Attached is your copy of Impell's final NFPA Code ComplianceReport performed under Contract C-6945. Please advise ifyou have any comments on the report.
Hichigan Electric Company - Contract C-6945Impell Job No. 0120-108
Oear Hr. Kobyra:
Please find enclosed the subject report. Per your request, four separatecopies of the main section and two separate copies of the appendices havebeen provided.
System maintenance recommendations and recoIIWIendations for AEP resolution ofoutstanding code open items/deviations will be provided in separate lettersby Hay 31, 1988.
Should you have any questions about the report, please call Oave Kipley or me.
Very truly yours,
Gary A. Weber, P.E.Project Hanager
GAW:br
Enclosure
300 TRI sTATE INTERYATIQN*L.5UITE 400 ~ LINcoLNsHIRE. IL 60015 ~ I3I2 <>40 2000
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REPORT APPROVAL COVERSHEET
gyp~ leg NFPA CODE COMPLIANCE EVALUATION
Report Humbler. o9-0>o-o>2~ geyfgtte: O
CIgg.. AEPSC deb Number. m»-1O8
yjygt INDIANA MICHIGAN POWER COMPANY - 0. C. COOK NUCLEAR PLANT
RECORD DF
PREPARED
NFPA CODE COMPLIANCE EVALUATIONDONALD C. COOK NUCLEAR PLANT
PREPARED FOR
AMERICAN ELECTRIC POHER SERVICE CORPORATION1 RIVERSIDE PLAZA
COLUMBUS, OHIO 43215
INDIANA MICHIGAN POHER COMPANY
FORT HAYNE, INDIANA 46801
PREPARED
BY'MPELL
CORPORATION300 TRI STATE INTERNATIONAL
SUITE 400LINCOLNSHIRE, ILLINOIS 60015
IMPELL JOB NO. 0120-108
IHPELL REPORT NO. 09-0120-0123
REVISION 0
MAY, 1988
TABLE OF CONTENTS
Approval Cover Sheet
Table of Contents
List of Tables and Figures
Record of Revisions
~PA
vi i
1.0 EXECUTIVE SUMMARY
1.1 Project Overview1.2 Conclusions
2. 0 INTRODUCTION
2.1 Scope of Hork2.2 Methodology2.3 General Assumptions
2-12-22-3
3.0 CODE COMPLIANCE EVALUATION
3.1 NFPA 10
3.1.13.1.23.1.3
3.1.4
3.2 NFPA 12
3.2.13.2.23.2.3
3.2.4
3.3 NFPA 12A
3.3.13.3.23.3.3
3.3.4
Scope of Evaluati'onAssumptionsDeviations and Recommendations/JustificationsReferences
Scope of EvaluationAssumptionsDeviations and Recommendations/JustificationsReferences
Scope of EvaluationAssumptionsDeviations and Recommendations/JustificationsReferences
3-23-23-2
3-3
3-73-93-9
3-10
3-213-213-22
3-22
Impell Report No.09-0120-0123
Revision 0May, 1988
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TABLE OF CONTENTS(Continued)
3.4
3.5
NFPA 13
3.4A.l3.4A.23.4A.3
3.4A.43.48.13.48.23.4B.3
3.4B.4
NFPA 14
Scope of Evaluation — 1971 EditionAssumptionsDeviations and Recommendations/,JustificationsReferencesScope of Evaluation — 1983 EditionAssumptionsDeviations and Recommendations/JustificationsReferences
3-323-323~33
3-333-'443-453-45
3-45
3.6
3.7
3.5.13.5.23.5.3
3.5.4
NFPA 15
3.6.13.6.23.6.3
3.6.4
NFPA 72D
3.7.13.7.23.7.3
3.7.4
Scope of EvaluationAssumptionsConclusions and Recommendations/JustificationsReferences
Scope of EvaluationAssumptionsDeviations and Recommendations/JustificationsReferences
Scope of EvaluationAssumptionsDeviations and Recommendations/JustificationsReferences
3-583-583-58
3-59
3-703-703-70
3-71
3-823-843-84
3-85
3.8 NFPA 72E
3.8.13.8.23.8.3
3.8.4
Scope of EvaluationAssumptionsDeviations and Recommendations/JustificationsReferences
3-1253-1263-126
3-126
4 ' AEPSC Supplemental Justifications(added by AEPSC)
Deviations h Recommendations/JustificationsNFPA 72E, "Automatic Fire Detectors"
3-5
3-15
3-25
3-39 53-52
3-63
3-78
3-112
3-127
4.1 Cross Reference to NFPA Code DeviationsIdentified by Impell Technical Report No.09-0120-0123, Tables 3.1-1 through 3.8-1(added by AEPSC)
4-3
Impell Report No.09-0120-0123
vii Revision 0May, 1988
RECORD OF REVISIONS
~Rvi~i ~Pa D ri i n f Rvi ion
Issued For Comment
Original Issue
Impell Report No.09-0120-0123
viii Revision 0May, 1988
1.0 EXECUTIVE SUMMARY~
~1.1 Project Overview
This report documents the methodology, assumptions and results forthe NFPA code compliance evaluation of the fire protection systemsin the Auxiliary Building, the Auxiliary Feedwater Pump rooms inthe Turbine Building, the Essential Service Hater Pump rooms inthe Screen House and the Unit 1 and Unit 2 Control Rooms at theDonald C. Cook Nuclear Plant. The fire protection systems inthese areas were evaluated against the following NFPA codes: 10,12, 12A, 13, 14, 15, 72D and 72E.
