ML20126H768

Summary of 850530 Meeting W/Util in Bethesda,Md Re Plant Fire Protection Program.Meeting Attendees & Std for Installation of Sprinkler Sys Encl

ML20126H768
Person / Time
Site:	Comanche Peak
Issue date:	06/07/1985
From:	Burwell S Office of Nuclear Reactor Regulation
To:	Office of Nuclear Reactor Regulation
References
NUDOCS 8506180443
Download: ML20126H768 (9)

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kg UNITED STATES NUCLEAR REGULATORY COMMISSION

WASHINGTON, D. C. 20555

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%+...++ JUN 0 71985 Docket Nos.: 50-445 and 50-446 APPLICANT: Texas Utilities Generating Company (TUGCO)

FACILITY: Comanche Peak Steam Electric Station Units I and 2 (CPSES)

SUMMARY

OF MEETING BETWEEN NRC STAFF AND TUGC0 TO DISCUSS THE COMANCHE PEAK FIRE PROTECTION PROGRAM A meeting between the NRC staff and TUGC0 was held on Thursday morning, May 30, 1985, in Room P-412, Phillips Building, 7920 Norfolk Avenue, Bethesda, Maryland.

The purpose of the meeting was to discuss the Comanche Peak Fire Protection Program. Specifically, the NRC staff requested the meeting to discuss the in-formation provided in the TUGC0 letter TXX-4422 dated February 19, 1985, and the forthcoming submittal concerning the placement of automatic sprinklers in certain fire areas. The NRC staff did not accept the placement of automatic sprinklers in certain fire areas as equivalent to the criteria given in Chapter 4 of NFPA 13, based on the information presented. The meeting attendance is listed on Enclosure 1.

Meeting Details During the onsite fire protection review the NRC staff had identified a deviation from the NFPA 13 Code, Section 4-3, requirements which specify that automatic sprinklers should be located close to the ceiling of protected areas. Paragraph 4.1.1.5 of the NFPA 13 Code allows deviations to these placement requirements provided that tests or calculations show comparable sensitivity and performance of the sprinklers to those installed in conformance with Section 4-3. The re-lated paragraphs from the NFPA 13 Code are reproduced on Enclosure 2. The ap-plicant has surveyed the station and identified the fire areas in which the automatic sprinklers were not pl e.ed near the ceiling as specified in the NFPA 13 Code. The applicant described the analysis it was proposing to submit in response to the above deviation.

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The applicant's analysis consisted of calculating and comparing the sizes (heat rate output) of transient oil fires located on the floor of each fire area which produces the following results:

A) Actuated a hypothetical automatic sprinkler located near the ceiling in conformance with NPFA 13, Section 4-3. )

B) Produced a temperature of 1000*F at the underside of the nearest cable tray. The 1000 F temperature was selected as a reasonable ignition temperature for the cable insulation used at CPSES.

C) Actuated the installed automatic sprinkler assuming the fire was centered below the cable tray but at a maximum horizontal offset from the sprinkler location. In this arrangement the sprinkler must be actuated by radiant heat flux from the fire.

Based on the meeting discussions the NRC staff concluded that the applicants analysis did not show comparable sensitivity and performance of the installed sprinklers to those installed in conformance with Section 4-3 of the NFPA 13 Code because:

A) The applicant's analysis did not include any comparison of response times for sprinklers located at the ceiling and at lower offset positions.

B) The applicant's analysis did not show that the fire size needed to actuate the lower offset sprinkler was always smaller than the sprinkler located at the ceiling.

The NRC staff also questioned whether the 1000"F temperature damage threshold was a adequated acceptance criteria since it did not appear to include any quantifiable margin or safety factor.

The NRC staff advised that TUGC0 had two alternatives to resolution of this  !

issue of installed sprinkler locations. '

A) Modify the installations to be in conformance with Section 4-3 of the NFPA 13 Code.

B) Request deviations from Section 4-3 of the NFPA 13 Code justifying each deviation by a detailed fire hazards analysis for that fire area.

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In order to expedite resolution of this issue, the NRC staff will send its fire protection experts to the site to inspect all of the fire areas where the sprinklers are not in conforwence with the NFPA 13 Code. The inspection will have the objective of identifying where limited modifications would bring the area into conformance with the NFPA 13 Code and those areas where the NRC staff experts believe that justification of a deviation to the NFPA 13 Code will be difficult to achieve. This inspection will be scheduled as early as the avail-ability of participants can be determined. The applicant indicated that there are approximately 15 areas that will need to be inspected.

