ML20023C351
| ML20023C351 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 01/21/1983 |
| From: | Fay C WISCONSIN ELECTRIC POWER CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20023C343 | List: |
| References | |
| NUDOCS 8305170252 | |
| Download: ML20023C351 (42) | |
Text
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Wisconsin Electnc roara couraur 231 W. MICHIGAN, P.O. BOX 2046, MILWAUKEE, WI 53201 January 21, 1983 Mr. J. G. Keppler, Regional Administrator Office of Inspection and Enforcement, Region III U. S. NUCLEAR REGULATORY COMMISSION -
799 Roosevelt Road Glen Ellyn, Illinois 60137
Dear Mr. Keppler:
DOCKET NOS. 50-266 AND 50-301 REPLY TO INSPECTION REPORT NOS. 50-266/82-17 AND 50-301/82-17 POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 Enclosed is our response to Inspection Report Nos.
50-266/82-17 and 50-301/82-17 which were forwarded by letter dated November 30, 1982.
As noted in the attached discussion of each item, we disagree with some of the findings and provide the basis for our position. We concur with some Items of Noncompliance; for these items we have stated corrective action to be taken, corrective steps taken to avoid further items of noncompliance, and dates when action will be completed. In addition, we plan to undertake further action in areas where we believe violations or neucompliances did not occur but where such actions would enhance our fire protection I
program. ,
Some of the findings appear to result from the inability to produce documentation at the time of the ipspection which was subsequently determined to be available. We are taking action related to the management of the fire prot 6? tion program in the plant which we believe will minimize such problems in the future.
Very truly yours, C
C 0305170252 030509 b'b# /
A PDR ADOCK 05000266 / hf' G PDR Vice President-Nuclear Power C. W. Fay Enclosures J AN 241983 Copy to NRC Resident Inspector
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RESPONCE TO INSPEChIC'N ' REPORT NOS.
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50-266/82-17 (DETP) AND 50-301/82-17 (DETP) u
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^- Violation 1, Item a (1)
Noncompliance 2.b(1) (82-17-OlA, Fire Pump Testing)_
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, We do not agree with the NRC opinion that Violation 1,
- Item a (1) , ,is a violation of Technical Specification 15.4.15 or 10 CFR 50, Appendix B, Criterion XI. With respect to Noncompliance B2-17-OlA,,we do not concur with the NRC opinion that our tests [have,not $4t National Fire Protection. Association (NFPA) standards. Furthfri we' foel the test results indicate adequate pump performance rather than mechanical malfunction.
' Technical Specificationitest TS-19, " Annual Fire Pump Capacity Test", does not need to measure the performance parameters stated in Violation 1, Item a (1) , or Noncompliance 82-17-OlA to comply with the NFPA standards for annual performance testing.
NFPA (1976), Chapter 11, Section 6.2, entitled " Field Acceptance Test", state [ in part "Upon co6pletion of the entire fire pump
- installation, an operating test shall be made...All applicable provisions of 12-1 shall be followed." NFPA (1976), Chapter 12, Section 1, is entitled " Field Acceptance Test". This term is understood to mean,a test performed following initial installation of a pump to ensure.acceptpbility. Our understanding is reinforced by NFPA'20 (1976), Chapter 12, Section 11, which states "The pump manufactur,er shall have an engineer present at the field acceptance'y.ests when requested by the installing contractor."
Additional $6hstantiayion of the intent of Field Acceptance Test is obtained from~NFPA 20 (1980), Chapter 11, Section 2.1, '
which states ",The acceptance test of the pump installation shall be,the responsibility of the installing contractor. Field acceptance test of the entire fire pump assembly shall be Terformed by the pump manufacturer or his qualified representative prtor s to acceptance of the installationsby the' owner." The licensee agrees that all the pump operating parameters' discussed in Noncompliance 82-17-OlA are applicable to the' Field Acceptance Test, however, the licensee does not agree that all these performance test parameters need apply to periodic performance tests performed on a routine basis. ,
The intent of our annual test has been to demonstrate pump capacities are acceptable. Thus, we believe that the~ appropriate code is NFPA 20 (1976), Chapter 12, Section 3.1, entitled
"# '"Ytarly Test". It does not state any specific test performance parameters to be obtained except "A yearly test shall be made
- at full capacity and over to make sure neither pump nor suction pipp is Oostructed." NFPA 20 (1980) ,xChaptgr 11, Section 3.1, under the title " Annual Fire Pump Tests", States "An annual test of the fire pump assembly shall be performed to determine its ability to continue to attain satisfactory performance at p'eak loads."
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It appears that the NRC may be applying the Field Acceptance Test requirement in this violation rather than the more appropriate annual test requirement.
Included in Attachment 2 are pump curves for the plant fire pumps. These curves show the manufacturer's curves, ASME Section XI pump performance limits (using the manufacturer's curves as baseline), and actual test data for 1978, 1979, 1980, 1981, and 1982. Of the 36 data points taken, only three fell outside the ASME limits and in directions which indicate no particular trend. Significant indication does not exist to suspect mechanical malfunction of the fire pumps or to believe they would not perform at 150% rated capacity.
We wish to point out that our pump capacity test, as presently performed, utilizes our fire system test facilities to their maximum capacity. It is impossible to generate test flows greater than those now attained with our existing test facilities. In addition, our highest flow test points are greater than the largest single expected fire flow given in the Fire Hazards Analysis.
CORRECTIVE ACTION / ACTION TO PREVENT RECURRENCE Although we believe test TS-19 to be adequate, we will revise the test to include additional performance data. This is consistant with our policy to make changes which we believe will enhance our operation. Additional data to be collected will be measured suction lift, diesel pump shutoff pressure, diesel engine speed, and electric pump motor current draw.
An additional section specifying proper analysis techniques will be included. Appropriate changes to TS-19 will be made by January 31, 1983.
Noncompliance 2.b (2) (82-17-OlB, Fire Signalling System Testing)
We acknowledge that TS-7 (Monthly Diesel Fire Pump Functional' Test) , TS-17 (Annual Testing of Diesel Room Sprinkler Valves),
TS-19 (Annual Fire Fire Pump Capacity Test), and TS-26 (Fire Main Flow Test) do not explicitly incorporate documented
, verification of alarm annunciation.
We disagree, however, with an interpretation of 10 CFR 50, Appendix B, Criterion XI, that it is always required to test annunciation actuation. Criterion XI states in part "A test program shall be established to assure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service..." For systems and ecuipment whose singular intent is to generate alarms then, of course, alarm annuniciation must be verified. However, for systems and equipment which generate alarm annunciation subsequent to
actuation and which are of an informational nature, then the generation of the alarm does not impact the satisfactory or unsatisfactory performance of the system or equipment to carry out its intended function.
An example may best illustrate our position. The re' quired performance of a smoke detector system is to generate an alarm. An operability test is then one which verifies the generation and receipt of alarms. A sprinkler system, on the other hand, would have the required performance to deliver water. Operability of the sprinkler system would be demonstrated by valve position and satisfactory nozzles appearance. The generation of a flow alarm, or the failure to do so, does not affect system performance in any manner.
For Point Beach Nuclear Plant systems where alarm annunciation is a part of operability assessment, alarm verification is being done as part of the operability test.
CORRECTIVE ACTION / ACTION REQUIRED TO PREVENT RECURRENCE A review of our fire protection tests will be done to identify informational alarms. Where informational alarms exist and can be expediently tested these alarms will be verified. This review will be complete by April 30, 1983.
Violation 1, Item a(2)
Noncompliance 2.b (3) (82-17-OlC, Fire Detection System Testing)
(a) Verification of Control Room Alarm The acceptance criteria for TS-16 is stated in the discussion section. To be specific, Section 1.0 reads in part "This should cause an alarm in the control room (emphasis added) and when the can is removed, the neon light on the smoke detector should be lit."
TS-16, Revision 1, contains a blank for initials following each detector location. This blank would be initialed upon satisfactcry testing of the detector. Unsatisfactory detector performance would result in no signature / initial and a note in the " Remarks" section.
