ML20214J698
| ML20214J698 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 05/18/1987 |
| From: | Carey J DUQUESNE LIGHT CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| 2NRC-7-130, TAC-62935, NUDOCS 8705280162 | |
| Download: ML20214J698 (9) | |
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'At5 2NRC-7-130 (412)393-7546 Beaver Valley No. 2 Unit Project Organization Telecopy (412) 393-7889 S.E.G. Building May 18, 1987 P.O. Box 328 Shippingport. PA 15077 United States Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555
SUBJECT:
Beaver Valley Power Station Unit No. 2 Docket No. 50-419 Fire Protection Systems Circuitry
REFERENCE:
NRC Letter dated April 30, 1987, Mr. Peter S. Tam to Mr. J. J.
Carey Gentlemen:
In the above-noted reference, the NRC staff transmitted a position paper to Duquesne Light Company (DLC) describing a proposed regulatory basis for imposition of NFPA 720 for alarms associated with suppression systems at Beaver Valley Power Station Unit No. 2 (BVPS-2).
The staff's letter describes specific concerns with regard to single breaks or ground faults precluding fire alarms in the control room and resulting in delayed fire brigade response.
Also, lack of " trouble" indication for suppression system control room alarm circuits was pointed out as a concern. The following is a description of the BVPS-2 fire detection and suppression systems (Refer to the attached Figures 1 through 4):
Fire Detection System (Figure 1)
All areas containing safety-related equipment are protected by the early warning fire detection system.
This system is a Honeywell Multiplex system consisting of smoke detectors (ionization and photoelectric) and flame detectors (ultraviolet).
This system is Class A as defined in NFPA 72D (1978) or a Style D system as defined in NFPA 72D (1980) from the detectors to the Control Room.
Carbon Dioxide Suppression System (F_igure 2)
The carbon dioxide suppression systems are provided with independent smoke or heat detectors which are interconnected with a Pyrotronics XL-3 system.
In addition to the CO2 suppression system actuation capability, the system 8705280162 870518 PDR ADOCK 05000412 F
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United States Nuclear Regulatory Commission Fire Protection Systems Circuitry Page 2 circuitry provides an alarm function which is duplicated by the early warning fire detection system suppression. These systems are Class A from the detectors to the XL-3 panel.
From the XL-3 panel to the Information Handling System Annunciator (IHA) cabinet, the fire trouble and lockout signals are supervised.
Per NFPA 70, Article 760, " Fire Protection Signaling Systems", supervised is defined as being able to detect a single open or a single ground fault on any circuit that would prevent proper alarm operation.
From the IHA cabinet to the Control Room, two separate information paths are provided.
These are the annunciator windows on the Building Service Panel and a printout from the plant computer.
This multiple capability to the Control Room assures that a fire in the area would not go undetected due to a single fault.
Halon Suppression Systems (Figure 3)
The halon suppression systems are provided with independent smoke detectors which are interconnected with the Pyrotronics XL-3 system.
In addition to the halon suppression systems' actu3 tion capability, the systems' circuitry provides an alarm function which is duplicated by the early warning fire detection system in the general fire area.
The system is Class A from the detectors to the XL-3 panel, From the XL-3 panel to the IHA cabinet, the trouble alarm is supervised.
The fire and discharge alarms are not supervised to the IHA cabinet.
However, the redundant fire detection system would provide adequate information as to the status of alarms.
As in the carbon dioxide system, two separate information paths are provided to the Control Room for the alarms.
Water Suppression Systems (Figure 4)
The water suppression systems are provided with heat detectors.
In addition to the water suppression systems' actuation capability, the sys-tem circuitry provides an alarm function which is duplicated by the fire detection system in the general area.
This system is Class B from the detectors to the local control panel.
The fire, discharge and trouble circuits are unsupervised from the local panels to the Control Room.
However, the circuits between the Control Room and the local pnels will be tested monthly as specified by Technical Specification Suw eillance Requirement 4.3.3.6.3.
