ML20141J581

Forwards Response to Open Items Identified During Fire Protection Program Site Audit & Swri Repts, ASTM E152-81 Std Methods of Fire Tests... & ASTM E119-83 Std Methods of Fire..., Supporting Fire Protection Provisions

ML20141J581
Person / Time
Site:	Seabrook
Issue date:	04/24/1986
From:	Devincentis J PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To:	Noonan V Office of Nuclear Reactor Regulation
Shared Package
ML20141J584	List: ML20141J581 ML20141J587 ML20141J593
References
SBN-1017, NUDOCS 8604280225
Download: ML20141J581 (13)

Text

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• SEABROOK STATION Engineering Office April 24 1986 Pub 5c Service of New Hampshbe SBN- 1017 T.F. B7.1.2 Now Hampshire Yankee Divleien United States Nuclear Regulatory Commission Washington, DC 20555 Attention: Mr. Vincent S. Noonan, Project Director Phi Project Directorate No. 5

References:

(a) Construction Permits CPPR-135 and CPPR-136, Docket Nos. 50-443 and 50-444 l (b) USNRC Letter dated April 4,19'16, " Trip Report: Fire Protection Site Audit - Seabrook Station Unit 1," V.

Nerses to R. J. Ilarrison l

Subject:

Fire Protection Site Audit; Response to Open Items

Dear Sir:

As indicated in Reference (b), during the site audit, the Staff identified several concerns regarding our fire protection program (e.g., l justification for particular fire protection provisions), which could not he i closed out during the audit because of the type of question asked or ita l complexity. Our response to these concerns is provided herewith as (

Attachment 1.  !

Pursuant to the Staff's request and as indicated in Attachment 1, we have

, also provided herewith the following reports in support of our justification for particular fire protection provisions, o Southwest Research Institute (SWRI) Report for Sh11 Project No. 01-8821-012 dated April 1986.

o SWRI Report for SWRI Project No. 01-8821-012a, dated March 1986.

We trust that the enclosed information satisfactorily addresnes the concern of the Staff and request that the acceptability of the enclosed be reflected in the upcoming supplement to Seabrook's SER.

Very truly ours, 8604280223 860424 3 /

DR ADOCK 0500 j j John DeVincentis, Director \

Engineering and Licensing  !

Attachmen t cc: Atomic Safety and Licensing Board Service List P.O. Box 300 . Soobrook, NH 03874 Totophone (603) 474-9521

SBN- 1017 ATTACHMENT 1 QUESTION NO. 1 Composite sheet rock steel barriers are serving as fire barriers in several plant areas. Fire test results were not available during the audit to substantiate the fire resistance rating of the barrier design (Section C.S.a of BIP (MEB 9.5.1)).

RESPONSE

A test specimen was constructed and both sides tested by a recognized test lab to ASTM E119-83, " Standard Methods of Fire Tests of Building Construction and Materials." Both the exposed steel face and the smooth face of the metal siding partition wall assembly successfully withstood the ASTM E-119-83 fire exposure test for 180 minutes. Only the smooth face successfully resisted the standard hose stream test without developing any openings. The exposed steel face, when subjected to the standard hose stream test was penetrated by the stream, allowing some direct passage of water through the wall system. The hose stream penetrated a small section of the wall system between the vertical edge channel and the concrete block of the test frame through the Pyrocrete-filled gap. The details of the wall assembly which allowed direct passage of water as shown by this have been modified with UL approved flashing details. No further testing is required.

The exposed steel face during testing leaked water in addition to direct passage as described in ASTM E-119-83. An evaluation of the locations of the composite sheet rock steel barriers was made and the affect of water leakage (not direct passage) through the barriers were made. The leakage was determined acceptable since safe shutdown is not compromised.

QUESTION NO. 2 A number of fire barrier penetrations, including bus duct penetrations and seismic gaps, are not protected by penetration seal designs qualified by fire test (Section C-5.a of BTP CMEB 9.5-1).

RESPONSE

All fire barrier penetrations and seismic gaps (see enclosed detail - Bisco Drawing No. S-33) have been approved by the ANI except those deviations submitted in SBM-970, Attachment 1, exemption Section III.n. No further deviations are expected in this area.

QUESTION No. 3 A number of door assemblies installed in fire barriers are not labeled by a nationally recognized testing laboratory (Section C.S.a(5) of BTP CMEB 9.5-1).

RESPONSE

A number of deviations to not labeled door assemblies have been submitted per SBN-932, Attachment 2, Items 8 and 11 and SBN-904, Attachment A, Items 5, 6, and 7.

