ML19326E044

Responds to Open Items Noted in 800324 Rept of Insp on 800226-29 Re Fire Protection.Obstructed Sprinkler Sys Heads Will Be Relocated Per Natl Fire Protection Stds

ML19326E044
Person / Time
Site:	Farley
Issue date:	07/21/1980
From:	Clayton F ALABAMA POWER CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 8007250479
Download: ML19326E044 (5)

Text

Na:an'a Pone co ;a9 f C: '4:rin i! r s: ea

C'Me 5:e 29-

• e - ngra~ A a:a a 252r' Te'e:ncr+ 2:5 323 t:0 .

L iA cVlJf!l fc.

Alabama Power July 21, 1980 *;"'"**'-"

Docket No. 50-348 Mr. James P. O'Reilly, Director

u. s. Nuclear Regulatory comission THIS DOCUMENT CONTAlifS ~

!0!$1SrNttastreetN.W. P00R QUAUTY PAGES Suite 3100 Atlanta, Georgia 30303

Dear Mr. O'Reilly:

Enclosed for your review is Alabama Power Company's response to the fire protection inspection conducted by Mr. W. H. Miller, Jr., on Februa ry 25-29, '_980.

If you have any questions or desire additional infor ation, please advise.

Yours very truly, i

f $.ueW. 'h F. L. Clayton/ Jr. F F

JDM/r*

Enclosure cc: Mr. R. A. Thomas Mr. G. F. Trowbridge Mr. W. H. Bradford e Mr. E. Reeves 9

_ 8 0 0 7 :2.s n DjP <

ENCLOSURE The following is a listing of open items as reported in Mr. W. H. Miller's Inspection Report dated March 24, 1980. It should be noted that the bulk of the open items deal with portions of the fire protection syst2r which, based on Mr. Miller's inspection, do not meet the provisions of ;2c%nal Fire Pro-tection Standard No.13 and Standard No.15. As noted in v. Viller's report:

"Section 4.1 (Table 4.1.1 Item E.3.(c)) of the FPPR states in part that the automatic sprinkler systems at the facility cccoly with the provisions of National Fire Protection AssociatSn Standard No. 13 (NFPA-13), Sprinkler Systems, and Standard No. ".5 ,NFPA-15),

Water Spray Systems."

APC0's intent in applying the applicable portions of these standards was to invoke such criteria where applicable to a nuclear plant and where they provide adequate fire suppression capability. Where implerentation of certain portions of these standards was unfeasible due to existing plant confirguration, APC0 developed a fire protection scheme, unique to each situation which provides equivalent, or i- some cases better, fire suppression capability than would have been provided by strict adherence to NFPA codes.

With this understanding, the open items are stated as they appear in Mr. Miller's report together with Alabama Power Company's (AFCO) response.

9 Item 5.a (1): Automatic Sprinkler Systems v

(a) Many portions of the sprinkler protected areas contain from minor to serious obstructions to the discharge of water in the event of fi re . This is due to sprinkler heads (discharge nozzles) being obstructed by electrical and mechanical equipment and components and by structural beams and supports as a result of the design and/or installation of the systems and as a result, does not fully -

meet the provision of Sections 4-2.3, 4-2.4, 4-3 or 4-4 of NFPA-13.

~

In general, sprinkler heads must be positioned to compensate for obstructions or additional heads must be provided.

(b) Sprinkler heads are installed below the ceiling /r- f of structures -

at a greater distance than that permitted by th provisions of Section 4-3 of NFPA-13.

Response

APC0 had perforced sprinkler system walkdcwns prior to the audit and was aware that existing plant configuration did not constitute strict adherence to the code provisions in all cases. Iri an effort to better define these conditions and to determine if such conditions constituted equivalent fire suppression capability, an additional detailed inspection was performed. Guidelines were established for the inspection to assist the walkdown team in evaluating code variances and determining whether in a ccepleted nuclear power plant adequate fire suppression capability is provided by the sprinkler systems as installed.

Page 2 .

The results of the walkdown are described as follows:

(1) Several cases were discovered where heads were icwer than 12" from smooth ceilings (Code Provision). In ncordance with the established guidelines, a head which is vthin 3" of the code provision (or 15" down), AFC0 propos.:s rc redification.