This requirement will be transferred to our fire protection program administrative procedures (Site Administrative Procedure 9D).
DLC has reviewed the NRC Staff's position paper with regard to current regulatory requirements and BVPS-2 commitments and has determined that a commitment to NFPA 72D for suppression system alarms has not been made and is not necessary at BVPS-2.
Furthermore, DLC believes that changes to current plant design and procedures which would accompany a commitment to NFPA 720 cannot be shown to provide a substantial increase in overall plant safety.
' United States Nuclear Regulatory Commission Fire Protection Systems Circuitry Page 3 Paragraph 1 of the subject position paper indicates that BTP CMEB 9.5-1, Section C.6.a specifies that detection systems should be Class A as defined in It also states that NFPA 72D is referenced by NFPA 12,12A and 13 NFPA 72D.
found in subsequent BTP sections.
DLC maintains its position that NFPA 72D is BVPS-2 is directly called out in the BTP only in regard to detection systems.
provided with an early warning detection system which is the primary means of fire detection.
This system is independent of plant suppression systems yet duplicate coverage of all safety-rel ated areas with suppression provides This detection system is designed to meet NFPA 72D Class A criteria.
systems.
Therefore, no fire in areas with suppression can go undetected.
DLC has committed to NFPA 12,12A and 13 for suppression system designs. However, the staff's attempted connection of these standards with NFPA 720 is tenuous at best.
NFPA 12 clearly refers to NFPA 72D as "... educational and informative material..." which is "...not a part of this NFPA document...".
NFPA 12A refers to NFPA 72D only in connection with detection, actuation and control NFPA 13 systems, but not in connection with operating alarms and indicators.
The refers to NFPA 72D with regard to electrically operated alarm attachments.
appendix to this standard indicates that "... central station, auxiliary, remote proprietary protective signaling systems are a highly desirable station, or supplement to local alarms..." but does not require other than local alarms as a minimum.
The position paper implies that DLC should identify nonconformances with NFPA 720 per Generic Letter 86-10 guidance.
By regulation, such an evaluation is required only for SRP acceptance criteria (10CFR50.34(g)).
NFPA 72D is not an SRP acceptance criterion applicable to BVPS-2 design of suppression system alarms and does not require such an evaluation.
Summary Fires would not go undetected due to the early warning detection system.
Therefore identification of fires through suppression system alarms is not a Since gaseous suppression systems (Carbon dioxide and Halon) safety concern.
have supervised trouble signals to the IHA cabinets and multiple pathways to the control room, concern over central indication of gaseous suppression system status is eliminated.
Unsupervised circuits associated with the water suppression systems between the local panels and the control room will be
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- United States Nuclear Regulatory Commission Fire Protection Systems Circuitry Page 4 tested monthly.
Based upon the. above, the present capability of the BVPS-2 fire detection and suppression systems is adequate and overall plant safety would not be significantly increased by modifying the suppression-system alarm circuits.
i DUQUESNE LIGHT COMPANY f
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Senior Vic(e Presidenty Y.J.farey-I GLB/ijr NR/JD0/GLB/SYS Attachments cc: Mr. P. Tam, Project Manager (w/a)
Mr. J. Beall, NRC Sr. Resident Inspection (w/a)
Mr. L. Prividy, NRC Resident Inspector (w/a)
Mr. William T. Russell, NRC Region I Administrator (w/a)
INP0 Records Center (w/a)
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United States Nuclear Regulatory Commission Fire Protection Systems Circuitry Page 5 COMMONWEALTH OF PENNSYLVANIA )
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COUNTY OF BEAVER
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On this /
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/ (( [, before me, a Notary Public iIl and for said Co$nonweadh and County, pers'onally appeared J.
J. Carey, who being duly ' sworn, deposed and said that (1) he is Senior Vice President of Duquesne Light, (2) he is duly authorized to execute and file the foregoing Submittal on behalf of said Company, and (3) the statements set forth 4
in the Submittal are true and correct to the best of his knowledge.
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