Consequently, we disagree with the NRC finding that our procedure TS-16 did not include demonstration of the control rocn annunciation.
s (b) Verification of Local Zone Indicating Unit Alarm Annunciation This statement is confusing because the tests which were audited during the inspection did not apply to a local zone configuration smoke detector system; as such, no local alarm annunciation was involved. The closest approximation to local annunciation was a small red indicating light on each detector. This was verified operable during the test by an appropriate initial for each detector. The acceptance criteria are stated in the " Discussion" section, it being
...the neon light on the smoke detector should be lit."
It is our speculation that the NRC inspectors were visualizing, in their minds, the other fire detection system being installed (which does have zones) rather than the system for which the procedures that they were reviewing were written.
(c) Testing of Detector Sensitivity The detectors were tested on a periodic basis using freon.
We agree that our test method did not adequately test detector sensitivity.
(d) Testing of Supervisory Circuitry Between the Control Room and the Zone Indicating Units or Between the Zone Indicating Units and the Detector Transmitter As previously stated, there were no zone indicating units on the detection system, thus, none could be tested. The supervisory circuit was tested at the time of each detector functional test. The alarm and supervisory wiring was common from the detector unit into the central alarm panel located in the control room. The separation of alarm and supervisory circuits took place in control at the central detector panel. A main control board alarm window was unique to the trouble circuit. It is the practice at Point Beach to note the failure to receive such an alarm when testing is in progress. Thus, the supervisory circuit was tested during each alarm test and verification consisted of noting the failure to receive an expected annunciator.
CORRECTIVE ACTION / ACTION TO PREVENT RECURRENCE The smoke detector system now in operation is a fixed sensitivity photoelectric detector system which utilizes local zone panels and an indicating panel in the control room. Functional testing of this system will meet appropriate applicable NFPA standards.
Detector sensitivity testing of this system is not required.
Violation 1, Item a(3)
Operability Surveillance Testing / Inspection Procedure for Fire Doors This finding states that there was "no surveillance testing inspection procedure established to assure operability of fire doors protecting safety-related areas". We note that Technical Specification 15.4.15.E requires a visual inspection of fire barrier penetration fire seals; fire barriers, including fire doors, have been inspected on the frequency specified in the Technical Specification. These inspections have been appropriately documented.
CORRECTIVE ACTION / ACTION TO PREVENT RECURRENCE In order to enhance our fire protection program, we have prepared a semiannual maintenance surveillance procedure (PC-70, Part I) to assure safe shutdown area fire door operability. This procedure documents a check for the defeat of the hold-open feature, verifies proper latch and -
closer operation, performs a general door hardware inspection, verifies freedom of operation, and also verifies any associated computer alarms.
Surveillance procedure (PC-70, Part Il also states " Operations personnel should lubricate or perform minor repairs to upkeep doors during performance of this periodic checklist. Should maintenance beyond the scope of Operations be required, a maintenance request should be submitted and noted."
Violation 1, Item b Noncompliance 2.b(4) (82-17-OlD, Test Acceptance Criteria)
We believe the NRC finding to be incorrect in stating that "no acceptance criteria" exists for many of our Technical Specification required tests. We acknowledge that some acceptance criteria were not explicitly stated in the procedure body but these are exceptions to the norm. .In addition, for tests where engineering review of test data was required to determine acceptable performance or operability, these reviews were performed and results documented.
At Point Beach, an individual's initials following the action steps of procedures are accepted as satisfactory indication that the procedural step was successfully completed. For example, the first step in TS-7, " Monthly Diesel Fire Pump Functional Test", states " Check oil level between "H" and "L" on dipstick." An operator's initials in the appropriately
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identified blank indicates appropriate completion of the procedural step, thereby successfully demonstrating an operationally acceptable level of oil in the diesel engine.
We feel some of the misunderstanding may be due to the fact that, in many of the cases, acceptance criteria are not extremely obvious but are included in the test as action steps.
However, this is a question of style of test preparation, not a lack of acceptance criteria. Test data were reviewed in cases where equipment performance or operability had to be determined, and documentation of such reviews are represented by the Fire Protection Supervisor review initial on the procedure itself.
Also, the Point Beach approach to acceptable test performance has been one of exception. Normal or expected conditions or results may not be identified in any special way whereas unsatisfactory or off-normal conditions are explicitly identified.
To address the specific tests of Noncompliance 82-17-OlD the following is presented:
- a. TS-7 (Monthly Diesel Fire Pump Functional Test)
In order to fulfill the NFPA 20 (1980) and Technical Specification 15.4.15 requirements, 12 parameters must be measured and fall within specific limits. All 12 are checked or measured in the test. Of these 12, eight have acceptance criteria stated. For example: Initials
- 10. Oil pressure should be between 30 psig and 70 psig. psig Water temperature should be between 140*F and 17 F. F
- 2. Check water level between cap and 1-1/2" below cap.
- b. TS-13 (Monthly Fire Equipment Surveillance We would like to point out that only certain portions of this test involve surveillance testing of Technical Specification required equipment which is conspicuously identified on the test procedure by double asterisks. Only these hose reels need to conform to Technical Specification surveillance standards. The equipment which is Technical Specification related are certain hose reel stations and an example of the surveillance criteria is shown below.
Please note that four of the five items listed have acceptance criteria stated implictly if not explictly.
TS-13 Page 2 CONDITIONS NORMAL INITIALS
- HR-47 FP-246 shut Hose in place Cover installed Nozzel shut Condition
- c. TS-16 (Bimonthly Fire Detector Testing)
The discussion section of TS-16 states "This should cause an alarm in the control room and when the can is removed, the neon light on the smoke detector should be lit."
Page 4 The sign-off section consists of:
Room Protected Location of Detector Signature Date for each Technical Specification required detector. We believe the discussion section states the expected action and I
a signature verifies the expected action has occurred.
- d. TS-17 (Annual Testing of Diesel Room Sprinkler Valves) l l We believe that, upon understanding the Point Beach system of j
procedure performance, the acceptance criteria for TS-17 is very explicit. As stated before, the practice at Point Beach has been to identify unacceptable performance. When acceptable performance is achieved it is indicated by exception, i.e., no comment and in most cases initials or l signatures are used to indicate completion of a procedural step.
Because of system changes, TS-17 no longer exists in the
, format it did at the time of the NRC audit. However, to
! clarify our point, we have included portions of the test
! as it previously existed.
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i 1.0 PURPOSE 1.1 Verify operability of motor-operated valves supplying sprinklers in the emergency diesel rooms.
1.2 Inspect for system integrity in sprinkler system for the emergency diesel rooms.
2.0 PROCEDURE 2.3 Give MOV-3742 an open signal.
2.3.1 Ensure MOV-3742 travels full open.
2.3.2 Close MOV-3742.
2.6 Inspect sprinkler piping and nozzles. Observe for the following:
2.6.1 Observe for structural integrity, i.e.,
no physical damage, hangers intact, etc.
of all the sprinkler piping.
Piping OK 2.6.2 Observe all nozzles for plugging.
Nozzles OK
- e. TS-19 (Annual Fire Pump Capacity Test)
Appendix "B" of 10 CFR 50 is not solely the QA program which governs Point Beach. The NRC has accepted the Point Beach QA program found in Section 1 of the FSAR which incorporates QA philosophy in addition to that of Appendix "B" of 10 CFR 50.
The test in question does not have any stated acceptance criteria because it is written utilizing the philosophy of Section 1.8.5 of the Point Beach Nuclear Plant FSAR which states " Supervisors may direct that data be gaken without the data taker being congnizant of the acceptance criteria when it is considered that forehand knowledge of the acceptance criteria may prejudice results. The supervisor is then responsible to verify conformance."
Acceptable performance of the fire pumps was documented in a memorandum dated July 10, 1981 following the reduction and analysis of test data. Thus, we believe test results have been evaluated to assure equipment operability and that this evaluation and operability have been documented.
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- f. TS-20 (Annual Fire System Automatic System Valve Actuation)
Selected portions of TS-20 are included below; they demonstrate that acceptance criteria are included in the test.