1.2 Conclusions
The evaluation concluded that the fire protection systems in theseareas of the Donald C. Cook Power Plant are generally incompliance with the NFPA codes reviewed. The systems wereevaluated against the code requi rements for each NFPA code edi tionto determine compliance, noncompliance, and open items, as shownin Appendix Bl through 88 of this report. Noncompliance and openitems identified for each code edition are identified in Sections3.1 through 3.8 of this report. Deviations were reevaluated todetermine whether each item could be deemed acceptable "asinstalled" based upon credited plant procedures or past practicesat the station. Deviations and open items which could not bejustified are identified below, by specific code:
NFPA 10 - Portable Fire Extinguishers
Several areas have Class A combustibles without havingextinguishers suitable for these C'lass A hazards.
2.
3.
Many locations exceed the maximum travel distances from thearea to an extinguisher.
The fire facilities drawings which identify the location offire extinguishers do not depict the actual installedconditions.
NFPA 12 — Carbon Dioxide Extinguishing Systems
Potential for personnel safety hazards associated withleakage of C02 from inside the protected space exists atsome pilot cabinet locations.
2. No documentation was available to verify that the liquidlevel gage on the tank is checked at least annually foraccuracy.
Impell Report No.09-0120-0123
Revisi'on 0May, 1988
0
I
4 p
3.
4.
5.
6.
Vent lines from the electro-pneumatic cabinets aredisconnected which may cause excessive quantities of C02to be discharged into the tank room.
No hydraulic calculations or test data was available for thecontrol room cable vault systems utilizing the newHalon/Co2 nozzles to verify their acceptability.
The manual pull stations could not be verified to have apull of less than 40 lbs. nor movement less than 14 inches.
No documentation was found to verify the hydrostatic testpressures or the equivalent lengths of the valves used inthe system.
NFPA 12A — Halon 1301 Fire Extinguishing Systems
Results of the original concentration tests in the computerrooms were unsatisfactory indicating that insufficientquantity of Halon is provided or inadequate sealing of therooms exists.
2.
3.
Manual operation of the extended discharge cylinders, in theabsence of electricity, could not be verified.
A system nameplate for each protected area was not provided.
NFPA 13 — Installation of Sprinkler Systems
Documentation to show the water supply graphs with thehydraulic calculations was not provided.
2.
3.
4.
5.
6.
7.
8.
Unlisted valves and waterf low indicator switches areprovided on the sprinkler risers.
Improper procedures were used when performing hydrauliccalculations on the sprinkler systems. An outside hosedemand was not added into calculation.
Sprinkler spray patterns in several areas were obstructed.
The hydraulic design data is not provided on the sprinklerdrawings.
Various sprinklers under ductwork are not provided withmechanical guards.
Sprinklers are improperly spaced in Contractors'ccess Area.
Sprinklers are not provided as required under all ducts.
Impell Report No.09-0120-0123
1-2 Revi si on 0May, 1988
Ci il
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9.
10.
Sprinklers which are 12 inches apart are not provided withbaffles, as required.
Documentation to verify the water tight capabilities of thefloor was not available for review.
Due to the lack of accessibility and documentation, it couldnot be verified that all sprinklers are free of paint andornamental finishes.
12. The control room cable vault's sprinkler riser retardchamber may discharge onto the floor which contains numerousunsealed penetrations.
NFPA 14 — Installation of Standpipe and Hose Systems
Hydraulic calculations are not available to verify that flowand pressure requirements are met for Class II and IIIstandpipe systems.
2.
3.
4.
6.
7.
Hose lengths specified by the code cannot reach all areas.
A pressure gage is not installed at the top of eachstandpipe.
The valve in the main standpipe supply connection fromTurbine Building is not approved for fire service use and isimproperly located.
Pipe and fittings are not included in Table of AcceptableMaterials and are only listed for ambient pressure of150 psi instead of 175 psi required by code.
Hangers to securely restrain piping are inadequate.
Haterflow alarms on the standpipe system are not provided.
NFPA 15 — Hater Spray Fixed Systems
Discharge patterns from nozzles protecting charcoal filtersare obstructed.
2.
3.
Documentation showing working drawings, specifications, andtesting results for all the systems was not available forreview.
One charcoal filter spray system contains piping with aninadequate support.
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1-3 Revision 0Hay, 1988
f '
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I
4. Hydraulic calculations to verify the adequacy of the systemsprotecting the charcoal filter units was not available forreview.
5.
6.
One filter has improperly sized pipe.
No pressure gages are installed on the water spray systems.
NFPA 72D - Installation, Haintenance and Use of ProprietaryProtective Signaling Systems
Unapproved equipment is used in the installation.2.
3.
4.
Surveillance tests do not verify receipt or resetting ofalarm and supervisory signals, in control room, fromsprinkler systems, fire pumps and manual hose stations.
Protection of manual alarm stations and detection devices toprevent accidental operation is not provided.
Power cables between the ACI A924 panels and the power panelare undersized.
5.
6.
7.
8.
9.
10.
Class B electrical supervision for the alarm initiatingcircuits from the "EF" panels is not provided.
Haterflow alarm devices for the Auxiliary Building hosestandpipe system controlled by valves ZMO-10 and ZMO-20 arenot provided.
Detectors are inaccessible for maintenance and testing dueto equipment obstructions.
Indication by the "EF" panels for trouble conditions is notprovided.
Procedures do not require that the appropriate individualsbe informed of alarm system impairments.
Data is not available to confirm fault and overcurrentcompliance for the cables used.
NFPA 72E —Automatic Fire Detectors
2.
Several detectors are exposed to mechanical damage.
The placement of detectors with respect to equipment, beamconstruction, and below ceilings in many areas is improper.
