ML20090M428

Reponds to IE Bulletin 75-04B Requesting Repts of Fire Protection Insps Conducted by non-NRC Groups Since 750322 & Position W/Respect to Recommendations Resulting from Insps

ML20090M428
Person / Time
Site:	Monticello
Issue date:	12/05/1975
From:	Wachter L NORTHERN STATES POWER CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20090M427	List: ML20090M428
References
IEB-75-04, IEB-75-4, NUDOCS 9104260271
Download: ML20090M428 (11)

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NSp NORTHERH STATES POWER C O M r' A N Y MIN N E A PO Li n. M IN N r m OTA Spect December 5, 1975 Mr. J G Kepplcr Direction, Region III Of fice of Inspection c Enforcement United States Nuc1 car Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137

Dear Mr. Keppler:

MONTICELLO NUCLEAR GENERATING PLANT DOCKET NO. 50-263; LICENSE NO DPR-22 In response to IE Bulletin 75-04B, reports of fire protection inspections conducted by non NRC groups since March 22, 1975 are submitted along with our position with rerpect to the recommendations resulting from these inspections.

Also included in this response is a description of the numerous fire protection inspections and equipment checks conducted on a scheduled basis by Northern States Power Company personnel. This description is included to give a complete picture of the fire protection practices in effect at our Monticello Plant.

We believe that your request for such inspection reports is most inappropriate in that it solicites judgements from an organization not competent to evaluate nuclear hazards, and whose principal interest is loss claim limitation and profitability of the insurance carrier without regard to costs to the insured.

This places the NRC in the position of intruding into and requiring disclosure of commercial material relating to insurance premium rate economies. The requested information is nevertheless provided here with our reliance on NRC prudence in the use and disclosurethere of.

1. Inspections By Non NSp Groups A. Nuclear Energy Liability Property Insurance Association inspection report dated August 6,1975 (Attachment #1) .

Response To Reconmendations 69-22 The reconnendation for automatic wet sprinklers in the areas listed was rejected on the basis that the fire protection in these areas is adequate as presently installed and the additional protection provided by automatic sprinkler systems did not justify their cost.

9104260271 760127 PDR ADOCK 05000263 O PDR

. l NORTH EF

• GTATES POWER COMPA*gY t )

• tr. J G Keppler Page 2 Dec. 5 The auxiliary holler is not a safeguard system and is housed in a room separated f rom the main power block by a wall and door. The emergency diesel generators are safeguards equipnent , but are redundant and designed to neet singic failure criteria to include adequate separation for fire protection. The units are housed in separate rooms with a properly designed fire door in the adjoining wall. The fuel " day" tank for each engine is placed in a room designed for fire protection which connects to the diesel engine room thrcugh a properly designed fire door.

Automatic fire detection devices which alarm in the plant control room are provided in all these areas so that any fire will be rapidly attacked.

Response To Recommendation 69-23 When Monticello was constructed it was the policy of Northern States Power Company to fight turbine fires using hose stations equipped with fog nozzles and portable equipment. This position was taken because of the potential for accidentally activating any fixed spray system and the destruction that would result from spraying cold water on a hot turbinc. This recommendation to provide automatic spray systems on the turbine generator was rejected in the belief that accidental discharge of an automatic spray system on a steam turbine is a nuch treater probability than is a fire and that such a discharge would be as costly as a fire in terms of equipment damage and resulting loss of generation. The turbine-generator is not safeguards equipment and design of the safety related portions of the plant took into account all possible turbine accidents including a fire.

Response To Recommendations 69-25 & 69 ,'

Cable trays are abundant in every area of the station and the potential for fire in these trays was addressed and dealt with in a number of ways during plant design and construction.

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1. Fire retardant covering was specified on most cables with special

! attention to those serving safeguards equipment.

l 2. Cable tray fill was monitored to assure that cicettical losses from the cables do not cause overheating in the trays.

3. Power cables and control cables were routed in separate trays.

4 Cabic tray separation providing adequate ventilation was a criteria throughout the plant while separation of the trays for rebundant safe-guards trains were designed to adequately satisfy single failure criteria.

Section 8 of the Monticello FSAR describes the Monticello design in this area.

5. The design objectives were satisfied by providing detectors for fire alarm in this room and by providing portable CO2 fire fighting equipment outside cach entrance door.

6. Horizontal trays are covered in areas where sparks from above could potentially become an. ignition source and vertical trays are scaled using fire retandant nacerial at each floor elevation.

