to be a 5 smoke detector necessarily.
6 MR. KERRs But you do require it to be 7 automatic.
8 ER. FERGUSON:
Not necessarily.
It all 9 depends on the system.
10 MR. KERR I did not 11 HR. SHEWMONs I am not sure the Byron people 12 realized tha t, so I would stay with that.
13 MR. KERRs I am surprised.
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14 HR. FERGUSON:
Where we are talking about an 15 area where there is a fire and we are protecting 16 shutdown systems, one of which needs to survive to be 17 able to shut down the plant, and they are in the same 18 fire areas, yes.
It is required to be an automatic 19 sys tem.
It is not necessarily required to be an i
20 automatic system identified by or actuated by smoke 21 detectors.
22 MR. KERR:
And you feel that you have taken 23 into account both the cost and benefits of the
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24 requirement ?
You see, there are some risks associa ted
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It is not all benefit.
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1 MR. FERGUSON:
That is true.
There are risks 2 on both sides.
If you have the fire and you ha ve no 3 fire suppression you risk the possibility of not having 4 either one.
5 MR. KERR:
But if you do not have 6
MR. FERGUSON:
If you design a system such 7 that every time somebody walks in the room it goes off 8 and shuts down things, then you are --
9 MR. KERR:
Come on.
We are talking about real 10 systems and wha t I as trying to get you to do is to look 11 at whether you enhance safety by having an automatic 12 turnoff.
Have you really convinced yourself that 13 automatic actuation is not just taking into account 14 fire, because this is not the only thing that sets the 15 plant at risk.
This is one of the things.
16 MR. FERGUSON:
True.
17 MR. KERR4 You really have taken into account 18 the cost and benefits of automatic actuation and you are 19 convinced that is the way to go?
l 20 MR. FERGUSON:
I do not know if any cost or 21 benefit studies have ever been made.
Mr. Benareya would 22 like to comment.
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23 MR. BENAROYA:
I believe I discussed some of
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24 this d'uring the Byron meeting and tried to set up we 25 have dry systems and we have deluge systems.
There are O
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1 many kinds of systems that car be designed and should be 2 designed properly for the particular condition.
3 We do not ask or require one method only.
All 4 we are asking is that they be designed properly and 5 there is always a way around looking at this, and the 6 cost benefit we expect the licensee to come and tell us 7 if something is wrong and we have --
8 MR. KERR If he came to you and said 9' automatic actuation is wrong, would you agree that he 10 could have it non-automatic?
11 MR. BENAROYA In the Byron case, as we 12 discussed before, we told them very clearly that 13 automatic was not needed.
14 MR. KERR Mr. Shewmon mus't have somehow 15 missed that message.
Maybe you did not tell him.
16 MR. SHEWMON:
Maybe that came up after the 17 meeting because it was my impression -- you insisted 18 they ha ve wa ter.
They had an automa tic suppression tha t 19 was' gas of some sort to inert, that that was not enough, l
20 as I recall.
21 MR. BENAROYAs What you say is absolutely 22 correct.
They had a system.
I said they also needed a 23 water system, and when the discussion came whether it
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24 should be automatic or not, I believe -- I thought"I 25 said it did not have to be automatic.
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MR. SHEWMON:
That is what they were looking
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2 for and they did not think they had it when they came 3 into the meeting.
If they went out with it, or if I O
4 misunderstood it, I am pleased to hear it.
5 MR. BENAROYAs I think we discussed that with 6 them also and explained it to them in our meeting 7 several times.
8 MR. SHEWMON:
Let me ask a different question 9 on this deluge business.
You were talking in your 10 presentation about metal barriers or Kaowool to decrease 11 the propagation of gas and thus the propagation of 12 flame.
It seems to me that a corollary of having a 13 metal barrier over the top of the pan is that the deluge
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14 system is much less ef fective.
15 You cannot quite flood the whole room up to 18 the ceiling, so presumably you are spraying water down 17 in from the top, and if you have a pan there that keeps 16 your gas f rom spreading it also keeps the water out, or 19 do I misunderstand the situation somehow?
20 MR. FERGUSON:
No.
That is correct.
If the 21 cable tray were co vered top to bottom water would not 22 get in.