SBN- 1017 ATTACHMENT 1 (continued)

Item 8 of SBN-932 was tested by a recognized test laboratory. (See enclosed Report SWRI Project No. 01-8821-012a ) .

The single swinging steel door assembly, No. EM41B, per UE&C Specification 9763.006-24-13, tested and remained in place without developing any openings and without undue warpage throughout a fire exposure period of 180 minutes and a standard hose stream exposure. The door, therefore, when tested in accordance with ASTM E152-81, Standard Methods of Fire Tests of Door Assemblies, achieved a fire resistance rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.

QUESTION NO. 4 Structural steel forming a part of or supporting a number of fire barriers is not protected to provide fire resistance equivalent to that required of the barrier (Section C.5.6.(2) (a) of BTP CMEB 9.5-1).

RESPONSE

A deviation is requested from the Requirement 10CFR50, Appendix R, III.G.a,

" Structural steel forming a part of or supporting such fire barriers shall be protected to provide fire resistance equivalent to that required of the barrier," for the following fire areas listed in Table 1.

Professional Loss Control., Inc. (PLC) conducted a Seabrook Structural Steel Survivability Analysis for those areas noted in Table 1. Wherever PLC indicated structural steel needed to be fire proofed, a structural integrity review was conducted on the fire areas as indicated by PLC temperatures. In most cases, the structure can withstand the potential loss of structural steel. No fireproofing will be done on these beams and/or columns. A few limited caser, some steel was fireproofed in a fire area but only steel indicated by PLC and needed to maintain the fire areas structure.

QUESTION NO. 5 Charcoal filters are not protected in accordance with the guidelines of Regulatory Guide 1.52 (Section C.S.f.(4) of BTM CMEB 9.5-1).

RESPONSE

A deviation was requested in SBN-970, Attachment 2, Deviation 13.

QUESTION NO. 6 By letter dated April 1,1982, the applicant submitted its comparison to Appendix R to 10CFR50. During the audit, the applicant informed the staf f that in view of continued program development, this comparison was outdated.

The applicant agreed to revise the comparison to reflect the plant.

RESPONSE

The comparison was revised and submitted in SBN-970, Attachment 1.

t l

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l SBN-1017 l ATTACHMENT 1 I

(continued)

! QUESTION NO. 7 Many of the details cf the fire protection features observed in the plant were 7 not as documented in the Seabrook Station SER. The ' applicant attributed this j to errors in the SER and agreed to identify all such errors to the staff.

i

RESPONSE

, This issue has been discussed with NRR by the Seabrook Project Office in l Bethesda. [

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i ATTACHMENT 1 SBN- 1017

.(Continued)

TABLE 1 Structural Steel Fireproofing Analysis Chart PLC Analysis of Area Shows Only Limited j Fireproofing of Structural PLC Analysis of Area Steel is Needed PLC Analysis of Area Shows Only Limited UFAC Han Determined Fire Shows no Structural Fireproofing of Structural Structural Can Accept ~ Miscellaneous

! Area / Zone Steel Fireproof Required Steel is Needed Steel Losses Notes ,_

EFP-F-1-A X MS-F-1A-Z X 1

MS-F-1B-Z X i I MS-F-2A-Z Does not contain exposed MS-F-2B-Z combustibles. Low Loading.

i MS-F-3A-Z X l

MS-F-3B-Z Does not contain exposed f

i combustibles. Low Loading.

1

! MS-F-4 A-Z X i

MS-F-5A-Z Exposed steel used for cable tray supports.

, Concrete slab is self-supporting.

1 9 v

i 1

ATTACHMENT 1 SBN- 1017 (continued)

TABLE 1 Structural Steel Fireproofing Analysis Chart PLC Analysis of Aree- I Shows Only-Limited Fireproofing of Structural .

l PLC Analysis of Area Steel is Needed  :

PLC Analysis of Area Shown Only Limited UE&C Han Determined l Fire Shows no Structural Fireproofing of Structural Structural Can Accept Miscellaneous- l Area / Zone Steel Fireproof Required Steel la Needed Steel Lossen Notes RHR-F-1A-Z X RHR-F-1B-Z X RHR-F-1C-Z X RHR-F-ID-7 X RHR-F-2A-Z X RHR-F-2B-Z X RHR-F-3 A-Z X RHR-F-3B-Z X CB-F-3B-A X CB-F-SI-O Does not contain exposed CB-F-S2-0 combustibles. Low loading.

EI-F-1A-A Slab is self-supporting.

ET-F-1B-A Do not need structure steel.