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. NORTH E F" STATEG POWER COMPA* Y

\ i Mr. J G Keppler Page 3 Dec. 5

7. Fire alarm systems are installed in potential fire areas throughout the plant for warning of fire, hose stations and portable extinguishers are spotted throughout the plant for fighting any fires that may start.

With the precautions aircady taken as listed above, the recocoendations 69-25 and 09-31 were rejected as being too costly for the added incremental protection they would provide.

B. Nuclear Energy Liability property Insurance Association inspection report dated September 26, 1975 (Attachment #2).

Response to recommendations:

Fire protection

1. The use of water spray in the cabic spreading room was evaluated and rejected during the design of the plant. The design objectives were satisfied by providing detectors for fire alarm in this room and by providing portable CO2 fire extinguishers outside each entrance door.

Having installed the above equipment in additien to the use of fire retardant cable, limited tray fill and all the other precautions already enumerated, the fire protection in the cable spreading room is considered adequate.

2. Since recommendation 1 was not implemented, the first part of this recommendation is unnecessary. The last portion is already in effect through the station work request authori:ation process.

3. Not applicable.

4 This recommendation is in effect by means of surveillance test #1116 semi-annually.

5. Responded to above for previous inspection responses to recommendations 69-25 and 69-31.

Training

1. Such a plan is in effect in the Monticello emergency plan.

2. This training is presented periodically by personnel from the General office as part of the plant retraining program.

3. The annual reviews of the Monticello emergency plan provides this recommended familiari:ation for key people of the fire department. Additional familiarization is not considered necessary in that any fire fighting c .ew entering the plant would be escorted in keeping with our radiation _afe y procedures.

4. Inspections addressing this concern are conducted by the plant operating staff and will be described later in this report. We judge this coverage to be adequate and intend no special inspection to respond to this recommendation.

NORTHEF's

• STATES POWER COMPA * *IY Nr. J G Keppler Page 4 Dec. 5

5. We conclude that the implication of this recommendation would provide no nore assurance that the plant is in a " fire safe" configuration than is now provided by existing administrative procedures, tests, inspections, and reports. It would serve no purpose, but to consunie more administrative time and generate more paper. The reconmiendation is rejected.

6. Responses to reconcendations 1 and 2 in this section respond to this item.

The Monticello emergency plan is presently constructed to respond to the kind of situation alluded to here.

7. Noted and will be completed, l Fire Detection j 1. Design is in progress to respond to this recommendation.

2. Noted

3. Noted - semi annual surveillance is now conducted.

Floor Penetrations

, 1. This concern wAs addressed and NRC was informed of action ta' Ken by our response to IE Bulletin 75-04A dated June 23, 1975. No further action is planned.

2. Noted and agree.

3. The s ta temen t is true.

Self Contained 3renthine Aoraratus

1. Recommendations noted and implemented.

Redundant Circuits

1. The plant was designed to achieve redundant circuit separation as described in Section S of the Monticello Final Safety Analysis Report. During cons t ruc tion , inspections assured that the design criteria were implemented. We do not believe it is necessary at this time to expand tha man hours required to reevaluate this large segment of the plant.

Watchman Service

1. Watchman are not fire inspectors, but are contracted to provide industrial security. Plant operator activities fulfill the needs of this recommendation inside the plant facilities.

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NORTHEF( STATES POWER COMPA y Mr. J G Reppler Page 5 Dec. 5

11. Inspections 6 Surveillance Tests Performed Hv Plant S ta f f A. Smoke detector surveillance test (semi annual).

7 A test to assure that all detectors in the cable spreading room f unction 1 properly and alarm at recommended settings.

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! B. Fire Protection System Test (monthly) l A test to assure that the fire pumps start to maintain proper operating pressures on the fire protection system header, j C. Fire Protection System Diesel Operation Test (weekly) j A test to assure proper operation of the diesel driven fire pump engine.

1 D. Cooling Tower Sprinkler Test (semi annual).

! A test to demonstrate that the sprinkler system for the cooling towers functions properly.

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, E. Transformer and Building Wall Deluge Test (semi Annual).

A test to demonstrate that these deluge systems function properly.

) F. Inspection of Plant liose Stations and Portable Fire f,xtinguishers (monthly) .

A check to assure that this equipment is in operable condition.

J i G. Several one time inspections were conducted at the request of NRC in IE Bulletir 75-04A. Recommendations implemented as a result of those inspections are

, documented in our response to IE Bulletin 75-04A, dated June 23, 1975 and in monthly update reports for that bulletin dated July 1975, August 1975, September 1975, October 1975, and November 1975.