Impell Report No.09-0120-0123
1-4 Revision 0May, 1988
3. The field of vision for the infrared detectors is obstructedby conduit/cable trays, other equipment or structure in manyareas.
4. Hany detectors were found obstructed or misaligned.
5. Surveillance testing is not in accordance with the code.
6. Improper spacing of detectors was found in several areas.
7. A smoke detector is placed too close to air supply diffusers.
Specific details, including the actual code sections, describingthese deviations and open items are presented in Sections 3.1through 3.8 of this report. These sections also provide thejustifications presented for the deviations and open items.
Impell Report No.09-0120-0123
1-5 Revision 0Hay, 1988
2.0 INTRODUCTION
Impell Corporation was contracted by American Electric Power ServiceCorporation, Indiana-Michigan Power Company, under Contract No. C-6945,to perform an NFPA code compliance evaluation of the fire protectionsystems in selected areas of the D.C. Cook Nuclear Plant.
D.C. Cook in their January 31, 1977 Response to Appendix A to BTP APCSB9.5-1 stated that: "All fire suppression systems have been designed andinstalled in accordance with the applicable NFPA Codes as follows: 12,12A, 13, 14, 15 and 17." This document also states, in Section E, FireDetection and Suppression, that: "Fire detection systems at the CookPlant conform to the applicable portions of NFPA 72D except for thetesting frequency specified in Paragraph 1232."
Although D.C. Cook did not commit to NFPA 10 and 72E, Impell wasrequested by AEP to include these codes as part of the review.
2.1 Scope of Work
Impell's scope of work was to determine the compliance, ornoncompliance, of the fire protection systems installed in theselected areas to the specific NFPA code requirements (editionyears identified by the utility) which were in effect at the timethe fire protection systems were designed and/or installed.
The areas of the plant, that were reviewed, included:
~ The Auxiliary Building
~ The Auxiliary Feedwater Pump Rooms in the Turbine Building~ The Essential Service Water Pump Rooms in the Screen House
~ The Unit 1 and Unit 2 Control Rooms
The NFPA Codes used for the evaluation included:
101212A13'4
1572D
72E
Portable Fire Extinguishers; 1970 and 1984 EditionsCarbon Dioxide Extinguishing Systems; 1968 EditionHalon 1301 Fire Extinguishing Systems; 1977 EditionInstallation of Sprinkler Systems; 1971 and 1983 EditionsInstallation of Standpipe and Hose Systems; 1971, 1978,1980 and 1986 EditionsWater Spray Fixed Systems; 1973 EditionInstallation, Maintenance and Use of ProprietaryProtective Signaling Systems; 1967 and 1979 EditionsAutomatic Fire Detectors; 1974, 1978, 1982 and 1984Editions
Impell Report No.09-0120-0123
2-1 Revision 0Hay, 1988
2.2 Hethodology
Impell conducted the code compliance evaluations in two phases.Phase I identified the fire areas/zones containingsafety-related/safe shutdown equipment and also selected therelevant code sections governing the functional aspects of thefire protection systems in these areas. The Phase II portion ofthe work consisted of the actual code verification effort.The identification of the fire areas/zones in the Phase I task wasaccomplished by reviewing the D.C. Cook Plant's Fire HazardsAnalysis which described the fire areas/zones containingsafety-related/safe shutdown equipment. Each of the identifiedNFPA codes were reviewed in depth to determine which sectionsspecifically addressed the ability of the system to operate. Codesections covering topics, such as: information only, referencesto other NFPA codes, construction or equipment arrangement andnonrelevant types of occupancies were not included in theevaluations as these sub]ects do not affect the ability of thesystems to function.
Each of the codes and their respective sections were developedinto a matrix, entitled Code Compliance Verification Checklist(CCVC) and shown in Appendix B1 through 88 in this report. Thismatrix identifies each code section to be verified, theverification method to be used (walkdown, document search or both)and a sugary of the results of the evaluation.
'o
facilitate the verification process, two additional matriceswere developed, a Halkdown Verification Checklist (NVC) and aDocument Verification Checklist (DVC). These checklists list theapplicable code sections; whether the installed systems did/didnot,comply or if the code sections were not applicable to theinstalled system; and comments for each noncomplying/notapplicable section. The DVC had an additional column to identifythe documents revi ewed for verification of the specific codesections.
In Phase II, walkdowns were conducted to verify each of the codesections. The walkdowns were conducted by four teams of twoengineers each. Each team was assigned two of the eight codes tobe verified. This effort was conducted at the D.C. Cook Plantduring the period of November 9 through December 1, 1987.
Upon completion of the walkdowns the teams returned to theirrespective home offices to complete the document search portion ofthe code verification process.
Impe11 Report No.09-0120-0123
2-2 Revision 0May, 1988
2.3 General Assumptions
This report utilized the following genera'l assumptions shown belowand the additional assumptions identified in Sections 3.1 through3.8 of this report.
All drawings, procedures, design specifications and otherdocumentation provided to Impell for use on this project arethe latest revision, most current, available.
2.
3.
4.
5.
Specifications and drawings were used to evaluate thepiping, fittings and miscellaneous hardware used in the fireprotection systems to confirm compliance with therequirements of the appropriate NFPA codes in effect at thetime of installation.
Horkmanship and construction practices during installationof the systems complied with the code requirements in effectat the time.
Engineering evaluations to provide justifications for thepartial detection/suppression coverages are outside thescope of this contract.
It is assumed that all Surveillance Tests and Procedures areproperly implemented.