However, the water would keep the pan at 23 whatever the water temperature is and with that kind of
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24 temperature in defining the fire we have not run an 25 experimant to know that the fire would go out, but it O
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2 if the cable were wide open.
3 We have been recently running a series of O
4 tests in the private research program looking at 5 vertical open cable trays, that is, with no protection, 6 with both qualified and unqualified cable and with 7 dif ferent kinds of these things -- protections such as 8 covers, coatings and so forth.
9 In an unqualified cable or s qualified cable 10 with one layer of cable on the tray which gets ignited,-
11 it will gen e ra te 1,000-degree temperatures in a small 12 room within four or five minutes.
With the pan, the 13 temperatures in the same room, with covered trays and no 14 suppression, the maximum temperature is limited to about 15 600 or 700 degrees and it takes fifteen minutes to 16 develop it.
17 In other words, the fire associated with the 18 cables burning inside a covered cable tray is much less 19 than those cables burning out in the open air.
20 HR. SHEWHON:
Thank you.
21 MR. SBERSOLE:
Bob, I take it you are moving 22 toward a degree of qualification in an environmental i
23 context of cabling which means you will not use all the
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2 splash-proof or whatever, switch gear, so that you can 3 stand either deliberate or accidental water spray.
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Is this what you are moving toward?
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LHR. FERGUSON.
Well, my feeling is that the 4
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6 cable itself, if it does not ha ve boxes and that sort of 7 thing, sh'ould withstand water.
Svited. gear I am not 8 sure that you would move towards -- I guess we have to 9 know whether we are talking about a new plant or an old 10 plant, but in an old plant the switch gear is there.
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11 It is not splash-proof and that sort of-thing 12 and the usual result is to put in something around that 13 room rather than try to fix the room itself, altho 1bh
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14 some people have proposed, you know, drift shields, 15 spissh shields and that sort of thing.
But it has yet,
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18 to be' seen how effective those are if you really have al 17 fire going on in the room.
18 HR. EBERSOLE:
Another thing is the thesis
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to that your automatic production system is so good at 20 these points of' concentration that in fact you will '
21 depend on them to protect the shutdown capability of the t
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22 plant.
These things are notoriously unreliable.
They 23 might not spray at all.
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', Do you not have to consider a potential j
25 burnout of one division and deal with it in concept?
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1 mean, are you putting the fire protection system in a 2 safety category?
3 MR. FERGUSON:
I guess when you talk about a
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i 4 safety catagory you have to talk about which kind of 5 safety.
If you are just dividing things into safety and 6 non-safety, I would say it is closer to a safety 7 category than a non-safety.
But some people, when you 8 say a safety category, this connotes the quality 9 assurance program, seismic design and all that sort of 10 thing.
11 MR. EBERSOLEs Will it work?
12 MR. FERGUSON:
I am not talking that kind of 13 saf ety category, but we are saying in areas -- in areas,
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14 particularly in older plants, if you are concerned about 15 a fire in that room you are depending on fire 16 suppression systems to maintain a way to shut down that 17 plan t.
18 MR. EBEBSOLEa In short, you are relying on 19 automatic fire protection to provoct the shutdown 20 capability?
21 1R. FERGUSONs You are relying on automatic 22 fire suppression and you are relying on the separation 23 either by physical distance of 20 feet or so or by a l ()
24 one-hour barrier.
1 25 You are also relying on your administrative l ()
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1 program to keep the fire from starting in the first 2 place and you are relying on having a group of people 3 there that can respond to a fire response regardless of O
4 wha t goes wrong, that you can add that back up.
5 MR. EBERSOLEs Sort of a composite def ense, 6 then.
7 MR. FERGUSON Yes, sir, because we do not 8 know of any one thing which will do it by itself.
9 MR. EBERSOLEs Well, you know of remote 10 shutdown capability.
11 MR. FERGUSON Yes, and we have tha t for 12 certain areas where we say that these -- for those areas 13 where we are saying remote, automatic suppression plus a
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14 one-hour barrier is not suf ficient, then we are asking 15 for a dedicated or an alternate shutdown system.
16 MR. EBERSOLE:
It might be 17 MR. FERGUSON:
All plants have th ose f or a t 18 lea st the control room and usually the cable-spreading 19 rooms, relay rooms and several other areas of the plant, 20 depending on how well separation was taken care of when 21 the plant was designed.
