ML20197G219
| ML20197G219 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 01/17/1984 |
| From: | Johnston W Office of Nuclear Reactor Regulation |
| To: | Novak T Office of Nuclear Reactor Regulation |
| References | |
| CON-WNP-0725, CON-WNP-725 NUDOCS 8401260442 | |
| Download: ML20197G219 (9) | |
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'JAN f 71984 MEMORANDUM FOR: Thomas Novak, Assistant Director for Licensing Division of Licensing FROM: William V. Johnston, Assistant Director Materials, Chemical & Environmental Technology Division of Engineering
SUBJECT:
FIRE PROTECTION SUPPLEMENTAL SAFETY EVALUATION REPORT -
WPPSS NUCLEAR PROJECT NO. 2 Plant Name: WPPSS Nuclear Project No. 2 Docket No.: 50-397 Licensing Stage: OL Responsible Branch & Project Manager: LB #2; R. Auluck CMEB Reviewer: D. J. Kubicki Requested Completion Date: ASAP Review Status: Complete In our memorandum of March 17, 1983, we indicated that we had not per-formed our fire protection site visit yet. Between March 22 and 25, 1983, we conducted our audit. As a result, we reached several agreements with the applicant concerning the adequacy of the fire protection program.
We also expressed a number of concerns pertaining to previous applicant commitments and the degree of compliance with our fire protection criteria.
These issues were delineated in our trip report of April 13, 1983.
By letters dated July 1, September 29 and October 28, 1983, the applicant provided additional information in response to our concerns.
Based on our evaluation, we conclude that the fire protection program, with the accepted deviations, meets the guidelines of BTP CMEB 9.5-1 and GDC-3 and is, therefore, acceptable.
Attached is our evaluatiun and the proposed license condition for the fire protection program.
i G401260442 840117 William V. Johnston, Assistant Director e ADOCK 05000397 Materials, Chemical & Environmenta!
- , Technology Division of Engineering l
Enclosure:
As stated cc: See next page
Contact:
D. J. Kubicki X27743 t
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. Thomas Novak JA+'l I 71964 cc: R. Vollmer t D. Eisenhut f
A. Schwencer 1 0. Parr
! M. Srinivasan V. Benaroya R. Ferguson R. Auluck .
T. Sullivan J. Taylor 2
S. Pawlicki D. Kubicki K. Scown S. Ebneter, Reg. I
- T. Conlon, Reg. II C. florelius, Reg. III ,
E. Johnson, Reg. IV l P. Sternberg, Reg. V I il t
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Chemical Engineering Branch / Fire Protection Section Supplemental Safety Evaluation Report WPPSS Nuclear Project No. 2 Docket No. 50-397 9.5.1 Fire Protection Program l
The SER stated that the staff's fire protection site audit was an open item.
The staff fire prote-tion site audit was conducted between March 22 and 25, 1983. As a result of the audit, the staff reached several agreements with the applicant concerning the adequacy of the plant fire protection program.
The staff also expressed a number of concerns pertaining to previous appli-cant commitments and the degree of compliance with the staff's fire pro-tection criteria.
By letters dated July 1, Septenber 29, and October 28, 1983, the applicant provided additional information on the fire protection program.
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SER Sections 9.5.1.5(1) and (4), 9.5.1.6(1) and (3), 9.5.1.7(2) and (6),
9.5.1.8, and 9.5.1.9 have been amended to reflect the results of the staff's evaluation of this information.
9.5.1.5 General Plant Guidelines (1) Building Desica The applicant, in Amendment 19, has committed that fire doors will satisfy the requirements of Appendix R to 10 CFR 50, Section N, which pertains to self-closing or administrative-closing procedures. In the site audit, the staff observed that stairway fire doors were equipped with fusible-link-type hold- t open devices, which are not consistent with that commitment. By letter dated .
July 1, 1983, the applicant committed to remove all fusible-link-type hold-open devices.on fire doors in stairways. The staff finds this acceptable.
There are double fire doors in the wall separating the redundant residual heat removal (RHR) rooms at the 422-foot elevation in the reactor building. The staff was concerned that :in the event of a fire in one RHR room, fire fighting efforts would necess'itate' entering the fire area from the other room, thus exposing both divisions to potential fire damage. However, during plant oper-ating periods, these doors are kept closed and locked. If an alarm is received frca either root., plant fire fighting procedures direct that confirmation of an emergency he accomplished from other room access points, without opening the common doors.
