ML20210S685
| ML20210S685 | |
| Person / Time | |
|---|---|
| Site: | Satsop |
| Issue date: | 07/16/1977 |
| From: | Tedesco R Office of Nuclear Reactor Regulation |
| To: | Vassallo D Office of Nuclear Reactor Regulation |
| References | |
| CON-WNP-1623 NUDOCS 8605290355 | |
| Download: ML20210S685 (15) | |
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D ENCLOSURE Fire Protection Questions for WPPSS Nuclear Pro.jects Nos. 3 & 5 1.
(General)
Your Fire Hazard Analysis (FHA) is deficient in the areas listed below. Expand the FHA to include the following additional information:
a a.
Provide a quantitative fire loading and its basis for each plant area described in the FHA.
b.
Where an automatic fire suppression system is installed, an analysis should be made to demonstrate that the plant can achieve its safe shutdown during a fire assuming malfunction of the fixed automatic fire suppression system in the area.
2.
(Table 9.5-5) l Table 9.5-5 indicates that dry hose stations will serve as primary j
fire suppression systens for RAB switchgear rooms, new fuel storage I
area and the spent fuel pool area. Provide additional infonnation to indicate the lochtfon of these hose statforsfor the above ar,eas.
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l these hose stations for the RAB switchgear rooms and the new fuel storage area are located outside these areas, wet hose stations should be provided. The hose stations for the spent fuel pool area should be the wet type also.
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'3.
(SectionA.4)
Describe the provisions taken to prevent lightning from initiating fires which could damage safety related equipment. Also describe tha provisions which show that the fire protection systems are
' afforded lightning protection.
4.
(Section A.7)
Confirm that the fire protection program for an entire reactor unit will be fully operational prior to initial fuel loading in that. reactor unit.
5.
(Section C.l.(a))
You state that redundant systems necessary for safe shutdown are separated such that both trains are not subject to the same fire hazard. Identify all the redudant systems necessary for safe shut-down which are separated only by distance. Describe the fire detec-tion system, the primary and backup suppression system provided for these systems. Provide the results of an analysis to demonstrate that for a postulated fire, including an exposure fire and failure of the primary fire suppression system, that' safe shutdown can still be accomplished. For any cases where safe shutdown cannot be assured, describe what additional measures will be taken.
6.
(Section D.1.(c))
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You state that where cable trays serving redundant trains of safe shutdown equipment are exposed to the same fire hazard, the cables will be separated by fire barriers.
Identify the areas where the above situation exists and discuss the fire protection provided for 5
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. these areas.
7.
(Section D.1(d))
(RSP)
Your response to Section D.1(d) of BTP 9.5-1 Appendix A indicates that the thennal insulation, radiation shielding and sound-proofing materials used may be combustible.
It is our position that the above materials used for WPPSS 3 & 5 should be non-combustible.
8.-
(Section 0.1.(f))
Identify all safety related cables and wiring installed above sus-pended ceilings. Describe the detection and fire extinguishing system to be provided in those areas.
9.
(Section D.1.5 and 15.2.12)
(RSP)
Throughout the fire hazard analysis, reference is made to the fact that floors, walls and ceilingsenclosing separate fire areas will have a fire rating commensurate with or exceeding fire hazards in the area.
It is our position that you clearly state in the PSAR that all walls, ceilings and associated penetrations enclosing separate safety related fire areas will have a minimum fire rating of three hours.
10.
(Section D.1.(5))
Substantiate the fire resistance capacity of the following items by verifying that their construction is in accordance with a particular design that has been fire tested.
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- a.
rated fire barriers b.
fire barrier penetration seals c.
fire stops in cable trays d.
fire dampers / fire doors, as well as how they are installed in the ventilation ducts that penetrate rated fire barriers of safety related areas.
Also identify the design and the test method us W and acceptance criteria.
11.
(Section D.l.(j)
List locations where mechanical piping penetrations through fire barriers are anchored at walls. Confirm that these fire barriers test have taken into account the mechanical loading of the pipe.
- 12. (Section.D.l. (j )
(RSP)
You state "where ventilation ducts penetrating fire barriers the ducts will be coated with materials having a fire rating equal to that of the barrier; the duct will be considered to be a physical extension of the fire area. Fire danpers will not necessary be provided in such ducts at the barrier penetrations". This is not acceptable.
It is our position that fire dampers should be provided in all duct penetrations through fire barriers.
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5-13.
(SectionD.2.(b))
List locations, amount and type of flamable gases in relation to any safety related areas or equipment. Include in your fire hazard analysis any flamable gas storage areas that could threaten safety related equipment.
