ML20147G480
| ML20147G480 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 12/20/1978 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Ippolito T Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 7812260192 | |
| Download: ML20147G480 (33) | |
Text
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PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 PHILADELPHI A, PA.19101 Shit LDS L D ALTROF F EL EC TRIC PR C C ION December 20, 1978 Re:
Docket Nos. 50-277 50-278 Thomas A.
Ippolito. Chief Operating Reactors Branch #3 Division of Operating Reactors U.S.
Nuclear Regulatory Commission Washington, DC 20555
Dear Mr. Ippolito:
Enclosed are responses to many of your staff positions stated in your letter of N o v e mb e r 17, 1978, regarding the Fire Protection Program at Peach Bottom.
Those positions not addressed in this response are designated in the enclosure by an appropriate note for each item.
It is our intention to address i
the remainder of the otaff positions in a 90 day response.
A schedule for completion of the modifications committed to in the attached enclosure will also be included in the 90-day response.
Should you have any questions on the above, please do not hesitate to contact us.
Very truly yours,
)
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s Enclosure 0@
0 781226o O 9
[
r FJ{fy, tyt!Ili;,1, Responses to '!RC Staff Positions Peach Botton rire Protection Progran Docket Mos. 50-277 and 50-278 Reference' Letter from Thonas A.
Ippolito, "uclear Regulatory Connission to Edward Bauer Philadelphia Electric Company; dated Novenber 17, 1978 TL,a.f,.f, P_o_s 1. t,t o n s, P F - 1,6 a (1,)_ C a,b_1 e s, a_h_o y e ' C o n t,r,o 1,,P o o_r! C.ci1,i,ng t
All exposed cables above the suspended ceilino, should be covered with a ffre retardant material which has been demonntrated offective by testing or install smoke detectors in this space which are located in accordance with the applicable NFPA standards.
EC_' 9.J1031RS.
This staff position will be addressed to in the 90-day response to pernit completion of our evaluation-S,t a_f,f, Po s i_t i o,n.P F,l_6 a_(.2_)_
Provide a stopladder adequate to reach the cables in this space.
This ladder should be stored at a dedicated location within the control roon complex with a sinn affixed reading "r0R F,!! C RG E N C Y USE - DO 40T RE40VC PROM C o l!T R 0 h R OO!!. "
Jie 3.0,9.n_,nji A stepladder will be stored within the control roon conplex of nufficient length to reach the npace above the quapended ceiling.
A s t ri n will be provided with the requested designation.
Et.a f_f, f,o n i_t_i o rt P r-16 a ( 3,),
Provide two 2 1/2 gallon prensurized water portabic extinquishers in the control roon complex such that they are availabic for use in all rooms of the control roon complex.
F g
Page 2 309P.qnsq Two 2 1/2 gallon pressurized water portabic extinguishers will be installed in one or more of the enclosed rooms within the control room complex.
Staff Position P T-16 b (l_ ), - Control Room Panels and Consoles Propose nodifications as necessary to assure that no redundant equipment (including cables) required for safe shutdown is located in a single panel without a solid fire barrier between compartments containing the redundant equipment.
The functional requirenants for a safe shutdown are discussed in staff position PT-26.
ScRPp n s e This staff position vill be addressed to in the 90-day response to permit completion of our evaluation.
Staff Position P F - 16h (2_),
All enclosed panels containing redundant safety-related equipnent should be provided with an early warning smoke detection systen.
1MLP9 n s e This staff position will be addressed to in the 90-day response to pernit completton of our evaluation.
Staff Position P T - 16 b (3_),
The licensee should verify that there is sufficient hose on the C03 hose recis in the control room to reach all areas of the control roon that contain ele ct rical equipment.
Ee_S.P_0_R S.E There is a 100 foot CO2 hose reels located a t the north and one at the south end of the control room.
Our investigation confirms the ability of the CO2 hoses to reach all a reas of the control room.
.P P.1 f c_(l_ ), Jin c_1 o_s c_d, R o o m s Uithin Contro1 Roon Etaf_f. P o s 1,t i o n s L
. Con _p_l,qx, All enclosed rooms within the control room complex should be provided with an early varning Cire detection system.
I i
Page 3 Responne Smoke detectors will be provided in the enclosed roons within the control room compicx.
Staff Positions P F - 16 c,( 2_)_
!! o unneenssary conbustible material should be stored in these rooms.
EE920 n s e, The housekeeping adminstrative control procedure vill require that unnecensary conhuntibic natorial should not be stored in the control room complex.
T' t,a_f, f Pjls_i.t i o n, 11F - 16 c_Q ),
The hose stations located in the turbine building adjacent to the control roon complex should be equipped with sufficient hose length to apply a water fog stream to all areas for the control room complex.
In addition these hose stations should be equipped with a variable gallonage fog nozzle with a ball-type shlit off.
.3M EP_0J1n c.
The hose stations located in the turbine building adjacent to the control room complex are equipped with sufficient hose length to apply a water fog ntrean to all areas for the control room complex.
Refer to reply to staff position PF-49 regarding the type of nozzle.
eit.A _ f..P O S.1.t i o_n s_
- P,P - 16 c,( 4,),
f All doors to enclosed rooms should be autonatically closed in the event of a fire or maintained closed at all times by adninistrative procedures.
Ventilation ducts and openings in the walls and doors between these enclosed rooms and the main control room should be fitted with dampers that are equipped with either a nanual or autonatic closing d e vi c e to prevent smoke and h eat from entering the nain control room.
If a manual closing device is used it should be capable of being operated Crom within the main control room at the opening to the room and a permanent sign should be posted at the device stating that it should be operated in the event of a fire in an adjacent area.
4 f
Page 4 P e s 2 o,n s,e n
A reply to your staff position will be presented in the 90-day response.
Staff Position PF-18 Fire Barrier Electrical and Mechanical Penetration Seal _ Qualification As stated in the initial NRC staff position PF-18 all clettrical penetrations in fire barriers surrounding fire zones and fire areas containing safety-related equipment (including cahics) should be sealed by methods demonstrated effective by testing.
In addition, mechanical penetrations in these fire zones and fire areas should also be sealed when significant quantities of conbustible naterial are present in the vicinity of the penetratration on both sides, or where the barrier separates safety-related equipment from fire zones or areas with a heavy combustible loading (e.g.,
cable spreading roons, control roon, zones or areas containing conbustible liquids, HPCI and RCIC rooms and ?!G set roons).
The licensee should p rovide a detailed description (including drawings and materials lists) for each of the types of electrical and ncchanical penetration seals that are used at the plant.
A description of the test procedure and ter results which are relied upon as proof of each type of s e al s qualification should be provided.
Any neu penetration seals that are installed in the future or should be qunlified by an existing seals which nust be replaced 3 independent testing laboratory in accordance with A ST!! E-119 and the following conditions.
1.
The cables used in the test should include the cable insulation naterials used in the facility.
2 The test sample should be representative of the worst case configuration of cable tray arrangement, anchoring, and penetration fire barrier size and design.