1.0 PURPOSE 1.1 To ensure that the automatic fire protection valves function properly.
1.2 To ensure that appropriate alarms are received.
2.0 TEST REQUIREMENTS 2.1 Actuation alarms are received when valves operate.
2.2 A trouble alarm is received when air pressure is low.
2.3 Deluge valves trip within 45 seconds of having heat applied to the HAD. Do not keep heat lamp on HAD longer than 45 seconds.
2.4 Deluge valves trip when the remote actuation switch is operated in the control room.
2.5 Deluge valves trip when the manual "T" handle is pulled.
8.0 TEST PROCEDURE Initials 8.1 #1 & #2 Warehouse #1 #2 8.1.1 Open the test valve in the north end of the building about 15' above the floor.
8.1.2 Log the pressure at which the automatic valve opened.
8.1.3 Log elapsed time since opening the test valve.
8.1.4 Actuation alarm.
8.1.5 Close the test valve.
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8.1.6 Close the post indicator valve to the warehouse and drain the I system. Reset the automatic valve and open the post indicator
,, valve. ._
8.1.7 Test #1 warehouse. Sat. Unsat.
8.1.8 Test #2 warehouse. Sat. Unsat.
8.4 Fuel Oil Tank East DV-3728 CAUTION: ASSURE THAT THE MANUAL ISOLATION VALVE IS CLOSED (FP-134).
8.4.1 Pull the manual trip handle and note the actuation alarm.
8.4.2 Reset the weight only.
> 8.4.3 Apply heat to the test HAD along side the tank. Measure and log the elapsed time. Remove heat. Turn off lamp.
Time 8.4.4 Reset the weight.
8.4.5 Operate the switch in the control room for DV-3728, fuel oil tank east and return the switch to normal. Note operation.
8.4.6 Loosen a plug in the HAD system junction block. Note the trouble alarms received.
8.4.7 Remote Light Horn 8.4.8 Tighten the plug.
8.4.9 Relatch the valve and reset the weight as soon as possible.
CAUTION: DO NOT OPEN THE ISOLATION VALVE.
8.4.10 Test Sat. Unsat.
- g. TS-25 (Alarm Valve Tests, Drain Tests, and Miscellaneous)
Selected portions of TS-25 are included below; they demonstrate that acceptance criteria are included in the test.
2.0 TEST REQUIREMENTS 2.1 Within 30 seconds of opening an inspector's test connection, an alarm should be received in the control room.
2.2 When a 1 " or 2" drain valve is opened, there should be a minimal drop on the installed pressure gauge for deluge valves.
2.3 When a 2" drain valve is opened, there should be no detectable pressure drop across an alarm valve.
8.0 TEST PROCEDURE Checkoff
? NOTE 1: LOG ALL DATA ON DATA SHEET ATTACHED. TEST PROCEDURE ASSUMES-THAT SYSTEM IS IN ITS NORMAL CONDITION.
NOTE 2: ARRANGEMENTS MUST BE MADE WITH SOMEONE IN THE CONTROL ROOM TO PASS THE kORD WHEN AN ALARM IS RECEIVED. A CHECK SHOULD BE MADE BEFORE EACH ALARM VALVE IS TESTED AND IF THERE IS ANY UN-CLEARED ALARM ON THE FIRE ALARM PANEL THE RELAYS FOR THOSE ALARMS SHOULD BE TEMPORARILY PULLED SO THAT THE ALARM TO BE TESTED CAN BE RECEIVED.
8.1 Ready Stores Mezzanine, PS-3735 8.1.1 Verify special sprinkler head fitting installed at end of inspector's test connection.
8.1.2 Open the inspector's test connection valve to the fully open position and measure the elapsed time until the word is passed that the alarm was received in control.
8.1.3 Close the inspector's test connection valve. Alarm should reseat itself.
8.1.4 Open the 2" drain valve on the alarm valve full open and then close it,
DATA SHEET FOR TS-25 ALARM ALARM ELAPSED VALVES LOCATION TIME DRAIN TEST PS-3735 Ready stores area and mezzanine PS-3737 Unit I turbine building intermediate PS-3939 Unit I turbne building ground Unit I hotwell spray Unit 2 hotwell spray PS-3732 Oil storage tank room PS-3740 Unit 2 turbine building ground PS-3738 Unit 2 turbine building intermediate PS-3733 Boiler room PS-3734 Day tank rooms FS-3718 F16 charcoal filter alarm SV-4883 3D fire curtain SV-4884 4D fire curtain IDV-3700 IX01 A@
1DV-3701 IX01 B@
1DV-3702 1X01 CO, 1DV-3703 IX02 DV-3709 Wall Spray 1DV-3704 Hydrogen seal oil system IDV-3705 Lube oil reservoir 2DV-3705 Lube oil reservoir 2DV-3704 Hydrogen seal oil system 2DV-3700 2X02 2DV-3701 2X01 C9 2DV-3702 2X01 B@
2DV-3703 2X01 A0 DV-3727 Fuel oil tank - east DV-3728 Fuel oil tank - west DV-3707 1&2X04 DV-3708 #1 warehouse DV-3753 #2 warehouse TEST CONDUCTED BY DATA ANALYZED BY DATE 3
- h. TS-26 (Fire Main Flow Test)
This particular test is one which requires data reduction and analysis to assure satisfactory system operability.
To verify the analysis is completed, Page 6 contains the following sign-off:
Test Performed By Calculations Performed By Calculation Compared to Previous Year's Data Fire Protection Supervisor Date Our acceptance criteria and techniques for the analysis are contained in Appendix A of TS-26.
1.0 HYDRAULIC PERFORMANCE CURVE ANALYSIS 1.1 The curve determines the maximum performance which can be expected of the system. Pressure-flow points lying under the curve can be obtained; points above the curve cannot. Section 11, Capter 5 of the Fire Protection Handbook discusses hydraulic performance curves.
1.2 If the slope of the curve remains the same from year to year it indicates no piping degradation is occurring. If, however, the slope of the curve increases system degradation is indicated.
The magnitude of changes in slope from year to year indicate the rate at which the piping system is deteriorating.
2.0 "C" VALUE ANALYSIS The factor "C" is the Hazen-Williams coefficient and is indicative of the condition of the pipe. "C" will decrease as the pipe deteriorates and wears with time. A decrease of up to 10 Letween years is acceptable.
If "C" decreases by more than 10, the cause should be determined.
Further analysis should include a review of all "C" factors f rom past years to identify any trend which may be occurring.
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CORRECTIVE ACTION / ACTION TO PREVENT RECURRENCE
- 1. The surveillance tests will be reviewed and portions of tests which apply to non-Technical Specification equipment and systems will be placed in non-Technical Specification tests. This will be accomplished following NRC approval of our proposed revised Fire Protection Technical Specifications, Sections 15.3.14 and 15.4.15, which will be submitted in the near future.
- 2. We will review all fire protection Technical Specification test items to assure appropriate acceptance criteria or acceptability limits are present where they are required to satisfy the intent of the procedure and are consistent with both our accepted QA program and the Point Beach test procedure philosophy. This will be completed by April 30, 1983.
Violation 2 Noncompliance 2.b(5) (82-17-02, Fire Door Limiting Condition for Operation)
Diesel Generator Room Door We acknowledge that the west door between the diesel generators was found in the open position without a fire watch posted. Although this door was equipped with an automatic hold-open device which used a fusible link to ensure closure in the event of a fire, there was a mechanical interference problem with the door sweep and the floor which caused the door to stick partially open.
CORRECTIVE ACTION / ACTION TO PREVENT RECURRENCE
- 1. The door sweep has been modified to eliminate door-floor interference.
- 2. A maintenance surveillance procedure has been implemented to provide for identification and repair of safe shutdown
! fire door malfunctions. (See response to Violation 1, Item a ( 3) , for further information.)
- 3. The automatic hold-open feature has been defeated and the fusible link removed.
- 4. This door, along with all other safe shutdown area fire doors, has been painted red to enhance conspicuous marking. This is intended to provide heightened personnel awareness that a fire door is in use. (The painting is consistent with security requirements.)
