ML020320491
| ML020320491 | |
| Person / Time | |
|---|---|
| Site: | PROJ0690 |
| Issue date: | 01/28/2002 |
| From: | Charemagne Grimes Division of Regulatory Improvement Programs |
| To: | Lochbaum D, Alexis Nelson Nuclear Energy Institute, Union of Concerned Scientists |
| Strnisha J, NRR/DRIP, 415-1092 | |
| References | |
| Download: ML020320491 (9) | |
Text
Enclosure 2XI.M26 FIRE PROTECTIONProgram DescriptionFor operating plants, the fire protection aging management program (AMP) includes afire barrier inspection program and a diesel-driven fire pump inspection program. The firebarrier inspection program requires periodic visual inspection of fire barrier penetrationseals, fire barrier walls, ceilings, and floors, and periodic visual inspection and functionaltests of fire rated doors to ensure that their operability is maintained. The diesel-drivenfire pump inspection program requires that the pump be periodically tested to ensure that the fuel supply line can perform the intended function. The AMP also includesperiodic inspection and test of halon/carbon dioxide fire suppression system.Evaluation and Technical Basis 1.Scope of Program: For operating plants, the AMP manages the aging effects on theintended function of the penetration seals, fire barrier walls, ceilings, and floors, andall fire rated doors (automatic or manual) that perform a fire barrier function. It alsomanages the aging effects on the intended function of the fuel supply line. The AMPalso includes management of the aging effects on the intended function of thehalon/carbon dioxide fire suppression system.
2.Preventive Actions: For operating plants, the fire hazard analysis assesses the firepotential and fire hazard in all plant areas. It also specifies measures for fireprevention, fire detection, fire suppression, and fire containment and alternativeshutdown capability for each fire area containing structures, systems, andcomponents important to safety.
3.Parameters Monitored/Inspected: Visual inspection of 10% of each type ofpenetration seal is performed during walkdowns carried out at least once every refueling outage. These inspections examine any sign of degradation such ascracking, seal separation from walls and components, separation of layers of material, rupture and puncture of seals which are directly caused by increasedhardness and shrinkage of seal material due to weathering. Visual inspection of thefire barrier walls, ceilings, and floors examines any sign of degradation such ascracking, spalling, and loss of material caused by freeze-thaw, chemical attack, andreaction with aggregates. Hollow metal fire doors are visually inspected at least once bi-monthly for holes in the skin of the door. Fire door clearances are also checked atleast once bi-monthly as part of an inspection program. Function tests of fire doorsare performed daily, weekly, or monthly (which may be plant specific) to verify theoperability of automatic hold-open, release, closing mechanisms, and latches.The diesel-driven fire pump is under observation during performance tests such asflow and discharge tests, sequential starting capability tests, and controller function tests for detecting any degradation of the fuel supply line.Periodic visual inspection and function test at least once every six months examinesthe signs of degradation of the halon/carbon dioxide fire suppression system. Thesuppression agent charge pressure is monitored in the test. Material conditions thatmay affect the performance of the system, such as corrosion, mechanical damage,or damage to dampers, are observed during these tests. Inspections performed at least once every month verify that the extinguishing agent supply valves are openand the system is in automatic mode.
4.Detection of Aging Effects: Visual inspection of penetration seals detects cracking,seal separation from walls and components, and rupture and puncture of seals.Visual inspection (VT-1 or equivalent) of 10% of each type of seal in walkdowns isperformed at least once every refueling outage. If any sign of degradation is detectedwithin that 10%, the scope of the inspection and frequency is expanded to ensuretimely detection of increased hardness and shrinkage of the penetration seal beforethe loss of the component intended function. Visual inspection (VT-1 or equivalent) of the fire barrier walls, ceilings, and floors performed in walkdown at least once everyrefueling outage ensures timely detection for concrete cracking, spalling, and loss ofmaterial. Visual inspection (VT-3 or equivalent) detects any sign of degradation ofthe fire door such as wear and missing parts. Function tests promptly detectdeficiencies in operational conditions. Periodic visual inspection and function testsdetect degradation of the fire doors before there is a loss of intended function.Periodic tests performed at least once every refueling outage, such as flow anddischarge tests, sequential starting capability tests, and controller function testsperformed on diesel-driven fire pump ensure fuel supply line performance. Theperformance tests detect degradation of the fuel supply lines before the loss of thecomponent intended function.In the test of the halon/carbon dioxide fire suppression system, the suppressionagent charge pressure is verified to be within in the normal band. Visual inspection sof the halon/carbon dioxide fire suppression system detect s any sign of degradation,such as corrosion, mechanical damage, or damage to dampers. The periodicfunction test and inspection performed at least once every six months detectsdegradation of the halon/carbon dioxide fire suppression system before the loss ofthe component intended function. The monthly inspection ensures that theextinguishing agent supply valves are open and the system is in automatic mode.