For heads lower than 15" on smooth ceilings, APCO proposes

.. to raise the head to within 12" of the ceili grprovided no obstruction or other adverse fire supprestien capability will result.

(2) Several cases were observed where heads were lower than 16" from beam and girder ceilings (Code Provision). In accordance with the established guidelines, a head which is within 3' of the code provision (or 19" down), APC0 proposes no modification.

,, For heads lower than 19" en beam and girder ceilings, APC0 proposes to raise the head to witnin 16" of the ceiling provided no obstruction or other adverse fire suppression capability will result.

(3) Heads that were found to be obstructed and can be shifted to improve water distribution will be relocated. If relocation of an obstructed head will not improve wate- distribution, APC0 proposes no modification.

(4) The Cable Spreading Room contains such massive congestion that I heads are obstructed and are located farther from the ceiling l than allowed by the code in many cases. APC0 does not propose any modifications for this rccm. A hot shutdcwn panel is currently under construction which will allow the plant to be brought to a safe shutdown condition with total loss of the Cable Spreading Rocm or Main Control Room.

Item 5.a (1)

~

(c) The sprinkler piping for the pre-action systems which contain over l 20 heads are not supervised as required by Section 5-3.5.2 of fiFPA-13.

Response

There are eleven (11) systems which contain over 20 heads and are presently not supervised. These systems will be modified to include air supervision.

Item 5.a (1)

(d) Test pipes (main drains) arranged to properly test the water supply to each system are not provided as required by Section 2-9 of tiFPA-13.

Response

In conjunction with tests of fire hose stations, the test valves will be partially opened to verify that flow connections are in order and no flow blockage exists. Provisions will be made to ensure that plant equipment is properly protected from water damage during the tests.

APC0 will perform tests once every three years.

Page 3 Item 5.a (1)_

( e) Sprinkler heads of different orifice sizes (1/2 and 3/8 inch) are used to hydraulically balance the systems. This is clearly pro-hibited by Section 7-4.3.1.5 of NFPA-13.

?.escon s e:

_ The issuance of replacement sprinkler heads w1 1 be controlled administratively to preclude inadvertent use cf the incorrect orifice size.

!!e, 5.a (1)

(f) The water spray system for the protection of motors at the service water intake structure utilizes closed type spray nozzles in lieu of the normally open type nozzles as required by Sections 1-3 and 2-3 of NFPA-15.

Resoonse:

Ten (10) pumps supply service water for both units. With an open type nozzle system, a fire associated with one (1) ;mp would cause all ten (10) pumps to be sprayed with water. It is Alabama Power Company's position that impinging water on all ten (10) pumps at a smoke alarm signal would constitute a possible safety condition in

, that all motors would be subject to a potential electrical shortage due to water bombardment. This is precluded by the use of tusable heads whn % would provide water only where necessary. Further, it is anticipa$ed that an oil type fire in this area would be of a sufficient temperature to readily fuse the low positioned heads.

Item 5.a (2) Exterior Fire Protectic., Water System Documentation , s not available to verify that the underground fira protection piping from the Unit 1 fire loop to the service wecer intake structure was flushed as required.

Response

Since documentation was unavailable, Alabama Power Company has re-flushed the lines as necessary and associated documentation is available for review at Farley Nuclear Plant.

Item 5.b Fire Prctection QA Program A review of the documentation available on the aut'o:ntic sprinkler systems and the exterior fire protection piping (yard loop) installation indicate that QA documentation may not meet the requirements of the existing safety-related operational and cen-struction QA programs. The licensee has agreed to develop by June 1, 1980, a list of QA/QC iocur,antation and record data which will be provided for all comp'eted fire protection modifications and those modifications presentiv in process.

e Page 4

Response

This list has been developed and is available for review at Farley Nuclear Plant.

Item 5.c Fire Pump House The batteries and chargers for the diesel driver ' ire pump No.1 were found to be located in the enclosure for t e electric driven fire pump and the start-stop switch for the ela tric fire pump was located in the enclosure for diesel fire pump I;o.1.

Response

Production Change Requests (PCR's)80-623 and 80-628 have been issued to designers for evaluation and resolution of both problems.

..

8