14.
(Section D,3.(c))
Provide design criteria and bases used in providing automatic sprinklers for congested runs of cable trays including cable densities, spacing, arrangement, amount of cable and divisional separation.
15.
(SectionD.3.(J)
Identify any cables which will be installed in floor trenches or culverts in the control room and describe the protection provided in these areas.
- 16. (SectionD.4.(r.))
Discuss the aperating mode of the ventilation system used for sEke removal in the fire areas addressed in your fire hazard analysis.
Include in your discussion, a) the equipmer.t used, b) operator actions required for this operation, c) the control excess to the equipment and d) the ability of the equipment to handle high temperatures gases i
t and particles.
- 17. (Section0.4(d))
Confirm that the air circulating system for charcoal filters will meet the single failure criteria per Regulatory Guide 1.52. Also confirm that there will be no exposure fire hazards that could ignite i
the charcoal filters.
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- 18. (Section D.4.(h))
(RSP)
Your response to Section D.4.(h) of BTP 9.5-1 Appendix A is not acceptable. It is our position that at least two extra air bottles should be located onsite for each self-contained breathing unit.
In addition, an onsite 6-hour supply of reserve air per breathing unit or compressors should be provided and arranged to permit quick and complete replenishment of uhausted supply air bottles as they are returned. Modify your design to meet the above position.
- 19. (Section0.5)
(RSP)
Your response to Section D.5 of BTP 9.5-1 appendix A is not acceptable.
It is our position that fixed self-contained lighting, consisting of fluorescent or sealed beam units with individual 8-hour minimum battery power supplies should be provided in areas which must be manned for safe shutdown and for access and egress routes to all fire areas. Safe shutdown areas include those required to be manned if the control room must be evacuated. Also, a portable radio comunications systems should be provided for use by the fire brigade and other operations personnel required to achieve safe plant shutdown.
- 20. (SectionE.1)
Verify that the fire alarm system which is designed according to NFPA 72-0 is a class A system with Class I circuits per National Electrical Code.
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- 21. (SectionE.1(b))
Clarify your response to Section E.1(b) of BTP 9.5-1 Appendix A to confinn that the fire detection systems will give annunciation in addition'to audible and visual alarm in the control room.
22.
(SectionE.2.(b))'
Verify that the fire pumps and their associated controllers will be U.L. and/or F.M. approved per NFPA-20. Also confirm that individual trouble alarms will be provided for each fire pump in the control room.
23.
(Section E.2(e))
Clarify your response to section E.2.(e) of BTP 9.5-1 Appendix A to confinn that the fire water supply of 300,000 gallons per tank is greater than the demands of three hose streams plus all sprinkler heads opened within the largest fire area irrespective of whether the sprinkler system is hydraulically designed or not.
24.
(SectionE.3.(a))
Identify safety related areas where hydraulically calculated automatic sprinkler systemare used. Provide a discussion of the criteria and bases to determine the density and spacing of equipment.
- 25. (Section E.3.(b))
Confim that all fire protection system control and divisional valves provided with monitor switches are connected tc, electrically supervised circuits.
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. 26. (Section E.3.(d))
Confinn that the placement of hose stations in the safety related areas will reach any location with one effective hose stream, consideration should be given to situations where the access to a single hose station may be blocked by a fire; in such cases an alternative hose station should be provided.
27.
(SectionE.3.(d))
Verify that your hose and sprinkler standpipe design criteria will provide for an alann in the control room when there is flow in a standpipe per NFPA 14.
28.
(SectionE.3.(d))
Justify that 3-inch diameter standpipes rather than 4-inch diameter standpipes as stated in BTP 9.5-1 appendix A are of sufficient size to supply the necessary flows.
29.
(SectionE.3.(d))
(RSP)
Your response to Section E.3.(d) of BTP 9.5-1 Appendix A is not acceptable.
It is our position that provisions be made to supply water at least to standpipes and hose connections for manual fire fighting following an SSE in areas within hose reach of equipment required for safe shutdown. The standpipe system serving such hose stations should be analyzed for SSE loading and should be
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provided with supports to assure system pressure integrity. The piping and valves for the portion of hose standpipe system affected by this functional requirement should at least satisfy ANSI Standard B 31.1
" Power Piping". The water supply for this condition should
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be obtained from a nornal seismic Category I water system.
30.