- 5. A modification is in progress to utilize the plant security computer to monitor the open/close status of all safe shutdown area fire doors. Most of-these doors now have their status monitored but others require additional hardware and/or security computer software modification. Such changes will be accomplished in a timely manner.
Items 1 through 4 have been completed.
Facade Stairwell Door This. door is one of many in the plant which is not a safe shutdown area fire barrier. These doors are considered to be industrial safety fire doors; as such, they are not subject to Technical Specification grade surveillance. We acknowledge that the door in question did have a malfunctioning latch mechanism which has since been repaired. We recognize that this door, along with others in its classification, are l important to the overal.1 industrial safety of our facility and employees.
CORRECTIVE ACTION
- 1. A maintenance request was submitted and the latching mechanism repaired.
- 2. Industrial safety fire doors will have a maintenance inspection performed annually in addition to the current system of priority attention when needed. The inspection will be identified on the Operation's computerized call-up program and will be completed by August 31, 1983.
Unresolved Item 2.c (1) (82-17-03, Fire Door Closure Devices)
The following steps have been taken to assure that automatic fire doors will close in case of fire and to preclude the use of foreign materials on fusible links:
- 1. All safe shutdown area fire doors have had their fusible
, links removed thereby effectively defeating the hold-open feature.
- 2. The semiannual maintenance surveillance procedure will ensure the fusible links are not inadvertently replaced on the safe shutdown area fire doors.
- 3. The annual maintenance surveillance procedure which will be performed on industrial safety fire doors will identify any unsatisfactory fusible links and facilitate their replacement with appropriately clean fusible links.
- 4. A memorandum will be issued to all plant personnel explaining the problems caused by the use of fusible links which may have foreign material on them.
Unresolved Item 2.c(2) (82-17-04, Fire Door Degradation)
Representatives of Steelcraft Manufacturing Company, manufacturer of the fire doors, and Underwriter's Laboratories have inspected fire doors at Point Beach Nuclear Plant which are equipped with the security appurtenances in question.
They have approved the fire rating of these doors as presently equipped (see Attachment 7). We believe no further action is required on this item.
Unresolved Item 2.c(3) (82-17-05, Fire Door Ratings)
The door manufacturer, Steelcraft Manufacturing Company, has been contacted regarding labelling and fire resistance ratings of fire doors. The fire door manufacturer produces several various sizes and models of doors. A particular model can be provided with or without a fire resistance rating label and with any of the listed fire resistance ratings up to the maximum rating for which that model door has been tested. The rating label which is provided with the door corresponds to the speci-fication of the purchases. Thus, the identical model door can be provided with no label or.with A, B, C, D, or E labels provided it has passed the "A" rating fire resistance test (B, C, D, and E are all less severe ratings). The two doors in question are of the iE-guage style manufactured by Steelcraft and are identical in construction (see Attachment 3). Original specifications called for a "B" rated door on the battery room and "A" rated door between the diesel generator rooms and the doors were supplied with the appropriate labels. The doors are in fact the identical model and both are physically capable of providing a three-hour fire resistance.
We believe no further action is required on this item.
Unresolved Item 2.c (4) (82-17-06, Dual Purpose Bullet Resistant Fire Doors)
The manufacturer of these doors, Chicago Bulletproof Equipment Company, has been contacted regarding the dual purpose rating of the doors. A letter from the manufacturer certifying the dual purpose listing of these doors by Underwriter's Laboratories is enclosed as Attachment 4.
We believe no further action is required on this item.
Violation 3, Item a Noncompliance Item 3.b (1) (82-17-07A, Contractor Training)
Our transmittal dated November 7, 1977 states,in response to 1.0.D(5) of Attachment 1,"An item of this orientation is basic fire protection which reviews the individual's responsibility in the event of a fire emergency."
At the time of the inspection, the Fire Protection Supervisor had not recently reviewed the General Employee Training Program specifically checking for compliance with our November 7, 1977 submittal. Since that time, we have determined the training is given as part of the General Employee Training received by all contractor personnel prior to receiving their security clearance. Specifically, contractors are directed to call Control if they should observe a fire, specifying the nature and location of the fire. An example of the sound of the fire alarm is given, with instructions that contractors may be required to evacuate the area. Instructions are given not to use elevators in the event of a fire emergency. It is our philosophy that the most important aspect of protection for a fire in progress is the early notification of the fire brigade. We do not train contractors or general plant personnel in fire fighting techniques and, therefore, our lines of defense are directed at the fire brigade.
We are, thus, meeting our commitment to train contractors on their responsibilities during fire emergencies.
CORRECTIVE ACTION / ACTION TO PREVENT RECURRENCE In order to ensure contractor performance with respect to plant fire protection matters rather~than just a fire emergency as committed to in our November 7, 1977 transmittal, we will prepare a more detailed training program for contractor supervisory personnel. This training will include indoctrination to administrative procedures regarding combustibles control, transient fire loadings, and ignition control permit authorization.
The administrative procedures required as base documents for this training and the training itself shall be in place by December 31, 1983.
Violation 3, Itel t b Noncompliance Item 3.b (2) (82-17-07E, Spill Training)
We do not agree with the NRC conclusion that "no procedures" for handling leaks and spills of flammable materials existed and "no training" took place on these procedures.
e Emergency Operating Procedure EOP-12A, Part 5 of the Wisconsin Electric Safety Manual,and Operations Standing Order, PBNP 4.12.47, specifically deal with flammable liquid hazards and appropriate handling of leaks and spills albeit the emphasis is very heavily slanting toward environmental protection. Also available in the plant videotape library is a presentation describing flammability of liquids and gases and the basics of combustion.
All plant personnel receive copies of the Wisconsin Electric Safety Manual at the start of employment. All fire brigade members who enter employment at the Auxiliary Operator Trainee position receive training on EOP's and view the videotape describing the flammability of liquids and gases. Fire brigade members receive annual retraining on EOP's and the flammable liquids videotape.
CORRECTIVE ACTION / ACTION TO PREVENT RECURRENCE In order to improve our fire protection program we will do the following:
- 1. Consolidate the information from the procedures referred to above in a single administrative procedure governing handling of leaks and spills of flammable materials.
- 2. Review and modify as necessary the procedure referenced in 1 above to ensure it is appropriate for conditions presently existing at Point Beach Nuclear Plant.
- 3. Train and periodically retrain all fire brigade members, plant supervisory personnel, and contractor supervisory personnel on the procedure governing the handling of flammable materials leaks and spills.
- 4. Document the training given on the procedure governing the handling of flammable materials leaks and spills.
The program consisting of Items 1 through 4 will be complete by December 31, 1983.
Violation 3, Item _c Noncompliance Item 3.b (3) (82-17-07C, Combustible Control Tours)
We agree that limited documentation presently exists of plant tours which were conducted to identify the improper use and/or storage of combustibles in safety-related areas. However, we disagree with the implication that plant tours were not being made when in fact they were.
Plant tours are made by supervisory personnel knowledgeable in nuclear power plant operations and fire protection. As such, these individuals are well qualified to identify improper storage as opposed to operational placement, safety-related versus -
non-safety-related areas, and minimal quantities as opposed to excess quantities of combustibles. Documentation at the plant shows that previous outside inspections, including those performed by the NRC, have found Point Beach housekeeping to be above average.
CORRECTIVE ACTION / ACTION TO PREVENT RECURRENCE In order to provide improved documentation with respect to the use and improper storage of combustibles in safe shutdown areas we will do the following:
- 1. The Fire Protection Supervisor and/or Duty Shift Supervisor will periodically conduct and document combustible control
. tours.
- 2. Plant management will continue to conduct, but not necessarily document, independent combustible control tours.
- 3. An administrative procedure shall be prepared which reflects Items 1 and 2 above.
Items 1 through 3 will be completed by April 30, 1983.
Violation 3, Item d Noncompliance Item 3.b (4) (82-17-07D, Combustibles Controls)
We agree that combustibles within a given plant area should be minimized. The limitations on combustibles will be determined by the work activity in any plant area. Safety-related areas are of particular concern.