22 MR. EBERSOLEs You mentioned,the dampers ought 23 to close when a fire occurs.
When a fire occurs a
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24 damper say not close until it hus transmitted extremely 25 high temperature gas to opposite sides of a hypothetical O
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2 other room without every catching it on fire and shut it 3 down, f or instance a switchboard.
O 4
In short, the ambient in the other rooms 5 becomes unscceptably high long before most dampers will 6 f unction.
What do you do about that problem and what do 7 you do about the loss of critical ventilation when the 8 damper shuts?
Lots of equipment needs continuity of air 9 flow to avoid even its own intrinsic delta t from
~
10 equipment heat rejection in the room itself.
11 You know, you have a contradictory problem 12 here.
You have to keep air moving to keep the rooms 13 cool but you have to shut it off to keep from
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14 MR. FERGUSON I agree with both of your 15 statements and I hope the designers are looking at that 16 very caref ully.
17 There are two aspects of that plant with 18 regard to the random closing of a fire barrier without a I tean closing of a fire damper without a fire.
19 fire 20 The people are looking at that and usually if there is a 21 location where a damper will cause that, th ey are 22 looking at two possible sources.
23 One is insulating the duct as it goes through
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24 a room so that you do not put the fire damper in and you 25 are essentially you do not have your damper at the O
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2 that barrier.
3 The other is putting in parallel dampers so O
4 for the random failure you may only cut down half the 5 flow.
However, I would say if there are areas where one 6 random f ailure like that is giving you a problem, you 7 have a problem with the systems design because you still 8 have, you know, it can go of from one fire.
You are 9 going to lose a lot more ventilation to one or two 10 rooms.
11 With regard to -- and there are two aspects to 12 this problem also with regard to shutdown.
I mean, one 13 aspect of it is the shutdown equipment that you want to
()
14 respond after the fire.
That is being taken care of.
15 The other is shutting down two or three dampers because 16 of fire and how that may affect other safety equipment.
17 MR. EBERSOLEa Yes.
18 HR. BENDER:
Bob, a couple of points.
- First, 19 with regard to the damper applications, where are ther 20 generally being used?
Is it normally in the areas 21 outside the containment?
Is that the main application 22 of them?
23 MR. FERGUSON4 Yes.
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24 HR. BENDER:
Do we do anything -- require any 25 analysis of the designers concerning what happens at the O
l l
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1 time these do not close?
2 MR. FERGUSON:
No.
We have not -- I do not 3 recall seeing any analysis even the other way around.
4 Supposing the fire was big enough to require that they 5 close, the kind of question tha t Jesse brought up.
Even 6 if the fire occurs, it is going to requits the damper to 7 close.
How much hot air has escaped before that and how 8 temperature sensitive is the equipment in the area where 9 that hot air is going?
10 MR. BENDER:
Usually the dampers are put in to 11 stop the supply of air, aren't they, as opposed to 12 isolate the system?
13 MR. FERGUSON:
Yes, but they are on both O
\\'
14 sides, actually.
15 MR. BENDERS Oh.
16 MR. FERGUSON:
The other argument there is if 17 you have air coming into the room whether or not, 18 depending on how well your fire has developed, you need 19 a certain-sized fire to overcome the forced ventilation 20 coming into the room before you start cooling the 21 thermal link that would be closing the damper.
22 MR. BENDER:
The other point I was going to 23 a sk is a more general question of the same type.
I knov 24 it is not possible for the Staff to go through and look 25 at every piece of the analysis that the designers do.
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l 2 raised about whether the design is being prope rly 3 executed, how much of the so-called quality assurance is O
4 needed to have comfort that the fire protection system 5 works, is designed and installed properly?
6 Do we have some position on that?
7 MR. FERGUSON:
We set forth in our guidelines 8 the kind of qualification or kind of quality assurance 9 program we think should go on, which essentially ta ke s 10 ten or twelve elements of Appendix B and say these are 11 the kinds of things we think should be applied to fire 12 protection equipment.
13 Other licensees have put this under.their
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14 Appendix B programs just because it is easier to do it 15 tha t way and then take exception to a few of the things 16 tha t they do not feel that they absolutely have to 17 have.