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~b. ~M S. B. Burwell, Project Manager Licensing Branch No. 1 Division of Licensing f

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ENCLOSURE 1 MEETING ATTENDANCE COMANCHE PEAK FIRE PROTECTION PROGRAM ,

, PLACEMENT OF AUTOMATIC SPRINKLERS THURSDAY, MAY 30, 1985 Texas Utilities Jack Redding Bob Dacko Rick Babb -

C. G. Creamer K. W. Dungan (consultant) 1 NRC Staff S. B. Burwell Steven West John Stang Dennis Kubicki Bob Ferguson V. S. Noonan (part-time) l l

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Enclosure 2 Standard for the installation of Sprinkler Systems trPA 18-1983 4-3 Position of Sprinklers.

4-3.1 Smooth Ceiling Construction (as defined in 4-1.3.1). Deflectors of sprinklers.shall be located 1 in. to 10 Chapter 4 Spacing,Imcation and Position in. (25 mm to 254 mm) below combustible ceilings or t in. to 12 of Sprinklers in. (25 mm to 305 mm) below noncombustible ceilings. The operating elements of sprinklers shill be located below the ceiling.

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Exception No.1: Defectors of sprinklers under beams 4-1.1 Easse Pn. acsp '"*les, shall be located 1 in. to 4 in. (25 rnm to 102 mm) below beams, and not more than 14 in. (356 mm) below combustible ceilings or not more than 16 in. (406 mm) e4-1.1.5* Clearance between spnnklers and ceilings may below noncombustible ceilings.

exceed the maximum specified in Secuan 4-3 provided that, nAlers for the conditions of occupancyyd, tests or calcula- Exception g,,,,,g,d, recessed Na 1 Speciarceiling-type and fush types may p)endent the tions show comparable sensitivity and performance of the operating element a6oor the c' rilmE and the deflector sprinklers to those installed in maformance with Secuan j,,,,,d narer the ceiling uAen installed in acardance with 4-3. their listing.

4-3.2 Beam and Girder Construction _(as defined in 4 1.3.2).

4-3.2.1 Deflectors of sprinklers in bays shall be located 1 in. to 16 in. (25 mm to 406 mm) below comb'ustible or noncombustible roof or floor nlarire Appendix A 4-3.2.2 Deflectors of synnklers under I-=== shall be located 1 in, to 4 in. (25 mm to 102 mm) below beams and The following notes, beari the same number as the not more than 20 in. (508 nun) below combustible or text of the Standard for the Installation of S 'nkler noncombustible mof or floor decks.

Systems to which they apply, mntain useful ex tory 4-3.2.3 Deflectors of sprinklers undeE concrete tee con-matenal and references to standards. ~

strucuan with stems spaced less than 7 M ft (2.3 m) but na Ap =a, u t p. v. =,=u ./sAs NFPA den ==,=4 more than 3 ft (0.9 m) on centers shall, ess of the

. . A=r a =p,t=dedA

, =#=/she *a p='Paa e.,=,ba4-depth of the tee, he located at or above a 1 in. (25 mm) below the level of the bottom of the stems of the tees

. - and comply with Table 4-2.4.6.

A-4-1.1.5 In ', determining equivalerit performance throup analytical or expen' mental methods, the sprinkler's sensiuvity, siway distribution, fire size and droplet sine penetration should be considered. Conditions of occu ,

such as height of storage,%ilding or eguipment con ra-tioris, obstrrtions, etc., which may anect spnnkler sensi-tivity should also be considered in evaluating both tests and calculatsoni.

Table 4-2.4.4 h of h h h w w Bessem of Besan Masimum Allowable Dissamer Distana from Sprinklee Deflector above

'* Side d Beam Bessem M Beam Less ihan t fa . . . . . . . . . . . . . . . . . . . . . . . C in .

I fa te les than I ft . . . . . ... . ....... . . I in.

I ft to less than I ft 6 in. . . . . . . . . . . . . . . . . . s. . . I in.

I ft 6 in. so les than 3 fa . . . . . . . . . . . . . . . . . .- 3 in.

' S fi so lens then s f 6 in. . . . . . . . . . . . . . . . . . . . 4 in.  !

i 3 ft 6 :n. so lens than 4 fi . . . . . . . . . . . . . . . . . . . 6 in.

4 ft toless than 4 ft 6 in. . . ........... . ... 7 in.

4 ft 6 in to less than 5 ft . . . . . . . ..... .. . . g in.

5 ft to less than 5 is 6 in. . . . .. . . . ... . . It in.

5 f 6 in. so leu than 6 ft . ... . . lg in.