The test sample should also be representative of the cabic sizes in the facility.
Testing of the penetration fire barrier in the floor configuration will qualify the fire stop for use in the vall configuration also.
3 Cables penetrating the fire barrier should extend,a t least three feet on the unexposed size and at least one foot on the exposed side.
4.
The fire barrier should he tested in both directions unless the fire barrier is nymmetrical.
Page 5 5.
The fire ba rrie r should be tested with a pressure differential acrous it that is equivalent t <> the naximum pressure differential a fire barrier in the plant is expected to experience.
6.
The tenperature levels of the cabic insulation. cable conductor cable tray. conduit. and ftre stop material should be recorded for the unexposed side of the fire barrier.
7.
Acceptance Criteria - The test is successful if-a.
The cabic penetration fire barrier has withstood the fire endurance test uithout passage of flame or ignition of cables on the unexposed side for a period of three
- hours, b.
The temperature levels recorded for the unexposed side are analyzed and demonstrate that the maximun temperature is sufficiently below the cable insulation ignitton temperature. and c.
The fire barrier remains intact and does not allou projection of water b ey o n d the unexposed surface during the hose stream test.
3e.sponse.
The type of nechanical pene t ra tions utilized for which documentation is available were described in our response to question 19 (letter ll a n k i n s to Lear, dated August 12 1977).
A fornal tent p rogran han not been perforned on these specific nochanical penetrations.
Uc are currently reviewing all plant barriers given "0" ratings in the safety analysis, and following the evaluatton ue vill upgrade the penetration if req uired.
Ucu penetration sealn that are installed or existinn seals which nunt he replaced vill be qualified by testing currently in progress in accordance uith AST't C-Il9 once these tests are succesqfully completed.
The detailed description of the electrical penetration s" In (including drawings, materials lists. and test proceduNs and results) will be provided in the 90-day responne.
He are pronently working with Bechtel Corporation in developing a
suitahic electrical penetration seal for use at our Lincrick Generating Station.
'lh e n this design becomes available, ue will use it for future insta11attons at Peach notton.
Eljl.f_
P.O.S i. t_i_o_n_ P P - 21 a,C a_b 1 e Epreadiun Poom f
3 The licensee should proceed with its plan to upgrade the existing ftre detectton system.
The upgraded systen should be demonntrated effective by testing as discussed in NRC staff position PF-27.
Pane 6
.9,9.p o,n,MJ1 The PPno r.ngineering and P.e s e a r c h Department is presently inventinating the installation of smoke detectors in the cab o spreading roon.
The results of the inventigation vill be reported in the 90-day response.
Refer to the reply to staff position PF-27 regarding smoke detector testinn.
S t a_{ f. P.o s i t i o,n_ P F -21 b The existin<; uanually-initiated total flooding C03 system should be converted to an autonatically-initiated system.
R.c H.p o rute This staff position vill be addressed to in the 90-day response to permit completion of our evaluation.
_S_t a f f P.o s t,t l o n. P F-.21 c 11 o s e stations located in the turbine buildien adjacent to the cable spreading roon should he equipped uith sufficient hose length to apply a unter fon stream to all areas of the cable spreading room.
In addition. these hone stationn should be equipped with a variable gallonage fon nozzle with a ball-type shut off.
.RfAp_o n_nji Refer tc the reply to staff position PF-49 for a discussion of this nn.;
S t a f f; P o n_i t_t o n
.P P 21 d, Provide nodifications as necessary
'n.g.. relocate one redundant division of safe shutdoun equipment to outside of the roon) to assure that both plants can he nafaly shutdoun renardless of danage to any equipment (including cables) located in the cabic spreading roon.
The follouing functions should be considered required for safc.shutdoun-1 Placinn the reactor in a subcritien1 condition and naintaining the reactor subcriti.al indefinitely.
2.
Bringing the reactor to hot shutdown conditions and naintaining it at hot shutdoun for an extended period of tine (l.c., lonner than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) using only normal sources of cooling unter.
t
r Page 7 4
3 Maintaining the reactor coolant systen inventory indefinitely using only normal sources of, makeup water.
4.
9 ringing the reactor to cold shutdoun c o n d i,.t l o n s within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
No credit shoul1 he taken for actions by plant personnel to repair damage to equipment required for functions I.,
2.,
and 3 The capability to perform all control actions necessary for functions 1.
2.
and 3 must he maintained in the control roon or at the renote shutdoun canels, and all power requirenents for these functions nust he satisfied by onsite sources.
In lieu of a s s u m i n ", that redundant equipment required for safe shutdoun vill be danaged by a ningic fire in the cable spreading room, the licensee may elect to demonstrato by test or analysis that the separation of redundant equipment is (o r can be made to be) sufficient to prevent such an occurrence.
Any assumptions used in an analysis nust he verifled by t e s t' data for natorials and equipment arranged in a configuration similar to that installed in the plant.
The possible deleterious affects of combustion products and unter or other fire suppression agents nost he considered.
External ignition sources and transient combustibles nust also be considered.
l!" s.Ilp_n s_e, This staff position ull1 be addressed to in the 90-day response to pernit completion of our evaluatlon.
R L a_ f.f. Ilo 31.t l,0.n, P F - 2/p1 fla djta_r;t c_ n_u i l,cli_ny;; F i r e o n e s 4B, 4C 120.
An.d. 12 C,
- F1rjt P r o_t; e,c_t_i_o_n, The licensen should provide sprinkler protection in fire zones 4C and 12C.
fio 3 PAnRe.
This ntaff ponition vill be addressed to in the 90-day response to permit completion of our evaluation.
S,t a f_f, P o s.i_t i o n, P F - 2,4Jt The opeo pipe penetrations through the floor slabs separating nonen 4B'and 40 from 128 and 12C should be sealed with a unter tight.
3-h ou r fire rated scalant nethod (See PF-34).
1 Page 8 P 0.s.p o n.n e.
This staff pocition u111 he addreoned to in the 90-day response to pernit completion of our evaluation.
'lt.aff. P,o s_ f_ t.1 o n ll P,- 2_4 c, Curhing nhoull he provided within the rooms (fire zonen 4H. 4C, 124 and 12C) to contain the oil fron a leak at the oil renervoir or oil linen to the roon of origin.
_P;e n p o n s e Thin staff position will be addressed to in the 90-day response to pernit completion of our evaluation.
ji t a f f_ P o,s i t t o n. _P F.2,6 fia f_e fih u t d_o w n A n a l z s 1.s The
.l l c o n s e e should reconsider LLs safe ahutdown a na ly sis assuming that offaite electrical power 1 r.
not available in the event of a ftre in any area of the plants.
The following should he considered functional requirements for a nafe shutdown-1 Placing the reactor in a subcritical condition and raintaining the reactor subcritical indefinitely.
2.
Bringing the reactor to hot shutdown conditions and maintaining it an hot shutdoun for an extended period of time (i.e longer than 72 hou rs ) uning only nornal s ou rces of cooling water.