Yours very truly, 2 kN D L J Wachter, Vice President fj

, Power Production & System Operation

, LJW/kd l cc: R S Boyd G Charnoff l

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Consideration of lessons learned from the loss of Brown's Ferry han resulted in

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Pre-emergcacy planning in being revised at the plant and additional training to being given en.ployees on firc fic,hting.

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W trR 2?/90 INFORMATION .

File No. H-163

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Eeronmendationn Centinued f ron previoun Report

.- t (Reviced 11-72) provide approved automatic .prinklern on a wet pipe systen , j k 0 3.' in the Emergency Dier.cl Cencra tor noor.ts, theAn Fuci Tank Rooms f or the dict.cl '

l, a minimum for the Auxiliary

' r.cnerators, and the Auy.111ary Bailer Room. (Do not {

Boiler Room, provide sprinklers over the firing cad of the boiler. . , **

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Pl an) l 1:ydraulically designed automatic water spray syctems of l69-23 proper (Revised 5-16-72) l density utilizing directional calid-cone cpray nor.nics cot. trolled by l 3

an approved preaction, wet pipe, or deluge valve, thould be provided for: .

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' (Do not ,1 b - Covernor, oil lines and bearings of the turbines and generator. - -

l i plan to do) .I 4

69-25 Sprinkler protection should be provided for major cabic tray installations.

In lieu of rprinklers, approved fixed pipe carbon dioxide protection with n

l connected reserve may be provided in confined arcan stich as the Cable Spread- l l ing Room. (Do not plan to do; now have smoke detectors in Cabic Spreading , t Room) .

69-31 The Elcetrical Penetration Rooms chould be provided with closed (AEC head criteria sprinklers, met, do water spray or carbon dioxide prote; tion as applicabic.

not plan f urther protec tion.)

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NUCLFAR U.'U:0Y LI AUltil PROPLRTY IMU3 ANCT. (".ortM tc.'i DUni C. Pl:00M, CPCU c.noai u c ;u September 26, 1975 Mr. C. L. Quinn, Assistant Vice President Marsh f4 11cLennan Inc. -

1515 llorthwestern fw k Duilding flinneapolis , !;innesota 4 55/.00

Dear Sir:

f10RTHERU STATf 5 PO',1f R C0"PANY MC:FICELLO ::.'; LEAR CC'!!.RATII!C PLNiT 110llT IC E LLO, *:... ESOTA f1EL-PI A FILE ::3.14-163 A special visit has beer, rade to the above facility by our field staff in accordance with fiEL-Pl/t Informion Bulletin of May,1975. The visit was conducted to discuss fire oretution and prevention with specific reference to your clients cable systems in view of the T.V. A. Brown's Ferry Station' fire.

The following recomendations are submitted as a result of this visit and will appear on the I:EL-PIA .ie crt following the next regular inspection.

Please review these items with yeur client at your earliest convenience.

If further information or clarificstion is required, do not hesitcte to contact us.

Recor:uiendations 69-25 and G-21 on our current Property Damage inspection Report calling for cable protection will be revised to reflect our current position on tnese hazards.

Reco w.cndations i FIRE PP0TECTIO:1 i

1. A standard installation of earn h:nd water spray sprini:lers controlled by an automtic delupe valve er,i products of cor.. bus tion actuated detectors should be proviood in the Cable Spreading Room. The deluge vc.lve should be located outside of the roo:: and connected to the station's annunciator sys teiii.

OR l If due to the presence of cnSir.ets in this room containing many critical relays, the ine.tallation of grin 41ers is not acceptable, an approved carbon dioxidc o. Italon 1;,.'l syst u should be installed and arranged to operato automatically upon cciuation of the ionization detection systen.

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. t i nr. C. l.. Quinn i Page 2 10 CFR 2.790 INFORMATION j Septeuber 26, 1975 h

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2. The ventilation system in the Cable Spreading Conm should be arranoed to shutdown whenever the extinquishing systeia is discharged. A written procc-dure und penait system should be adopted that would require employees to 1 obtain written peronssion to impair fire protection equipment.

3. An acceptance test of the fire protection system includinq a complete J

discharge, should be conducted and witnessed by the installer and a -

NEl.-PlA representative.

l 4. An investigation into the sensitivity adjustments of the ionization

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detectors should be made to ascertain that they will initiate a signal

] without injy delay upon sensing gases given of f by overheating or burning i insulation encountered in arcos where these detectors have been or will be installed to detcct incipient fires.

) 5. In conjunction with the reconmended water spray sprinklers for the Cable Spreading Room, similar protection should be provided over the cabic t trays elscuhere throuchout the plant where stacked levels of cabics are i

located, i ,TEAINIHG j l. Establish and maintain a complete " Pre-Planning for Emergency" program, i 2. This should include the providing, equipping and training of a plant fire brigade to be used in the event of an emergency.

