ML20247R629

Discusses Deviations from NFPA Code & Basis for Use of Portable Detection Sys.Util Reviewed Sys & Determined That, Supplemented W/Expanded Hourly Fire Watch Duties & Increased Testing,Sys Is Operable Detection Sys

ML20247R629
Person / Time
Site:	Davis Besse
Issue date:	07/28/1989
From:	Shelton D TOLEDO EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
1689, TAC-60994, TAC-60995, TAC-61745, NUDOCS 8908080071
Download: ML20247R629 (29)

Text

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.o TOLEDO

%s EDISON A Centenor Energy Compary DONALD C. SHELTON Voe Pretadent,-Nuclear M'S*" "

Docket Number 50-346 l

License Number NPF-3 Serial Number 1689 l

July 28, 1989 l

Unfted States Nuclear Regulatory Commission Document Control Desk Vashington, D. C.

20555 Subj ect:

Fire Protection - Portable Detection System (TAC Numbers 60994, 60995 and 61745)

Gentlemen:

In telephone conversations with Nuclear Regulatory Commission (NRC) staff members, Messrs. Wambach, Kubicki and Ulie, on February 22 and 27, 1989, Toledo Edison explained its intention to use a portable detection system in

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order to reduce certain continuous fire watches-to an hourly fire watch patrol at the Davis-Besse Nuclear Power Station. The NRC was informed that the system has certain National Fire Protection Association (NFPA) Code deviations, but that Toledo Edison had evaluated the deviations and considered the portable detection system, supplemented by expanded hourly fire watch duties and increased testing, to be an OPERABLE fire' detection system in accordance with the Davis-Besse Op'erating License Technical Specifications.

The NRC requested Toledo Edison to_ identify the deviations and the basis to consider the portable detection system as OPERABLE.

Davis-Besse Technical Specification 3/4.7.10, " Fire Barriers" specifies the following Action statements:

With one or more of the above fire barriers inoperable, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, j

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either:

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1.

Establish a continuous fire watch on at least one side of the j

Q affected fire barrier, or l

.fp 2.

Verify the OPERABILITY of the fire detectors'on at least one side o

of the affected fire barrier and establish an hourly fire watch' j

g patrol.

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P In the past year, five fire doors in three fire areas vere declared inoperable gh due to hardware deficiencies. These doors'did not have operable fixed fire I

gg detection on either side. Continuous fire watches were established in Ott I

THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO, OHIO 43652 I

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Docket Number 50-346 License Number NPF-3 Serial Number 1689 Page 2 accordance with the above Action statements.

In order to reduce the required continuous fire watches to hourly fire watch patrols, Toledo Edison put into place a portable detection system on one side of each of the inoperable fire doors. Before this system was put in place, Toledo Edison completed a safety evaluation for the portable detection system. This safety evaluation concluded that the portable detection system meets the requirements of an OPERABLE detection system as defined in the Davis-Besse Technical Specifications despite certain NFPA Code deviations.

As shown in the attached Figure 1, the system consists of one or more U.L. -

listed detectors, a power supply and monitor unit, an auto-dialer and message unit, connecting cables, and a standard phone line connected to standard telephones. The fire detectors may be plac d in more than one room or more than one elevation of the plant and *19 to three fire detection zones can be established.

A fire alarm signal is transmitted when the following conditions exists:

1.

a detector goes into alarm; 2.

a short occurs between the two conductors of the alarm sensing circuit; or 3.

a ground occurs on the psottive side of the alarm sensing circuit A trouble signal is transmitted when the following conditions exist:

1.

an open circuit occurs in the interconnecting viring in the detection circuit; 2.

the normal AC supply to the Power Supply and Monitor Unit is lost; or 3.

power is lost to the detector power supply.

Upon receipt of a fire (or trouble) alarm, a local alarm at the monitor unit sounds, the alarm (or trouble) light on the monitor panel is energized and the system automatically dials the Control Room, Central Alarm Station (CAS), and the Secondary Alarm Station (SAS) in sequence until the call is acknowledged or until the sequence is repeated 5 times. A recorded message is played describing whether the alarm is a fire or trouble alarm.