(SectionF.1, Figure 9.5-la)
Your fire protection design criteria and bases for the areas inside primary containment do not meet our guidelines. Submit a fire hazard analysis for the areas inside containment. Analyze the con-sequences of a fire due to an oil leak in reac'or coolant pumps or a t
fire in safety related cables inside containment in your FHA. Figure 9.5-la indicates a single fire water line penetrates containment and supply water for hose stations inside containment. Confinn that sufficient water for fire protection inside the containment can be supplied though the single line asstaning a moderate pipe leak on the ifne; also confirm that the piping perietrating containment boundary upto and including the isolation valves will be designed to quality group B and seismic Category I requirements.
31.
(Set.tionF.2)
(RSP)
You state that only portable Halon extinguishers are provided inside the control room.
It is our position that Class A hanct portable fire,
extinguishers be provided in accordance with NFPA 10, to' p,rovide the ability to extinguish small deep seated fires inside the control mom.
- 32. (SectionF.2)
Identify those safey related control room cabinets that' contain cables from both divisions. Provide results of an analysis of the consequences of a fire in each cabinet. The analysis should take 4
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into account the damage to wiring and instrumentation in adjoining safety related cabinets due to heat and corrosive vapors. Describe any additional measures necessary to assure plant safe shutdown under the above conditions.
33.
(sectionF.3)*
Confirm that location of sprinkler heads or spray nozzles ins,ide the cable spreading rooms will be arranged considering cable tray sizing and arrangments to assure adequate water coverage for electrically initiated fires and/or exposure fires.
- 34. (SectionF.4)
Identify the location of plant computer room relative to control room and other safaty related areas. Describe the fire protection measures provided to prevent fire and smoke damage to safety related
- equipment.
- 35. (SectionF.5)
In your response to Section F.5 of BTP 9.5-1 Appendix A you indicate that cabling passing through the switchgear rooms serving the VHS dry cooling tcwers will be minimized. Describe the, type and quantity of cabling passing through the UHS switehgear rooms. Confirm that the automatic Halon fire protection system provided in this area is adequate for the type of fire hazard present.
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- 36. (Section F.8)
In the event of a fire in the turbine building which might cause the turbine building roof to collapse, demonstrate that safe shut-down can be accomplished.
- 37. (SectionF.9)
(RSP)
Your response to Section F.9 of BTP 9.5-1 Appendix A is not acceptable.
It is our position that the day tanks should be a maximum capacity of 1100 gallons and located in the diesel generator area under the following conditions:
(a) the day tank shculd be located in a separate enclosure, with a minimum fire rating of three hours, including doors and penetrations. The enclosure should be ventilated to avoid accumulation of oil fumes, (b) the enclosure should be protected by automatic fire suppression systems such as AFFF or sprinklers.
- 38. (SectionF.11)
(RSP) Your design criteria for fire protection in safety related pep areas deviate from the guidelines in BTP 9.5-1 Appendix A.
It is our position that you modify your design to meet these Appendix A guide-lines in providing fire barriers with minimum three-hour rating around each safety related pop and automatic sprinklers inside each safety related pump room. Otherwise, detailed analyses should be provided to demonstrate that without protection of fire barriers and auto-matic sprinklers, a postulated internal or exposure fire in a safety related pump area will not impair capability of plant safe shutdown.
)
- 39. (Section F.12. F.13)
(RSP)
You state that fire detectors will not be provided in new fuel area and spent fuel pool area. This is not acceptable.
It is our position that you provide automatic fire detection in the new fuel area and spent fuel pool area. The automatic f' ire detection should alarm and annunciate in the control room and alarm locally..
40.
(Section F.14)
(RSP)
Your fire hazard analysis does not demonstrate that the radwaste.
equipment located in the reactor auxiliary building is not in need of fire resistive construction and automatic fire det.ection. It is our position that you modify the design to the radwaste building from other areas of the plant by fire barriers having at least three-hour ratings and provide automatic fire detection in the radwaste building to alarm and annunciate in the control room and alann locally.
- 41. (Section F.15)
Your responses to section F.15 of BTP 9.5-1 Appendix A is not complete.
Provide additional information to demonstrate that WPPSS 3 and 5 meet the Appendix A guidelines in the decontamination areas.
42.
(SectionG.3)
Confirm that hazardous chemicals will not be stored in areas containing or exposed to safety related equipment.
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- 43. (Section 15. 2.12.2.f)
You indicate in Section 15.2.12.2.f of the PSAR that the electrical ponetration area has no fire barrier to separata the areas housing redundant trains of equipment. The protection of redundant trains will be dependent on the 40-foot space separation. Since a 40- foot,
t distance"is very marginal for adequate protection from an exposure fire in Ihe area, we require that you provide additional measures in this area to assure that a common exposure fire will not damage both redundant trains of safety related equipment inside the electrical penetration area.
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