').
flaintaining the reactor coolant systen inventory indefinitely using only normal sources of nakeup water.
4.
Bringing the reactor to cold shutdown conditions uithin 7? hours.
If all of the redundant equipment (including cable in condult) avn l la b le to perform any of the above functions (assuntng a loss of offuite electrical pover) is located in a ningle fire area, the specific separation that exists and any combustible naterial between the redundant equipnent should he identified.
No credit should he taken for actions by plant personnel to tepair danage to equipnent required for functions I..
2.,
and 3 The capability te perform all control actions necessary for functionn I.,
and 3 nunt be maintained in the control roon or at the renote shutdoun panels and all power requirements for these functions must he satisfied by onsite sourcen.
t Page 9 1
The specific results of the above r e a n a ly s i s should be reported separately for each area in each unit.
EeS_P_0ASe This staff position will be addressed to in the 90-day response to p e r mi t completion of our evaluation.
S_ M f_f..Ilo S 1 t.i o_n, P P,2 7 S_m o k_c D_e t_c c_t_i_o n
.S y s_t_c n.
T_e_s_t s In situ tests should be conducted uith suitable smoke generation device to verify that the products of conbustion from a fire would be 'p romp tly detected by installed smoke detectors and the ventilation air flow patterns in the area do not significantly reduce or prevent detection response.
Bench tests should be conducted to verify that snoke detectors will provide pronpt response and have adequate sensitivity to the products of
'l conbustion for the combustibics in the area where smoke doctectors are installed.
If any fire detection systems are found to be inadequate. appropriate modifications sh ou ld be made to provide adequate detection.
E.c B_RRREE The ionization type smoke detectors at Peach Bottom were nanufactured by Pyrotronics Inc.
They are Factory !!a nu a l and Unde rwri t e rs Laboratories tested and approved.
We do not knou of an recognized method for performing "in situ" test on an installed smoke detection system.
Uc believe that the state of the art utilized in the ent ineering design of smoke detection systems ensures effective early varning protection.
Staff Position P F - 2 8 (a ), S u p e r v i s i o n of Fire Doors Fire doors should be inspected semi-annually to verify that scif-closing mechanisms and latches are in good working order.
.R_ t S P o " S t A semi-annual inspection program will be implemented as requested.
Staff Position P F - 2 8 (b_),
Fire doors should be provided with electrical supervision from the control room or maintained closed by one of the following-i.
[-
Page 10 (1) Lo ck ed closed and inspected weekly to verify that the doors are in the closed position.
The fire brigade commander should h ave ready access to keys for all locked doors.
(2) Provide with automatic release nechanisms and inspected monthly to verify that doorways are free of obstructions.
(3) Provide with self-closing mechanisms and inspected daily to verify that they are in the closed position.
Pic.S PJln_s g This staff position will be addressed to in the 90-day response to permit completion of our evaluation.
Staff Position PF-281c),
Areas protected by automatic total flooding, gas suppression systems should h ave electrically supervised scif-closing fire doors.
i ERSlgn s_g The doors to all the areas protected by gas suppression systems 1
(diesel generator building. cabic spreading room, and llPCI room) will be ele ct ri cally supervised by the security systen from the control room, cxcept for one door associated with the ll P C I area.
The practicality of including supervision at this door in the security system will be investigated and reported in the 90 day response.
All doors subject to this requirenent have s elf -
closing devices except for the water tight doors to the diesel generator building.
The security supervisory system will ensure closure of these doors.
Staff Position P P - 2 9 (a_)_ E n e rj e n_cl Switch 3 e a_r_ P_o o_n s, Portable C03 extinguishers should be installed in the corridor on the west side of the area and in the turbine building such that at least two are visible from the entrance to each of the switchgear rooms.
Rgsp_onse Two portable CO2 extinguishers will be installed in both the corridor on the west side of the switchgear rooms, and in the turbine building on the east side of this area (t otal of four CO2 extinguishers) in accordance with your criteria.
O 9
i
4 Page 11
.S L a. f_f,Po s_i,t i_o n, P.r;- 2 0 (b.)_
The hose stations located in the turbine building and the corridor on the cant side of the area adjacent to the owltchgear rooms should he equipped with sufficient hose length to apply a water fog stream to all of the rooms.
In addition these hose stations should he equipped with a variable gallonage fo; nozzle uith a hall type shut off.
1: e_n p o n n e l
Refer to the reply to' staff position PF-49 for a discussion of this matter.
Q t a f_ f,,P o s i t_l o n, llP - 2 9.(_c_)_
The supervision of the fire doors between adjacent suitchgear rooms should he in accordance uith Pr-23.
EU.AfloA5i.e.
Refer to reply to staff position 28a.
A reply to 28b will be prennnted in the on-day responac.
Staff Ponition P F-30 (a ) Station Battery. Roons An early warning fire detection system which alarns in the control room should he installed in each hattery room.
The installed systen should be demonstrated to be e f f ect ive by tenting as discussed in fl R C staff position PF-27.
Respo_nne A smoke detector system with alarns in the control room vill be inntnlled in each hattery roon.
El.3_f I.
P 0_8.A L_131"..P ";- 3 0 (b )_
The existing ventilation air flou detection nysters should be upgraded to include an air Clou detector in each hattery room upstrean of the exhaust damper for the room.
l
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Page 12 i
R e ny o a s e_
l l
The existinn ventilation air flou detection system will be upgraded to include air f low detection for each battery room.
rtt a f f_
P.o n_ i t i o n P r - 3 0. ( cj.
The supervinton of the fire doors betueen adjacent battery roons should be in accordance with PF-28.
Jt_e s pp n s c.
Refer to reply to staff position 28a.
A reply to 28 b will he presented in the 90-day response.
S t a_f f_
P_o.s i t i o n P P;- 11_( a1 lin e r3e n,c,v, D i e_s e 1 C e n e r, a t o r_.Qtti l d,i i!fi A curb should be provided to p re vent the flov of conhustible 11 quids under the doors between the individual diesel generator roons at the 127' e le va tion.
The self-cloning and latching devices on all the doors at all elevations should be inspected and repaired or replaced as necesnary.
The supervision of these doorn should be as stated tu PF.V.9 S D R n ?.c A curh or door ntil will be installed to prevent the flou of conhuntlble liquida under the doors between the individual dienel r, e n e r a t o r roons at the 127 foot elevation.
'l e f e r to the reply to ntaff ponition PF-28 a and c regarding supervision of these doors.
Defocttvo devices on all doorn wilI be repaired an necessary.
TL.a f f.
P(Di. t t o r.
.P, F_ - 1 1. (b l l
t The licennee should verify that all penetrations in the valls between individual roonn in the dienel generator building are
{
scaled to a three hour rating at all elevations and that any ventilation ducts in the valls have three hour fire danpers.
4 I
page 13
!!R'iP.o..n sy, The unila betueen the dicsc1 generator roons vill be re-examined, and as necessary a ll p ene t ra tions uilt be scaled to a 3-h ou r ratinn.