In the event of a significant fire in the north RHR room, it will be necessary to open the common doors to use the fire hcse from the standpipe system. How-ever, plant fire fighting precedures stipulate that two hose lines will be exten& d. One will be used to fight the fire; the other will be used to pro-tect die door opening pnd the adjoining RHR room. It is the judgment of the staff that a fire will not propacate through the doorway and cause damage to shutdown-related systems from both divisions because (1) the high ceiling in ~~
the RHR rooms will act as a heat sink and will channel smoke and hot gases.away '
from the doorway, and (2) the doors will only be opened after the arrival of the fire brigade with charged hose lines.
l The applicant ha$ provided 3-hour and l\-hour fire doors / dampers in heating, '
l ventilating, and air conditioning (HVAC) ducts that penetrate fire-rated walls. '"
l During the site audit, the staff observed that no dampers had been installed in '
l the concrete slab at the top of the Division 1 and 2 motor control center (MCC) rooms. In a letter dated July 1,1983, and in Amendment 24 to the FSAR, the applicant committea to install a 3-hour fire damper in the concrete slab in the Division 1 MCC room. However, there is no damper in the slab in the Division 2 l
MCC rocm. Because each room is a separate fire area (separated from the other j by 3-hour-firc-rated walls, floor, and ceiling), a fire in either room will not i
affect the capability to achieve and maintain safe snutdown conditions. There-j fore, the absence of a fire damper in the Division 2 MCC room has no fire safety significance and is, consequently, acceptable.
In a letter dated September 29, 1983, the applicant identified a number' of fire
! damper assemblies that have not been tested by an independent lacoratory. These assemblies consist of Underwriter's Laboratories (UL)-listed, 3-nour-fire-rated doors installed in unlisted frames or supports. The support assemblies for l
1 l
! WNP-2 SSER 4 9-4
g'uillotine-type fire dampers consist of a 12 gauge steel "C" channel that is used as a guide in which the door slides. A 3/16-inch angle is welded to the channel, and the angle is bolted to the wall with -inch-diameter bolts. The bolts are placed on a maximum spacing of 18 inches on center, with a 2 -inch minimum imbedment. The frames for trap door-type dampers are constructed of 10 gauge steel. These are bolted to the wall or floor using -inch-diameter bolts. The construction and installation of the frames and supports is compar-able to listed assemblies. The unlisted assemblies are generally in areas of low fire loading. Where a significant fire load exists, the area is equipped with an automatic fire suppression system. Consequently, the staff does not expect a fire in these areas to develop elevated air temperatures that would pose a threat to the integrity of the dampers. Therefore, on the basis of its evaluation, the staff concludes that the unlisted fire damper assemblies are an acceptable deviation from Section C.S.a of Branch Technical Position (BPT) CMEB 9.5-1.
The SER stated that interior walls and structural components, thermal insulating materials and components, and radiation shielding materials are noncombustible.
During the site audit, the staff was concerned that the laminated wall panels in the control rom and the foam insulation in several areas of the plant were combustible. By letter. dated October 28, 1983, the applicant provided verifi-cation that these materials have a flame-spread rating of not more than 50 when tested in accordcnce with the method identified in American Society for Testing and Materials (ASTM) Standard E-84. This conforms with Section B.4 of BTP CMEB 9.5-1 and is, therefore, acceptable.
(4) Control of Combustibles In Amendment 19, the applicant committed to comply with National Fire Protection Association (NFPA) Standard 30, " Flammable and Combustible Liquid Code." During the site audit, the staff observed that in the water filtration building the diesel fuel day tank wds on unstable pipe supports. This condition was contrary to the commitment. The staff was concerned that if the supports failed, a diesel fuel spill and resulting fire would occur. By letter dated July 1,1983, the applicant committed to redesign and strengthen the supports to conform with ]
NFPA 30. On the basis of this commitment, the diesel fuel day tank will con-form with Section C.S.d of BTP CMEB 9.5-1 and is, therefore, acceptable.
s There is no curb in the coorway between the turbine generator building and the -
reactor building at door T-114. The staff was concerned that if a significant oil spill occurred in the turbine generator building and the oil ignited, a flammable liquid fire would propagate through the doorway. However, an open head, deluge-type automatic fire suppression system protects the oil piping in the area. The floor in the turbine generator building is sloped away from the doorway toward five floor drains. In a letter dated October 28, 1983, the applicant committed to provide an additional hose station off the standpipe system to supplement the existing fire protection in the area of the doorway.
The staff finds this acceptable.
9.5.1.6 Fire Detection and Suppression ,
(1) Fire Detection The areas that are equipped with fire detectors are identified in the applicant's Fire Protection Evaulation Report. In general, fire detectors are provided in WNP-2 SSER 4 9-5
'al1 locations that contain safety- or safe-shutdown-related systems. The fol-lowing areas do not contain fire detectors:
north valve room, reactor building, elevation 548 feet sampling room, reactor building, elevation 548 feet north and south valve rooms, reactor building, elevation 522 feet reactor water cleanup (RWCU) pump room, reactor building, elevation 522 feet RHR valve room 307, reactor building, elevation 501 feet travelling incore probe (TIP) room, reactor building, elevation 501 feet north valve room, reactor building, elevation 471 feet below steel grating, reactor building, elevation 422 feet The fire load in these areas is low. Combustible materials are also widely dispersed. Consequently, the staff does not expect a fire of any significant magnitude or duration to occur. If a fire were to to occur in these areas, it would be detected by fire detectors in adjoining locations or by plant operators, who would summon the fire brigade. The safety related equipment in these areas consists primarily of tanks and piping not significantly prone to fire damage.
