ML20148T479

Informs NRC of Util'S Positions on Outstanding Fire Protec Issues.W/Encl 761019 Ma Firefighting Academy Ltr to Util Re Training Prog

ML20148T479
Person / Time
Site:	Yankee Rowe
Issue date:	12/01/1978
From:	Moody D YANKEE ATOMIC ELECTRIC CO.
To:	Ziemann D Office of Nuclear Reactor Regulation
References
NUDOCS 7812050210
Download: ML20148T479 (14)

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Telephone 6l7 366-90ll rwx 760 290 0739 YANKEE ATOMIC ELECTRIC COMPANY s.a.2.1 k .

20 Turnpike Road Westborough, Massachusetts 01581

.YANKEli December 1, 1978 United States Nuclear Regulatory CtetIssion Washington, D.C. 20555 Attention: Office of Nuclear Reactor Regulation D. L. Ziemann, Chief Operating Reactors Branch #2 Division of Operating Reactors

References:

(a) License No. DPR-3 (Dock.et No. 50-29)

(b) USNRC Letter dated November 1, 1978, from D. L. Ziemann to R. H. Groce,

Subject:

Staff Positions on Outstanding Fire Protection Issues (c) YAEC letter (WYR 78-89) dated October 16, 1978, from D. E. Moody to D. L. Ziemann,

Subject:

Fire Protection Evaluation Safe Shutdown Methods.

Subject:

Yankee Positions on Outstanding Fire Protection Issues Yankee has reviewed the expressed NRC concerns and staff positions in Reference b. above. In addition, we have reviewed Enclosure 1 to Reference b. to insure that it correctly represents YAEC's responses to the NRC staff positions. We find several instances where it does not, and these are listed here.

H.2, Switchgear room Halon system, was listed as A, accepted. It should i have been S, study. l l

H.4, Battery room air flow alarms, was listed as R, rejected. It should l have been A, accepted.

l J.5, Weatherproof hose house ventilators. It was agreed at the site visit that YAEC had adequately answered this concern, and that it would be deleted.

J.8.d, portable radios dedicated for fire brigade use, is listed as R, rejected. We feel it was agreed at the site visit that YAEC had adequately responded to the concern, and that it would be deleted. i 1

0.1, dealing with shutdown considerations. At the site meeting, l of /

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U. S. Nuclear Regulatory Commission December 1, 1978 Att: Office of Nuclear Reactor Regulation Page 2 considerable discussion was held on this item. YAEC feels that it was decided that the words " alternate shutdown method" rather than

" dedicated shutdown system" more fully expressed the NRC concerns on this subject.

R.4.c, has no designation of action taken beside it. It should be A-I.

Attachment 1 to this letter contains YAEC's response to the unresolved NRC staff positions. Several of those responses are proposed alternatives which we feel adequately answer the concerns expressed in the NRC positions. We trust that the responses will resolve the oustanding issues; however, should you have any questions, please contact us.

Very truly yours, YANKEE ATOMIC ELECTRIC COMPANY s

D. E. Mo Manager of Operations v---,

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Attachment 1 Several NRC staf f- positions dealing with fire protection were listed as  ;

rejected or under review by YAEC. Those positions have been reviewed and YAEC's responses follow here. We have not included those positions to which we previously agreed. <

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A. Primary Auxiliary Building A.4. Hydrogen-Storage Room should have forced air vent with low air flow alarm.

Response: There nra twelve 6 inch diameter holes open in the floor of the room (six on both the east and west side) and three 9 3/4 inch diameter vents in the roof directly above the H2 manifold. With the dampers of the vents ,

weighted to stay open, the YAEC f eels that this is enough natural circulation to ensure that there will not be a buildup of H2 in the room. .In addition, ignition sources have been minimized by making the .

i area a No Smoking area, using only nonsparking tools and enclosing the electrical equipment in explosion f

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proof fixtures. Personnel will be instructed that air flow in the room is not to be restricted. .

B. Diesel Generator Room B1. Fuel oil piping should be rerouted outside the safety injection i pump area of D-G building.

Response: Subsequent conversations with nembers of the NRC review '

team defined the concern, namely that a ruptured fuel oil line in this area could result in a large quantity ,

of fuel oil being released without plant operator awareness and endanger all safety injection pumps. [

The fuel oil line is the supply to the diesel generator day tanks and is under pressure from the elevation head of the fuel oil storage tank in the yard.  !

YAEC has addressed the concern and proposes to add the following modifications as a substitute for the l 1

staf f position.

