ML20214Q490
| ML20214Q490 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 11/28/1986 |
| From: | Jacqueline Thompson Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8612050173 | |
| Download: ML20214Q490 (23) | |
Text
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Docket Nos.: 50-424 and 50-425 m 28 M APPLICANT: Georgia Power Corrpany FACILITY: Vogtle Electric Generating Plant, Units 1 and 2
SUBJECT:
SUFFARY OF AUDIT HELD OCTOBER 6-10, 1986 ON FIRE PROTECTION From October 6 to 10,1986, the staff visited the Vogtle Electric Cer.erating Plant, Units 1 and 2 to conduct a site audit on fire protection. Participants are listed in Enclosure 1.
As a result of the staff's audit, a number of concerns pertaining to the applicant's commitments, the justifications for particular fire protection designs, and the degree of corapliance with staff guidelines were expressed.
A detailed surrary of these audit items, prepared by D. Arnold, is provided in Enclosure 2. At the close of the audit, the applicant agreed to respond i to these issues in a timeframe that will supr, ort the Vogtle Unit I fuel load date.
In addition, the audit held discussions on the SER open items and FSAR comnitments pertaining to fire protection. Enclosure 3 is a listing of specific areas that the staff questioned and the coments given by the applicant.
\9 John W. Thcmpson, Project Manager PWR Project Directorate #4 Division of PUR Licensing-A
Enclosure:
As stated cc: See next page
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BECHTEL M. Larson SOUTHERN C0f:PANY SERVICES J. Bailey J. McLeod J. Naddy GEORGIA POWER COMPANY J. Hartka R. Sprankle FRANKLIN RESEARCH T. Stoney ROLF JENSEN 8 ASSOCIATES, INC.
D. Arnold bec: Licensee & Service List
- ENCLOSURE 1 PARTICIPAftTS NRC i BECHTEL A. Singh M. Larson SOUTHERN C011PANY SERVICES J. Bailey M. McLeod J. Maddy GEORGIA POWER COMPANY
- d. Hartka ,
R. Sprankle FRANKLIN RESEARCH T. Stoney ROLF JENSEN & ASSOCIATES, INC.
D. Arnold a
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Enclowec (
a Enclosure Fire Protection Site Audit i Trip Report Vogtle Electric Generating Plant, Unit 1 Docket No. 50-424 Introduction Between October 6 and 10, 1986 a Fire Protection Site Audit was conducted at Vogtle Electric Generating Plant, Unit 1.
Representatives from NRC-NRR, NRC-IC Region I, and Rolf Jensen &
Associates participated.
As a result of the audit,
. a number of agreements regarding the adequacy of the fire protection program were reached. In addition, we expressed a number of concerns partaining to previous applicant commitments; the justification for particular fire protection designs; and the degree of compliance with the staff's fire protection criteria.
The agreements and concerns can be summarized as follows:
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1.
To comply with Section C.6.c(1) of BTP CMEB 9.5.1, sprinkler systems and manual hose station standpipes should have l connections to the plant water main so that a single active failure or a crack in a moderate energy line cannot impair both i the primary and the backup fire suppression systems. We
observed that certain sprinkler systems and hose stations were not connected as required.
The applicant statap that a crack is a moderate energy line will not impair both the primary and backup fire suppression capability since adequate backup capability exists through the use of adjacent hose stations. In some cases, an additional length of fire hose will be required to reach the hazard area affected by the single failure or crack.
The hose will be provided at the nearest operable hose station and will be of sufficient capacity and length to provide coverage for the area left unprotected by the impaired hose station.
2.
In the Fire Hazards Analysis contained in Appendix 9A of the FSAR, the applicant committed to provide noncombustible therma insulation with a flame spread rating not to exceed 25 as measured by tne ASTM E-84 test method.
The audit team requested information confirming compliance with this commitment for chilled water pipe insulation used in the plant. The applicant provided information which confirmed that the chilled water pipe insulation (closed cell polyethylene type) installed has a flame spread rating which does not exceed 25.