3. f amiliarize the public fire department with the plant icyout, operations i and protection facilities on a yearly basis so t'io municipal fire department personnel will have adequate hnculedge of the location of the hazards, and l

best methods of fighting a fire in this Plant. ,

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4. Conduct thorough and recorded scif-inspections of the plant and fire protec-tion cquipment to eliminate, as far as possible, all sources of ignition and minimize the spread of fire in critical areas containing combustible contents such as lubricating cil, cable insulations etc.

5. Any planned impairment to the fire protection equipment should be reported i to the Minneapolic Office using fl A furnished impainoent cards f urnished for this purpose. In the event of an emergency shutdown of fire protection equipment a phone call should be made in addition to the mailing in of the j impairment ccrds.

A summary of the above would include the following:

a) Impairment to fire protection such as defective equipment, shut off

valves, electrical services, etc.

. b) Solf-inspection and deficiency correction.

I c) firc fighting procedures and plans of action, i

d) Coordination of plans with the local fire department.

10 CFR 2.790 INFOktnATION

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lir. C. 1. fluinn i J Page 3 septe.nber P6, 1975 10 CFR 2 790 INFORMATION

5. (contd).

e) Salvage procedures related to fire and windstorm losses.

f) Coordination with civil defense and police authorities.

9) Welding and hot work supervision.

6. lhe energenc'/ organizatin.1, of pecole tiained in the use of fire protection equipnant, should bc trained for proper reaction to the worst conceivable cueigency sitva1 ion under the Nost unfavorable conditions that night exist at any givnn time.

7. It is understcad that a check will be rede of the municipal fire department equipment to detenaine thi.t all threads on hoses, nozzles, etc. are copatible with those used on the pl6nt site.

FIRE DETECTI,03

1. lhe exhaust fans situated in the roof of the turbine building which are now operated r.:anually should be converted to full 09tomatic operation by r'enns of U.L. listed ionization type detection systems.

2. It is understcod that a check will he made on the roof of the building to see that the intake for 1:e fans in the cable spreading roon and the control room are: situated a suf ficient distance froM the exhaust 50 recirculation of sc.oke loc:en air to the building will not take place during a fire.

3. It is understood that a program will be set up to test the smoke detectors in the cabic spreading roco ot. a yearly basis using approved method as recomended by the manuincturer of the devices.

LLOOR PEi!E,TPJT10"5 I. All foam plastic penetration seals should be removed and fire wall and floor openings through which 91cetrical cables er conduits penetrate should be pretur.ted against the passege of flame and smoke by devices and constructions appreytd by !!EL-PI A. Comnlete details of planned penetration fire barriers thould be revicued uith I:EL-PI A in advance.

2. Tersporary wall and floor openings thould be sufficiently scaled with a noncor..bustible natorial at the end of each working day to insure the fire integrity of the floor.

3. It is understood open fla.:ies are never used to check the installation, gas tightness and integrity of penetration scals.

l 10 CFR 2 790 4 TOU% TION n-

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September 2f, 197r, 10 CFR 2790 INFORMATION Sfl T-CO'nMi!r3 0C0ATilIUC APP,W.TUS

1. At present one Scott Air-Pal: self-contained breathina unit is kept in the control room and it is etcceienued that an additional unit be installed in thir. rcom for ucr by the second imo stationed in this area, it is understood that suf ficient reserve air is raintained in the warehouse to naintain the six air-pak units on the prealises for at least one hour of continued operation.

REDUl'DfJ1T_ CIRCUITS 1.

It is understood a check will be made to determine the location of redundant circuits circuits, in th? cable spreciding roon in relation to primary Class IE if it is deterc.ined that the iedundant circuit eculd be jeopardized by burning cables in the room the redundant circuit should be separated from a primary Class IE circuits by a mininum three hour fire wall.

If this is net possible to da, the redundant circuits in the room shotild be removed a sufficient distance within shielded trays so there will b3 no possibility of fire cc: :anicatinD from other burning cables to these critical circuits.

WATCHM?J: CERVICE 1.

At present the watchmn tours the exterior of the building only and it is recomendad that nignts and ucekends unen tutal carscnnel is limited to five men on the tite, the t;atchman's tours be expanded to include areas fire hazard. within the plant where combustibles are located thus creating a Sincerely yours,

/ 9 MW ,

. D Mmt.n

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J nn J. Calnay 0 W.

Manager - Property JJC/jan 4

i 10 CFR 2 790 IF* * ' TinN

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