Therefore, pending arrival of the brigade and eventual extinguishing of the fire, no loss of safety function would result. On the basis of its evaluation, the staff concludes that the absence of fire detectors in the referenced loca-tions is an acceptable deviation from Section C.6.a of BTP CMEB 9.5-1.
During the site audit, the staff observed that in several fire areas, smoke detectors were not installed at each floor elevation. The staff was concerned that if smoke stratification occurred, the detectors that are installed at the ceiling would not function. By letter dated July 1, 1983, the applicant veri-fied that the ventilation system is designed to facilitate movement of smoke toward the detectors. Specifically, air is supplied near the floor and is exhausted at the ceiling. Therefore, based on the prevailing ventilation pat-terns in the areas, cot { pled with the thermal column produced in a fire, the-staff has reasonable assurance that ceiling-mounted detectors will activate.
On the basis of its evaluation, the staff concludes that the design of ceiling-mounted detectors in multifloor areas conforms to the guidelines of Section "
C.6.a of BTP CMEB 9.5-1 and is, therefore, acceptable.
- The staff was concerned that photoelectric-type smoke detectors were installed at a spacing greater than that permitted by NFPA 72E and the UL listing. By
- letter dated July 1, 1983, the applicant verified that the greatest detector -.
spacing is 750 ft ,2 which conforms to NFPA 72E and the listing. The staff finds this acceptable.
(3) Sprinkler and Standoipe Systems The SER stated that the sprinkler systems are designed to the provisions of NFPA 13. However, in the site audit, the staff observed that sprinkler heads in the radwaste and control building were obstructed by cable trays and other structural features. By letter dated July 1, 1983, the applicant committed to install additional sprinkler heads and to adjust existing sprinklers to correct all sprinkler pattern deficiencies. On the basis of this commitment, the sprinkler systems will conform with Section C.6.c.(3) of BTP CMEB,9.5-1 and are, therefore, acceptable.
WNP-2 SSER ,4 9-6
SSER 3 stated that a fire-rated coating was used to protect cables for one shutdown division in lieu of an automatic sprinkler system in certain fire areas. During the site audit, the staff observed that this coating was to be used to protect certain instrument racks and panels. The staff was concerne'd that the coating had not been tested for this application and would fail under postulated fire conditions. By letter dated July 1, 1983, the applicant com-mitted to enclose these components in a partial-height, 8-inch concrete block wall. The wall is 1 foot higher than the components and is equipped with a 1-hour fire-rated door. The wall and door will protect the components from radiant heat from a fire until the arrival of the fire brigade. Convective heat and smoke will be dissipated into the ceiling area, away from the enclo-sure. The staff, therefore, concludes that the partial-height wall and 1-hour fire-rated door are acceptable deviations from Section C.S.b of BTP CMEB 9.5-1.
The staff was also concerned that the fire-rated coating in the reactor build-ing and in the radwaste and control building was vulnerable to damage from fal-ling debris caused by a fire in these areas. However, the amount of combustible material in these areas is low and widely dispersed. Consequently, a fire would be of limited magnitude and duration. Because of the presence of smoke detec-tors, a fire would be discovered in its initial stages before significant damage resulted. The smoke and hot gases from a fire would be dissipated into the ceiling, throughout the area, and up through open stairways and hatchways. It is the opinion of the staff that, as a result, falling debris would be limited.
The staff, therefore, has reasonable assurance that the integrity of the coating applied to conduit and cable trays in these areas would be maintained throughout a postulated fire event.
By letter dated March 4,1983, the applicant stated that hose stretch tests had verified that all locations of the reactor building could be reached by not more than 150 feet of hose. The staff was concerned that subsequent structural modifications in the Division 2 MCC ' area at elevation 522 feet had invalidated the results of those tests. By letter dated July 1, 1983, the applicant veri-fled that post-modification hose str' etch tests confirmed that the MCC area can be reached from two standpipe outlet's using no more than 150 feet of hose. The ]
staff finds this acceptable.
9.5.1.7 Fire Protection for Specific Plant Areas (2) Control Room Complex ' ')
The SER stated that the control room is separated from other areas of the plant by floor, walls, and ceilings having a minimum fire-resistance rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.