This information complies with the requirements of BTP CMEB 9.5.1 and the applicant's commitment.
- 3. During the audit, the staff requested information regarding the specific method for determining the quantity of Halon 1301
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withinstoragetanksassociatedwithHalon1301firesuppressioh systems.
Theapplicantintendsonusingason{ctype, level measuring instrument to determine Halon level.
In the FSAR, the applicant committed to comply with NFPA 12A which provides requirements for the design, installation and maintenance of Halon 1301 fire suppression systems. NFPA 12A requires Halon quantity be determined by weicht. The applicant agreed to re-evaluate the acceptance criteria specified in the applicant's Halon system maintenance procedure to ensure that the normal and minimum Halon liquid levels determined by the sonic level measuring instrument are based on the normal and i
minimum weight of Halon per NFPA 12A and to compensate for th accuracy of the instrument.
Revisions, as required, to Halon system maintenance procedures will be made prior to fuel load.
This ensures the applicant's procedure will comply with the NFPA 12A regarding determining Halon quantity by weight.
i 4.
NFPA 13 is a nationally recognized standard on the installation and design of automatic sprinkler systems. FSAR Appendix 9B and Table 9.5.1-9 address the applicant's compliance with NFPA 13 for sprinkler system design.
The applicant proposes to modify their current description of NFPA 13 compliance presented in the FSAR.
Due to the complexity of the plant, determination of compliance t
with NFPA 13 is based in part upon the professional judgement of l
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qualified fire protection engineers.
In recognition of this, the applicant's description in the FSAR will bg revised to indicate that sprinkler systems in safety-related or safe-shutdown related areas are in compliance with NFPA 13 or have been specifically evaluated by a registered fire protection engineer and found to provide an acceptable level of fire protection.
These evaluations were conducted during the applicant's Fire Protection Finalization Program which included specific criteria involving the acceptability of sprinkler head obstructions.
All fire areas centaining redundant trains of equipment and cable required to achieve safe shutdown and for which separation or barrier deviations are identified in FSAR Appendix 9A will comply with the specific requirements contained within NFPA 13.
Based on the staff's review of the acceptance criteria described in the applicant's Fire Protection Finalization Program, the installation of sprinkler systems in accordance with the criteria of the finalization program is an acceptable deviation from technical requirements of Section C.6.c(3) of BTP CMEB 9.5.1.
5.
To comply with Section C.5.a(14) of BTP CMEB 9.5.1, floor drains, sized to remove expected fire fighting water flow without flooding safety-related equipment, should be provided in
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e those areas where fixed, water fire suppression systems are installed.
i During the audit, the staff requested an evaluation of charcoal filter unit drainage capacity with respect to the maximum flow expected from the installed deluge systems. The applicant determined that the existing drainage capacity of the filter units is insufficient to keep up with deluge system flow.
The applicant committed to revise fire fighting pre-plans for the zones containing charcoal filter units to indicate that the threaded drain caps must be removed to ensure drainage of fire suppression water.
Based cn the administrative controls provided by the applicant and the manual operation of the deluge systems, this is reasonable assurance that the existing deluge systems within charcoal filter units will not flood safety-related equipment.
Therefore, the existing drainage capacity is an acceptable deviation from the technical requirements of Section C.5.a(14) of BTP CMEB 9.5.1.
6.
To comply with Section C.5.a(3) of BTP CMEB 9.5.1, openings fo pipe, conduit and cable tray penetrations through fire barriers which separate fire areas should be sealed or closed to provide a fire resistance rating at least equal to that required of the
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barrier itself.
Penetration designs should be qualified by tests.
The temperature levels recorded for thosunexposed side of penetration designs should demonstrate that the maximum temperature does not exceed 325 F.
In Appendix 9B of the FSAR, the applicant commits that the unexposed surface temperature of penetration designs does not exceed 325 F.
During the audit, the staff requested information confirming that this specific commitment is met. The applicant provided information which confirmed that 325 F is not exceede on the unexposed surface for penetration designs used in the plant.