Impell Report No.09-0120-0123
2-3 Revision 0May, 1988
3.0 CODE COMPLIANCE EVALUATIONS
This section provi'des a detailed review of each specific NFPA codeevaluated. This review includes: the scope of work for each evaluation,what assumptions were made, and a table listing the deviations/open itemsfrom the specific code sections and the recommendations/)ustificationsfor each deviation or open item.
Impell Report No.09-0120-0123
3-1 Revision 0May, 1988
3.1 NFPA 10 - Portable Fire Extinguishers
3.1.1 Scope of Evaluation
The evaluation of the portable fire extinguisher system wasreviewed under the 1984 edition of the code. Although thesystem was installed under different edition years from 1970to 1984, the difference in the edition requirements wereminimal and the 1984 edition year was deemed to be moreapplicable to the installed system.
The evaluation of the portable fire extinguisher systemverified the following features:
l. Proper types of fire extinguishers have been providedbased upon the characteristics of the anticipated fires.
2. Fire extinguishers have been properly distributedthroughout the plant.
3. Procedures for the Inspection, Maintenance and Rechargingof fire extinguishers are satisfactory.
3.1.2 Assumptions
The following assumption has been made for the evaluation ofNFPA 10.
3.1.3
1. Service activities performed on the fire extinguisher byall outside service companies are performed in accordancewith the appropriate sections of the code.
Oeviations and Recommendations/Justifications
In several areas of the plant it has been recognized thatClass A extinguishers are not provided for the protection ofClass A combus'tibles. In many of these instances, the FHAhas taken credit for the NFPA 10 code section that permitssmall hose stations, for use by building occupants, to beused as a replacement for every other extinguisher requiredfor Class A protection.
As brought out in Section 3.5 of this report, the hosestations that are provided in this plant for use by "trainedindividuals only" and, as such, cannot be used to offset therequirement for Class A extinguishers.
The portable fire extinguisher system at the plant is incompliance with .NFPA 10 except as identified by the openitems and deviations in Table 3.1-1. The table also providesrecommendations/justifications for these items.
1984Deviation:Several fire zones inbui lding have Class Aoccupancies and are notprovided with extinguisherssuitable for Class A hazards.These zones are:
which are not within 75 feetof a Class A extinguisher or50 feet of a Class 8extinguisher.
AEP to provide justification.
4-3.2 1984Deviation:The extinguisher locationsare not properly identifiedon the fire facility drawingsand procedure.
AEP to provide justification.
4-3.4.24 4.3
Deviation:1984 The date of inspection and
the initia'ls of the inspectorare not recorded.
Justification:Fire extinguishers inspectionsare only performed by thesafety and assessment department.All extinguishers have tags whichindicate the month the inspectionwas performed by a hole beingpunched in the card. This-satisfies the intent of the coderequirement.
1-6. 2 1984Deviation:Several extinguishers are notlocated in their designatedlocations as shown on thefire facilities drawings.
AEP to provide justification.
Impell Report No.09-0120-0123
3-6 Revision 0Hay, 1988
3.2 NFPA 12 - Carbon Dioxide Extinguishing Systems
3.2.1 Scope of Evaluation
This analysis evaluates the automatic carbon dioxide firesuppression systems installed in the following firearea/zones to the requirements of NFPA 12. The 1968 editionof NFPA 12 was the edition under which the systems wereinstalled and evaluated.
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39
40A4084142A42842C4546A46846C47A47855565758
Quadrant 1 Cable TunnelQuadrant 4 Cable TunnelQuadrant 3N Cable TunnelQuadrant 3H Cable TunnelQuadrant 3S Cable TunnelDiesel Oil Pump Room1 CD Diesel Generator Room1 AB Diesel Generator Room2 CD Diesel Generator Room2 AB Diesel Generator RoomDiesel Oil Pump RoomQuadrant 3N Cable TunnelQuadrant 3H Cable TunnelQuadrant 3S Cable TunnelQuadrant 4 Cable TunnelQuadrant 1 Cable TunnelQuadrant 2 Penetration CableTunnelQuadrant 2 Penetration CableTunnel4kv AB Switchgear Room4kv CD Switchgear RoomEng. Safety Syst. h HCC RoomEPS Transformer RoomEPS Control Rod Drive RoomEPS Hotor Control RoomEng. Safety Syst. h HCC RoomEPS Transformer RoomEPS Control Rod Drive RoomEPS Motor Control Room4kv AB'Switchgear Room4kv CD Switchgear RoomSwitchgear Room Cable VaultAuxiliary Cable VaultControl Room Cable VaultControl Room Cable Vault
Chapter 4 of this code applies to hand hose line systems.Twenty one hand hose lines are installed in the area/zonesevaluated to the requirements of this code. The reels arelocated as follows:
Fire Fire~A ~n
HH
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B
B
CCC8B
C
A 1 North wall of East/Hest corridorE 5 On wall beside Haste Evap.
Condensate TanksE 5 On wall across from the freight
elevatorE 6N On North wall by MCCE 6S On East wall by MCC'sB 79 On North wall of corridor between
DG'sB 85 On South wall of corridor between
DG'sC 32 Behind elevator across from roll-
up doorHH 44N On North wall of corridor across
from stair44N On East wall by ramp44S On East wall by ramp41 On East wall by MCC's45 On East wall by MCC's90 On East wall — outside 4kv96 On East wall - outside 4kv52 On East wall by ltg. cabinet51 On Hest wall by elevator52 On East wall by MCC129 Outside door of UlCR130 Outside door of U2CR69 On wall by stairs
Some code sections were not applicable, and therefore werenot evaluated. These code sections specifically providerequirements for the following:
Impell Report No.09-0120-0123
3-8 Revision 0May, 1988
1. C02 systems protecting flammable/combustible materialssuch as chemicals containing their own source of oxygen,reactive chemicals, etc.