We do not feel the listing of examples under Noncompliance i 82-17-07D (Page 15) dated November 30, 1982, accurately reflects the overall conditions associated with each item listed. In order to clarify the issue, and also to resolve each item, the licensee has enclosed as Attachment 1 the list from Page 15 of the NRC audit and has included additional pertinent information.
We agree that " trash" combustibles should be removed from plant areas in an expedient manner. We wish to point out that some working materials, even though they are combustible,
may be required in a given plant area for lengthy periods of time, particularly when major modifications, such as those involved with TMI requirements and fire protection system upgrading, are underway. We agree that such combustible loadings should not exceed acceptable limits unless special precautions are taken.
CORRECTIVE ACTION / ACTION TO PREVENT RECURRENCE We propose at this time to update our response of November 7, 1977 to Attachment 3, Item c, to read " Point Beach Nuclear Plant policy and practice shall ensure the removal of all trash combustibles from the area following the completion of the activity or at the end of each work shift, whichever is sooner. Combustibles in the area which are not trash shall be allowed to remain until the end of the work activity so long as they conform to transient fire loading evaluations."
To ensure that trash combustibles are promptly removed from plant areas and to ensure that transient fire loading is not excessive, with special emphasis on safe shutdown areas, the licensee will do the following:
- 1. Have plant personnel conduct combustibles tours as outlined in the response to Noncompliance 82-17-07C, with implementation by April 30, 1983.
- 2. Place in operation a transient fire loading evaluation program as described in the response to Noncompliance 82-17-07E,with implementation by June 30, 1983.
- 3. Provide training on the new fire protection administrative and functional procedures to fire brigade members and plant work group supervisors, with completion by December 31, 1983.
Violation 3, Item e Noncompliance Item 3.b(5) (82-17-07E, Work Review for Fire Hazards
- a. Transient Fire Loads - Maintenance Requests Following our submittal of November 7, 1977, the maintenance request (MR) form was modified to include a checkoff addressing assessment of special fire hazards and precautions which might be required. This checkoff was included in the
" Action by Maintenance /I&C's" section. During a recent revision of the MR form, the fire hazards checkoff was inadvertently removed and, thus, was not being completed.
Noncompliance 82-17-07E suggests that fire brigade leaders or assistant brigade leaders would be more qualified than Maintenance /I&C supervisors to review maintenance requests for hazards due to transient fire loads. Although brigade leaders and assistants are qualified fire brigade members, they may not be intimately familiar with all maintenance practices, procedures, and materials. For this reason, we believe specific work group supervisors are better able to assess combustible hazards which may occur.
CORRECTIVE ACTION / ACTION TO PREVENT RECURRENCE To ensure the appropriate review with respect to transient fire loads, we propose the following:
- 1. Initiate a change to the MR form and governing administrative procedure to include checkoffs indicating the need to consider special fire hazards and precautions.
- 2. Initiate changes to administrative procedures PBNP 3.5 and PBNP 3.6.2, Superintendent - Maintenance and Construction and Superintendent - I&C, explaining their roles in MR transient fire load assessment.
- 3. Initiate a change to administrative procedur~e PBNP 3.31, Fire Protection Organizations, clarifying the Fire Protection Supervisor's role in MR transient fire load assessment.
- 4. Train appropriate plant personnel on the administrative procedure changes made according to 1, 2, and 3 by September 30, 1983.
Items 1, 2, and 3 shall be accomplished by March 31, 1983.
- b. Transient Fire Loads - Modifications l
We agree that some work being performed at the plant is not followed by plant maintenance group supervisors or plant technical staff supervisors. This has happened because the large amount of backfit work required by TMI commitments has exceeded the capacity of the plant staff. All Fontractors who do work on site are under the supervision of Wisconsin j Electric liaison personnel, however.
a
CORRECTIVE ACTION / ACTION TO PREVENT RECURRENCE In order to ensure that modification work is properly evaluated with respect to transient fire loads, the licensee will do the following:
- 1. Use transient fire load procedures, combustibles control procedures, ignition control procedures, and other administrative fire procedures to ensure modification work is being properly evaluated, monitored, and performed with respect to fire protection.
- 2. Train work group supervisors and Wisconsin Electric liaison personnel on the administrative procedures referred to in 1.
Items 1 and 2 shall be completed by October 30, 1983.
Violation 3, Item f Noncompliance 3.b(6) (82-17-07F, Hot Work Authorization)
The licensee agrees that supervisory personnel other than fire brigade chiefs or assistant fire brigade chiefs are allowed to authorize ignition control permits. We feel that the line supervisory personnel at Point Beach are sufficiently responsible to authorize ignition control permits. This situation is necessary due to the large amount of work presently being performed at the plant.
CORRECTIVE ACTION / ACTION TO PREVENT RECURRENCE We propose at this time to update the response to Attachment 4, Item 2A, of our November 7, 1977 submittal to read " Supervisory personnel who have received appropriate fire protection training and have been a'pproved by the Fire Protection Supervisor may authorize the issuance of an ignition control permit. A fire chief or assistant fire chief must approve the ignition control permit prior to the commencement of work."
The training referred to above will consist of the following:
- 1. Completion of the contractor supervisory personnel training referred to in the response to Noncompliance 82-17-07A.
- 2. Completion of training regarding general and plant specific basic fire prevention and extinguishment.
Items 1 and 2 shall be completed by August 31, 1983.
Violation 3, Item g Noncompliance 3.b (7) (82-17-07G, Fire Fighting Strategies)
We have specif.ic fire fighting strategies (Fire Emergency Plans, FEP's) for the control room, cable spreading room, vital switchgear room, and diesel generator room. These plans include identification of combustibles in each area, identification and applicability of extinguishing agents in each area, fire attack tactics, identification of specific hazards which may exist, identification of specific equipment located within the area, and procedural instructions for fire brigade and operating personnel.
Fire fighting strategies for areas or equipment not addressed in FEP's are dealt with in Fire Attack Plans (FAP's). The FAP's delineate strategies to be used in fighting different classes of fires and fires which could occur in equipment unique to power plants. The information in FAP's include precautions associated with that class fire and where applicable, the equipment involved, basic fire fighting tactics that apply, specific extinguishment methods, and guidance to operating personnel.
Our records show that the NRC found our FEP's and FAP's satisfactory fire fighting strategies in July 1979. Specifically, documenta-tion from the NRC Office of Inspection and Enforcement referring to an audit conducted June 26 and 27, 1979. Item 3.e states "The inspector reviewed the licensee's fire fighting procedures and attack plan and found that they adequately specify actions to be taken by the fire brigade, coordination of efforts with the Two Creeks Volunteer Fire Department, and actions to be taken by the plant superintendent, security guards, plant operators, and general plant employees."
Based on the findings of the 1982 NRC audit and substantiated by our own triennial fire protection audit, as performed by Professional Loss Control, Inc., we agree that additional fire fighting strategies should be developed for other plant areas.
CORRECTIVE ACTION / ACTION TO PREVENT RECURRENCE We will prepare specific fire fighting strategies (FEP's) for plant safe shutdown areas which do not now have FEP's.
In addition, existing FEP's will be reviewed and updated if necessary. We will complete these actions by June 30, 1984.
All fire brigade memb-ars will receive training on new and updated FEP's when they become available.
4 Violation 3, Item h Noncompliance 3.b (8) (82-17-07H, Valve Position Control)
The administrative control mechanism used to verify the position of a critical manually operated valve in the fire protection system is the. checklist in Technical Specification test TS-23, Monthly Valve Lineup Verification. This checklist specifies the position each valve should be in. TS-23 is performed monthly.
The NRC auditors found valve FP-20 in the proper open position but without a " red lock" affixed. A review of TS-23 shows that through some oversight valve FP-20 was not specifically identified to have a " red lock" affixed as were other critical valves in the fire protection system.
CORRECTIVE ACTION / ACTION TO PREVENT RECURRENCE Technical Specification test TS-23 has been reviewed and modified as required to include a verification that red locks are installed on all critical valves in the fire protection system, including FP-20.