5.Monitoring and Trending: The aging effects of weathering on fire barrierpenetration seals are detectable by visual inspection and, based on operatingexperience, visual inspections performed at least once every refueling outage todetect any sign of degradation of fire barrier penetration seals prior to loss of theintended function.Concrete cracking, spalling, and loss of material are detectable by visual inspectionand, based on operating experience, visual inspection performed at least once everyrefueling outage detects any sign of degradation of the fire barrier walls, ceilings, andfloors before there is a loss of the intended function. Wear, missing parts, or holes inthe fire door are detectable by visual inspection and, based on operating experience,the visual inspection and function test performed bi-monthly which detects degradation of the fire doors prior to loss of the intended function.The performance of the fire pump is monitored during the periodic test to detect anydegradation in the fuel supply lines. Periodic testing provides data (e.g., pressure) fortrending necessary. The performance of the halon/carbon dioxide fire suppression system is monitoredduring the periodic test to detect any degradation in the system. These periodic testsprovide data necessary for trending.
6.Acceptance Criteria: Inspection results are acceptable if there are no visualindications of cracking, separation of seals from walls and components, separation of layers of material, or ruptures or punctures of seals, no visual indications of concretecracking, spalling and loss of material of fire barrier walls, ceilings, and floors, novisual indications of missing parts, holes, and wear and no deficiencies in thefunctional tests of fire doors. No corrosion is acceptable in the fuel supply line for the diesel-driven fire pump. Also, any signs of corrosion and mechanical damage of thehalon/carbon dioxide fire suppression system are not acceptable.
7.Corrective Actions: For fire protection structures and components identified withinscope that are subject to an aging management review for license renewal, the applicant is to expand the scope of the 10 CFR Part 50, Appendix B, program toinclude these in-scope structures and components to address corrective actions, confirmation process, and administrative controls for aging management during theperiod of extended operation. This commitment is documented in the final safetyanalysis report (FSAR) supplement in accordance with 10 CFR 54.21(d). Asdiscussed in the appendix to this report, the staff finds the requirements of 10 CFRPart 50, Appendix B, acceptable to address corrective actions, confirmation process, and administrative controls.
8.Confirmation Process: See Item 7, above.
9.Administrative Controls: See Item 7, above.
10.Operating Experience: Silicone foam fire barrier penetration seals haveexperienced splits, shrinkage, voids, lack of fill, and other failure modes (IN 88-56, IN 94-28, and IN 97-70). Degradation of electrical racing way fire barrier such as smallholes, cracking, and unfilled seals are found on routine walkdown (IN 91-47 and GL 92-08). Fire doors have experienced wear of the hinges and handles. Operatingexperience with the use of this AMP has shown that no corrosion-related problemhas been reported for the fuel supply line, pump casing of the diesel-driven firepump, and the halon/carbon dioxide suppression system. No significant aging relatedproblems have been reported of fire protection systems, emergency breathing and auxiliary equipment, and communication equipment.ReferencesNRC Generic Letter 92-08, Thermo-Lag 330-1 Fire Barrier, December 17, 1992.NRC Information Notice 88-56, Potential Problems with Silicone Foam Fire BarrierPenetration Seals, August 14, 1988.NRC Information Notice 91-47, Failure of Thermo-Lag Fire Barrier Material to Pass FireEndurance Test, August 6, 1991.NRC Information Notice 94-28, Potential problems with Fire-Barrier Penetration Seals
,April 5, 1994. NRC Information Notice 97-70, Potential problems with Fire Barrier Penetration Seals
,September 19, 1997. XI.M27 FIRE WATER SYSTEMProgram DescriptionThis aging management program applies to water-based fire protection systems thatconsist of sprinklers, nozzles, fittings, valves, hydrants, hose stations, standpipes, waterstorage tanks, and aboveground and underground piping and components that aretested in accordance with the applicable National Fire Protection Association (NFPA)codes and standards. Such testing assures the minimum functionality of the systems.Also, these systems are normally maintained at required operating pressure and monitored such that loss of system pressure is immediately detected and correctiveactions initiated. In addition to NFPA codes and standards, which do not currentlycontain programs to manage aging, portions of the fire protection sprinkler system,which are not routinely subjected to flow, are to be subjected to full flow tests at themaximum design flow and pressure before the period of extended operation (and at notmore than 5-year intervals thereafter). In addition, a sample of sprinkler heads is to beinspected by using the guidance of NFPA 25, Section 2.3.3.1. This NFPA section statesthat "where sprinklers have been in place for 50 years, they shall be replaced orrepresentative samples from one or more sample areas