This information complies with the requirements of BTP CMEB 9.5.1 and the applicant's commitment.
7.
To comply with Section C.S.a(5) of BTP CMEB 9.5.1, door openings in fire barriers should be protected with equivalently rated doors, frames and hardware that have been tested and approve a nationally recognized laboratory.
- In Appendix 9B of the FSAR, the applicant identified numerous special purpose doors locat e d
in fire area boundaries which have not been specifically teste and approved by a nationally recognized laboratory. The special purpose doors serve as pressure doors, bullet resistant doors or watertight doors. ,
The applicant committed that each pressure and bullet resistant door has been fabricated to approved Underwriters Laboratories l
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' labeling procedures for a 3-hour rating and also to the appropriate'NFPA standards.
This construction was certified by the manufacturer.
During the audit, the staff requested documentation assuring that each door is certified by the manufacturer. The applicant provided information which confirmed that certificates of fire labeled construction were available for all of the refere special doors.
The certificate confirms that the doors were fabricated to Underwriters Laboratories labeling procedures for a 3-hour rating and to NFPA 80 and NFPA 252 standards. This information complies with the applicant's commitment. The certificate of construction indicates that the doors meet i
exceed the requirements of UL labeled fire doors and are therefore, their use within fire area boundaries are an acceptable deviation from section C.5.a(5) of BTP CMEB 9.5.1.
8.
Charcoal filter units at Vogtle Electric Generating Plant are equipped with heat detection and a manually operated water sp deluge fire suppression system.
Due to a concern for inadvertent initiation of the water spray system and potential leakage through the isolation valves, either blank flanges with a spool of pipe removed or a spectacle flange has been provided for each charcoal filter deluge system.
This condition will be described in a future FSAR revision.
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As a result of this physical modification, replacement of the spool piece or reversal of the flange must be performed prior to t
activation of the water spray.
The staff was concerned that the access requirsd to install the spool or reverse the flange could be hindered by a fire within the unit. The units were inspected during the site visit and it was concluded that if a fire were to occur in a charcoal unit, the exterior of the unit could be adequately cooled with hose streams, allowing the necessary modifications to take place. The applicant committed to revise prpcedures and fire pre-plans te address this issue including ensuring maintenance personnel are available to facilitate the spool installation.
It is therefore concluded that physically blocking the flow of water to the charcoal filter spray system with a blank flange i and spool or a spectacle flange is an acceptable modification necessary to prevent inadvertent leakage through the isolation valves.
9.
Section C.7.b states that there should be no carpeting in the control room. Appendix 9B of the applicant's FSAR states that a limited amount of carpeting is provided in the control room.
The applicant committed that the carpet installed has flame spread, smoke contribution and fuel contribution ratings of 25 or less.
-9 o During the audit, the staff requested documentation which confirms the applicant's commitment is met. The applicant provided the required information.
Based on the limited quantity and low combustibility of the installed carpet, the installation of carpet in the control room is an acceptable deviation from the technical requirements of Section C.7.b of BTP CMEB 9.5.1.
10.
During the audit, the applicant was requested to identify the location of keys that may be required to access areas required for alternative shutdown. The keys will be located in the control room however, the alternative shutdown procedure did not require operators to take the keys during execution of the alternative shutdown procedure.
The applicant committed to revise administrative procedures to require operators to possess required keys in the event of control room evacuation. This commitment complies with staff requirements.
11.
To comply with section C.5.g(l), fixed, self-contained lighting consisting of fluorescent or sealed beam units with individual 8-hour minimum battery power supplies should be provided in areas that must be manned for safe shutdown and for access and agress routes to and from all fire areas. Appendix 9B of the FSAR currently states that the applicant conforms with these
requirements.
'. The applicant indicated that this is true for all' areas except the main control room and outdoor pecess routes.
The control room lighting is described in FSAR Section 9.5.3.2.3.
The power circuits to the control room lights have been analyzed as safe shutdown circuits and have been protected so that any fire outside the control room complex will not disable both trains of lighting. Therefore, for fires for which shutdown is accomplished within the control room, existing emergency lighting will assure that adequate lighting is maintained.