While in alarm, the battery backup can support the operation of the system for approximately 19 hours2.199074e-4 days <br />0.00528 hours <br />3.141534e-5 weeks <br />7.2295e-6 months <br />.

If a trouble alarm is received, or a fire alarm that can not be cleared, the system would be declared inoperable and the necessary continuous fire watches established within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> in accordance with Davis-Besse Technical Specifications.

Placement of the detectors for the portable system would be based on the recommendations of a fire protection engineer or qualified individual using the guidance of NFPA Standard 72E. The placement of the detectors would consider obstructions and air flows in the area. The cables from the detectors vould not be run in conduit or cable tray, but would be routed and secured so as not to interfere with routine plant operations. The system would not be connected to the existing fire protection system or any safety-related equipment.

The only interface to existing plant systems is through the 120 VAC power supply and plant telephone system.

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Docket Numbar 50-346 License Numbar NPF-3 Serial Number 1689 j

Page 3 Toledo Edison's review of the portable detection system concludes that It is comparable to the NFPA Style A.5 system using the 1986 edition of NFPA 72D.

j The deviations to NFPA 72D - 1986 are identified'in Attachment 1.

National Fire Protection Association Section 72D requires that system supervision be provided. The portable detection system at Davis-Besse is a.

-l supervised system with the exception of the auto-dialer and the phone line-l connections.

In order to compensate for this NFPA deviation, the hourly fire l

vatch is assigned expanded duties. The hourly fire watch patrol vill check i

the mc,nitor panel of the portable detection system at least 'once per hour for j

alarm indications and vill verify the phone line is physically connected. The j

remaining cable connections are supervised and are not required to be checked by the hourly fire watch. A functional test of the auto-dialer, message' unit and phone lines vill be performed at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> as well as a 4

check of any alarm indications. This functional test is performed at the I

monitor panel. The system would also be subject to a periodic six-month 1

l channel functional test, in accordance with the Davis-Besse Procedure

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DB-FP-00009, Fire Protection Impairment and Fire Watch.

1 Another deviatica from NFPA 72D involves the pover' supply features of the-portable detection system. The batteries provided for.the auto-dialer and j

message unit are not rechargeable. When the portable detection system is in I

service, the non-rechargeable batteries will be replaced following any period of AC power loss to the system or at least once per six months of operation.

j Although the safety evaluation mentioned above vas written for the specific use described above, Toledo Edison intends to use the portable detection system in other instances where the plant configuration and conditions would 4

be acceptable for its use. The use of the system would allow the replacement

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of a continuous fire watch by an hourly fire watch patrol.

J In summary, Toledo Edison has reviewed the portable detection system and has determined that it, supplemented with expanded hourly fire vatch duties and increased testing, is an OPERABLE detection system in accordance with the Davis-Besse Technical Specifications.

j If you have any questions regarding this matter, please contact Mr. R. W. Schrauder, Nuclear Licensing Manager, at (419) 249-2366.

Very truly yours, 1

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Attachment cc:

P. M.. Byron, DB-1 NRC Senior Resident Inspector A. B. Davis, Regional Administrator, NRC Region III D. J. Kubicki, NRC/NRR Staff Reviewer 1

T. V. Vambach, DB-1 NRC Senior Project Manager l

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• Dochet Number 50-346 l

License Number NPF-3 3erial Number 1689 Figure 1 FIGURE 1 j

PORTABLE DETECTION SYSTEM l

CABLES TO DETECTOR

- STRINOS DETECTOR

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3 BUZZER BATTERY POWER ON ON ON ON ON ON O