S,t a f,f, I! o n Q i o n IE-31 (c,),
The licconee should verify that the drains in the individual roomn do not discharge to a connon header that would provide a pathway for conbustible liquids between rooms.
ESH lio.n n,c, The drains in the individual roons dischar",e to a common header, however this does not provide
- n. pathway for conbustible liquids between roons.
The drains from the diesel generator roons are 2 feet above the header and each is supplied with a backwater valve.
The drain discharges to a 300 gallon dirty oil tank outside.
An.y overflou in into a 1000 gallon sump located in a renote area of the au xili a ry room.
The overflou line is 2 feet belou the elevation of the drains from'the auxiliary room.
S t,a.f f,,p o,s. I t_1.,0.n, P I!- 31,(d ),
An early unruinn smoke detection nynten which alarms locally and in the control room should be provided for all the roons in the diesel Scnerator bu i ld i n g.
Eeftp.onsjl Additional snohe detectors vill be provided to supplenent existing heat detectors in the diesel generator rooms.
A smoke detectton systen vill he ins t a lle d in the annitiary roon.
S t a_f, f, P o,n 1,t_J,o n,.P F -- 3_1,ie ),
The capability should be p rovi de d to trip the ann 111ary boiler fuel oil transfer pump.nanually from outside the area in uhich it is located.
A requirement to trip the transfer pump should be included in a written pre-fire s t r a t e ",y plan for the area to be used in ftre b r i s,a d e training.
See also pF-35 for the dienel nenerator fuel oil transfer pumps.
I Page 14 SE9.pgn,se The requirement to trip the auxiliary boiler fuel oil transfer pump nanually from outside the area will be included in the pre-fire strategy plan.
The control station for this pump is located outside the area in the auxiliary boiler house.
Staff Position PF-32 Em e r ge n cy J igh, t_i ng Fixed emergency lighting consisting of fixed sealed beam units with individual battery power supplies should be provided for access to and egress from the control room, the cable spreading room, the emergency switchgear and battery rooms, and the ground floor below via s t e. '
- u a y No.
9
.B.eJUtonse This staff position uill be addressed to in the 90-day response to permit completion of our evaluation.
Staff Position PF-33 Energeacy Communi_ cation Portable two-way radio units capabic of communicating with all areas of the plants should be maintained available for the fire brigade.
One unit should be available for each on-duty member of the fire brigade.
\\
E 0 G PRn_s.c.
j There are two fixed connunication systems at Peach Botton-the Private Automatic Branch Exchange system, and the Public Address system.
The first system has an independent power source (48 v battery), and the PA/ Party line system is fed from a r e gu la r and an autonatic alternate feed (both sources are fron the emergency l
power buses).
This ensures a high level of reliability and redundancy in the plant communication system.
The reactor would be scramned during a major fire that would jeopardize safety related equipment, substantially reducing ove rall p lant background noise.
This would further enhance the effectiveness of the fixed communication system for fire fighting operations.
As a backup to the above mentioned systems, at least 6 two-way radio units will be maintained available for the fire brigade.
These units will be under the administrative control cI the Shift Supervisor (Fire B riga de Leader), or Shift Superintendent.
l l
(l Page 15 Staff Position PF-34a Safe Shutdown Re_quirements The licensee should re-e va lu a t e the effects on safe shutdown of a fire in the primary containment.
This re-evaluation should be made in accordance with MRC staff position PF-26.
P e s_p o n_s_e, t
This staff position will be addressed to in the 90-day response to permit completion of our evaluation.
Staff Position PF-34b The existing fire detection system should be demonstrated to be effective as an early warning system in accordance with NRC staff position PF-27.
.Ep a p qJLs c_
This staff position will be addressed to in the 90-day response to pernit completion of our evaluation.
Staff Position PF-34c The licensee should verify that a hose from the existing hose stations in the secondary containment can reach the areas where oil from the recirculation punps would flow.
R_c,rgi o n s e The existing hose stations located on the 135 foot elevation of the reactor building contain sufficient length to eject a stream of water onto the 119 foot elevation below the recirculation pumps where the oil would accumulate.
Staff Position PF-35 Fmer_pte n_c_y. D i e s e l Concrator Fuel Oil Transfer Punos In response to NRC staff question Q-48, the licensee stated that the transfer pump could be turned off by tripping the load center which supplies power to the '1 C C located within the diesel generator compartment.
The licensce's response is acceptable provided: (1) no other equipment required for safe shutdown is supplied from the same load center, and (2) the requirement to trip the load center is included in a written pre-fire strategy plan for the area to be used in fire brigade training.
a Page 16
_R.c s n o.n _s e, Our initial response to staff question Q-4G was not clear on this subject.
The MCC located in the diesel generator c o mp a r t n'e n t can be tripped at the load center by opening the MCC f eeder breaker and not by tripping the entire load center.
The safe shutdown analysis already assuned the loss of this MCC for a fire in a dicac1 generator compartment.
Therefore, there is no other equipment required for safe shutdown that is affected by the tripping of this MCC.
The requirement to trip the load center will be included in the p re-f i re plan.
Staff Position pP-36a Conbustible L i q.u i_d_ C,u r b_s, The dikes in.the nain turbine lube oil storage tank roons should be upgraded to contain the full contents of all tanks in the roon plus the quantity of fire suppression water needed to suppress a i
postulated fire.
This may be accomplished by increasing the h eigh t of the existing curbs or by adding curbs at the room doors.
If curbs are added at the doors, verification should he prcvided that an oil fire in this room will not spread to other areas via the floor drains outside the existing curb.
Eq?20_n_!!E The area is protected by a sprinkler systen, and the existing i
d i '< o is sized in accordance with MTPA (i.e.
contents of larges single tank).
A fire in this area would not jeopardize the nearest safety related cable, which is located approximately 300 feet avay.
Therefore. we believe that further nodifications in this area are not necessary.
Staff Position PF-36b Verification should be p rovi de d that the reactor feed turbine lobe oil reservoir roon curbs are adequate to contain the full cotents of the reservoir plus an added margin for fire suppression water.
If inadequate, the curbs should be upgraded to provide the necessary capacity.
Ecs_PonSe The curbs installed at the 150 foot elevation are sufficient to I
contain the full contents of the RFPT and 19 minutes 01 sprinkler flow.
We believe the present design is satisfactory.
Curbs at the 135 foot elevation will be raised to contain the entire contents and a 20 minute. sprinkler flow.
I d
Page 17 Starf Ponition PP,-3,7,.(_a_), T u r b,,1,n q.9 1_1_d i,u.3 Early *inrning Ctre detectors should be provided in all areas of the turbine buildinn where safety-related cables or cables for safa shutdnun equipment are routed.
52n.P.9 nyg All safe shutdoun nethods are availabic follouing a ftre in all arcan of the turbine building uith the exception of fire zones 7PA (corridor betueen energency suitchacar roons and the raduaste buildinn), and portion-of 73B beneath the emeracucy nuitchgear rooms.
