ML20099A223

Provides Addl Info to Close Certain Fire Protection Issues Discussed in Util 850123 & 0204 & NRC s.Evaluation of Fire Door R3-13 & Criteria for Fire Protection Yard Header Hydrostatic Test Encl

ML20099A223
Person / Time
Site:	Fermi
Issue date:	03/04/1985
From:	Jens W DETROIT EDISON CO.
To:	Youngblood B Office of Nuclear Reactor Regulation
References
NE-85-0365, NE-85-365, NUDOCS 8503060572
Download: ML20099A223 (8)

Text

..

Wayne H. Jens

. Vul0 Present Nuclear Operatxms Fermb2 6400 North Daue Highway ISOn (Newport.Mchigan 3133 sas-41so 48166 March 4, 1985 NE-85-0365 Director of Nuclear Reactor Regulation Attention: Mr. B. J. Youngblood, Chief Licensing Branch No. 1 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D. C. 20555

Dear Mr. Youngblood:

References (1) Fermi 2 NRC Docket No. 50-341 (2) Detroit Edison to NRC Letter,

" Qualification of Fire Doors",

NE-85-0030, January 23, 1985.

(3) Detroit Edison to NRC Letter, " Additional Fire Protection Information", NE-85-0275, February 4, 1985.

(4) NRC to Detroit Edison Letter, " Fire Protection Deviation Requests for the Fermi 2 Facility", March 1, 1985.

Subject:

Resolution of Certain Fire Protection Issues This letter contains additional information to provide closure to certain fire protection issues discussed in references (2), (3), and (4).

i Fire Doors

! Except for door R3-13, Detroit Edison commits to have Underwriter's Laboratory (UL) affix UL labels to che subject unlabeled fire door assemblies or replace the subject door assemblies with ones approved and labeled by an independent testing laboratory.

Detroit Edison will proceed as expediently as possible to accomplish the above, considering the fact that UL is an independent laboratory and Edison cannot dictate 00 85j30gog % i ,

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l Mr. B. J. Youngblood, Chief March 4, 1985 NE-85-0365 Page 2 1 their schedule. Edison considers that sufficient documentation was provided in reference (2) for all fire doors except R3-13 and R3-20 to provide reasonable ~

justification for the interim period that the doors will perform their intended function.

With respect to tire door R3-20, this door will be replaced by a labeled door. Until it is, interim justification is provided by the deviation request provided in reference (3), which documents the fire resistive capabilities of the door. In addition, since these capabilities dil not fully comply with UL standards, Detroit Edison commits to patrolling the stairwell in the northeast corner of the control room on an hourly basis with a qualified fire watch. This is consistent with Technical Specification 3.7.8 for deficient fire rated assemblies.

With respect - to fire door R3-13, Attachment A to this letter is a revised permanent deviation request from the one submitted with the reference (3) letter. As you are aware, door R3-13 is larger than Chicago Bullet Proot doors currently listed by UL.

Fire Detectors Except for the torus room, with - respect to the permanent deviations requested in Attachment B to the reference (3) letter, Detroit Edison commits to installing additional detectors or relocating detectors to meet the requirements of NFPA 72E or providing additional justification to the satisfaction of the NRC staff that equivalent detection capability exists.

Detroit Edison believes that sufficient justification is provided in reference (3) for granting an interim deviation until these actions are completed. These actions will be completed no later than June 30, 1985, consistent with the interim deviation . requests for detectors in reference (3). We understand that the deviatioa request for the torus room is acceptable.

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Mr. B. J. Youngblood, Chief March 4, 1985 NE-85-0365 Page 3 Hydrostatic Testing of Fermi 2 Fire Protection Yard Piping As discussed in Attachment C of reference (3), the hydrostatic test results of the fire protection yard piping for Fermi 2 did not explicitly meet the

• requirements of NFPA 24 for new piping. As also stated in reference (3), since the system is ten years old, Edison considered the test results acceptable. -However, to better quantify the leakage test results from the earlier hydro, Detroit Edison committed to NRC Region III to reperform the hydro prior to June 30, 1985. The maximum acceptance criteria in the new hydro will be 264 gallons of leakage in two hours at a pressure of 200 psi. The justification for this acceptance criteria is contained in Attachment B and is based on NFPA 24 and the Factory Mutual Handbook. Detroit Edison commits to take those actions necessary for its fire protection yard piping to meet these acceptance criteria. It should be noted that the results of the old hydro referred to in reference (3) also satisfies this acceptance criteria. This fact combined with the commitment to perform a new hydro and meet justified acceptance criteria provide the necessary assurance ,

that Detroit Edison's fire protection yard header at Fermi 2 will meet its design requirements.

If you should have any further questions, please contact Mr. O. Keener Earle at (313) 586-4211.