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COMANCHE PEAK JUN 0 7 E65 Mr. M. D. Spence President Texas Utilities Generating Company 400 N. Olive St., L.B. 81 Dallas, Texas 75201 cc: Nicholas S. Reynolds, Esq. Mr. H. Shannon Phillips Bishop, Liberman, Cook, Resident Inspector / Comanche Peak Purcell & Reynolds Nuclear Power Station 1200 Seventeenth Street, N. W. c/o U. S. Nuclear Regulatory Washington, D. C. 20036 Commission P. O. Box 38 Robert A. Wooldridge, Esq. Glen Rose, Texas 76043 Worsham, Forsythe, Sampels &

Wooldridge Regional Administrator 2001 Bryan Tower, Suite 2500 U. S. NRC, Region IV Dallas, Texas 75201 611 Ryan Plaza Drive Suite 1000

. Mr. Homer C. Schmidt Arlington, Texas 76011 Manager - Nuclear Services Texas Utilities Generating Company Lanny A. Sinkin Skyway Tower 3022 Porter Street, N. W. #304 400 North Olive Street Washington, D. C. 20008 L. B. 81 Dallas, Texas 75201 B. R. Clements Vice President Nuclear Mr. Robert E. Ballard, Jr. Texas Utilities Generating Company Director of Projects Skyway Tower Gibbs and Hill, Inc. 400 North Olive Street, LB#81 11 Penn Plaza Dallas, Texas 75201 New York, New York 10001 Ms. Billie Pirner Garde  ;

Mr. A. T. Parker Citizens Clinic Director l Westinghouse Electric Corporation Government Accountability Project P. O. Box 355 1901 Que Street, N. W.

Pittsburgh, Pennsylvania 15230 Washington, D. C. 20009 Renea Hicks, Esq. David R. Pigott, Esq.

Assistant Attorney General Orrick, Herrington & Sutcliffe Environmental Protection Division 600 Montgomery Street P. O. Box 12548, Capitol Station San Francisco, California 94111 Austin, Texas 78711 Anthony Z. Roisman, Esq.

Mrs. Juanita Ellis, President Trial Lawyers for Public Justice Citizens Association for Sound 2000 P. Street, N. W. Suite 611 Energy Washington, D. C. 20036 1

1426 South Polk ,

Dallas, Texas 75224 l

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COMANCHE PEAK cc: Ms. Nancy H. Williams CYGNA 101 California Street San Francisco, California 94111 Mr. Dennis Kelley Resident Inspector - Comanche Peak c/o U. S. NRC P. O. Box 1029 Granbury, Texas 76048 Mr. John W. Beck Manager - Licensing Texas Utilities Electric Company Skyway Tower 400 N. Olive Street L. B. 81 Dallas, Texas 75201 Mr. Jack Redding Licensing Texas Utilities Generating Company 4901 Fairmont Avenue Bethesda, Maryland 20814 William A. Burchette, Esq.

Heron, Burchette, Ruckert & Rothwell Suite 700 1025 Thomas Jefferson St., N. W.

Washington, D. C. 20007 1

Mr. James McGaughy Southern Engineering Company of Georgia 1800 Peachtree Street, N. W.

Atlanta, Georgia 30367-8301

i O O ? 1965 In order to expedite resolution of this issue, the NRC staff will send its fire protection experts to the site to inspect all of the fire areas where the sprinklers are not in conformance with the NFPA 13 Code. The inspection will have the objective of identifying where limited modifications would bring the area into conformance with the NFPA 13 Code and those areas where the NRC staff experts believe that justification of a deviation to the NFPA 13 Code will be difficult to achieve. This inspection will be scheduled as early as the avail-ability of participants can be determined. The applicant indicated that there are approximately 15 areas that will need to be inspected.

S. B. Burwell, Project Manager .

Licensing Branch No. 1

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Division of Licensing DISTRIBUTION:

See Attached Page l

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LBf1/DL se' LB [P/ /DL CP/TRT l

l SBurwell/mac BJ ngblood CJ/ munell VSNgonan l 06A W85 06/ 85 06/p/85 06/ /85

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l MEETING

SUMMARY

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4911InfiffilE%91Eh4 NRC Participants NRC PDR L PDR S. B. Burwell NSIC Steven-West PRC System. John Stang LB#1 Reading File Dennis Kubicki Project Manager S. B. Burwell Bob Ferguson M. Rushbrook V. S. Noonan (part-time)

Attorney, OELD.

R.'Hartfield*

.0PA*

OTHERS bec: Applicant & Service List

• Caseload Forecast Panel Visits ~

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