Ue vill provide early varning detection for,:one 78A and vill inventinate the feasibility of such a systen in zone 78B, and report our conclusions in the 90-day response.
E.lf ff Il0_3_ i t_ip.n I F
,3,7, { b ),
P, a r l y '/a r ni n g fire detection nhould he provided in the fin i t 2 turbine generator conpartment uhtch houses the ficxible Itquid radunste nurne tank.
I" 8_PM.uf 0 t.
The ficxibic liquid radunste nurge tank has been removed fron the Peach 30tton building.
There are no plans to relocate this tank uithin the butiding utthout first considering the potential fire h a.r. a r d.
S t a f f. P o s i,t i o n.,P P;- 3_ P;a, T u r_b_i,p e BtL_1dina - Hyd.ro,nen S c_a_l, 01_1, Irn i,t, i
Tha nupprension systen protecting the seal oil units should be upgraded to provide automatic actuation.
.S.RU.o n_n e, The suppresaton systen protectinn the seal oil units presently providen automatic actuation.
E t,a, C, f. Pas 1Lijul.Il[-3,;Sh.
A-curb uhould be provided to contain the oil in the sent oil units within the area of coverage of the sprinkler synten.
The curb height abould provide suffLetent volume to contain the oil plus an added ' ma rgin f or fire suppression vater.
Page 18
!!_e_spon,pe The curb around the neal oil units uilt be upgraded.
fL _a_f,f, J1o s 1 L_i_o q P F-3 9a To_r_us C o mp a_r,t_n e n t,s_. - J2i_r e.
t P_ro_te.c_ tion o
Early varning ftre detectora should be provided in the torus c o mp a r t rne n t s.
.N !!!iil9?..S.E This staff position vill be addressed to in the 90-day response to permit completton of our evaluatlon.
Q.t a f f P o s i_t_l o_n PJ-3_9b, In each torun compartment, the ladders to the catualk should be relocated so that there are four laddern with ench one adjacent to a different door f r o rt the pump roons to the torus compartment.
The ladders nhould be designed to permit access to the catwalk by fire brigade nenbers wearing energency breathing units.
Response
This ntaff position vill be addressed to in the 90-day response to pernit completton of our evaluation.
S t a_f f. Po s,I_t i o n liF - 3 9_q In each torua compartment, four ftre hose stations should be provided on the catualk. one at the head of each ladder.
necause the catualk la in close p roximi ty to the cable trays, a cabic fire could render a hose station inaccesalbic even with early detectton of the ftre.
Thererore, sufficient hone should be provided at each hone station such that all parts of the cable tray systen are accensible fron two hose stations.
The ftre hose nLationn nhould have 1-1/2-lnch hose equipped with conbination s pray /s t ra inh t strean unzzlen.
R efLP oJULc.
I This starf positton will be addressed to in the 90-day responne to permit conpletion of our evaluntLon.
l
Page 19 TL a_f f_ Po n i t_1 o n P,F,- 3,9 d_ T o r u,n C oflita r L;ne n t 5, t
i Portahic nnoke renoval equipment should he provided with the capabliity to exhaust snoke outnide the building in the event of 1,
a fire in either Lorus compartnent (See also PP-41.)
Resnonne Refer to the rep ly to staff position PP-41 for a discussion of this na t t e r.
Staff Position PF-40a Floor Drains - Conbustible Liquid Areas 011 from a leak in either notor generator set room will not spread to the annociated notor nencrator set tube oil roon via the floor drain systen.
.R.011p_o n a c.
The it-G set oil pump roon drains will be plugged, separated, or provided with backwater valves to prevent an oil pathway via the
!!-G set roon drainage systen.
.P ojt t ip_n
.P,F' - 4 0 it fl.tjL,_ f f
l 011 from a leah in a diesel generator room the dicsci c, e n e r a t o r building a u xi lia ry bay or diesel fire pump roon util not spread to other safety-related areas.
t P.(iAp o_n,py',
Refer to the reply to staff position 31a and b.
PortaIl_ S,o_ke,,"enova1 rquiu'ent TL 3.f.f. PJts I.t i,o n.
I;P,- 41, tf f l
L Pbrtable air handline, units should be n r o vi,le d consisting of three fire service, explosion-proof onoLe ejectors (5000 cfn each) and flexible ducting for smoke renoval throughout the plant.
Proceduren should be developed for use of this equipment by the fire brigade in all areas of the plant with particular emphants on compartments with difficult access in the reactor.
radunnte and control buildings.
,_._ ~
9 l,
f Page 20 P:0_HI!o n s e, Three portabic air handling units, an deacribed, vill be provided for amohe renoval in those arean of the plant where they would be effective.
I' r o c e d u r e n will be developed for the use of thin equipment by the ftre brigade in thene areas.
I ft,.a f, f, Ponition pF-42 Fire fla z a r d o Analvsin t
The potential for an unmitigated ftra in the r e c o rab i n e r building to cnune an unacceptable relenne of radioactivity to the site boundary should be evaluated.
The evaluation should be performed in accordance with guidelines in Regulatory Guide 1 98.
The relennes from both off-gan r e c o rab i n e r trains as well as the ventilation system charcoal filters should he used in the evaluation unlans it can be demonstrated that an u n mi t t ;;a t e d ftre would not involve all of this equipnent.
The potential for 3an explonions and the apread of fire via cables and other conhuntibles should be considered.
.R_o n.P. tin a e This ataff ponition vill be addrensed to in the 90-day response to pernit completton of our evaluatton.
At,a,f f, to t!I t,t o,n, P r-4,4 a. Ile a e tytr, ytu_t, L_d 1 nza Early un rn tnn f t re detection should he provided in the follouing reactor building fire zonen:
li n i t 2 fire zonen 5 11, SJ, 51:, In, 20, 21, 23 linit 3 fire zones 1 311, 13J, 1 3 P.
27, 29, 30, 31 R e.11:1o njt(1 The need for early warning fire detectors in zones 5 11, 5.1, 1 31!
13J uill he evaluated and reported in the no-day response.
The renaining zones have a ninimal ftro load and numerous nothods of safe shutdoun an evidenced by the nafe shutdoun analysin.
Therefore, detectors are not required in these areas.
II.t_d.ff P.(LF l.t 1,o n J21.'- 4,4,11 The-storane of coribustibles in nnfety-related arean of the I
reactor buildings should be discont(nued.
Page 21 I u,R p p_nj3,c.
t lionnehooping procedures vill be upgraded to ensure that storage of conbuntibles is prohibited in arenn uhere if ignited would renuit in damage to safety related equipment.
Staff Position P F-4 5 (a ) C i r c u l a t i n g, U,a t e r_ P o,.rgp_h,o u s e The extsting thernal detectors in the high prensure service v a t. c r pump roons (f t re arean 143 and 144) should be replaced or supplemented with early warning type fire detectors.