Sincerely, cc: Mr. P. M. Byron bk)

Mr. M. D. Lynch Mr. C. B. Ramsey (NRC-RIII)

Mr. L. A. Reyes (NRC-RIII)

Mr. J. F. Stang U. S. NRC Document Control Desk Washington, D. C. 20555

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Mr. B. J. Youngblood, Chief March 4, 1985 NE-85-0365 Page 4 bec: Approval Control F. E. Agosti L. B. Bregni W.-F. Colbert O. K. Earle W. J. Fahrner D. Holland W. H. Jens R. S. Lenart P. A. Marquardt R. D. Olson l T. Phillips F. Svetkovich G. M. Trahey O. K. Earle (Bethesda Office)

Secretary's Office (2412 WCB)

NRR Chron File

ATTACHMENT A Evaluation of Fire Door R3-13 1.0 PROBLEM STATEMENT Test No. 2* was a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire test for door R3-13 which has a transom, and is 3'8" wide which exceeds the width limits of listed doors by this manufacturer. This door met the conditions of acceptance of UL10B for a 1 1/2 hour rating.

1.1 AREA DESCRIPTION Door R3-13 separates the control room from the Turbine Bldg. extension, floor elevation 643'-6". This security door is installed in a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire resistance wall on the south side of the control room. This door is located approximately 25ft from the Turbine Building 3rd floor. (Refer to sketch No. 1).

1.2 FIRE HAZARDS ANALYSIS Fixed combustibles in the Turbine Building. extension is negligible (less than 1 lb/sq.ft.). The Turbine is located approximately 70 ft away.from R3-13 behind a concrete shield wall, (approx. 20ft high). The lube oil storage rooms for the turbine are located on the first and second floor of the turbine building in fire rated rooms with automatic sprinkler protection.

Presently fixed combustibles located north of column 12 between columns K-N are negligible (less than 1 lb/sq. ft. consisting of miscellaneous panels and wiring). Transient combustibles could be present during turbine outages, but they will be controlled administratively. Typically they would be located on the turbine floor east of column K, which is approximately 40ft from door R3-13.

1.3 FIRE PROTECTION The control room has ionization smoke detectors installed above the drop ceiling and in the control room panels. The control room is manned at all times.

Halon and CO2 Portable fire extinguishers are located

, on the north and south walls of the control room. The I turbine building extension contains one hose station

and two portable fire extinguishers (CO2 and dry chemical). Ionization smoke detection is provided in the turbine building extension and adjacent area.

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. l 1.4 SAFE SHUTDOWN EQUIPMENT l The control room contains safe shutdown panels that i have been protected to minimize exposure damage.

The turbine building extension contains no' safe shutdown equipment.

1.5 CONCLUSION

Door R3-13 is considered adequate for its installation in a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rated fire wall assembly. Because the Turbine Building extension contains no fixed combus-tible material, and transient combustibles are main-tained by administrative controls, a two hour assembly provides adequate protection.

• UNDERWRITERS LABORATORIES INC.; Project 83NK23366, File NC699, Report NC6992 " Fire and Hose Stream Test of Security Doors RB3-13 and RB3-20".

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Attachment B

" 'I Criteria for Fire Protection 4 Yard Header Hydrostatic Test

- s 1, -

-C Test Pressure The test pressure of 200 psig is based on interpreta-tion of NFPA 24 as well as background in ANSI B31.1 and ASME;B & PV hydro testing.. It should be noted that on page'5-12 of the Factory Mutual Handbook (reference 1) there'is a discussion of hydrostatic pressure testing of new systems. The first sentence of the second paragraph is identical to the wording in the NFPA 24 code and reads as follows. "The hydrostatic test pressure should be 200 psi or 50 psi above the maximum static pressure, whichever is greater." However on page 15-15 under the heading of " Investigating Breaks",

the first two sentences read " Hydrostatic tests are frequently used to determine the condition of under-ground piping. The tests.are made at 150 psi minimum pressure but at least 50 psi above the normal static pressure." By' testing at the design pressure of the fire header plus 50 psi this condition is satisfied.

Aq such'r the 200 psig suggested rehydro test pressure

,for a ten year old system is appropriate.

4 Leakage Criteria With respect to acceptable leakage from the buried fire mains several points must be made. First, neither the NFPA, Factory Mutual, or valve manufacturers' litera-ture address leakages past aged valves. Therefore the NFPA 24 allowable leakage for valves was used in this analysis. Second, hydrant leakage permissible by NFPA 24 was used in this analysis for similar reasons.

Third, on page 15-17 of the Factory Mutual Handbook, a range of leakages for old piping systems based on pipe diameter are specified under " Rate of Leakage". This table was used to develop the criteria for joints.

A summary of the acceptable leakages is as follows:

Joints 190.0 gallons (for 231 joints)

Valve Seats 3.8 gallons Hydrants 70.3 gallons (for 15 hydrants) 264.1-gallons

's References

1) Factory Mutual, Handbook of Industrial Loss

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Prevention, 2nd Edition.

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