Violation 3, Item i Noncompliance 3.b(9) (82-17-07I, Offsite Fire Department Drills)
When the fire brigade training and drill program was established in 1978, the fire year was determined to begin on June 1 and end on May 31 of the next year. As the work load increased on the plant staff, this particular system proved to be cumbersome, particularly for record retention, retrieval, and review. Thus, in 1981 the fire protection year was extended six months to coin-cide with the calendar year. The coincident change in our records retention, retrieval, and review system masked the fact that a drill with the Two Creeks Volunteer Fire Department had not been done during calendar 1980. To date, in approximately 4-1/2 years of required compliance, there have been four drills with the Two Creeks Volunteer Fire Department.
CORRECTIVE ACTION / ACTION TO PREVENT RECURRENCE ,
In order to ensure continued compliance, and to facilitate records retention, retrieval, and review of this compliance, the licensee will do the following:
- 1. Adjust the fire protection calendar to coincide with the calendar year. (Already complete.)
- 2. Prepare a computer program to tabulate and review individual and crew fire training records. This system will record training, drill, and fire brigade meeting attendance for individual fire brigade members, compare it with requirements, and uniquely identify incomplete or tardy items. (Already complete.)
- 3. Computerize crew (fire brigade) records and requirements.
This will encompass drills with the Two Creeks Volunteer Fire Department and will be complete by August 31, 1983.
Violation 3, Item j Noncompliance 3.b (10) (82-17-07J, Fire Brigade Training)
We agree that (1) Crew C failed to conduct a fire drill during the first quarter of 1982 and (2) fire brigade members had not attended a brigade meeting during the second quarter of 1982.
Failure to conduct this particular training and the Crew C drill on a timely basis decurred during the first half of 1982 because of the unusual work load resulting from cn acute personnel shortage necessitated by the need to augment the licensed staff. As a result, the required review failed to recognize the training and drill deficiencies on a timely basis. At the time, records of fire training, drills, and compliance were kept manually in written copy. This system was very labor intensive and time consuming. The review process to ensure timely compliance was even more difficult.
We assess the lack of a fire drill and untimely completion of fire brigade meetings to have been caused by an inefficient records retention, retrieval, and review system coupled with a temporary shortage of qualified personnel.
CORRECTIVE ACTION / ACTION TO PREVENT RECURRENCE We would note that the requirements for brigade fire drills is two-pronged. Along with providing crew drills, they provide individual fire fighter drill compliance. Each fire fighter is required to have two drills per calendar year; this has been accomplished for 1982. For 1982, 21 brigade drills were required; only the one identified by the NRC was missed.
All regular fire brigade members attended the second quarter brigade meeting of 1982 by July 24, 1982. Staff and security fire brigade members attended sometime later.
In order to prevent future difficulties involving the fire fighting recordkeeping system we will do the following:
- 1. Develop a computerized records retention, retrieval, and review system for individual fire brigade member qualification requirements. (Already completed.)
- 2. Develop a computerized record retention, retrieval, and review system for crew fire drill requirements by August 31, 1983.
Unresolved Item 3.c (82-17-08, Quality Assurance Audits)
The fire protection program at Point Beach is audited on an annual basis by both the Wisconsin Electric Quality Assurance Division,(QAD) and the Wisconsin Electric System Fire Protection Officer (SFPO). In the past, these audits have been conducted independent of one another. The scope of the QAD audits, those referenced in unresolved item 82-17-08, were based primarily on administrative control of procurement, modification requests, and maintenance requests. The scope of the audits conducted by the SFPO are technically oriented to verify adherence to Technical Specification and regulatory requirements and commitments.
In addition, an audit is conducted every three years by an outside independent fire protection consultant. We believe this method of auditing assures that all aspects of the fire protection system are being audited on at least a yearly basis by appropriately trained and qualified personnel.
CORRECTIVE ACTION / ACTION TO PREVENT RECURRENCE In response to the request to broaden the scope of the QA audits and to increase auditor fire protection qualifications, the following action will be implemented:
- 1. Future annual audits will be conducted on a joint basis by QAD and SFPO.
- 2. The QAD auditor will be a qualified lead auditor. The SFPO will be familiar with technical requirements of the fire protection program a:td meet the requirements of membership for the Society of Fire Protection Engineers.
It is our belief that the two personnel will compliment each other and will assure that a complete review of the fire protection program will be accomplished. A triennial audit of the fire protection system by an independent outside consultant accompanied by the SFPO and QAD representative will verify the adequacy of this approach.
Unresolved Item 4.b (82-17-09, Fire Extinguishers)
Two pressurized water fire extinguishers are located in the control room and are available for any fire emergency which should arise. The two extinguishers were placed in the control room in order to comply with the 1979 NRC Fire Protection Safety Evaluation Report recommendation. Obviously, these extinguishers are intended for use on Class "A" fires.
We also know that fires which involve insulation and cabling require water application to effect total extinguishment of a deep-seated fire and to cool hot embers. It is, thus, prudent practice to have pressurized water e::tinguishers available should the need for them arise.
We do not feel that the use of a pressurized water fire extinguisher equipped with a standard nozzle on an electrical fire in the control room presents any significant shock hazard to the operator for the following reasons.
Control room personnel are trained fire brigade members aware of the electric shock hazard associated with water application to energized electrical equipment and would make every effort to deenergize equipment prior to water application. Being trained fire fighters, our brigade members know that straight stream application of water to energized electrical equipment is the most hazardous. Should the need occur to apply water to energized equipment, they would use methods which provide themselves maximum protection, such as partially placing a thumb over the nozzle, deflection of steam against a nearby wall, or interfering object; i.e., any method which would break the straight stream.
The pressurized water extinguisher itself, although not recommended for Class "C" fires, is inherently quite safe.
The table in Attachment 5, taken from the NFPA Fire Protection Handbook has been included for your information. We have indicated the conditions which would most likely be encountered in the Point Beach control room. An explanatory paragraph from the same source is included. Thus, it can be seen that as long as a distance of 1.6' is maintained less than 1 milliamp (ma) of current should be transmitted. It is generally held that 3 na of current is the lower threshold of feeling for most people.
Ontario Hydro Research Division conducted a test in 1958 on the electrical conductivity of hose streams. Portions of their data are included for your information in Attachment 6.
Point Beach extinguishers have approximately 1/4" nozzle tips and are charged to 100 psig. Using the Ontario Hydro data for 1/2" tips at that pressure it can be seen that, at a distance of 5' a potential of 2,880 volts would have to be encountered in order to generate 3 ma of current to the operator. Voltages
j .*
of this magnitude are not generally encountered in the control room. Applying a 1/2" steam, at 100 psi, at 5' to a 600 volt differential produces only a 0.5 ma current. Again, 3 ma is the lower threshold of feeling.
An additional safety factor is induced at Point Beach because all pressurized water extinguishers are charged with deionized water.
CORRECTIVE ACTION / ACTION TO PREVENT RECURRENCE We wish to upd:Le our correspondence of January 13, 1979 to delete any reference to deflector-type nozzles.
We do not plan to modify deployment of our pressurized water extinguishers in the control room.
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ATTACHMENT I (82-17-07D)
Item a - Dry Ion Exchange Resin, El. 44' Spent Fuel Pit Building Additional Information This area of the plant is not a safe shutdown area nor is it a safety-related area. The storage volume limit is determined by practical industrial safety.
Resolution This is not a safe shutdown area, there is no ready ignition source and personnel activity in this area is minimal. We plan no further action at this time. Should conditions change we would reevaluate the situation.
Item b " Point Beach Hilton" Additional Information This enclosure retains enough heat to prevent the steam generator instru-ment lines from freezing during the winter thus it was necessary to allow continued plant operation. We are sure that fire retardant lumber was used but concur the markings are not discernible.
Resolution Electric heat tracing is being installed on the instrument lines and the enclosure will be removed.
Item c - Wood Planking & Scaffolding at Component Cooling Water Heat Exchanger Area Additional Information This was not a storage area rather an ongoing TMI backfit modification. The scaffolding supports are steel with only the planking being wood.
4 Resolution Any unnecessary lumber has been removed, and upon completion of work, all scaffold material will be removed.
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Page 2 Item d - Ll. 52' Service Elevation Wood 3 Additional Information '
This is a nonsafety related area.