2. Packaged (pre-engineered) systems.
3. Systems (and systems components) for high pressure C02protection.
4. Fixed, local application systems.
5. Systems des1gned for protection of process and storagetanks or combustible dust areas.
6. Areas where free-flow of the agent occurs.
7. Ventilation systems which do not shutdown (or close).
8. Systems for enclosed electrical equ1pment with run-downtimes.
9. Hazard whose ambient temperatures are below O'F or above200'F.
3.2.2 Assumptions
The following assumptions have been made in the evaluation ofNFPA 12.
l. Vendor documents describing listing/approval of systemcomponents are accurate.
2. The material/grade of pipe and fittings specified wasused in the system 1nstallation.
3. Documents reviewed are the latest available revisions andreflect "as-built" conditions of the plant.
4. In addition to American Electric Power ServiceCorporation, the authority having jurisdict1on for Unit 1
is NELPIA and for Unit 2 is IRI.
3.2.3 Deviations and Recommendations/Justifications
The carbon dioxide fire 'suppression systems evaluated meetthe requ1rements of NFPA 12 except as 1dent1fied by the openitems and deviations in Table 3.2-1. The table also providesrecommendations/justifications for these items.
Open Item:Locations of the pilotcabinets are such thatexcept for zones 55, 5657, 58, 59, 60, 7, 27,38, and 39 leakage of C02from the protected areasmay cause the oxygenconcentration to fallbelow acceptable limits.
Deviation:The pressure vent linesfrom the electro-pneumaticcabinets for the 4 mainheader valves and zones55 — 60 is disconnected sothat excess C02 ventsinto the tank room.
AEP to provide justi ficati on.
AEP to provide justification.
1311131213131314133
1968Open Item:Documentation to verify theauthority having jurisdict-ion was indicated and theauthorities requirements wasnot available for review.The requirements for testingand listing of equipment isincluded in this documentat-ion. Documentation to verifythat plans and calculationswere approved prior to workstarting was also not avai 1-able for review.
Justification:The systems were under theauthority of AEPSC. Plans,calculations, etc. were reviewedand approved . Additionally,acceptance tests were performed andand the systems were found to besatisfactory. Although after thefact, the approval, testing, etc.serves to meet the intent of thiscode requirement.
1322 1968Deviation:The plans do not containsufficient detail todetermine the hazards in thearea and the effectivenessof the system.
Jus tificati on:The FHA, schematic drawings, vendorcalculations and test resultsprovide sufficient detail todetermine the area hazards and theeffectiveness of the system.
Impell Report No.09-0120-0123
3-15 Revi si on 0Hay, 1988
T(Continued)
DEVIATION AND RECOMMENDATIONS/JUSTIFICATIONSNFPA 12 — C02 Extinguishment Systems
Open Item:No documentation was avail-able to verify that materialchanges necessitated by fieldconditions were approved or"as-built" drawings provided.
Open Item:No hydraulic calculations ortest data were available forreview for the new halon/C02nozzles in the control roomcable vaults.
Justification:Halkdowns did not identify anyobvious deviations from specifiedmaterials. AEPSC has also createdschematic flow diagrams whichaccurately reflect "as-built"conditions.
AEP to provide justification.
1341 1968
1422 1968
Open Item:The documentation whichdetails that tightness to the.selector valve, etc. wasverified was not availablefor review.
Deviation:The NFPA 72E Code Complianceevaluation concluded thatdetector spacing was notadequate in several zones.
Justification:The systems are tested on a 6 monthbasis (detection) and 18 monthbasis for "puff tests". The pipingtightness, leaks, etc. are verifiedvia these tests.
Justification:Refer to the NFPA 72E CodeCompliance Summary - Code Section2-6.5.
1423
1431
1968
1968
Deviation:The connections of the panelsto power sources are not incompliance with NFPA 72D.
Deviation:The ACI A909 panels are notlisted by an independenttesting laboratory. ThePyra-larm "EFR" and "GRC"panels are also not incompliance with NFPA 72D.
Justification:Refer to the NFPA 72D CodeCompliance Summary — Code Section2221.
Justification:Refer to the NFPA 72D CodeCompliance Summary - Code Section2032.
Impell Report No.09-0120-0123
3-16 Revision 0May, 1988
(Continued)
DEVIATION AND RECOMMENDATIONS/JUSTIFICATIONSNFPA 12 — C02 Extinguishment Systems
Deviation:The manual pull stations forzones 7 and 27 are notconveniently located andeasily accessible.
Deviation:The manual pull stations forzones 56 and 57 are notconveniently located andeasily accessible.
Deviation:The manual emergencyoperation is not locatedclose to the automaticallycontrolled valves for zones56 and 57.
Open Item:Documentation to verify thatmanual controls shall notrequire a pull of more than40 lbs. nor movement of morethan 14 inches was not avail-able for review.
Justification:Since plant procedure PMI-2270requires the C02 systems to beisolated and returned to service byby security for normal entry, aguard must be called to the areaprior to system actuation when afire is discovered. This willallow sufficient time to get tothe manual station.
Justification:Manual actuation stations areavailable on the "EF" panel whichis a short distance from thehazard. The short delay involvedwould not impact fire growth.
Justification:The actual location of the valvesand manual release is not an issuesince the carbon dioxide system isused as a back-up to the halonsystem in these two fire zones.The intent of this requirement isto ensure that the automaticvalves can be observed foremergency operation. Since thesystem is a back-up to the halonthis degree of assurance is notnecessary.
