ML20213E404
| ML20213E404 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 04/13/1983 |
| From: | Kubicki D Office of Nuclear Reactor Regulation |
| To: | Benaroya V Office of Nuclear Reactor Regulation |
| References | |
| CON-WNP-0582, CON-WNP-582 NUDOCS 8304200432 | |
| Download: ML20213E404 (7) | |
Text
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0 :7 DISTRIBUTIO!Q e ile CMEB WPPSS 2 File MEMORANDUM FOR: Victor Benaroya, Chief Chemical Engineering Branch Division of Engineering THRU: Robert Ferguson, Section Leader Chemical Engineering Branch Division of Engineering FROM: Dennis Kubicki Chemical Engineering Branch Division of Engineering
SUBJECT:
TRIP REPORT: FIRE PROTECTION SITE AUDIT - WPPSS NUCLEAR PROJECT NO. 2 Plant Name: UPPSS Nuclear Project No. 2 Docket Number: 50-397 Licensing Stage: OL Responsible Branch: LB #2 Project Manager: R. Auluck Chemical Engineering Branch Reviewer: D. Kubicki Between March 22 and 25,1983, we conducted our fire protection site audit at the WPPSS Nuclear Project No. 2. A representative of our consultant, Gage Babcock & Associates, participated.
As a result of the audit, we reached several agreements regarding the adequacy.
of the fire protection program. In addition, we expressed a number of concerns /
questions pertaining to previous applicant commitments; the justification for particular fire protection designs; and the degree of compliance with our fire l protection criteria. A summary of these issues is enclosed. The applicant agreed to respond to our concerns.
Ikd' X4 Dennis Kubi i
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( [ A" f y Division of Engineering
Enclosure:
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Enclosure Chemical Engineering Branch / Fire Protection Section Fire Protection Trip Report WPPSS Nuclear Project No. 2 Docket No. 50-397 Introduction Between March 22 and 25,1983, we conducted our fire protection site audit at the WPPSS Nuclear Project No. 2. A representative of our consultant, Gage-Babcock and Associates participated.
As a result of the audit, we reached ~ a number of agreements regarding the adequacy of the fire protection program. In addition, we expressed a number of concerns pertaining to previous applicant commitments; the justification for particular fire protection designs; and the degree of compliance with our fire protection criteria. The agreements and concerns can be summarized as follows :
Agreements
- 1. The applicant has designed those components required for hot shutdown so that rupture or inadvertent operation of fire suppression systems will not adversely affect the operability of these components. Where necessary, appropriate protection is provided to prevent impingement of water spray on components required for hot shutdown. Redundant trains of components that are susceptible to damage from water spray are physically separated so that manual fire suppression activities will not adversely affect the operability of components not involved in the postulated fire.
- 2. The 1 inch tap off the fire main in the pump house will be removed.
- 3. We were concerned that in the cable spreading room, because of limited.
accessibility for fire fighting, a fire could cause damage to redundant shutdown cables. Based on our evaluation of the fire protection for the room' (area-wide fire detection and suppression, along with a cable tray fire suppression system; 3-hour fire rated perimeter walls; and separation of redundant shutdown related cables by more than twenty feet with no intervening combustible materials) the protection is consistent with the material we reviewed and found to be in compliance with Section III.G of Appendix R.
Concerns The following is a list of fire protection concerns raised during the audit.
The applicant agreed to provide a written response to resolve these concerns.
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- 1. To satisfy the requirements of Appendix R and the guidelines contained in Section C.6.a of BTP CMEB 9.5.1, all areas of the plant that contain safety
, related equipment should be equipped with a fire detection system. We observed that the following areas of the plant, which contain safety related equipment, are not provided with fire detectors:
- a. Reactor Building, El . 548, North and South Valve Rooms
- b. Reacter Building, El . 54'8, Sampling Rooms
- c. Reactor Building El . 548, RHR Heat Exchanger Rooms
- d. Reactor Building, El. 522, North and South Valve Rooms
- e. Reactor Building, El. 522, RWCU Pump Room
- f. Reactor Building, El . 501, RHR Valve Room #307
- g. Reactor Building, El . 501, T.I.P. Room
- h. Reactor Building, El . 471, North Valve Room
- 1. Reactor Building, El . 422, Below steel grating
- j. Fire Area RC III, @ 501' elevation
- 2. To comply with Section C.6.a of BTP Cf1EB 9.5.1, the fire detection systems should be designed in accordance with NFPA standard No. 72E. Section 4-3 of the standard stipulates that the location of smoke detectors must anticipate smoke stratification. We observed that in several fire areas, such as RC III adjoining the control and cable spreading rooms, smoke detectors were not instal?ed at each floor elevation. The applicant should verify that the location of smoke detectors in areas that encompass more than one floor elevation will not be compromised by smoke stratification.
- 3. In our SSER of December 27, 1982 we accepted the use of a cable tray / conduit wrap that had withstood a 3-hour fire exposure when tested in accordance with ASTM E 119. We noted in our site audit that the applicant proposed to use the cable wrap material with fire dampers and doors to protect certain
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instrument racks and panels. The wrap material with the fire dampers and doors have not been tested for this application. We therefore do not have reasonable assurance that the protection would be able to withstand an anticipated fire exposure.
- 4. By letters dated January 21, 1982 and October 4,1982, the applicant committed to wrap one train of safe shutdown cables and conduits so as to protect them from fire damage. We observed that in the Reactor Building and in the Rad-waste and Control Building the protected trays and conduits are potentially vulnerable to damage from unprotected trays, HVAC ducts and structural mem-bers. The applicant should verify that collapsing debris will not damage redundant shutdown related cables.