shall be submitted to arecognized testing laboratory for field service testing." It also contains guidance toperform this sampling every 10 years after the initial field service testing. In addition toNFPA codes and standards, which do not currently contain programs to manage aging,portions of the fire protection sprinkler system that are not routinely subjected to flow areto be subjected to full flow tests at the maximum design flow and pressure before theperiod of extended operation (and at not more than 5-year intervals thereafter). Finally,portions of fire protection suppression piping located aboveground and that are exposedto water areshall be disassembled and visually inspected internally once every refuelingoutage non-intrusively inspected (e.g., ultrasonic testing) to ensure that corrosion agingeffects are managed and that wall thickness is within acceptable limits
. Theseinspections are performed before the end of the current operating term, after the 50-yearsprinkler head testing, and at 10-year intervals thereafter during the extended period ofoperation. The purpose of the full flow testing and internal visual inspections is to ensurethat corrosion, microbiological influenced corrosion (MIC), or biofouling aging effects aremanaged such that the system function is maintained.Evaluation and Technical Basis
1.Scope of Program:
The aging management program focuses on managing loss ofmaterial due to corrosion, MIC, or biofouling of carbon steel and cast-ironcomponents in fire protection systems exposed to water. Hose station s andstandpipe s are considered as piping in the AMP.
2.Preventive Actions:
To ensure no significant corrosion, MIC, or biofouling hasoccurred in water-based fire protection systems, periodic flushing, systemperformance testing, and inspections are conducted.
3.Parameters Monitored/Inspected: Loss of material due to corrosion and biofoulingcould reduce wall thickness of the fire protection piping system and result in systemfailure. Therefore, the parameters monitored are the system's ability to maintain pressure and internal system corrosion conditions. The NRC GL 89-13 recommends periodic flow testing of infrequently used loops of the fire water system at themaximum design flow to ensure that the system maintains its intended function.
4.Detection of Aging Effects:
Fire protection system testing is performed to assurerequired pressures. Internal i Inspections of aboveground fire protection piping andthe smaller diameter fire suppression piping are performed on system componentsusing non-intrusive techniques (e.g., ultrasonic testing) (when they are disassembled) to identify evidence of loss of material due to corrosion. Theseinspections are performed before the end of the current operating term, after the 50-year sprinkler head testing, and at 10 year intervals thereafter during the period ofextended operation.
As an alternative to non-intrusive testing, the work controlprocess may include a visual inspection of the internal surface of the fire protectionpiping upon each entry to the system for routine or corrective maintenance, as longas it can demonstrated that inspections are performed (based on past maintenancehistory) on a representative number of locations on a reasonable basis. Theseinspections must be cable of measuring (1) wall thickness to ensure againstcatastrophic failure and (2) the inner diameter of the piping as it applies to the flowrequirements of the fire protection system. If the environmental and materialcondition s that exist on the interior surface of the below grade fire protection pipingare similar to the conditions that exist within the above grade fire protection piping
,the results of the inspections of the above grade fire protection piping can beextrapolated to evaluate the condition of below grade fire protection piping. If not,additional inspection activities are needed to ensure that the intended function ofbelow grade fire protection piping will be maintained consistent with the currentlicensing basis for the period of extended operation. Repair and replacement actionsare initiated as necessary. Continuous system pressure monitoring, periodic systemflow testing performed, and interna l inspections of aboveground piping are effectivemeans to ensure that corrosion and biofouling are not occurring and the system'sintended function is maintained. In addition, general requirements of existing fireprotection programs include testing and maintenance of fire detection andsuppression systems and surveillance procedures to ensure that fire detectors, aswell as fire suppression systems and components, are operable.Visual inspection of yard fire hydrants performed once every six months ensurestimely detection of signs of degradation, such as corrosion. Fire hydrant hosehydrostatic tests, gasket inspections, and fire hydrant flow tests, performed annually,ensure that fire hydrants can perform their intended function and provide opportunities for degradation to be detected before a loss of intended function can occur.Sprinkler systems are inspected before the end of the current operating term, afterthe 50-year sprinkler head testing, and at 10-year intervals thereafter during theextended period of operationonce every refueling outage to ensure that signs ofdegradation, such as corrosion, are detected in a timely manner.