For fires inside the control room complex, the existing battery back-up (1-1/2 hours) for the control room ceiling lights is adequate to ensure an orderly transfer of control to the alternative shutdown procedure. All areas requiring access for
! alternative shutdown are provided with the required lights except as identified below.
Certain access and agress routes for alternative shutdown areas are located out-of-doors. The lighting for these exterior access and egress routes is part of the security lighting system.
The security lighting is powered by a dedicated generator which operates in the event of a loss of normal power supply to the security system. The security generator is located physically separate from the main plant and from the 1
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control room. As such, a fire necessitating access through exterior areas will not impact the security generator. The i
security generator has sufficient capacity and fuel supply to power the yard lighting for the 8-hour specified time period.
Additionally, the applicant has confirmed that dedicated flashlights will be available to operators required to traverse exterior areas in the event of alternative shutdown and that procedures will require operators to take such flashlights.
Based on our review, we conclude that the use of proposed emergency lighting systems and dedicated flashlights provide an acceptable margin of safety equivalent to that provided by the requirements of Section C.5.g(l) of BTP CMEB 9.5.1. ,
12.
In Appendix 9B, the applicant committed to install smoke detectors within the main control board. During the audit, the staff determined that the detectors were not installed as committed.
In response, the applicant provided documentation which confirmed that the smoke detectors will be installed within the main control board.
The detectors will be installed in accordance with FCR's E-FCRB-17741 and E-FCRB-17740, as well as Drawing Change Notice
No. 16 to Drawing CX3DJ001.
This information complies with the requirements of BTP CMEB 9.5.1 for main control boards and the applicant's commitment.
13.
During the audit, the staff identified locations where cable trays protected by in-tray water spray nozzles were provided with solid tray covers located between the cable insulation and spray nozzles.
The applicant stated that tray covers are provided on certain cable trays with instrumentation cable, areas of potential mechanical damage to cable trays and as needed to comply with Regulatory Guide 1.75. Tray covers are also installed where required to limit the induced voltage from adjacent power cables; reducing noise levels in instrumentation cables.
Water from the in-tray nozzles will not impinge directly en the cable insulation to control / suppress a cable tray fire when the tray covers are present.
However, the water from the sprinklers will provide a cooling effect to the cable tray cover and limit fire spread to adjacent trays. Based on this alone, the installation of limited tray covers between in-tray spray i
nozzles and cable insulation is acceptable.
14.
During the audit, the staff observed that the seams between hollow metal fire door frames and the wall in which they are installed are sealed with caulk. There was concern that in the l
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event of a fire, these caulked openings would fail permitting fire, smoke and hot gases to propagate through $he resultant openings.
During the audit, l the applicant provided information regarding the above stated concern.
The information consisted of fire door installation details. The details indicated that the jambs of hollow metal fire door frames are filled with grout or mortar.
The installation of grout within the frame would pr, event the passage of significant fire, smoke and hot gases in the event the cosmetic surface caulk failed. On this basis, the, staff concludes that the installation of fire doors with respect to the caulked seam conforms to the staff's guidelines.
15.
During the audit, the staff requested information demonstrating that penetration seal designs are approved for use in 3-hour rated assemblies.
Test documentation provided demonstrated that qualification tests were successfully performed. However, certain installations identified in the field exceeded the largest seal size which had been qualified by tests.
For those " oversized" penetrations, the applicant utilized a noncombustible damming board partitions to subdivide the seal i
into sections within the maximum tested seal size. These partitions were not attached to the penetration opening.
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. 14 The staff was concerned that due to the untested s penetration design and the unattached damming board partitions ,
the penetration seals would not perform as required.
During the audit, the applicant provided justification for the installation provided.
This infermation did not adequately resolve the staff's concerns. The applicant indicated that several fire tests have been performed using noncombustible damming boards to partition wall openings in fire test assemblies without attachment to the opening. Pending receipt and review of representative fire tests, this issue remained open at the conclusion of the audit.
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