The area outside the diesel room docrs will be enclosed with a curb so arranged that any leakage from the fuel oil supply piping will be contained and directed to  !

the drainage co11cetion tad. which is provided with  !

a high level alarm. In addition, a fireproof partition will be provided to insure that any potential fuel J l

oil piping leak will not spray beyond the confines of the enclosing berm. In this uanner, any potential i

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t r leakag- ill be contained and plant operators will be alerted to the existance of a fuel line leak in time to take corrective action. s B.2. An automatic suppression system should be provided to protect each diesel generator room with flame detector actuation.

Response: YAEC feels that the addition of an automatic fire suppression system would decrease the reliability of the diesel generators. Specifically, this could occur when a small fire, such as a fuel header leaking onto the exhaust manifold, started burning and actuated the fire protection equipment. Use of an automatic sprinkler system would require tripping of the diesel because of potential damage to the vulnerable electrical equipment in the room. Actuation of an automatic gaseous system could prohibit the access of plant personnel to correct the source of the problem, and the diesel would have to be secured to insure that (1) the source of fuel or ignition was eliminated, and (2) an adequate concentration of the gas could be maintained. The result is that small fires, which would alarm and be put out by operators using portable extinguishers, would require the securing of the diesels; thus decreasing their reliability.

As an alternative, YAEC proposes the installation ~of a fused head dry pipe system, manually operated from outside the diesel room. The increased detection capability in the rooms will alert the. operators.

If it is a fire, they will fight it manually, and if it appears that they cannot control it, the brigade leader will open the manual valve, thus applying the sprin'kler water to the fire.

YAEC feels that this is a much preferred alternative to the NRC position.

B.4. The doors between the Diesel Generator Rooms should be electrically supe rvi sed.

Response: The fire doors between the D.C. Cubicles ride on an inclined track to shut and remain shut by gravity.

The doors have never been blocked open as part of the plants normal routine. Based on the above, the plant ,

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does not feel that the doors need to be supervised.

B.6. The diesel fuel oil shutof f valve to the diesel generator rooms should be modified to actuate by an electro thermal link actuated by the automatic suppression system.

Response: YAEC feels that this is unnecessary. There are i

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presently two _ thermal links in the room, either of l which, when broken, will shut of f the flow of diesel ' i fuel oil to the diesel generator rooms. We feel that i l

this~is sufficient. It should be.noted that spurious operation of the link at' a time when the diesel was .

I needed could degrade the safe operation of the unit.

B.7. The diesel generator room should have. a drain to outside the room )j as a backup to the existing limited ' capacity floor drain.

Response: Each D.G. Cubicle has a floor drain that goes to a collecting tank with a capacity of 637 gallons, which alarms at 23", corresponding to 177 gallons. Because each cubicle will be curbed, the YAEC feels that even-if a pipe should break, there would be sufficient time for the operator to secure the . flow of oil without it spreading to the other cubicles.

C. Vapor Container No outstanding issues D. Fuel Storage Vault D.1. Wood storage boxes should be removed.

Response: The fuel storage area is not needed to safely shut down the plant. The amount of wood in there is small, there are no ignition cources. In addition, there is no better place to store the boxes, which contain control rods and belong in that area. For these reasons, YAEC feels that the wood boxes need not be removed.

E. Mechanical Equipment Room #3 E.1. A fire hose station should be provided- for Mechanical Equipment Room No. 3.

Response: There is a hose house within 105 f eet of the mechanical equipment room which contains as a minimum 150 ft.

of 2 1/2" hose, 200 ft. of 1 1/2" hose and two 1 1/2" combination nozzles. The area between the hose house and the mechanical equipment room is clear, with a straight line to the door. The hose house will supply ,

fire fighting capacity and equipment in excess of a hose station in nearly the same time, and is a more reliable supply. Therefore,, YAEC feels that a hose station is no needed to protect mechanical equipment Room #3.

F. Screen Well Pump House There are no outstanding issues.

G. Heating Boiler Room G.1. An automa tic sprinkle r system should be provided in the heating boiler room.

Response: The heating boilers operate only when the reactor plant is shut down, hence, present no hazard to Safe Shutdown.

Fuel oil is present in this room at all times, however, since the make-up supply to the emergency dierel generator passes through the area. Yankee li currently evaluating this situation and will either remove the fuel oil piping and thus remove the hazard, or provide automatic sprinkler coverage for the area.