5.Monitoring and Trending:
System discharge pressure is monitored continuously.Results of system performance testing are monitored and trended as specified by the NFPA codes and standards. Degradation identified by non-intrusive or internalinspection is evaluated. 6.Acceptance Criteria: The acceptance criteria are (a) the ability of a fire protectionsystem to maintain required pressure, (b) no unacceptable signs of degradationobserved during non-intrusive or visual assessment of internal system conditions,and (c) that no biofouling exists in the sprinkler systems that could cause corrosion inthe sprinkler heads.
7.Corrective Actions: For fire water systems and components identified within scopethat are subject to an aging management review for license renewal, the applicant is to expand the scope of the 10 CFR Part 50, Appendix B, program to include these in-scope systems and components to address corrective actions, confirmation process, and administrative controls for aging management during the period of extendedoperation. As discussed in the appendix to this report, the staff finds therequirements of 10 CFR Part 50, Appendix B, acceptable to address correctiveactions, confirmation process, and administrative controls.8.Confirmation Process: See Item 7, above.9.Administrative Controls: See Item 7, above.
10.Operating Experience: Water-based fire protection systems designed, inspected,tested and maintained in accordance with the NFPA minimum standards havedemonstrated reliable performance.ReferencesNFPA 25: Inspection, Testing and Maintenance of Water-Based Fire ProtectionSystems, 1998 Edition.NRC Generic Letter 89-13, Service Water System Problems Affecting Safety-RelatedEquipment, July 18, 1989 Table 3.3-2. FSAR Supplement for Aging Management of Auxiliary Systems (continued)ProgramDescription of ProgramImplementationSchedule*Compressed air monitoring (BWR/PWR)The program consists of inspection, monitoring, and testingof the entire system, including (1) frequent leak testing valves, piping, and other system components, especially those made of carbon steel; and (2) preventive monitoringthat checks air quality at various locations in the system toensure that oil, water, rust, dirt, and other contaminants are kept within the specified limits. This program is in response to NRC GL 88-14 and INPO's Significant Operating Experience Report (SOER) 88-01. It also relies on theASME OM Guide Part 17, and ISA-S7.0.1-1996 as guidancefor testing and monitoring air quality and moisture.Existing programFire protection(BWR/PWR)The program includes a fire barrier inspection program and adiesel-driven fire pump inspection program. The fire barrier inspection program requires periodic visual inspection of firebarrier penetration seals, fire barrier walls, ceilings, andfloors, and periodic visual inspection and functional tests of fire rated doors to ensure that their operability is maintained.
The diesel-driven fire pump inspection program requires that the pump be periodically tested to ensure that the fuel supplyline can perform the intended function. The AMP alsoincludes periodic inspection and test of halon/carbon dioxidefire suppression system.Existing programFire water system(BWR/PWR)To ensure no fouling has occurred in the fire protectionsystem, periodic full flow flush test and system performance test are conducted to prevent corrosion from biofouling ofcomponents. Also, the system is normally maintained atrequired operating pressure and is monitored such that loss of system pressure is immediately detected and corrective actions initiated. The AMP relies on testing of water based fire protection system piping and components in accordancewith applicable NFPA commitments. In addition, thisprogram will be modified to included (1) portions of the fire protection sprinkler system that are subjected to full flow tests prior to the period of extended operation and (2) portions of the fire protection system exposed to water are internally visually or ultrasonically inspected.Program should bemodified before the period of extended operationFuel oil chemistry (BWR/PWR)The AMP relies on a combination of surveillance andmaintenance procedures. Monitoring and controlling fuel oil contamination in accordance with the guidelines of ASTM Standards D1796, D2276, D2709, and D4057, maintains the fuel oil quality. Exposure to fuel oil contaminants such aswater and microbiological organisms is minimized byperiodic cleaning/draining of tanks and by verifying the quality of new oil before its introduction into the storage tanks.Existing program