18 MR. BENDER:
I am more concerned with the fact 19 that having agreed upon something that when it gets 20 installed it might not be exactly what was expected.
Do 21 you make a physical audit?
How effective is that?
22 MR. FERGUSONs Well, I think there are two 23 kinds of things tha t are going on, but our experience
()
24 has been we have reached agreements with the licensees 25 on certain things and have gone back for other reasons I
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1 and happenad to check on something and we find our own
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2 engineers found under those conditions that sometimes 3 they were not what we expected.
-,3 V
4 In other cases we found that th'ey were, and 5 wha t percentage one way or the other I do not know.
ICE 6 is doing inspections as part of their normal review of 7 modifications as they are made, and they have brought up 8 on occasions some problems that maybe their quality 9 assurance program was not up to date or up to speed.
10 Some of the things were not installed in a way that 11 would provide the protection we thought we were getting 12 when we sat down and agreed to something over a 13 con f erence table.
14 We are now also starting up a new fire 15 protection program to go back and make a more 100 16 percent auilt of those modifications made to meet 17 Section 3.G of Appendix R.
That is the alternative 18 shutdown systems and fire protection in those areas l
l 19 where you are depending on them for protection of safo 20 shutdown equipment.
21 The first visit is scheduled for D. C. Cook on 22 April 12 and I think~after we go through that we can 23 better answer that question, but I would say my
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24 experience more from what kind of calls we get from 25 licensees -- I mean, from our ICE inspectors that there ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON' 0.C. 20024 (202) 554 *.345
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I are a number of places there things are not being
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2 inctalled quite as well as we would like them to be.
3 MR. BENDER Just with regard to the 4 sprinklers themselves, do we know, for example, that all 5 the sprinkler heads are open and that they are screwed 6 on tight enough so that when the water gets turned on 7 the head does not blow off as well as --
8 MR. FERGUSON They are all subject to those 9 kinds of pre-opera tional inspections, but the only ones 10 we hear about is where the head does blow off.
You 11 know, things go wrong during the pre-operational tests.
12 We do not hear about the successful tests.
13 MR. OKRENTs Has your group looked at the fire
()
14 section of the Zion PR A or the Indian Point PRA?
15 MR. FERGUSONs We looked briefly at the Zion te PRA some time ago and we are in the process of looking 17 a t the Indian Point one now.
18 MR. OKRENT4 Did you develop any comments on 19iti Did you agree with it or did it tell you anything 20 th a t influences your ideas in the area
.f fires or 21 wha teve r?
22 MR. FERGUSON:
With regard to the Zion we 23 raised a question about unether the PRA was done before
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24 or af ter the modifications to comply with Appendix R 25 were made.
We raised questions about the fire growth O
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1 model, with regard to the fire growth model, and we 2 raised some questions.
We wanted to get together with 3 the cor: tractor and go over more in detail just how he O,-
4 handled fires.
We have never had such a meeting with 5 the contrac*.or.
6 With regard to Indian Point, we really are 7 just gettiny into it.
I scanned it, but I sort of had 8 the same sort of thing.
My feeling was I am not clear 9 that they looked at the fire hazards analysis of the 10 plant when they made that report.
But I have not had an 11 opportunity to speak with the contractor to know just 12 what they had done.
13 If the plant meets the regula tions there 14 should be no area of the plant where a fire will occur 15 t ha t would reduce you below the level that I siated, 16 t ha t you would have a system in order to shut down.
So 17 they are going beyond.
Essentially what they are 18 saying, I guess, is that in some areas they are 19 arbitrarily postulating more failures than we postulate l
20 ve would get to have reliance on the fire systems.
21 MR. OKRENTs I would like to pursue the last 22 statement you just made.
In fact, I was going to ask 23 you a question about it.
()
24 Have you yourrelf asked either the Office of 25 Research or some technical assistance group to look in a
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.1 probabilistic way at the reliability of the features 2 that you would now be satisfied with and what the chance 3 of, for exsaple, having a fire and a damper door not O
4 closing or, you know, ot:ter kinds of things to see both 5 the potential unreliability of the system -- is it small 6 enough or whatever, are the eff ects modest enough and 7 this sort of thing?