H. Switchgear Room H.2. An automa tic total flooding Halon 1301 suppression system should be provided.

Response: YAEC will comply with this position.

H.4. Air flow alarms should be provided for the battery room exhausts.

Response: As noted in the cover letter, this was incorrectly listed as rejected; YAEC had agreed to comply with this position.

1. Control Room I.4. Cables above the f alse ceiling, in the Control Room, should be coated with a flame retardant coating. (Above control board and in side wall risers.)

Response: There are only a small amount of cables above the main control board. The cable trays on the south wall are all separated f rom one another by at least 18 inches with the exception of the two trays containing the 2300 volt cables. The 2300 volt cable trays are 4 inches apart with metal dividers between sets of cables, and. the cable sets are wrapped with asbestos above the ceiling. The cables above the dropped ceiling have a minimum amount of horizontal travel before they go through the concrete ceiling. The ceiling penetrations have all been sealed with a ANI approved three hour fire seal. There are three ionization detectors spaced over the south edge of the control boards. The panels of the dropped ceiling are easily removed for f ree access to the area above the ceiling.

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Therefore,. YAEC does not feel that spraying the cables is necessary.

J. Yard Loop and Hose Houses - Portable Equipment J.1. Each hose house should have the following additional equipment:

f. One Haligan forceable entry tool The doors for areas of the plant that contain equipment required for safe shutdown are either controlled by our security system or arc unlocked. In the event'of a fire the

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doors could be readily unlocked f rom the security console.

The ready access of a haligan forceable entry tool would be contrary to the philosophy of the security program adopted by the plant as requested by the NRC. Therefore, the plant feels that forceable entry tools should not be obtained for use.

J.3. Pos t barricades should be provided for the hydrants and PIV's which could be damaged by vehicles.

There is one hydrant and one PIV not protected by a physical structure of some type. The hydrant is 14 feet and the PIV is 10 feet from the nearest drive. Each is on a lawn between the road and a building. Between the road and the lawn is an asphalted storm drain ditch. The ditch has rounded shoulders but is 14 inches deep 8 feet in front of the hydrant and is 16 inches deep 7 feet in f ront of the PIV. The vehicle speed through these areas is slow, theref ore, the. plant feels based on slow speed of vehicles, the storm drain and the position of the devices that post barricades are not needed.

J.S. Hose houses should have weather proof ventilators.

Response: As discussed in the cover letter, this position was adequately addressed previously, and should be deleted.

J.7. A foam cart should be provided f or foam pick-up tubes and ten containers (5 gallons cach) of foam. Adaptors should be provided so pick-up tubes can be fitted to 2 1/2 inch hose.

There are three areas in which foam is stored for use:

a. 35 gallons in Compressor Room of Waste Disposal Building.

b. 25 gallons in Turbine Building at North door.

c. 45 gallons in the Security Diesel Generator Building l

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• NOTE: 25 gallons has been ordered for training purposes and to insure we have 100 gallons These supplies of foam are ' physically separated so as not to jeopardize all the foam with one fire, yet store it close to the various sources of flammable liquids. A foam cart could not be stored in an area where the foam would not be subject to freezing, be readily accessible, and would not be in the way of normal plant evolutions. The pick-up tube in the waste disposal building is made for use on a 2 1/2 inch hose and the pick-up tube in the turbine building is for use on a 1 1/2 inch hose. They are sized to the hose that they would normally be used on. Based on the above discussion the plant does not feel that the foam cart and adapters increase the suppression capability.

J.8. Additional equipment should be provided at equipment storage locations consisting of:

d. Three portable radios dedicated to the fire brigade and plant operations personnel emergency use should be provided.

Response: As.noted in the cover letter this was adequately answered at the site meeting, and should be deleted.

c. Four air breathing apparatus and eipti spare bottles should be provided.

Response: YAEC will comply with this position.

J.10. A cooling tank should be provided at the air recharging station (compressor)

Response: YAEC has been consistently able to fill air bottles to the required pressure at a rate of less than five minutes per bottle. This was explained to the NRC team during the site visit. In addition, YAEC has agreed to purchase four more extra breathing apparatus and eight spare bottles (J.8.e). For this reason, we see no need to provide a cooling tank at the air recharging s tation.

J.11. A cascade recharge system with the existing large air storage filters should be provided.

Response: There are two compressors located at the air recharging-station, providing ample means of filling air bottles.

Because of this and the reasons expressed in J.10 above, YAEC sees no need to add a cascade recharging system to the air recharging station.