- ET-F-lC-A ET-F-1D-A

~ 'ET-F-SI-0

ATTACHMENT 1 SBN- 1017 (continued) ]

l TABLE I Structural Steel Fireproofing Analysis Chart PLC Analysis of Area Shows Only Limited Fireproofing of Structural PLC Analysis of Area Steel is Needed PLC Analysis of Area Shove Only Limited UE&C Has Determined Fire shows no Structural Fireproofing of Structural Structural Can Accept Miscellaneous Area / Zone Steel Fireproof Required Steel is Needed Steel Losses Notes DG-F-3A-Z X DG-F-3 B-Z X DG-F-3E-A X DG-F-3F-A X PAB-F-1A-Z X PAB-F-1 B-Z X PAB-F-IF-Z X PAB-F-11G-A-A X PAB-F-SI-0 Does not contain exposed PAB-F-S2-0 combustibles. Low loading.

PAB-F-2A-Z X PAB-F-2 B-Z X l PAB-F-2C-Z X PAB-F-3A-Z X PAB-F-3B-Z X l PAB-F-4-Z X PAB-F-1J-Z X

- -- - - - - o

ATTACHMENT 1 S3N- 1017 (continued)

TABLE 1

' Structural Steel Fireproofing Analysis Chart PLC Analysis of Area Shows Only Limited Fireproofing of Structural PLC Analysis of Area Steel is Needed PLC Analysis of Area Shows Only Limited UE&C Has Determined Fire Shows no Structural Fireproofing of Structural Structural Can Accept Miscellaneous Area / Zone Steel Fireproof Required Steel is Needed Steel Losses Notes PAB-F-1K-Z Does not contain exposed combustibles. Low loading.

FSB-F-1A X SW-F-1A-Z Structure is separated from fire area used for safe shutdown by seismic gap. Can accept loss of structure.

SW' F-1B-A Loss of this structure does SW-F-IC-A not affect safe shutdown.

SW-F-l D-A Structure is isolated from SW-F-lE-Z remaining fire areas.

SW-F-2-0 1

l l _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _

~

ATTACHMENT 1 SBN- 1017 (continued)

TABLE 1 Structural Steel Fireproofing Analysis Chart PLC Analysis of Area Showc Only Limited Fireproofing of Structural PLC Analysis of Area Steel is Needed PLC Analysis of Area Shows Only Limited UE&C Has Determined Fire Shows no Structural Fireproofing of Structural Structural Can Accept Miscellaneous Area / Zone Steel Fireproof Required Steel is Needed Steel Lossen Notes CT-F-1A-A Loss of this structure does CT-F-1 B-A not affect safe shutdown.

CT-F-1C-A Structure is isolated from CT-F-ID-A remaining fire areas.

CT-F-2A-A CT-F-2B-A CT-F-3-0 CE-F-1-A X FPH-F-1A-A loss of this structure does FPH-F-1B-A not affect safe shutdown.

FPH-F-lC-A Structure is isolated from remaining fire areas.

1 ATTACHMENT 1 SBN- 1017 (continued)

TABLE 1 Structural Steel Fireproofing Analysis Chart PLC Analysis of Area Shows Only Limited Fireproofing of Structural PLC Analysis of Area Steel is Needed PLC Analysis of Area Shows Only Limited UE&C !!as Determined Fire Shows no Structural Fireproofing of Structural Structural Can Accept Miscellaneous Area / Zone Steel Fireproof Required Steel in Needed Steel Losses Notes TB-F-1B-A Loss of this structure does TB-F-1A-Z not affect safe shutdown.

T B-F-1C-Z Structure is isolated from TB-F-2-Z fire atess used during safe TB-F-3-Z shutdewn by seismic gap.

NES-F-1A-A Loss of this structure does not affect safe shutdown. Structure is isolated from fire areas used during safe shutdown by seismic gap.

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CONCRETE WALL DLOCK WALL NOTES

• DEC 2 71985

1. BISCO Field Engineer shall originate SEABROOK STATI0o, specific details illustrating field conditions.

2. Roto-Foam within gaps must be totally '

removed, or a 3-hour fire rated seal must be installed on both sides,to a TYPICAL INSTALLATION depth of 6 inches. i

3. k'here only sealing one side. a BISCO SE-Foam ##*"## b seal yith a depth of 7 " is required. #'te: 9/23/84 U E 3-IIOUR FIRE P2TED. GAP SEAL BISCO (IIORIzONTAL OR VERTICAL) g sex wr em ,z . ,z. 35 ,

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/2. IL f( brand indus trust s.nke s, ;nC. to g. no.