Resolution Scrap and trash material has been removed.
Item e - Spray Paints, Solvents, Lubricants Additional Information No comment.
Resolution P
The material in question has been properly stored or removed.
Item f - One Piece of Plywood Additional Information No comment.
l Resolution The one piece of wood has been removed.
Item g - RHR Pump Area, El. 19' t
Additional Information Some materials were in this area because a decontamination effort was taking place.
I Resolution The area has been cleaned up.
J F
3 4
l 4
J Attachment 1 Page 3 Item h - Combustibles in Auxiliary Feedwater Pump Room 1
Additional Information The scaffold, planks and ladder were part of ongoing TMI backfit modification work.
Resolution The area has been inspected and unnecessary combustibles removed. The other material will be removed upon completion of the work. .
Item i - A Wood Stool Under A Diesel Day Tank Additional Information No comment.
l Resolution l The wood stool has been removed.
- Item j - Wooden Ladders Additional Information Ladders have been stored in specific areas throughout the lifetime of the plant. They were in place at the time our Safety Evaluation Report was conducted and were not considered significant enough to have been mentioned in the area combustibles loading assessments. s Resolution None required.
Item h - Vehicle Parking Near Diesel Generator Rooms Additional Information No comment. '
Resolution A rectangular area adjacent to the diesel generator rooms has been
- designated a no parking area. Yellow lettering and yellow cross hatching on the asphalt conspicuously denote the area as "No Parking" along with signs to that same effect.
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FIRE DOOR SELECTION GUIDE ""
This chart is intended only for general usage in the selection of Fire Doors and Frames. It should be used in conjunction with Local and State Building Codes.
PROTECTION TYPE DOOR TYPE RECOMMENDED DOOR LOCATION REQUIRED STEELCRAFT DOORS REQUIRED OF EXPOSURE Apartment Suite It4 or 1/3 Hour Moderate F L18 L20-1-3/4" Entrances Automotive oealer 3 Hour Extreme F L18-1 2 '4_"
Show Room To Garage Boiler Rooms 3 Hour Extreme F L18-1 3/4" Chemical Lab. Rooms 1 1/2 Hour Se,ere J,V g L20- g '
Corridors (Fire) 1 1/2 Hour Severe F. V L18-1 3/4" 3/4 or 1/3 Hour Moderate F.V,N,G,PG2,FG3 L18, L20-13/4", S16-1-3/4" Corridors (Smoke)
Doors Between 1-1/2 Hour Severe FV L18. L16-1-3/4" eactory & office E xtreme F L18, L20-13 4
Electrical Eauipment 3 Hour Elevator Eausoment 1 1/2 Hour Mcv*erate F, V L18-13/4" Exits Between Building 3 Hour E xtreme F L16 L18-1-3/4" Exits To Exterior Fire 3/4 Hour Moderate F L18 L20-13/4" Escapes Furnace Room in 1 1/2 Hour Severe F. V L20-13/8". L20-13/4" Muitiole Family owellings Garage To House 3/4 Hour Moderate F L20-1 3/3" Severe F. V L18, L20-13/4" Garage To Apartment 1 1/2 Hour Mosoital Labo<atories 1 1/2 Hour Severe F, V L18. L20-13/4" Hospital Patient Rooms 3/4 or 1/3 Hour Moderate F.V,N.G L18-1 3/4" Kitchen Area 11/2 Hour Severe F, V L18-1 3/4" E xtreme F L20-1-3/8", L18-13/4" Legal oocument Storage 3 Hour E xtreme F L20-1-3/8", L18-1-3/4" Paint Rooms 3 Hour Room Partitions 3/4 or 1/3 Hour Moderate F,V,G L20-1 3/8" Stairwells 1 1/2 Hour Severe F. V L18-13/4". T-18. T 20-13/4" 3/4 Hour Moderete F L20-1 3/8" Storrie Closets Severe F L18, L20-13/4" Stor.ge Closets 1 1/2 Hour Warehouses 3 Hour Extreme F L18 L16-14/4" NOTE: LF20, LF18 and LF16 edge seem filled doors and L20 Textured doors may be substituted for somstar gepe doors shown above when specified.
I F = FLUSH PANEL V = VISloN LIGHT ,
N = NARROW LIGHT W G= HALF-GLASS LIGHT FG2 = Two GLASS LIGHTS FG3 = THREE GLAC LIGHTS F V N G FC2 FG3 i
' ~
Page 2 .
OTEELCRAFT FLUSH SINGLE FLUSH PAIRS STILE & RAIL DOORS OF DOORS DOORS (S16) l l
SINGLE I.2H L2H Max.Sias and Rating LT2 H Max. Sias and Rating. LT2H Peirs are met pernetted 4000 UL C & E LF2H 3472 UL ABCDE
(
L2H Max. Sias and Rating L264 Max. Sias and Rating LT2H 8072 UL 8CDE LT2H Sg72 UL A EI "I Lf2H 4080 UL BCDE L18 4 Max.Sias and Rating -
L1H LF184 8080 UL A8CDE hWW ***
LF1H 40100 UL ABCDE C =
~
- s072 UL 8 mthest astreger LM Mez. Siam W R4 LF1H Lty Men. Sias and Rating
! 40100 UL ABCDE PAIR LF164 8000 UL ABCDE
'9872 UL 8 mthest astregni t
T2H Max.Sias and Reting Max.Sias and Rating T184 4072 UL SCDE Max. Sias and Rating Deers have 2500 tesem rating TF2S4 8072 UL SCDE l
Deers are linuted to flesh, O '*" *"*"
Deers are lienrted to flush, hWwh typok visiea lite and narrow lite p
Pameis not pernutted 1290 square inches per link Neither dienension tSOS: deers wthout astregni must use (2) M #*
vert. red fire exit devices DUTCH DOOR FG2 doors shown above.
FG3 doors also avel!able.
'8072 deers mthout stregni rnest use
- artosastie flush bolts (inactive les0 sad single point lock (active les0.
Most aise use coordinating device.
L184 Max. Size end Rating L154 4072 UL A8CDE See Note 9 et right for nweally-operated flush or surface be,tts.
-4 = 13/t" thick deors 4 = 13/4" thick doors.
SEE NEXT PAGE FOR EXAC' u
(
6
. o_
. - ATTACHMENT 4
, ..' [ M e?K @
CHICAGO BULLET PACCF EGUIA. CO.
225o WESTEAN ave.
PARK FCAEST. IL GOdSS U.sA
~
PH 31E/481-3400 TLX 255194 Date: 28 July 1978 Utility: Wisconsin Electric Power Canpany Generating Station: Point Beach Nuclear Power Plant Architect / Engineer: WEP Co.
Chicago Bullet Proof Equipnent's Job !F78077 & 78146 Custcmer Name and P.O. # WEP Co. A-04590-8 & A-07039-S Chicago Bullet Proof Equipment Co. (CEP) certifies that we have tranufactured the following bullet resistive equipnent in accordance with the owner's plans and specifications:
78077 / A-04590-S A) Door and Frame Asserrbly for Cable Spreading Rocm.
B) Partition for cast wall of Control Room consisting of a vision panel and wall annor trodules.
C) Partitions (2,J for north and south walls of Control Pocm consisting of wall annor, vision panels, and Door / Frame Asserriolies (Nos. 61 & 65).
Note that three subject Door / Frame Assemblies are also listed by Underuriters' 4 12bornrnm as. inc. for the 3-heur fire and hose stream test, as well as being_
l liullet resistive. Labels for these products c.re affixed to the hingeside edge l of door.
A 78146 / A-07039-3 A) Two (2) Door / Frame Assentlies (Nos.17 & 25) for Central Alarm Station.
Note that three subject Door / Frame Assemblies are also listed by Underwriters' laboratories, Inc. for the 3-hour fire and hose stream test, as well as being bullet resistive. Labels for these products are affixed to the hingeside edge of door.