O O

O O

O I

OFF

- Ol F OFF OFF OFF OFF ZONES SYSTEM 10WER 1

2 3 TROUBLE ON ON O O

O O

O w

TROuBLEO O

O i

ALARM O O

O DETECTOR 7

3 END OF LINE CONNECTOR A

B C

D

^

^

TELEPilONE L

J LINE AC POWER TRANSFORMER BATTERY 7/11/89 KMS

I REVIEW 0F THE PORTABLE DETECTION SYSTEM FOR COMPLIANCE WITH NFPA 72D - 1986 STANDARD FOR THE INSTALLATION, MAINTENANCE, AND USE OF PROPRIETARY PROTECTIVE SIGNALING SYSTEMS l

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Docket Number 50-346 License Number NPF-3 Serial Number 1689 Page 1 INTRODUCTION The Davis-Besse Technical Specifications and fire protection program require

'l an hourly fire patrol if there is operable fire detection on at least one side of certain inoperable fire barriers; otherwise, a continuous fire watch is required. A portable detection system is available from Innovative Technological Services, Inc. which can be used to provide adequate fire detection on at least one side of an inoperable fire barrier and reduce the l

required continuous fire watch to an hourly fire patrol. This portable detection system was reviewed against the guidelines of NFPA 72D - 1986 in order to document the adequacy of the system and to document the resolution of identified Code deviations.

SCOPE l

l The scope of this review is limited to the portable detection system (ITS Model 103-89), the use of a telephone at the central supervising station and the administrative controls unique to the application of the system.

A number of provisions of the code deal with generic issues related to the organizational structure, policies, and administrative controls of the plant.

These provisions have been addressed in the NFPA 72D - 1975 Code Review, provided to the NRC in letter dated July 31, 1989 (Serial Number 1685), and are considered outside the scope of the review for the portable detection system.

Additionally, the code also addresses the installation configuration of detection systems.

The configuration of the portable detection system is based on the specific application and may be different each time it is installed. Therefore, those provisions of the Code addressing installation configurations are also outside the scope of this review.

SUMMARY

In summary, the results are as follows:

Code Sections Reviewed 46 Code Sections Complied With 10 Code Sections Not Complied With 12 Code Sections Complied With Intent 7

Non-Applicable Code Sections 17

i Do'ck:t Number 50-346 Lic:nsa Numb:r NPF-3 j

Serial Number 1689 j

Attachme.nt 1 J

Page 2 COMPLIANCE MATRIX l

CODE COMPLIANCE CODE COMPLIANCE SECTION STATUS

_SECTION STATUS l

1-4.1 2-8.1 C

1-4.2 2-8.2 C

1-4.3 3-2 NC i

2-2.2 NC 3-5.1.1 CVI

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2-2.2.1 CVI 3-5.1.2 l

2-2.3 CVI 3-8.1 1

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2-2.4 CVI 3-9.1 NC

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1 2-4.3 CVI 3-9.3 C

2-4.5 3-9.4 C

l 2-6.3 NC 3-10.1 NC l

. 2-6.4.1 C

3-10.3 l

2-6.4.2 NC 4-2.2 C

2-6.5.1 4-2.3 2-6.5.2 4-3.1 CVI 2-6.5.3 4-3.2 NC 2-6.5.4 4-3.3 C

2-6.5.5 4-4.1 CVI 2-6.6.1 C

4-4.2 2-6.6.2 C

4-5.1 NC 2-6.6.3 C

4-5.2 NC 2-7.1 NC 4-5.3.1 2-7.2 NC 4-5.3.2 2-7.3 NC 4-6 LEGEND:

Corapliance NC Non-Compliance C

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=

Compliance With Intent Not Applicable CVI

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Do'ckot Numb 2r 50-346 License Numb r NPF-3 Serial Number 1689 Page 3 1

SYSTEM CAPABILITIES The capabilities are as follows:

Fire detection:

The system <is provided with UL listed fire detectors.

The detector placement'is determined by a' fire protection engineer or l

qualified individual.'

l Signaling:-

a) The system provides for transmitting fire alarm signals and' fire detection system' trouble signals to any one of three locations (control room,'CAS and SAS).

b) The. signal consists of a prerecorded message transmitted via'the plant t;lephone system.

c) A fire' alarm signal vill be produced:

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1) When a detector goes into alarm.

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2) When a short occurs between the two conductorn of the alarm sensing circuit.