8 Have you ever tried examining your own 9 regulations that way?
.rst answer is no, 10 MR. FERGUSON4 I think the #
11 we have not done that.
A lot of the probabilistic work 12 was done under Research, but I am not sure how -- I do 13 not know of any effort that went toward the purpose of 14 examining the regulation itself.
15 Our whole review of the fire hazards analysis 16 was just taking the probability of fire in any area as 17 being one and then saying we think you need thir kind of 18 equipment to prevent that fire from destroying all 19 capability of being able to shut you down.
20 The other way we have gone is to say that we 21 vant a certain minimum left, one train in hot shutdown, 22 and the argument now is wha t consists of real fire 23 damage.
Jesse alluded to a qualification program and,
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24 you know, is a cable which had gone through a 500-degree l
25 temperatura rise real fire damage or not.
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1 The only thing that is available is the kind 2 of thing that is in LOCA.
3 MR. SHEWMON:
Some people move earthquakes 4 around.
Some people move barrels of oil.
5 MR. MOELLER:
I had a couple of questions or 6 comments.
You were not satisifed or you had concerns 7 about the PR A for Zion as related to fire protection.
8 Do you have a written report that expresses your 9 concerns or summarizes them?
10 '
MR. FER GUSO N :
No.
11 MR. M0ELLERs I mean, then, how a re we to know 12 about them or how -- I would think a written report --
13 MR. FERGUSON:
I assume the written report 14 would be made when we complete our review.
Right now we 15 were given it to review.
We asked for a meeting with 16 the contractors to discuss our concerns and we are still 17 vai ting for that meeting to be set up.
18 MR. MOELLER:
The second --
l 19 MR. FERGUSON:
I assume a written report will 20 be made.
21 MR. MOELLER4 The second comment is, of l
22 course, the help that will be provided to you by a fire l
23 suppression system or control system is heavily I ()
24 dependent upon the detection m'echanism in these
~
25 automatic detectors tha t you have been talking about.
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i i
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1 I just quickly looked up how many failures of 2 fire detection systems, either a failure of the monitor 3 or it actuating when it should not, how many of these O
4 had occurred as reported in LERs for the last four 5 years, just in air cleaning systems, and there were 6 several dozen of them.
7 Have you done a systematic review of the LERs 8 pertaining to failures of fire detection systems and 9 issued a report on it?
10 MR. FERGUSON:
No, we have not.
11 MR. MOELLER:
Have you asked Carlisle 12 Michaelson 's group to do this?
13 MR. FERGUSON:
No, we have not.
14 MR. MOELLER:
Isn't this a pretty important 15 subject or isn't the total performance of your -- of 16 these fire suppression systems in the power plants --
17 isn't the performance almost totally dependent upon the 18 reliability of these fire monitors, these aut.omatic 19 actuation systems?
20 MR. FER GUSON s Well, there are two kinds of 21 automatic actuation systems.
One is just the common 22 sprinkler system.
23 MR. MOELLER:
No, no.
That is not what alerts
()
24 you to it.
That is the control, is it not?
I mean, I 25 am talking about the system that turns on the spray O
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2 MR. FERGUSON:
In a room that we would be 3 talking about that, let us assume we would have a room 4 that is not manned and has an a utoma tic suppression 5 system and it could have an area sprink1cr system in 6 it.
So if any fusable link went off it would start 7 spraying water and it would also annunciate that a fire 8 was going on with a water flow alarm.
Whenever any one 9 goes off it is alerted.
10 In that same room there wo uld be an 11 independent automatic fire detection system, let's say 12 smoke detectors or whatever the licensee has chosen to 13 p u t in there.
Maybe there would be 10 or 20 such things 14 spread throughout the room.
15 MR. MOELLERa So you are saying you --
16 MR. FERGUSON:
That would independently 17 annunciate that there was a fire in that room, even Jf 18 the sprinkler system did not go of f and would initiate 19 the' action of a fire brigade to respond to the fire.
20 MR. MOELLER:
So you are saying that there are 21 so many of these detectors and different types of 22 detectors to actuate these systems that the failures 23 being reported in the LERs really are not of too much
()
24 concern.
Then I wonder why we make them report them as 25 an LER.