.li,,esponne The heat detectors ullt be replaced with snoke detectors.
Jj tjt _f_,P._ojt t_f o n P, P - 4 5_ (b_)_
f i
Curhina, should be provided within the diesel ftre pump roon (f t re a ren 145) adequate to contain the volume of the day tank plus the volone of vater r ecl u i r e d to extinguish a fire in this room.
4 Pc_spoe,ge_
i A curh vill be added at the door to contain the volune of the day tank and a suitabic oprinkler flou.
Lt. a ff, P.e s 1,,t_i_o rt P P - 4 5,(c )_
j A fonible link actuated shut-off valve nhould be provided in the fuel nupply line from the underPround storage tank at a point as clono as possible to uhere the line enters the diesel ftre pump room.
E".8.PSLn,se A fonible link shutoff valve or a high tenperature nuitch shutoff to the transfer punp uill be provided.
AtJL.f.f. Ilo n,1,tJJLit I P - 4 5 (3 ),
1 The exinting fire damper in'the vall of the diesel fire punp room should he verified as havi.a a 3-hour fire ratinn or the danper should be replaced with a neu 3-hour fire dauper.
Page 22 R,e,s,p,o n.s e 11anufacturer's tests confirm that the existing damper 1.s quallfled to 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rating.
Et,a f f_,P,o s_i_t 1.o n l', F - 4,5 (,q ),
The unter tight doors in the fire zone separations between compartments uithin the circulating unter pumphouse should be supervised as stated in PF-28.
Resyonse The three doo rs that access the center section of the Circulating Unter Punp structure (zones 143.[44. & 145), and the dooro hetueen zones 143 and 144 vill be nonitored in the control roon by the new security systen.
There is a sLntenent in the staff concern that should be modified.
You designate un emergency service water pump for each plant.
There is, houever, a tie line that allous the pumps to provide cooling unter to either unit.
Staff Position Pf, - 4_6, ( a_), " a_d u_a s t e, J'_u i_1 1_i n g Jii r e Z.o_n e 7_2 A 3
The doors to stairway number 34 in the radwaste butiding should be supervised in accordance w i t h P F - 2 ll. Supervision of Fire Doors le s,p o ny q Refer to reply to ataff position 28n.
A reply to 23b vill be presented in the 90-day response.
FLaff Il 0.n_i_ t, i_o,n, P r,- 4_6,.(,b, ).,
The fire hazard resulting from health physics cleanian and repair operations helng conducted in the corridor of the raduante buitdine, (roon 154) at the i16-foor elevatton should be nitignted by either:
(1)
Renoving all operations and storage from this area.
(2)
Providing a ftxed automatte sprinkler systen in this area.
Page 23 EEG P "J18_E The health physics cleaning and repair operations to breathing equipesent has been permanently relocated fron the 116 foot elevation corridor of the raduaste building to.a conpletely enctoned natal ntructn're.ncar the radiochen lab on the 11(i foot elevation of the turbine building.
Conbustibic naterials of a significant quantity are-not store or utillzed in this structure.
S. tAff P qs,I t i o n
,P F-4 6,ic_),
Early varning ftre detection should be provided t h r o u l;h ou t all arcan of fire zone 72A which contain or expose safety-related cabling or equipment to a fire.
R.cs p o n s e Fire zonen 72A consists of 14 roons on four elevations.
Twelve of these roons do not contain redundant equipment required for the safe shutdoun of the plant.
Poon 154 contains a feu safety related cable trays and conduit (one channel only) and sone cables required for sone conventional plant shutdown nethods.
Mine shutdown nethods would be avaliable folloutng a fire in this roon.
Since the health physics cleaning operation has been renoved from this room and there are many nethods availabic to shutdoun the reactor follouing a ftre in the zone an early varning detection systen is not needed for the area.
The remaining room is roon 381 and ou r evaluation of this area util be presented in the 90-day response.
TLL A I..f.
EP_ n i_t.ip n,
.I',[- 4 fu.1, The licensee should verify that the presently installed detection systen in roon 301 (fan roon 165-foot elevation) provides effective early varning indication of a fire.
The procedure for deternining this should follou the ruideltnes outlined in PF-27.
Snohe Detectton Systene Teats.
P08Lutn,s,e, t
This staff position vill be addressed to in the 90-day response to permit completion of our evaluation.
T' tA,,f 110 s_i t,1,0 n Pf - 4,7.fil_r c J[o _s_e T_est,in3 f
i Fire hose should be hyd ros ta tically tested periodically at a pressure 50 psi above the maximum service pressure of the fire water system.
Cxterior hose should be so tested annually;
.inte rior h ose should be so tested every three years.
)
page 24 l!" 8J"U! s e The Technical Specifications presently requires the station fire hoses to be hydrostaLically tested at a pressure of 250 psig every three years.
This test pre <4sure exceeds that requested in the staff position.
The maxtmum service pressure of the fire water system 18 125 psig.
All of the exterior hoses at the facility are protected from the environnent by appropriate encionures.
Therefore, it is our opinion that the testing frequency for all protected hoses remain at every three years as required by the existing Technical Specifications.
Staff Position P P-4 ft(,a.)_ Y a r d Area The environmental station pipe located at the hydrant just north of the administration building should be relocated so it does not interfere with the rotation of the hydrant urench.
Opening a hydrant can require as nany as 21 full turns, 110"10U15.J1 Corrective action utll be taken to provide adequate clearance.
?L a.( (
.P 0 % 11.1 o n. PJ;
't ;.QQ.
L P
flyd ran t s should be kept free of snou and ice accuuulations during l
uinter months.
Il e s p o n n e, A d mi n i s t r a t.I v e control procedures will be established to inplement this r ert u i r eme n t.
!! t:.!!.( f P.(m.i.l i o H.
PF.-48_.(_c).
Il o s e cart hounes should be maintained free of snov and ice a c c uinil a t i on during winter nonths to permit the free access to the hose cart.
Ilh e r e the hose cart house doors are close to grade level, the doors should be nodifled no that small accumulation of ice utjl not prevent the doors fron opening.
._.,.y
Page 25 R e_s p,o n s e Administrative control procedures will be established to implement this requirement.
5 Staff Position PT-48(dl The yard hydrant located in the middle of the yard on the west side of the plant should be turned to allow hoth 2-1/2-inch
{
outlets to be utilized.
At present one outiet faces a vall about 18 inches away.
E ERS_P.qnsq The yard hydrant in question vill be rotated or relocated to ensure that both 2 1/2 inch outlets can be utilized.
Staff Position PF-48(el j
The hydrant located at the southeast corner of the turbine building is leaking and needs repair.
Additionally. this same hydrant is too lov and should be raised so that the outlets are at least 18 inches above ground e
Respo_ns_c The leak on this hydrant has been repaired.
An inspection of the hydrant's seviceability revealed that there is sufficient clearance between the outlets and the ground to casily facilitate connection of hoses.