3) When a ground occurs on the positive side of the alarm sensing' I

circuit.

d) A trouble signal vill be produced:

1) When an open circuit occurs in the interconnecting viring in the-detection circuit.

2) When the normal AC supply to the Power' Supply and Monitor' Unit..is lost.(assuming battery backup is available).

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3) When power is lost to the detector power supply.

e) A local audible and visual signal is provided when a trouble condition is detected.

l f) A local visual indication is provided when an alarm condition is l

signaled.

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.Do'ckat1 Number 50-346-

.4 Licznsa Number NPF-3 Serial Number 1689 Page 4 Power Supply a)' The Power Supply and Monitor Unit is provided with a battery backup to-the AC supply. This is a rechargeable battery which is connected in parallel vith the normal'DC power supply.

b) The Auto-Dialer and Message Unit-is equipped with two non-rechargeable batteries, one for operating the unit and one for retaining.the unit's J

memory.

c) A test switch is provided for use in checking the batteries-in the Auto-Dialer and Message Unit.

d) When fully charged, the Power Su" ply and Monitor Unit battery ca'n provide for approximately 51 hours5.902778e-4 days <br />0.0142 hours <br />8.43254e-5 weeks <br />1.94055e-5 months <br /> of operation with no alarn present or 19 hours2.199074e-4 days <br />0.00528 hours <br />3.141534e-5 weeks <br />7.2295e-6 months <br /> with a fire alarm signal present.

e). When installed, the Auto Dialer and Message Unit battesies can provide for 500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> of operation with no call cycle or 40' complete. call cycles.

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Do'ckat'Numbzr 50-346!

Licensa Numbar NPF 1,

-Serial Number 1689; I

Page 5.

l NFPA 72D.- 1986 STANDARD COMPLIANCE REVIEW i

1 DEVIATIONS:AND CONCLUSIONS 1

. CODE SECTION:

2-2.2

SUBJECT:

Listing of' Equipment' j.

' STATUS:

Non-Compliance-SVALUATION:

Contrary to.the requirement.of'2-2.2, a number of items of equipment utilized'in the system a"2 not listed for fire protection signaling service (e.g.,

the Iover Supply aid Monitor Unit, the Auto-Dialer and.

Message Unit, the Telephone). The Auto-Dialer and J

Message Unit is' listed under UL standard number 1023,;

l Housenold Burglar - Alarm System-Units. The. remaining, components are commercially purchased and'have.

multiple'uses which are-not listed for fim protection service. The use of such components for th.is type service is acceptable since.the operability of the.

system is enhanced'by the hourly and daily system 1

tests, j

f CONCLUSION:

No further action is required.

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Do'ck2t Numb:r 50-346 l

Licensa Number NPF-3 Serial Number 1689 i

Page 6 NFPA 72D - 15oo l

STANDARD COMPLIANCE REVIEW 1

DEVIATIONS AND CONCLUSIONS

---,E S.EC. TION:

2-2.2.1 i

COD

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SUBJECT:

Limiting Operating Conditions l

STATUS:

Comply With Intent EVALUATION:,

Contrary to the requirements of 2-2.2.1, no evidence j

that the Power Supply and Monitor Unit could operate j

under the specified temperature and humidity

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conditions was available. Considering that the unit i

is assembled from commercial grade compoa.ents and that i

the specified operating conditions are not severe, it l

is reasonable to consider the unit can perform I

throughout the range of conditions to be found in the l

plant.

CONCLUSION:

No further action is required.

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i Do'ckat Numb:r 50-346 i

Lictnsa Numb:r NPF-3 i

Serial Number 1689 l

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l Page 7 NFPA 72D - 1986 1

STANDARD COMPLIANCE REVIEW l

DEVIATIONS AND CONCLUSIONS j

CODE SECTION:

2-2.3

SUBJECT:

Acceptance Tests j

i STATUS:

Comply With Intent l

1 EVALUATION:

The testing specified by the Code is not impleme.ted.

l The vendor manucl specifie; the testing of the system

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following installation and includes alarm and i

supervisory testing.