However, peripheral areas are separated from the control room proper by a parti-tion that is not fire rated. The staff was concerned that a fire nriginating in the peripheral areas would spread to the control room prcper and damage critical shutdown-related systems. By letter dated July 1,1983, the applicant committed to install an automatic sprinkler system in these peripheral areas.
The staff finds this acceptable.
The SER described the power generation control complex (PGCC) system in,the control room. By letter dated December 9, 1981, the applicant agreed to comply with all of the fire protection specifications in GE Topical Report NED0-10466, Revision 2, dated March 1978, which was previously approved by the staff. By letter dated October 28, 1983, the applicant requested approval for a deviation WNP-2 SSER 4 9-7
from the specifications of NEDO-10466, to the extent that it stipulates the use of steel and aluminum in the floor plates in the PGCC design. Approximately 4%
of the floor plates in the plant are of a nonmetallic, composite material.
This substitute material is used in lieu of the standard floor plates to accom-modate irregular shapes and close tolerance fittings.
The staff had two concerns with its use. The first is that the material would represent a significant hazard, based on its flammability. The secono concern is that the plates would not remain in place upon discharge of the Halon fire suppression system. The composite material was tested in accordance with the method of ASTM E-84. The flame-spread rating as determined by this test was less than 50, and the smoke-developed rating was less than 10. This conforms with Section B.4 of BTP CMEB 9.5-1 and is, therefore, acceptable.
By letter dated October 28, 1983, the applicant verified that during 10 dis-charge tests of the Halon fire extinguishing system, the substitute floor plates remained in place. On the basis of its evaluation, the staff, therefore, con-cludes that the limited use of the substitute floor plates in the PGCC system represents an acceptable deviation from NEDO-10466.
In the October 28, 1983 letter, the applicant indicated that another composite material is used in a single location in the control room as an insulation
" washer" between the PGCC floor frame and a termination cabinet. Approximately 80% of this material is unexposed to the air, leaving a narrow strip that could ignite. The flame-spread and smoke-developed ratings of this material are 115 and 150, respectively. To reduce the ease of ignition of this material, the applicant ccamitted to apply and maintain a fire-retardant coating on the exposed surface. The staff finds this acceptable.
(6) Diesel Generator Building The deisel generators are protected by a pre-action-type sprinkler system.
During the site audit, the staff observed that the sprinkler heads and baffle -
plates did not provide complete protection (coverage) for the area. By letter ~
dated October 28, 1983, the applicant committed to install additional sprinklers and adjust the baffle plates to eliminate this deficiency. On the basis of this commitment, the fire protection for the diesel generators conforms with Section C.7.i of BTP CMEB 9.5-1 and is, therefore, acceptable.
_]
9.5.1.8 Summary of Deviations from BTP CMEB 9.5-1 SSER 3 identified the following fire approved deviations from the staff's fire protection guidelines:
(1) control room vent closure (2) seismic design of standpipe systems (3) floor drains in day tank room (4) deletion of a fire suppression system in the following seven plant areas:
remote shutdown room (RC-1X) switchgear room #1 (RC-XIV)
WNP-2 SSER 4 9-8
. general floor area (R-1) - elevation 471'-0"
. general floor area (R-1) - elevation 501'-0"
. general floor area (R-1) elevation 522'-0"
. general floor area (R-1) elevation 548'-0"
. general floor area (R-1) elevation 572'-0" (5) the use of 150 feet of hose stations in the reactor building On the basis of its evaluation of the supplemental information submitted af ter the site audit, the following additional deviations from BTP CMEB 9.5-1 have been approved:
(6) lack of a fire damper in the Division 2 MCC room (7) unlisted fire damper assemblies (8) lack of a curb at the door between the turbine generator building and the reactor building (9) lack of fire. detectors in the following
. north valve room, reactor building, elevation 548 feet
. sampling room, reactor building, elevation 548 feet
. north and south valve rooms, reactor building, elevation 522 feet
. RhCU pump room, reactor building, elevation 522 feet
. RiiR valve room 307, reactor building, elevation 501 feet
. TIP room, reactor building, elevation 501 feet
. north valve room, reactor building, elevation 471 feet
. below steel grating, reactor building, elevation 422 feet (10) partial-height fire wall at safe shutdown related instrument racks (11) fire protection for control room peripheral areas 5 (12) composite floor plates in the PGCC system.
9.5.1.9 Conclusion s Based on its evaluation, the NRC staff concludes that the fire protec-tion program with the accepted deviations listed in Sections 9.5.1.8 above meets the guidelines of BTP CMEB 9.5-1 and GDC-3 and is, therefore, acceptable.
! Fire Protection License Condition
! The licensee shall fully implement and maintain all provisions of the approved fire protection program. (PM should list all the NUREG docu-ments where the approved fire protection program is described, including those sections issued by CMEB, ASB, EPLB, LQB and QAB.)
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