In addition, Chicago Bullet Proof Equipnent Co. certifies that the bullet resistive equipment described above successfully defeats the threat of the High Power Rifle as defined in Underwriters' Inboratories, Inc. Standard ,
for Safety UL 752. 'Ihe High Power Rifle as defined in UL 752 is a .30-06 Springfield Rifle using 220 grain soft point amunition and developing a velocity of 2410 FPS and an energy of 2830 Ft.-Ibs. at the muzzle. For j further test parameters and and description refer to UL Standani 752.
I
Attachment 4 Paae 2 Ah Un#5nriters' Iaboratories listing tag appears on each unit that csp
maqufactures.
ha infon:iation on each label includes the type of equipment, number. model number, ballistic rating and manufacturer's control W e appearance of the listing tag signifies that samples of the pnaduct with the ULhave been submitted to Underwriters' laboratories and found to cmply Standard.
In addition, CBP is required by UL to subscribe to the UL Follow-Up Service to insure our continued empliance with the standard requirements and correct any deficiencies.
examinations by UL representatives, as well as destructive testing of selectedWe s samples fran both the factory and open market.
De relation between the Undenriters' Standard and the United States Nuclear Regulatory Nurrber 37, Conmission nursday, February requirements is stated in the Federal Pagister, Volume 42 24, 1977. ,
cciarents: Title 10, part 73 contains the following.
(6) "We proposed nile used the term " Bullet penetration Resistance."
Ccaments indicated a need for a clear meaning, since the meaning of
" Bullet penetration Resistance" was covered in the tenn " Bullet Resisting" defined and used by the Underwriters' laboratories (UL Standarc UL 752),
the rule set forth below was changed to use the tenn " Bullet Resisting" and a new definition has been added in 73.2 to correspond to the definition of " Bullet Resisting" used by the Standard 752.
"73.2 Definitions -
(9) " Bullet Resisting" means protection against emplete penetration, passage of fragments of projectiles, and spalling (fragmentation of the protected material resistingthatbarrier)." can cause injury to a person standing directly behind the bullet As a further explanation, the NBC's NuReg 0220 Acceptance Criterion 3.1.5.A. specifies UL's High power Rifle (HpR) ballistic level as the perfonnance standard required. Therefore,'
based upon the above, the units found to be in empliance with the UL 752 High power Rifle category would also be in compliance with the NRC Regulations. This takes into consideration all parameters of the test, including the type of weapon, amnunition, muzzle velocity and tolerances for both velocities and spalling.
i mc0t [
.< am OIICAGO BULLET FPf0F EQUIRENT CGIpANY day o ,
19 3 Q W WA o cuht Gatary public
.~
4 ATTACHMENT 5 The results of tests made in 1934 for the Fire Brigade of Paris, France, present what is perhaps the most comprehensive guidance (see Table 13-1C).
Tbe distances given in Table 13-IC are based on preventing the transmission of 1 ma (milliampere) current to a fire fighter in contact with a nozzle or hose. The tests covered only voltages to ground ranging from 115 to 150,000 V and the groupings of the voltages do not correspond to current standard U. S. voltages. The maximum size of the nozzle used in the tests is non-standard in the United States.
TABLE 13-1C MINIMUM SAFE DISTANCES BETWEEN HOSE N0ZZLES &
LIVE ELECTRICAL EQUIPMENT RECOMMENDED FOR THE PARIS, FRANCE, FIRE BRIGADE Voltage Voltage Safe Distance (Feet) to Between Diameter of Nozzle Orifice Ground Conductors 1/4 in.* 3/4 in.* 1-1/4 in.*
115 230 1.6 3.3 6.6 460 480 2.5 9.8 16.4 3,000 5,195 6.6 16.4 32.8 6,000 10,395 8.2 19.7 39.4 12,000 20,785 9.8 21.4 49.2 60,000 103,820 14.8 39.4 72.2 150,000 259,800 19.7 49.2 82.0
- Figures rounded off from metric scale.
i i
h t
i
- ATTACHMENT"5
^
Page 2 TASLEI FIRE HOSE STREAMS NEAR LOW VOLTAC>E ELECT,RICAL C!R' CULTS .
CURRENT IN HOSE STREAM AT NOZZLE O! STANCE OF FIVE FEET CURRENT IN MILLIAMPERES TIP SIZE VOLTS TO IN INCHE'S 0 PSI 50 N 100hSt G.RCUND .
~
125 O O O '
1/2 - 250 0 0 0 600 0.65 0.55 0.50 .
. 125 ' O O O 5/8,
- 250 . 0' O 0.4 i 600 1. 0 1.0 0.00 g 125 0 d 0 -
3/4 250 0.7 0.6 0.55
(.
600' l.5 1.4 1. 2 I l
125 - 0.45 0.4 0.4 7/8' . 250 -
0.9 0. 8 0.75 '
600 1.9 1.8 f.6 125* 0.5 0.5 -
0.4 1 250 1.1 1. 0 0.85
( 600 2.2 2. 0 1. 8
. .. I'2 5 0.55 0.50 0.45 11/8 250 ' l.2 1.1 0. 9 600 2.4 2.2 1. 9
. 125
- 0.7 0. 6 -
. 0.35 11/4 250 l.5, 1.3 0.75 GOO
- 3.0
- 2.G 2.2 E- 52
mas c Raner b FIRE HOS E STRIAMS NEAR L!VE ELECTRICAL APF/ RATUS TIP SIZE DISTANCE KV FOR 3 c.A CURRENT IN INQHES IN FEET 30 PSI 50 PSI 100 PSI 5 2. 6 2.88 2.88 1/2 10 11. 2 17.0 17. G 15 37.0" 4 0. 0 *
- 4 0. 0 '
- 20
- 5 1.6 f.6 10 f.7 3.84 3.84 3.84 5/8 15 26.0 15.0 7. 0
. 20 13 0.0** 58.0 18.0 25 13 0.0** 13 0. 0 *
- 90.0 5 I. 06 1.! 8 1.3 10 2. 6 2.6 '
3/4 2. 9. -
15 G.4
~
6.4 5. 2
- 20 41.0 19.0 12.0 ,
25 27.0 .
5 0.86 0.86 0.98 10 ,
- 1. 8 2.08 2.16
!O 15 . 4. 5 4.5 20 4.5 15.0 11. 2 6.7
, 25 12.7 30 50.0 32.0
.5 0.G 6 0.66
~
10 0.86 1.4 1.G l.8 15 2. 6 I
2.6- 3.0 20 5.2 4.5 25 4.5
- 2G.3 7.I 6.4 30 12.0 9. 0 5 0.G 6 0.66 0.7G 10 1.3 1.42 1. 8 15 2. 2
- i 1/8 2. 6 2. 8 '
20 3.0 3.0I 25 4.3 4.5 4.5 5.65 30 .
5 0. 5 0.58 0.66 10 f. 04 1. 2 1.4 i 1/4 15 f. 8 2.2 2.2 20 2. 8 2. 8 25 3.7 4.3 s.05 30 CURiiCNT LESS THAN 3 f.1!LLI Ar.tPEllES '
E- 53
ATTACHMENT 7 .s
~~7.** ,. UNDERWRITERS LABORATORIES INC. e S:'.uli
~
f
'J I993 00.O 1*
September 1, 1982 The Steelcraft Manufacturing Co.
9017 Blue Ash Road Cincinnati, OH 45242 I
t~ .
Subject:
Field Inspection of Fire Doors And Frames At Point Beach Nuclear Power Plant, Two Rivers, WI Gentlemen:
Based on your request dated April 26, 1982, a field inspection of the subject units was performed by our Appleton inspector on July 6 and August 23, 1982. Our inspector was accompanied during the inspection by your representative Mr. G. Battista, and Mr. Mike Kaminski.
Our inspection revealed that the doors and frames complied with our requirements and our Listing Mark was applied to s the product.
l As agreed on by all parties involved we will invoice Wisconsin Electric Power Co. for the cost involved in this inspection.
4 Thank you for your cooperation.
[
very truly yours, Reviewed by:
h C DICK WALTHER ED SCHRAND Engineering Associate Engineering Team Leader Follow-Up Services Follow-Up Services y cc: Wisconsin Electric Power Co.
Milwaukee, WI Attn Mr. M. Kaminski l
l l l
t L