Toledo Edison has reviewed and f

accepted the vendor manual and the vendor manual is i

specified to perform this testing. Based on the system design and uses of the system, this testing j

provides an adequate level of esting to comply with j

the intent of the code.

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CONCLUSIONS No further action is re-quired.

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'Do'ckat Numbhr 50-346'

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-Licensa Numbar NFF-3 q

Serial Number.1609 l

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'Page 8 NFPA 72D'- 1986 STANDARD COMPLIANCE REVIEW.

DEVIATIONS AND. CONCLUSIONS C09E SECTION:

2-2.4 SUBJECT Certificate'of Compliance

' STATUS:

Comply With Intent EVALUATION:

.A Certificate of Compliance-is not directly applicable l

to the Portable Detector System since it is a i

portable / temporary system used as a supplemental means to monitor'for fires in various situations. When the portable detection system is utilized, the installation is made in accordance with plant i

procedures which document acceptable installation similar to'e Certificate of Conformance.

1 CONCLUSION:

No rurther action is required.

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Docket Numbsr 50-346 Lic nsa Numb 2r NPF-3 Serial Number 1689 Pace 9 NFPA 72b - 1986 STANDARD COMPLIANCE REVIEV DEVIATIONS AND CONCLUSIONS CODE SECTION:

2-4.3

SUBJECT:

Periodic Testing STATUS:

Comply Vith Intent EVALUATIQN:

The monitor panel of the portable detector system will be checked at least once per hour for alarm indication and vill verify that the phone line is physically connected. The remaining cable connections are supervised and are not required to be checked hourly, A functional test of the auto-dialer, message unit and phone lines and a check for alarm indications vill be performed at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The functional test is performed via a test switch located at the monitor panel. Additionally, a channel functional test will be performed at least once per 6 months when the portable detection system is in continuous use for that time or greater.

CONCLUSION:

A periodic six-month channel functional test will be developed by August 31, 1989.

_ - _ _ _ _ - _ = _ -_ _.

Docket Number 50-346' l

Licensa Numbar NPF-3 Serial Number 1689 Page 10 NFPA 72D - 1986 STANDARD COMPLIANCE REVIEW DEVIATIONS AND CONCLUSIONS 1

CODE SECTION:

2-6.3

SUBJECT:

Power Supply Features i

STATUS:

Non-Compliance i

EVALUATION:

Contrary to the requirement of code section 2-6.2.3 as invoked by 2-6.3, the secondary power supply battery in the Power Supply and Monitor' Unit can provide energy when the primary power supply voltage is belov 85% of rated voltage. Additionally, the secondary l

power supply for the Auto-Dialer and Message Unit f

consists of batteries which are not storage j

(rechargeable) batteries as specified in 2-6.3.

The i

loss of AC power to the portable detection system and

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operation under battery power would normally be i

indicated by a trouble alarm transmitted to the

-l central supervising station.

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l The system operational voltage range is limited to approximately 85% of the nominal nameplate voltage (120 vac).

Since the nonrechargable batteries are directly connected across the de power supply, it vill provide power to the system anytime its output voltage equals or exceeds the de power supply voltage. Thus, during an extended period of reduced ac voltage to the i

system, the battery capacity could be reduced to the l

85% limit or belov once the-ac source drops below the i

i operating limit of 85%. This reduced capacity would still ensure an alarm would be sent if power were subsequently lost.

Additionally, the capacity of these batteries is i

sufficiently large relative to operation time and~

number of call cycles to allow-a periorlic battery replacement program to assure adequate capacity is maintained.

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Plant personnel would be aware of the loss of alarm indication to the central supervising station.

Separate-rechargeable' batteries for the Monitor Unit tre used to provide a trouble indication at the monitor panel, which would be'rtadily visible to personnel performing the hourly check of the monitor panel. Additionally, a functional' test of_the Auto-Dialer, Message Unit and phone lines are performed at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This functional.

test would identify if normal AC power is' lost and if i

the battery capacity is inadequate to transmit the alarm to the central supervising station.