Staff Position PF-48(fl A naintenance program should be established for the hydrants uhich. vill require that each hydrant have the caps renoved, threads lubricated and the hydrant barrel check to be sure there is no water in the barrel in the fall of the ycar.
Ecsgqnsg A nalntenance progran vill be established for the hydrants which will require that ench hydrant have the caps removed threads lubricated and the hydrant barrel checked in the fall of the year.
Staff Position PF-4S(gl Each hose cart should be provided with the follouing additional equipment
i' l j
Page 26 (1)
One 2-1/2-inch bydrant gate valve (2)
One forcibic entry tool (halligan or similar)
(3)
One 2-1/2-inch fog nozzle Ec_8 P o!LS.e.
(1) One 2 1/2 inch hydrant gate valve will be installed in each hose cart.
(2) The availability of forcible ent ry tools on site presents a potential internal security problem.
In the event of a fire, control room personnel can e s t a bli sh accessibility by the fire brigade to all areas of the plant.
In addition, shift supervision possess the necessary keys to u nlock any door within the plant.
It is our opinion that the disadvantages of such a tool far outucigh the advantages.
(3) The 2 1/2 inch fog nozzle is applicable for use only by professional fire fighters.
We will make these nozzles available to the offsite fire departments by providing them uith the hose carts.
To inp rove the reach of the hose equipment, a 1 1/2 inch fog nozzle with applicator uill be provided uith each hose cart for use by the ftre brigade i
members.
I, i
Staff Position PF-48(hl Two hose houses should be provided at the east side of the plant located at the hydrants nearest the northeast and s ou theas t corners of the turbine building.
Each house should contain, as a mininum, the following equipnent (1) 150 feet of 2-1/2-inch hose (2)
Two 75-foot lengths of 1-1/2-inch hose (3)
One gated wyc having a female 2-1/2-inch inlet and two 1-1/2-inch male outlets (4)
Two 1-1/2-inch and one 2-1/2 inch adjustable spray nozzles (5)
One forcible en t ry tool (lla lli ga n or similar).
(6)
!!ydrant and hose coupling s panner urenches (7)
One 2 1/2 inch hydrant gate valve.
t Pnge 27 P e n p o.n n e Prenently there is a hone cart located at the north. south and noutheant areas adjacent to the turbine b u i l d i n ;;.
!!c believe this providen sufficient hose c o v e r n a. e - in these areas.
To ensure conelete hone coverage of the facility. we propose that an additional hone cart he.inntalled at the yard *eent of the reactor h u l l d i n o,.
e vill install all the additional enulpnent requested in each house c :: c e p t for the forethle entry tool (refer to reply o n P F'- 6 Tb, ).
'i t,a_ f f, P,o n i t i,0 n PT-49-1, I n t e r l,o r, 1[o s e R t,a t i o.ny, Additional hone shou l l be provided on interior hose stations an requtred to ansure thnt all safety-related areas and arena that pose a fire hazard to sa ctv-related areas. can he reached with r
sufficient hone to p e rmi t effective application of a hone strean to all portions of the areas to be protected,
'1 h e r e more than r hose in reqntred to reach thene arcar a naxinun of 100 feet o 50 feet of l-3/4-inch hone may be added.
Uhere aore than 150 feet of hone is required to reach these areas, additional hose ntattonn nhoulI be inntalled.
U e s p os t u e, A survey perforned by the PUC0 Rafety Department conff.rmed that all safety related areas, a n.1 arenn that pose n fire to safety related arean, c1n he reached with installed hose.
The hone stations in unfety related a r c a r. are limited to 100 foot.
There are two non-safety related areas in the reactor buildinn 180 foot and 214 foot elevations. that cannot prenontly be reached fron any hone station.
A d d.i t i o n a l hose reels will he installed to provide coverane to these areas.
Qta,fr P o q 1. t 1,o 31 P F - 4,9,- ? I n t e r l o r, l[o s.e Q t a L t.o.n.n All existinq and neu hose stations should have the hone connected to the ho9e station valven.
fl o u p o n s e t!c nou require that all houe stations ohould have the hose connected to the hose station valve.
Qtaff, Ponition Pr-49,-3 T itt e r i o r H o n e, Etatipnn i
All hono nLatlonn in the vicinity of safety-related equinnent that c ou l,! he lamaged by a hose strean or nenr electrical eluipment or could he a ha-ard to ftre fighters s h o o l :1 ho
4 Pane 20 equipped uith va riabic gallonage fon aozzles with a ball-type shut off.
.H3?.P O.n_n e All of the Peach Got ton h one s t a ti ons are equipped uith Alfco Fog nozzles.
It is our considered opinion that this type rep res en ts the ben t -indus t ri al type nozzle available for une at Peach Sottom.
Due to the sophisticated training required in the use of a variable nallonage nozzle. use of this type of nozzle vould reduce the fire f igh ting effectiveness by the fire brigade, and uould pose a serious personnel safety hanard-
'la n y years of experience uith the Alfco Fog nozzle han demonstrated it to be very effective in fighting many types of firen.
'! e do agree that the inntallation of a hall type nhutoff valve has nerit, and such a device will be added to each hose nozzle.
Staff Position Pr-50a Administrative controls and Qu a 1_1 ty_
d 'UL". r a n c e, Confirm that-(1) the " appropriate tine" for renoval of c onhu a t ib le s from work areas is norna11y at t. h e end of each shift or following the completion of the activity, ubichever is sooner (2) for work acttvtLies during najor outagen '/hich require note than one shift operation, the renoval of combuutthles yto t n e c e s.s,a ry, f o,r, the c o *3p_1 e t_l o n,o f,,t_h e,,u o r ( (f.e.
rans, debris, oil npills, etc.), vill Se accomplished at the end of each shift. and following the comp le t i on of this prolonned uork activity all conhuntibles will then be removed.
SoPilo?,n.?
Combustiblos, uhich !C ignited uould damage safe shutdoun equipment in the vicinity. uill nornally be (1) renoved from the work area at the end of each shift or follouing the completion of the activity, whichever is sooner: or (2) placed la fire resistant containers for disposal follouine, the completion of the activity.
Etaff,."fAltipn, pr _Q05 Conftrm that the offstte ftre departments, at least once a year.
uill participate in ftre brigade drills and practices.
P a ", e 29 P c s p,0 n n e As descrthed in a nrevious responoe to the Conniscion the Peach Sotton rnere,ency Plan providou for annual briefinns of personnni fron the local ften department on fire f("Stinn aspects of the site.
"ithin one year following completion of the neu security i n n t a l l a t. l o n at Peach Motton, the local ftre departnent will be invited to participate in a ftre brigade drill to familiarize then with access capabilities.
In addition. the 'i t a t i o n Superintendent v il l requent their n o r t i c i p a t f. o n in nite ftre drills when in his jud"enent, najor modificationn in the security installation physical orientation of the plant or ftre finhting syntems varrants such an exercise.
9 t.a,f f P.o n t.t i o ! P lf - 5 0.c.