AEP to provide justification.
144 1968Deviation:Remote signals from the C02panels to the control roomare not electricallysupervised.
Justification:Refer to the NFPA 72D CodeCompliance Summary — Code Sections2411 and 2422.
Impell Report No.09-0120-0123
3-17 Revision 0May, 1988
(Continued)
DEVIATION AND RECOMMENDATIONS/JUSTIFICATIONSNFPA 12 — C02 Extinguishment Systems
1623 1968Open Item:The specifications did notspecifically require that thepipe be reamed and cleanedbefore assembly and theentire piping was blown outprior to the nozzles beinginstalled.
Justification:The intent of this requirement isto ensure that the pipe of nozzlesare not blocked by foreignmaterial. The systems were alltested and are tested on an 18month basis. These tests includeagent flow which assures that thepiping network and nozzles are notblocked by foreign materials.
163 1968Open Item:No documentation could befound which adequatelyaddresses the acceptabilityof the in-line check valvesinstalled to isolate thehalon system from the C02system in the cable vaults.This is specifically true forthese valves in a carbondioxide use.
Justification:A full discharge acceptance testwas performed on the halon system.There were no problems or concernswith the check valves duringperformance of this test.
16321634
171
1968
1968
Open Item:No documentation was avail-able. to verify the hydrostatictest pressure or equivalentlength of the valves used inthe system.
Deviation:The systems evaluated weretested on an 18 month basisrather than annually.
AEP to provide justification.
Justification:The intent of the code is to verifysystem operability on a regularbasis. The "puff tests" are anacceptable alternative since thesystems are subject to specificprocedures governing theirimpairment.
1712 1968Open Item:No documentation was providedwhich showed that systemdischarge tests shall be madewhen inspection indicatestheir advisability.
Justification:The system undergoes a "puff test"on an 18 month interval. This isan acceptable time interval forsystem discharge testing.
Impell Report No.09-0120-0123
3-18 Revision 0May, 1988
T 8(Continued)
DEVIATION AND RECOMMENDATIONS/JUSTIFICATIONSNFPA 12 — C02 Extinguishment Systems
1716 1968Open Item:No documentation was avai 1-able to verify that theliquid level gages arechecked annually.
AEP to provide justification.
1721 1968
2212 1968221322212441
2212 196822132441
Open Item:No documentation wasprovided which specificallydiscusses the corrections ofsystem impairments.
Deviation:Two reactor cable quadrants(zones 8 and 26) containcurtain dampers in theceiling which are not closedupon system actuation.Additional gas is notprovided to compensate forthis leakage.
Deviation:Small openings are found inthe walls constructed inzones 55 and 60 which permitthe escape of carbon dioxideto the corridor which doesnot contain C02 dischargenozzles. Additional gasis not provided to compensatefor this leakage.
Justification:The plant procedures provide formitigating measures to be takenwhen systems are impaired. Also,the systems evaluated aretechnical specification. Thisindicates that their impairment isto be corrected in a timely manner.
Justification:The system discharge tests indicatethat since the openings are in theceiling an acceptable level ofC02 concentration was reached andmaTntained.
Justification:A discharge test was performed forthe zones. The only open item wasa fan without a damper. This hasbeen compensated for by dampersand/or fan interlocks. Therefore,the installation is acceptable.
22212441
1968Deviation:Door 332 in fire zone 18 isnot provided with a device toclose upon system actuation.Additional gas is notprovided to compensate forthis leakage.
Justification:This door is not a normal path oftravel and is provided with a selfcloser. Additionally, it is not acommon practice to breach doors bybarring them open in the plant.The intent of this coderequirement is therefore met.
Impell Report No.09-0120-0123
3-19 Revision 0May, 1988
(Continued)
DEVIATION AND RECOMMENDATIONS/JUSTIFICATIONSNFPA 12 — C02 Extinguishment Systems
Open Item:The method of volume deter-mination by the vendor wasnot available for review forthis code requirement.
Deviation:The discharge times for thezones designed for flash fireprotection (zones 13, 15, 1618, 19 and 21) are in excessof 1 minute.
Justification:System discharge tests wereperformed whi ch determined thequantities of C02 to beacceptable.
Justification:This fast discharge time isdesigned to provide suppressionprior to metal surfaces beingheated. The discharge times areunder 2 minutes and theconcentration held for asufficient period of time. Thisshould prevent re-ignition of thefuels by the hot surfaces.Additionally, manual C02 hosereels are provided for use.
Impell Report No.09-0120-0123
3-20 Revision 0Hay, 1988
3.3 NFPA 12A-Halon Fire Suppression Systems~
~ ~3.3.1 Scope yf Evaluation
This analysis evaluates the automatic Halon 1301 firesuppression systems installed in the following firearea/zones to the requirements of NFPA 12A — 1977 Edition.The 1977 edition was the edition under which the systems wereinstalled.
FFP~rbk FFF ~UU
BBBBBB
57
58
7172
1 Control Room Cable Vault and HotShutdown Panel Cable Area
2 Control Room Cable Vault and HotShutdown Panel Cable Area
1 Computer Room2 Computer Room
Some code sections were not applicable, and therefore, werenot evaluated. These code sections specifically providerequirements for the following:
1. Local application Halon fire suppression systems.
2. Halon systems protecting multiple hazards by the use ofdirectional valves.
3. Halon systems/components installed at altitudes in excessof 3,300 ft.
4. Halon systems actuated by heat detectors.
5. Halon systems utilizing factory charged nonrefillablecontainers.
6. Halon systems providing protection of hazards containingflammable liquids and/or gases.
7. Halon systems providing protection of hazards containingexotic flammable/combustible materials.
3.3.2 Assumptions
The following assumptions have been made for the evaluationof NFPA 12A:
,
l. Vendor documents describing listing/approval of systemcomponents are accurate.