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Docket Number 50-346'-

Licensa Number NPF-3 Serial Number 1689 Attachment'l l

Page 11 l

code Section:

2-6.3 (Continued)

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1 CONCLUSION:

' When the' Portable Detector System is in service,.the non-rechargeable batteries'will be replaced following l

any period of AC power _ loss or at least once-per six l.

months of operation.

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Docket Number 50-346 Licensa Number NPF-3' Serial Number 1689

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Page 12

,j NFPA.72D'- 1986 STAND /2D COMPLIANCE REVIEW DEVIATIONS AND CONCLUSIONS j

-CODE SECTION:

2-6.4.2

SUBJECT:

Connection to Light and Power Service STATUS:

Non-Compliance EVALUATION:

Contrary to the requirement of Section 2-6.4.2, th'-

e connection to the light and power source is not to a dedicated branch circuit and neither.the circuit nor the connections are mechanically protected. The system is designed to receive power from a standard 120 vac wall receptacle using a flexible cord.

Since.

vall receptacles are not single' units on a single branch circuit,.the provision of a dedicated branch circuit cannot be assured.

Due to the portable nature of the system, the use of flexible cord for providing power.is a necessity.

However, the portable detection system is provided with battery backup and.the loss of power would be indicated by a trouble light at the monitor panel and by a trouble alarm transmitted to the central supervising station.

CONCLUSION:

No further action is required.

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. Docket Numbhr 50-346

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Licensa Number NPF-3.

Serial Number 1689

. Attachment 1 Page 13' NFPA 72D 1986 STANDARD COMPLIANCE REVIEV.

DEVIATIONS AND CONCLUSIONS

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CODE SECTION:

2-7.1

SUBJECT:

Monitoring Integrity of Installation Conductors 1

STATifS:

Non-Compliance ~

EVALUATION:

Contrary to the requirement of 2-7.1, the integrity of.

installation conductors between;ti.a system control O

unit and'the central supervising l station is not:

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- monitored.- Additionally automatic recording of

.i signals in the central supervising station is not

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provided. ' This is compensated for by! the hourly check of the' phone line connection'andifor alarm indications-and by the daily functional test of the auto-dialer-

i and message unit and's check for alarm indications and for physicalJconnection of the phone line.

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CONCLUSION:

No furtherLaction is required.

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Docket Numbar 50-346 Licensa Number NPF-3 i

4 Serial Number 1689 l

I Fage 14 NFPA 72D - 1986 STANDARD COMPLIANCE REVIEV

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DEVIATIONS AND CONCLUSIONS j

CODE SECTION:

2-7.2

SUBJECT:

Connections of Installation-viring STATUS:

Non-Compliance LVALUATION:

Contrary to the requirement of section 2-7.2, the connections of installation-viring to the alarm-indicating appliance (telephone) is not monitored for integrity. This is compensated for by 1

the hourly check of the phone line connection and for alarm indications and by the daily functional test of the auto-dialer and.*essage unit and a check for alarm indications and for physical connection of the phone line.

CONCLUSION:

No further action is required.

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'Dockat Numb:r'50-346

. License Numbar NPF-3' Serial Number 1689 Page 15

i CODE SECTION:

.2-7.3

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SUBJECT:

Effeet of Faults STATUS:-

Non-Compliance 1 i

. EVALUATION:

Contrary to the' requirement of.section 2-7.3, a single ground. fault in the. interconnecting'viring of the 1

indicating device circuit can cause an alarm signal.:

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Specifically,.a ground on the positive, side of1the circuit utilized to signal an alarm condition can i

result in'an alarm signal being produced..When an-

.f alarm signal is received, it will be investigated.

If a trouble alarm is received,.or a fire alarm that can not be cleared,.the system would be declared inoperable and the necessary continuous fire watches established within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> in accordance with Davis-Besse Technical Specification.

C_0NCLUSION:

No further action is required.