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1 MR. FERGUSON:
Well, we have -- I would not 2
3 MR. MOELLER:
That is what you said.
You said O
4 there are so many of them.
You said they were on 10 or 5 20-foot centers, that they were diverse means of 6 detecting a fire and turning on the spray and that it 7 really -- you had total confidence that the system would 8 work and that I do not need to worry about these LERs 9 being reported.
10 So I am wondering, then, why a re we reporting 11 them as LERs.
12 MR. FERGUSON4 Well, I did not say that.
13 MR. MOELLER:
Well, I --
14 MR. FERGUSON:
I said there was a particular 15 aspect that I did not mention that I was not concerned 16 with.
There are other aspects like we mentioned earlier 17 where a smoke detector went off. inadvertently and it did 18 not just annunciate a fire.
It sprayed water over 19 several pieces of equipment and I think those kinds of 20 things are important to look into.
21 We do not do a statistical study of such 22 things, but what we do do is we look at every LER that 23 comes across the desk and if there are any of those
()
24 which we feel they are looking into we look at them on 25 an individual basis, but we just have not done any, you
. O
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1 know, general study of the thing.
2 We do have -- are developing a program to take 3 a look more at this interaction between fire protection O
4 systems and safety systems and shutdown systems.
We are 5 very concerned about that because there are some of 6 these things which -- the event I said, I mentioned 7 before, the system is going in that was inadequately 8 designed or under-designed and we really do not find out 9 about it until the LER occurs.
10 But we are not monitoring everybody's design 11 as they are going in.
12 MR. SHEWHON:
Have we about made our point?
13 Can we close it up?
14 MR. MOELLER:
Well, one last comment.
You say 15 you do look at all of the LERs and, you know, you 16 examine and review them.
Is there a written report of 17 your findings of the reviews of the individual LERs?
18 MR. FERGUSON:
Only in the case where we find 19 -- and I am speaking now for my section.
I am not 20 speaking for Carlisle Michaelson -- the 'only written 21 reports we put out is where we find an event which we 22 van t to follow up on, particula rly the incident where 23 several spray systems were put off because of the
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24 under-designed fire detection system, the North Anna 25 fire.
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1 We are also -- Mr. Michaelson's group put out 2 one based on -- there were a number of these smoke 3 detectors which initiated systems and that we should co 7-V) 4 into it, and that was -- that, plus our other -- our own 5 initiation at the beginnings of this program to look at 6 the interaction.
7 So we definitely believe that more study needs 8 to be worked on that aspect of it.
9 MR. MOELLER:
Thank you.
10 MR. FERGUSON:
Any written report will be put 11 out.
12 MR. BENDER:
Just one last question, Mr.
13 Chairman.
How far have you people gotten in looking at fi sd 14 the sodium fire problems associated with the CRBR?
15 MR. BENAROYAa We are just getting involved in 18 tha t and we will not be looking at the sodium fires in 17 the primary system ourselves..The CRBR group will look 18 into it.
We 3ra going to look at the other plant 19 fires.
20 MR. BENDER:
When you say the CRBR group will 21 be looking into it, what is their expertise as opposed 22 to yours?
23 MR. BENAROYA:
I cannot talk for them, I am
()
24 sorry, Mr. Bender.
25 MR. BENDER:
But do you think that is the O
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1 right way to do it?
2 MR. BENAROYAa I do not know.
3 MR. BENDER:
Thank you.
O 4
MR. SHEWMONs Thank you.
I would like to take 5 a short break and then we will come back and deal with 6 probability and risk -- quantitative safety goals.
7
( R he r eu p o r., a ': 9:55 o' clock a.m.,
the 8 Cor ittee went off the record.)
9 10 11 12 2
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D NUCLEAR REGULATORY COM4ISSIC*f This is to. certify that the attached proceedings before the
,0 in the matter of: ACRS-264TH GENERAL PIETING Date of Proceeding: Ap[112, 1982 Docket flumber:
Place of Proceeding:
Washington, D. C.
wore held as herein appears, and that this is the original transcript thereof for the file of the Comm1.ssion.
DAVID S. PARKER Official Reporter (Typed)
F
=A
/
(SIGNATURE OF REPCR m )
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