2. The material/grade of pipe and fittings specified wasused in the system installation.
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3-21 Revision 0Hay, 1988
3. Documents reviewed are the latest available revisions andreflect "as-built" conditions of the plant.
4. The authority having )urisdiction for Units 1 and 2 isAmerican Electric Power Service Corporation.
3.3.3 Deviations and Recommendations/Justifications
The Halon 1301 fire suppression syst'ems evaluated meet therequirements of NFPA 12A except as identified by the openitems and deviations in Table 3.3-1. The table also providesrecommendations/)ustifications for. these items.
Deviation:The original test results forthe computer rooms (zones 71and 72 were unsati sfactory.This indicates that thehazard areas may not containa sufficient quantity of Halon1301 for a sufficient periodof time.
Open Item:Calculations for the extendeddischarge cylinders installedfor the protection of thecontrol room cable vaults(zones 57 and 58) were notavailable for review.
Open Item:Documentation of any materialchanges required by fieldconditions was not availablefor review.
AEP to provide justification.
Justification:References provided indicate thatdischarge tests for the controlroom cable vaults were satisfactoryThe availability of calculationsfor these cylinders is not an issuesince the Halon concentration ismaintained for a sufficient periodof time. The placement of thetest probes was sufficient toverify a good distribution ofHalon.
Justification:The plant specifications complywith the requi rements of this code.Walkdowns did not identify anyobvious deviation from thespecification requi rementspertaining to material.
Impell Report No.09-0120-0123
3-25 Revision 0May, 1988
(Continued)
DEVIATION AND RECOMMENDATIONS/JUSTIFICATIONSNFPA 12A — Halon 1301 Extinguishment Systems
Justification:The computer room systems (zones71 and 72) are very small and theirpipe routing is consistent withthe UL listed design manual. Thedrawings submitted for review werealso within a reasonable toleranceof the installed system.
The control room cable vaultsystems (zones 57 and 58) areadequately shown in schematicdrawings produced by AEPSC. Anyfuture changes in system layoutmay be easily accomplished byreviewing these drawings.
1-8.2.3 1977Open Item:The NFPA 72E Code ComplianceEvaluation indicates that thesmoke detectors installed inthe control room cable vaultsare spaced in accordance withNFPA 72E for signaling.However, the Halon systemactuation is accomplished bysignals from cross zoneddetection circuits and notevery ceiling bay in thevaults is provided with crosszoned detectors. This mayresult in delayed responsefor system actuation, whichis in conflict with the intentof the code requirements.
Justification:Every bay in the area is providedwith a detector which wi 11 alarm inthe control room. Plant operatorsw'ill immediately respond and caninitiate the system manually.
1-8.3.2 1977Deviation: Justification:The ACI 2035 panels used for Refer to the NFPA 72D Codethe Control Room cable vault Compliance Summary - Code Sectionhalon systems are not listed. 2032.
Impell Report No.09-0120-0123
3-26 Revi sion 0May, 1988
T(Continued)
DEVIATION AND RECOMHENDATIONS/JUSTIFICATIONSNFPA 12A — Halon 1301 Extinguishment Systems
1-8.3.5 1977Deviation:The manual actuation for theControl Room cable vaults(zones 57 and 58) are notlocated conveniently andeasily accessible.
Justification:Hanual actuation stations areavailable on the "EF" panel whichis a short travel distance from thehazard. The short delay involvedwould not impact fire growth.
1-8.3. 6 1977
1-8.3.7 1977
Open Item:Operation of the extendeddischarge cylinders protect-ing the Control Room cablevaults (zone 57 and 58) viathe Ansul Automan could notbe verified in the absence ofelectricity. The maincylinders contain manualreleases at the "master"cylinder which couldpotentially discharge themainbank but not the extendeddischarge cylinders.
Open Item:Documentation to verify thatmanual controls shall nothave a pull of more than 40pounds nor movement of morethan 14 inches to secureoperation could not be found.
AEP to provide justification.
Justification:The manual pull stations for thehalon systems evaluated are listedfor this service. They areintended for this service and aretherefore acceptable.
1-8.5.1 1977Open Item:The NFPA 72D Code ComplianceEvaluation could not finddocumentation to verify thatalarms for the Control Roomcable vault (zones 57 and 58)are provided in the hazardto indicate system alarm,pre-discharge and discharge.
AEP to provide justification.
Impel 1 Report No.09-0120-0123
3-27 Revi sion 0Hay, 1988
(Continued)
DEVIATION AND RECOMMENDATIONS/JUSTIFICATIONSNFPA 12A — Halon 1301 Extinguishment Systems
Open Item:No documentation could befound to verify that theHalon used for the systemscomplies with MilitarySpecification HIL-H-12218B.
Deviation:A system nameplate is notprovided for any of theareas/systems which wereevaluated.
Open Item:Documentation to verify thatjoint compound, tape orthread lubricant shall beapplied to only the malethreads of the joint was notavailable for review.
Justification:The agent and equipment ispurchased from a fire protectioncontractor. It is specified in theP.O. that all equipment is for useas part of a Fire Protection QAprogram and each item (or package)must be UL listed or FH approved.For the computer rooms, thesystems are pre-engineered andtherefore acceptable since theyare approved or listed as apackage. In the case of the agentfor the control room cable vaults,in order to meet UL listingrequirements, the fill stationsmust be UL listed. Therefore,these systems are also acceptable.