L. Turbine Building L.1 An automatic foam deluge system should be provided for the following:

a. Lube 011 reservoir Response: YAEC will comply with this position,

b. H2 seal oil unit Response: Because of the decision to curb the area and drain oil and water out of the building, the existing deluge system can be used. It will be modified to be automatic and independent of sprinklers and hose stations protecting the same area.

c. Trans former oil cooler Response: A decision has been made to curb the area and drain any oil outside the building. The transformer oil has level alarms which indicate a leak to the control room. Automatic fire suppression will be provided by the modified deluge system described in L.1.b above.

L.2. The turbine lobe oil reservoir should be dyked to contain the contents of the lube oil reservoir plus an allowance for suppression water.

Response YAEC will comply with this position.

L.4. An automatic sprinkler system should be provided throughout the turbine building with a 0.3 gpm/ft2 density over the most hydraulically remote 3000 ft2 The feed to the system should be independent of deluge systems and hose stations protecting the same area.

Response: The existing sprinkler system will be modified and/or extended to meet the above requirement for areas of the turbine building under the operating floor. YAEC does not intend to extend the system to the operating floor or to the area of the turbine building under the switchgear room.

L.6. The oil s torage room doors should be curbed to contain normal oil storage (500 gallons) plus an all.owance for suppression water.

Response: The oil storage room is presently curbed with a six inch curb. With this curb the room will hold over 1900 gallons.

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l M. Fire Water Supply M .1. An automatic start diesel fire pump rated for at least 2000 gpm 0125 psi should be provided with an independent feed ta the yard loop unde rgrou-d sy, tem. Valving should be provided at the _ yard loop connection, independent of the existing loop feed, per NFPA 20.

Response: It is YAEC's intent to comply with this position by meeting the requirements of BTP 9.5-1, Sections E.2.c and e. However, due to the many variables to- be considered when evaluating 'the position (dealing mainly with the _ space available for such a modification) we cannot provide detafis at this time. The study is continuing, and these details will be provided in the near future.

H .3 . Fire Pumps should start at 110 and 100 psig.

Response: The plant. will_ change the setting of the pressure switches to start the fire pumps at the above pressures.

N. Yard Hazards 1

No rtutstanding issues

0. Shutdown considerations 0.1. An citernate shutdown method should be provided which is independent of the turbine building, switchgear room, control room, manhole #3 and single cable run in PAB f or charging and shutdown pumps.

Response: Our proposed alternate shutdown method was submitted to you in Ref erence c. of the cover Ictter. At a meeting in Bethesda on November 8, further informa tion van requested. Specifically, Yankee was asked to review the ins trumentation requirements for the shutdown methods previously described and to verify that the information would be available to the operating crew pe rf o rming t he shu tdown. Acquiring that inf o rma tion must not require assistance which would affect the manpower needs of the fire brigade.

This information is currently being developed. As i agreed in our telephone conversation of November 28, 1978, it will be provided before startup of the plant.

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P. . Fire Dampers P.1. Fire dampers with a rating equivalent to fire barrier penetrated should be provided to isolate the control room and switchgear .

room from the turbine building.

Response: YAEC will comply with this position.

Q. Fire Brigade Q.4. Fire brigade members should have of fsite hands on fire fighting training.

Response: Attachment 2 lists the training being given to the fire brigade at present. This was based upon the reccmmendation of the Massachusetts Fire Fighting Academy. At present, it is not practical to increase the amount of , or change the type of , hands on training; nor do we presently agree that it is necessary. YAEC will f urther evaluate the present training; and, if changes are deemed necessary, will make them.

R. Steps should be taken to enhance manual fire fighting espability, including interim fire fighting actions, at the earliest possible time.

R.1. Increase fire brigade size to seven trained members. (Action has been initiated by the licensee to have five trained members on day shif ts and an hourly fire watch of safety-related areas at all other times, until the unit is shut down for refueling.)

Response: This position now applies to the time from plant startup until the changes and modifications indicated in other staf f positions are comple ted; and was discussed f ully at the meeting on November 8. At tha t me e ting , the 1 actions we had taken between the time of the site visit and the meeting on the improvement of our manual fire fighting capability was sufficient for you to reduce this requirement to five fully trained members with an interim requirement of hourly plant tours until we have completed the changes and modifications indicated in other staf f positions. Therefore, YAEC will address itself to the five member fully trained fire brigade criterion rather than to the seven.