ConfIrn that- (l) class roon instructions include the correct nethods for f t ", h t i n g h yd ro ne n ftres, tunnel fires and record fCle firen (2) fire b r i r,a d e practice sensions r e ", a r d i n g the pro 9er nethods of f inh t inn f t ren include fires of a nintlar n a ", n i t u d e,
conplexity and diff(cult." as those which coul1 occur in a nuclear peuer plant and provide b r i o.a d e members experience in the use of enerrenev b r e a t h i n ". apparatus under s t r e,n u o u s, c o n d i_t i,o n s.
i'ennonne (a) The cire Protection plan util he revised to require clau9toom instructtons on the correct rethods for ftphting h y d r o n, e n ftren, tunnel fires. and record flle ftron.
(b) Ao described in a p revioo n response to the Comnission practice cessions for the ftre bri nado nenbers will include actual extinnoishnent of varioun typen of fires while untng enernency breathing anparatus.
Thin provifes the ftre bricade nenborn uith the exporlence required for finhtinn the typen of firen that c o o l.1 he expecte! to occur in the power plant The t r a i n i n ", session olli provide the individual with experinnce in f[qhttr.n a typical ftre uhile wearing enernency breathinn apparatus.
In addition, frequent on the job experience in the voartne of breathing apparatun under adverne conditions is obtained by the nenbers of the fire br13ade as a result of the plant'<. radiological protection requirements.
If it han been deternined that a nenber of the fire hrinade han not recetved sufficlent experLonce In the one of breathinn apparatun, additional traintn" v111 he p ro vi ded for that i nd i vi du a l.
page 30 R t.a. f f. P.o s i t,i o,jt pf-5 0,d l
Conftrn that p r o ". r a ns are estahlinhed for Quality l
A n n u r a n c e / q u it t i t y C o n t r o l to 'crify that personnel are trained in the testin; of fire protection systens.
Pesp.ojtse The t e s t i n ". of fire protection syntens ulll he controlled and d o cu me n t e 'l in accordance uith the statlon's quality assurance progran.
The testtan of ftre protection systens in ansta,ned to cr1ft and 09eratfor; type personnel '/ h o ponnons the skills necestary for this task.
Additional quality annurance for the traininn of personnel involved in testinn vill he provided only for those tents involvine, nkilla not nornally required by these i
grounu.
1 t_ a f. f Po s i t i o.n. J'l-QO c, Channo the vords and phrasen such an "nay" "should" "should be "would" "uould he",
noted t h rou gh ou t in the rire Protectton olan and A u ",u n t 11, 197'l letter to - "shall" "v i ll ". or "shall he" or "uill he" an appropriate to the nnhject under dinconnlon.
M " 9.Ro.!UU'.
Thin staff position util be addressed to in the 00-day response to pernit conpletion of our e va lu a t ion.
8.t,a fl P.o st t,i o n Ili;- 5 0 f, i
Confirn that prefire plan otratenten vill he entablished for fi",htinn flron in all snfetv-related arean and arean prenentina a h a r. a r d for safety-related equipment.
\\lso indiente uhether these plans include requirenento to t ri p - (1) the auntliary boller fuel oil trannfor norp nannally from outside the area in which it is located and (2) the load center ubich supplion rover to the notor control center located uithin the diesel 'enerator c o n p.i r t n e u t.
0.e n p ".n s ('.
Pre-ftre plan a t r a t e r; t e n vl11 he ontablished for i i a.h t i n a firon in all safety related arnas and arean procentin: a h a ?. a r d for nafety related e q u i p r'e n t.
Thene plann ullt include the requirerent to trip (1) the auxiliary li o l l e r fuel oil trannfer pump manually fron outside the area in uhich it in located and
e a
P a e, c 31
(?) the load center which nupp]les pover to the motor control center located uIthin the dienel nenerator compartnento.
';r a f f
, on.itIon. PP-50g p
The ohift Supervinor should ohycicallv nurvev all v o r; areas "here work in to be perforned prior to isnuance of the Ie,nition Source control Chock.
Peoponso If an ipnitton nource in to be uned the worker is required to notify hin "opervisor before the v o r ': is initiated-who in turn vill if a fire h e r. a r d entnts prepare an Innition Cource Centrol I,t a t.
After doncriblon the fire hasard an! the p revent ion precautioun uh tch nhall be uned, the w o r';
'l u p e r v i s o r will contact Shift 'i u p e r v i s i o n.
Shift Supervision vill revicu, revice an necennarv and approve the Contro] Chech List.
If upon inqpectlon of the wo rk area by Rhift qupervinton it in his judneuent that a ftre hazard doen not exist the une of the innitton source Control Check I, l s t nay be unived.
Othervine it in not neconsary for him to phynically survey every work area haned on his 1nowledge of the plant.
Additionally. every work requent is reviewed by 'i h l f t "npervision to deterrine the need for I"nition "ource Contro1 and thin reviou is docuneuted on the
'f a in t ena nce Pequent Forn.
1 t a f f, po,itton PJ - } P h.
At
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hrtrade fire drills should be critiqued by q u a l f f i m' t,dividual, independent of the utility's staff.
These c r i t iq ue, oi ll annure that profennional fire ft"htino o wertise in nv111ahle to update and correct nintales in fire f i nh ti n" techniquen uhlch are not ob vi ou n to the u t t l l t " ' '. stafr,
",e n n o.n n e prC9 han qualifted ftre f i g h t i n o. exnertine independent of the plant utaff vithin thb 1afety hepartnent tho Oas Operations firo 1chool and the Administration and r a i n t o r niviolon.
\\t tbree vear interva19 a fire dr111 ullI he eritlined by personnel fron one of theqe croup who is o r;;a n t > a t i o na l l" independent of the at1tten utaff
\\t leaut everv 36 nonthn an ournide P i' C o qu,llf!cd ftre protection consultant will innpect the fire orevention w r o ", r a n.
The consultant Nv elect to c r i t t -[ u e a f t re drill do r t no his ins pect ion of the facility.
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i q t a f f. P,o n i t 1 o n.
PP-50,1 S u r t o ", n'a l o t e n a n c e and nodifications in b u i l d i n y <; containinr, 1
qafety-related nystens or equipnent, the adninistrative controls
<;overninr "transtent fLre loads" should require (1) an in plant l
l revteu to identify potential fire loads, and (2) an necessary, a dill t i ona l fire protectton for the wo rk acttvity procedure.
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\\ d ni a l s t r:i t i ve controls vill be established requirinr. that a nerber of the niant staff should (1) conalder potential ftre h a r. a r d s aquociated with the rennested naintenanco or modification oork in areas containtnr, nafety related avsters or equipnent and
(?) an nocenonry spectfy addLtlonni ftre orotcetton for the actlvity in the controlling vork procedure or instruction form.
i Thene c o n t ro l:. 'i n conjunction uith the to,nition <; o u r c e controls uill iirovide anfficient fire protection
<l u r i n a, the work a c t i v i t :'.
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