- 5. To comply with Section C.7.b of BTP CMEB 9.5.1, control room peripheral areas should be protected by an automatic fire suppression system and should be segregated from the control room proper by one hour fire rated construc-tion. We observed that the peripheral areas were neither protected by an automatic fire suppression system nor segregated by one hour fire rated construction.
- 6. In Amendment 19, the applicant committed to comply with NFPA-Standard No.13 in the design of automatic sprinkler systems. In fire' zone RC-III in the Radwaste and Control Building, the sprinkler heads are obstructed by cable trays and other structural features which conflict with the requirements of Section 4-4 of NFPA 13.
- 7. To comply with Section C.6.a of BTP CMEB 9.5.1, the smoke detectors should be tested and accepted for specific applications by an independent testing la boratory. The applicant should veri.fy that the photoelectric smoke detectors have been approved for a 1200 ft.2 sqacing as observed in the plant.
- 8. To comply with Section C.S.a of BTP CMEB 9.5.1, interial wall and structural components and thermal insulation material should be noncombustible. The applicant should verify that the laminated wall panels in the control room and the urea-formaldehyde foam insulation observed in several areas of the plant are noncombustible.
- 9. In Amendment 19, the applicant connitted to comply with Section III N of Appendix R to 10 CFR 50 regarding the supervision of fire doors. We observed that stairway fire doors in the Reactor Building have fusible-link type hold Open devices which are not consistent with the commitment.
- 10. In Amendment 19, the applicant committed to install U.L. labeled, 3-hour rated fire doors in the following locations:
- Hydrogen recombiner room (RB - El . 572')
Division 1 & 2 MCC rooms (RB - El . 572')
Fire Zone R-XVIII (MCC rooms)
We observed that unlabeled doors were installed in these locations.
- 11. In Amendment 19, the applicant committed to install a fire damper at the duct penetration of the concrete slab at the top of the Division 1 and 2 MCC rooms (Reactor Building, elevation 572 ft.). We noted that no damper had been installed at these locations.
- 12. In Amendment 19, the applicant committed to comply with NFPA Standard No. 30,
" Flammable and Combustible Liquids Code." In the water filtration building, the diesel fuel day tank is on unstable supports which is contrary to this i commitment.
- 13. In Amendment 19, the applicant committed to comply with NFPA Standard No.15 in the design of the water spray fire suppression systems. We observed that the water spray heads and baffle plates protecting the diesel generators and fuel tanks do not provide complete protection (coverage) for the hazards in the area which is not consistent with that commitment.
14 In Amendment 19, the applicant committed to seal' any openings in fire barriers to prevent the passage of smoke and heat. We observed a penetration of the wall between the diesel generator rooms and the switchgear rooms which is not consistent with that commitment.
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- 15. In Amerdment 19, the applicant committed to install a pre-action sprinkler system in the diesel generator fuel oil storage tank rooms in accordance with NFPA Standard No.13. We observed that the deluge valves for these systems had tripped for no apparent cause.
- 16. To comply with Section C.S.a of BTP CMEB 9.5.1, fire barriers should be provided to separate redundant safety divisions so that both are not subject to . damage from a single fire. On elevation 422 ft. of the Reactor Building, we observed that access for manual fire fighting is through a single door in a fire wall which separates redundant shutdown components.
If this door was opened during a fire both shutdown divisions would be vulnerable to damage.
- 17. To comply with Section C.7.h of BTP CMEB 9.5.1, fire doors and other pene-trations of fire barriers in the Turbine. Building should be located so as not to be directly exposed to a turbine oil fire exposure or spill . We observed that there was no curb or floor drain at the fire doors at elevation 441 ft. of the Turbine Generator Build'ing to prevent the possi-bility of oil leaking from a turbine oil line rupture from past:ing through the fire doors.
- 18. In Amendment 19, the appficant indicated that the plant was in compliance with Section III G of Appendix R. By letters dated January 21 and October 4,1982, the applicant committed to wrap one train of safe shutdown cables and conduit so as to protect them from fire damage. The applicant should verify that all cables and components associated with the " dedicated" shutdown capability (the " chosen" system as defined during the audit) are protected from fire damage and that redundant shutdown systems are isolated in separate fire areas.
- 19. By letter dated March 4,1983, the applicant indicated that hose stretch tests had verified that all locations of the Reactor Building could be reached with not more than 150 ft. of fire hose. We observed that in the Division 2 MCC area on elevation 522 feet, structural modifications have occurred which may affect the results of the hose stretch tests. The appli-cant should verify that the MCC area can be adequately protected by the manual hose system.
l 20. The following features of the fire protection program were observed to be j incomplete:
l The installation of the TSI Thermal Lag Fire Barrier around shutdown-l related cable trays, conduit, and panels.
The repeaters for the plant radio communications network (these repeaters have to be located and/or protected such that they are not vulnerable to damage from a fire).
i Hose, nozzles, gated wyes, caps, etc. associated with the standpipe hose stations.
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Supervision (tamper switches, locks.) for internal and external water supply control valves.
Deactivation of fire pump shutdown controls in the control room.
Penetration seals for fire rated walls and floor / ceiling assemblies.
Removal of non-fire rated transoms over fire doors.
Removal of' styrofoam daming at penetrations of fire rated walls and floor / ceiling assemblies.
Installation of 8-hour battery powered lighting units per Section III J of Appendix R.
The fire wall which separates the Service Building from the Turbine Generator Building at elevation 441' .
Fire doors have not yet been installed at the following locations:
- b. Fire Area R XVIII - Valve Room t
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