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Docket Number 50-346 i

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Licensa Number NPF-3 j

Serial Number 1689 Page 16 I

NFPA 72D - 1986 STANDARD COMPLIANCE REVIEV DEVIATIONS AND CONCLUSIONS j

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CODE SECTION:

3-2

SUBJECT:

Prevision for Manual Alarm Initiation i

STATUS:

Non-Compliance

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EVALUATION:

Contrary to the requirement of section 3-2, a means for manually initiating an alarm signal is not-provided. A hourly fire vatch checks the system and if there is a problem, the hourly fire watch would report any conditions as required. Manual initiation is not used on any installed Davis-Besse detection system and is not appropriate for a portable system.

CONCLUSION:

No further action is required.

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D'ockst Number 50-346 Licensa Numbar NPF-3 Serial Number 1689

- Attachment 1 Page 17 NFPA 72D - 1986 STANDARD COMPLIANCE REVIEW DEVIATIONS AND CONCLUSIONS CODE SECTION:

3-5.1.1 j

SUBJECT:

Location, Maintenance, and Testing of Detectors STATUS:

Comply With Intent EVALUATION:

The detector placement is-determined by a fire I

protection engineer or qualified individual. This is compensated for by the hourly check of the phone line connection and for alarm indications and by the daily j

functional test of the auto-dialer and message unit and a check for alarm indications and for physical j

connection of the phone line. Additionally, a channel functional test will be performed at least once per 6

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months when the portable detection system is in continuous use for that time or greater. The testing i

for this type of system complies with the intent of j

the code. The frequent testing specified serves to l

identify system problems and would allow for corrective maintenance following a failure. Thus the location, maintenance and testing of automatic fire i

detectors as used in the Portable Detection System j

comply with the intent of the code.

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CONCLUSION:

A periodic 6 month channel functional test will be developed by August 31, 1989.

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Docket Numb:r 50-346

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License Number NPF-3 Serial Number 1689 Page 18 NFPA 72D - 1986 STANDARD COMPLIANCE REVIEV DEVIATIONS AND CONCLUSIONS CODE SECTION:

3-9.1

SUBJECT:

Performance and Capacities of Initiating Device Circuits STATUS:

Non-Compliance EVALUATION:

Contrary to the performance requirements of table 3-9.1 relative to initiating device circuits, the j

Portable Detection System (PDS) does not provide the J

abnormal condition operating features required for j

style "A" circuits. Although the system does provide for a-trouble signal on a single open and an alarm signal on a vire-to-vire short, a single ground can produce an alarm signal in lieu of the specified trouble signal. When an alarm signal is received, it vill be investigated. This is compensated for by the

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hourly check of the phone line connection and for alarm indications and by the daily functional test of j

the auto-dialer and message unit and a check for alarm indications and for physical connection of the phone line.

I CONCLUSION:

No further action is required.

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Docket Number 50-346 Licente Numb r NPF-3 Serial Number 1689 Page 19 NFPA 72D - 1986 STANDARD COMPLIANCE REVIEW DEVIATIONS AND CONCLUSIONS CODE SECTION:

3-10.1

SUBJECT:

Performance and Capacitier. of Signaling Line Circuits STATUS:

Non-Compliance EVALUATION:

Contrary to the performance requirements of table 3-10.1 relative to signaling line circuits, the portable detection system does not provide the i

i abnormal condition operating features required for style 0.5 circuits. No indication of trouble is

)

provided on either an open or single ground condition.

l This is compensated for by the hourly check of the phone line connection and for alarm indications and by the daily functional test of the auto-dialer and message unit and a check for alerm indications and for physical connection of the phone line.

CONCLUSION:

No further action is required.

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Docket Numbar 50-346

eA -

License. Number NPF-3 L;

_ Serial' Number 1689 24 Page 20:

NFPA 72D -'1986

-STANDARD COMPLIANCE REVIEV DEVIATIONSLAND CONCLUSIONS CODE-SECTION:

4-3.1-

SUBJECT:

Provision'of' Audible Trouble Signals l

1 STATUS:-

LComply With' Intent.