E410 renatssance drive Rev. Description Ency. Appl. Date O.C. Appl. Date par 4'rease. E 6@6s S-33 ,

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BISCO SEALANT MATERIALS PAFR4ETERS MAIERIAL SE-FOAM D

_EPTH 7 " k TEST NO.

FIRE RATING 3-Hour BARRIER 748-134/1025-07 Floor Yes 748-134/1025-07 Wall _ Yes BARRIER CONSTRUCTION 748-134/1025-07 Concrete or Block ,48-134/1025-07 PENETRATION Metal Lined Yes 748-134/1025-07 Clear Opening Yes Egoxy Coated 748-134/1025-07 No N/A MAXIMUM PENETRATION SIZE Round N/A .

N/A Square 4%" wide max.

748-134/1025-07 MAXIMUM FRSE AREA N/A N/A MINIMUM CLEARANCE N/A . N/A CABLE TRAY CONSTRUCTION N/A N/A CABLE COMPOSITION N/A N/A MAXIMUM MECHANICAL PENETRANT SIZE N/A N/A AIR PRESSURE LEA *< AGE AT " W.C. Zero 748-150 MAXIMUM PRESSURE RESISTANCE Zero Leakage ,

2 psi 748-150 With Leakage 3.0 psi w/128.0 SCFH Leakage 748-150 RADIATION RESISTANCE 1.04 x 108 RADS M-215 TEMPERATURE LIMITATIONS -500F to + 4250F M-215/Dow Spec.

MAXIMUM ALLOWABLE PENETRANT MOVEMENT Lateral N/A .- N/A Axial N/A N/A NOTES:

b, Roto-Foamwithingapsmustbetatallyremoved, ora 3-hourfire rated seal must be installed on both sides, to a depth of 6 inches.

RECEWED UE&C DEC 2 71985 SEABROOK STAT l0F EEh5Eb SE4L buTaj l **' Y'"'" Y Yl6S h I z n -g( DETAIL NO O OEIGmk AS Rev. Description

?/x/c- kQ im45 s-33 Eng. Appl. Date O.C. Appl. Date ,

=

Diane Curran Esquire Calvin A. Canney Harmon & Weiss City Manager 2001 S. Street, N.W. City Hall Suite 430 126 Daniel Street Washington, D.C. 20009 Portsmouth, NH 03801 Sherwin E. Turk Esq. Stephen E. Merrill, Esquire Office of the Executive Legal Director Attorney General U.S. Nuclear Regulatory Commission George Dana Bisbee, Esquire Tenth Floor Assistant Attorney General Washington, DC 20555 Office of the Attorney General 25 Capitol Street Robert A. Backus Esquire Concord, NH 03301-6397 116 Lowell Street P.O. Box 516 Mr. J. P. Nadeau Manchester, NH 03105 Selectmen's Office 10 Central Road Philip Ahrens, Esquire Rye, NH 03870 Assistant Attorney General Department of The Attorney General Mr. Angie Machiros Statehouse Station #6 Chairman of the Board of Selectmen Augusta, NE 04333 Town of Newbury Newbury, MA 01950 Mrs. Sandra Gavutis Chairman, Board of Salectmen Mr. William S. Lord RFD 1 - Box 1154 Board of Selectmen Kennsington, NH 03827 Town Hall - Friend Street Amesbury, MA 01913 Carol S. Sneider, Esquire Assistant Attorney General Senator Gordon J. Humphrey Department of the Attorney General 1 Pillsbury Street One Ashburton Place, 19th Floor Concord, NH 03301 Boston, MA 02108 (ATTN: Herb Boynton)

Senator Gordon J. Humphrey H. Joseph Flynn, Esquire U.S. Senate Office of General Counsel Washington, DC 20510 Federal Emergency Management Agency (ATTN: Tom Burack) 500 C Street, SW Washington, DC 20472 Richard A. Hampe Esq.

Hampe and McNicholas Paul McEachern, Esquire 35 Pleasant Street Matthew T. Brock, Esquire Concord, NH 03301 Shaines & McEachern 25 Maplewood Avenue Donald E. Chick P.O. Box 360 Town Manager Portsmouth, NH 03801 Town of Exeter 10 Front Street Gary W. Holmes, Esq.

Exeter, NH 03833 Holmes & Ells t 47 Winnacunnet Road Brentwood Board of Selectmen Hampton, NH 03841 RFD Dalton Road Brentwood, NH 03833 Mr. Ed Thomas FEMA Region I Peter J. Mathews, Mayor 442 John W. McCormack PO & Courthouse City Hall Boston, MA 02109 Newburyport, MA 01950 Stanley W. Knowles, Chairman Board of Selectmen P.O. Box 710

_ North Hampton, NH 03862