Yankee Atomic Electric Company, in an ef fort to resolve the question on interim fire brigade size (until additional automatic suppression systems'and increased detection systems are installed) proposes the following.

We will train and add to -ach shif t one additional aux.411ary operator. Our interim fire brigade will then consist of four trained fire fighters, with the Shif t Supervisor as brigade leader. They will be

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. c supported by two security personnel.who will provide communications and life safety help. In addition, these support personnel will be responsibic for I providing additional air bottles, portable ventilation eq uipme nt , and other additional fire fighting equipment

'as directed ~by the brigade leader.

It should.be realized that it will take time to hire and train these additional personnel. Until they are hired, trained and on shift, we propose to provide e fire brigade of five trained fire fighters, led by the Shif t Supervisor, at any time that significant maintenance and/or construction activities are .taking place in any area needed to safely shut down the plant or in any area where a fire could affect the ability to safely shut down the plant. This fire brigade will be supported by two security personnel with the duties stated previously. At any other time (backshif ts, weeke nds, holidays, when significant work is not going on) the fire brigade will consist of three trained fire fighters, led by the Shif t Supervisor, and the two support security personnel. It is our intent that after the additional codifications, revisions and additions have been cade to the automatic suppression systems and detection systems, the normal fire brigade at Yankee Rowe will consist of three trained fire fighters led by the Shif t Supervisor, '

and backed up by two support personnel at all times on all shif ts.

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1. Attachm:nt Two

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%ap / Au,,o&w3%),any&say ovvision or c c: c u PATIO N AL C pWC ATIO N hgu, ,j , (/M,

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• 6L'O N$ r MNf l'M' $/$l October 19, 1076 Day Berry Technical Assistant  ;

Yan!:ce \ tom.i c Elo::tric Comnany Rowe , 'l A n1367 Re: Fire Brigade Training Schedule and Course Outline

Dear 'fr. Rerry,

In reference to our meeting of October 8th re?.arding fire brigade training, the following _nrogram is submitted. It is both theory and nractical designed to provide tho  ;

brigade rember with firefighting knowledge and safety nractices in the following areas:

I. Breathing Anparatus 11/29 - 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> A. Necessity B. Function and operation C. Safety precautions D. Donning E. Practical application

7) II. Ilose and Noz:1cs 11/30 - 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> A. Construction D. Care and maintenance C. Testing.

D. Advancing E. Pepack ing F. No::1c operation 111. Portahle Pi rc Extinguishers 12/1 - 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> A. Chenistry of Fire D. Cl assi ficat inn C. Proper apnlication D. Foan application  ;

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. I V.- Electri ci tY 12/2 - 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> A. ' Elect ric utility company inst allations R. Flectricity en the hirnan hocly C. .Extinnuishing firns involvin : clect rical fires .

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V, titonatic Sr,rinkler Systens 12/2 - 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />

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3. Dr" sys ten C. n e luga it is undarstood that you can provide thn fo11ovinr1 facilitics and couipment.

1. rorridor and ailiacerit roons first floor of enerating plant for practical annlication with breathina apnaratus and hose lines (dry) .

2. Facility for re-charging air bottles.

3. (7) 208 purnic K fire extinguishers

. (5) 15ff C07 cxtinguishers J (5). 2's callon water extinguishers

< 4. (1) 5' X 5' X 8" pan g 5.

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!I2 fuel oil Gnsolinc

7. Fonn concentrato I

Mditional equipment will be supplied by the Firn Acadenv.

The program is scheduled for. four days , 9 a.m. to 4 o.m. and the suggested starting 4

1 date is 11/29 finish 12/2.

The instructor and administrativo costs for this program is $958.00.

1 The policy of the 'lassachusetts Firefighting A.cader"/ at this time does not provide j ror charnina tuition for industrial trainina courses. Chanter 842 Acts of 1971 authorizes

. the Flrc Acadeny to accept donatiers or grants from private firms or corporations to re-

imburse such expenditures. This program could not be offered otherwise.

Your interest in innroved brigade practices reficcts your professionalism and the 4

If you have questions please feci free to tsafety standards of call no at (617) 568-8348. Yankee Atomic Electric.

II "crv truly yours ,

1 E {sa m d Captain Dud Kirknan Progrn.n Specialist i

OTE : Donations nado payable to:

' lass achusetts Fire fighting Acadeny T-ust rund

'tr. P,dvard 11. McCornack , .Tr. , Adninist rat or c.c. Laerence Faria E. A. Sawve r, Yankee Atomic B",/ j h i

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