'.lq EVALUATION:

. Contrary to the requirement of section 4-3.1, a

. distinctive audible signal 11s not provided in the j

eentral supervising station. In the event ofoa~

I trouble condition, the central supervising' station (e.g.,: control' room) telephone vill; ring. However, control room personnel'are aware of the installation of'the system and that is uses the telephone for alarms. Once the telephone is answered, a' unique-audible trouble message is provided..

CONCLUSION:

No further action'is required.

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Dockst Numb:r 50-346 Lic nsa Number NPF-3 Serial Number 1689 Page 21 NFPA 72D - 1986 l

STANDARD COMPLIANCE REVIEW DEVIATIONS AND CONCLUSIONS CODE SECTION:

4-3.2

SUBJECT:

Silencing Switch STATUS:

Non-Compliance EVALUATION:

Contrary to the requirement of section 4-3.2, the act of silencing the trouble signal in the central supervising station vill not result in the transfer of the trouble indication to a lamp or other visual indicator.

See section 4-5.1.

CONCLUSION:

No further action is required.

Docket' Number 50-346 Licensa Numbar NPF-3 Serial Number 1689 Page 22 NFPA 72D - 1986 STANDARD COMPLIANCE REVIEW DEVIATIONS AND CONCLUSIONS 1

CODE SECTION:

4-4.1'

SUBJECT:

Distinctiveness of Audible Signals j

STATUS:

Comply With Intent EVALUATION:

. Contrary to the requirement of Section 4-4.1, the audible signal appliance provided in the central supervising station is a telephone and is used for a number of purposes. Thus, distinctiveness of audible; signaling.is not achieved.

As stated in the evaluation of the Section 4-3.1 deviation, incoming telephone calls are answered by control room personnel.- Once the telephone is answered, a unique and distinctive' message will be received. Thus, the intent of the code'is satisfied.

Contrary to the requirement of Section 4-4.1, fire protection signals are not given precedence over other incoming signals.

If the control room phone is busy, the auto dialer of the portable detection system would call an alternate, manned location to deliver its message.

CONCLUSION:

No further action is required, m-

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Docket Number 50-346 Licensa Number NPF-3 Serial Number 1689 Page 23 NFPA 72D - 1986 STANDARD COMPLIANCE REVIEW DEVIATIONS AND CONCLUSIONS CODE'SECTION:

4-5.1

SUBJECT:

Means of Alerting the Operator STATUS:

Non-Compliance EVALUATION:

Contrary to the requirements of 4-5.1, the central

. supervising station (e.g., control room) is not provided with two different means (one of.which shall be audible),'in addition to a recording device, for.

alerting the operator when a signal is received.

.)

Although the system does provide an audible means of.

alerting the operator (the telephone rings), no provision for recording or other means of alerting the j

operator is available. The system does, however,-

provide audible. signaling capability for each of three separate manned supervising stations (control room, CAS, SAS). Thus, a failure of one. alerting device or the failure of one operator to acknowledge an incoming signal vill result in the signal being redirected to an alternate supervising station. This redundant signaling feature, provides assurance of operator notification equivalent to that which multiple means of alerting an operator would provide.

Also contrary to the requirements of.4-5.1, the central supervising station is not provided with signals indicating a restoration of alarm or trouble i

conditions to normal.

Such indication is provided verbally by a hourly fire watch who checks the systems and reports any problems.

1 J

CONCLUSION:

No further action is required.

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6ocket Number 50-346 r

Licensa Numbar NPP-3' Serial Number 1689

'Page 24 NFPA 72D - 1986 STANDARD COMPLIANCE REVIEW.

DEVIATIONS AND CONCLUSIONS CODE SECTION:

4-5.2 SUBJECTc Recording-and Redisplay of Signals STATUS:

Non-Compliance EVALUATION:-

Contrary to the requirement of section 4-5.2, automatic visual recording of incoming signals is not provided and no mechanism for redisplay of signals received is available. The unique application of-this portable detection system does not lend itself.to the requirements of a permanently installed system.

CONCLUSION:

No further action is required.

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