AEP to provide justification.
Justification:The systems were acceptance testedand have been discharged on an 18month interval as' part of theirtesting. The intent of this coderequirement is to ensure the pipingnetwork is not blocked and toensure a tight fit in the pipingnetwork. The discharge tests haveverified these items. Therefore,the intent of this requirement ismet.
Impell Report No.09-0120-0123
3-28 Revision 0Hay, 1988
(Continued)
DEVIATION AND RECOMMENDATIONS/JUSTIFICATIONSNFPA 12A — Halon 1301 Extinguishment Systems
Open Item:Documentation to verify thatwelding and brazing alloyshave a melting point greaterthan 1000 F could not belocated.
Open Item:No documentation could befound which verifies that thepiping was blown out beforethe nozzles were attached.
Open Item:No documentation could befound to verify that theinline check valves installedin the Control Room cablevault systems to isolate theC02 system from the Halonsystem are listed/intendedfor this specific service.
Deviation:The systems are notthoroughly inspected andtested at least annually.A full discharge test isperformed on an 18 monthbasis.
Justification:The integrity of the pipingnetworks were tested by initialsystem discharge tests and the18 month testing which has beencompleted. Any fai lure of pipingnetworks would have appeared
- during these tests. Additionally,the systems are not installed inarea/zones where a quick build-upof heat from a fire may causedamage to system piping prior todetection.
JustificationThe systems have been dischargetested on an 18 month basis. Thisassured that no blockage occurredin the piping network.
Justification:A full discharge acceptance testwas performed on the halon system.There were no problems or concernswith the check valves during theperformance of this test.
Justification:The systems should not be subjectto hazards which could render theminoperable or adversely affecttheir functionality. Strictprocedures are in place to ensuretheir operation followingmaintenance. The 18 month testingaddresses the full operability ofthe system and is thereforeacceptable.
Impell Report No.09-0120-0123
3-29 Revision 0May, 1988
AB -1(Continued)
DEVIATION AND RECOMMENDATIONS/JUSTIFICATIONSNFPA 12A - Halon 1301 Extinguishment Systems
Open Item:No documentation was foundwhich indicates thatdischarge tests will4eperformed when inspectionindicates their advisability.
Open Item:No documentation was foundwhich indicates thatinspection reports for theComputer Rooms (zones 71 and72) are filed with the owner.
Open Item:No documentation was foundwhich indicates that thesystem(s) are inspectedvisually following anapproved schedule andprocedure between annualtests.
Justification:The systems evaluated are testedon an 18 month interval as a partof their testing/inspection.Deficiencies identified from thetesting/inspections should berecorded for corrective actions.This is a sufficient criteria tomeet the intent of this coderequirement.
'ustification:
Procedures are in place atinstallations such as this forsystem inspections. Thisrequirement is more applicable toinstallations where inspection/testing reports are not maintainedin general.
Justification:The systems are tested on an 18month basis. This detail ofinspection/test is adequate.Additionally, the weights andpressures are verified andrecorded on a 6 month basis.
Deviation:1-11.8 1977 The weight and pressure of
the container is not recordedon an attached tag.
Justification:The intent of this requirementis to provide an easy means ofreviewing weight and pressure forinspections. The cylinder weightsand pressures are identified on acylinder nameplate. Therefore,the intent of this requirement ismet. Additionally, the weightsand pressures are verified andrecorded on a 6 month basis.
Impell Report No.09-0120-0123
3-30 Revision 0May, 1988
(Continued)
DEVIATION AND RECOMMENDATIONS/JUSTIFICATIONSNFPA 12A - Halon 1301 Extinguishment Systems
Deviation:The initial discharge of theHalon systems in the ControlRoom cable vaults (zones 57and 58) is in excess of 45seconds. The coderequirement is less than 10seconds.
Justification:This requirements is in place dueto the toxic by-products of Halon1301 and its effect on personnel asit decomposes in the presence ofhigh temperatures. The shorterdischarge time permits the agent toreact faster, not permitting thetime exposure of the agent to thehigh temperatures. The cablevaults are not normally occupiedareas and the Halon systems areisolated from automatic actuationwhen personnel are in the vaults.For these reasons, the dischargetime is acceptable.
Impell Report No.09-0120-0123
3-31 Revi sion 0May, 1988
3.4A NFPA 13-1971 Sprinkler Systems~
~ ~3.4A.1 Scope of Evaluation
This analysis is to verify that the sprinkler systems in theDrumming Area, Aux. Bldg. Crane Bay (High Roof) Area, andthe Control Room Cable Vault Area are in compliance with thestandards of NFPA 13 — 1971 edition. The systems at D.C.Cook were originally designed under the jurisdiction of the1971 Edition of NFPA 13. Over the course of D.C. Cook'history, modifications to the sprinkler systems wereperformed. The last of these modifications were completedunder the jurisdiction of the 1983 Edition of NFPA 13. Forthe purpose of this evaluation only the original (1971) andlast (1983) Editions of NFPA 13 in effect during the systemdesi gn/installation phase were utilized. Systems which hadno modifications following the initial design were evaluatedagainst the requirements of the 1971 Edition. Systems whichwere modified following the initial design, or designedafter the initial design, regardless of what year, wereevaluated against the requirements of the 1983 Edition.Changes in the code editions between 1971 and 1983 were notsubstantial to warrant a separate evaluation for eachedition. Additionally, the deviations/open items identifiedin the evaluation could not be fully addressed by utilizinginterim code editions. The following areas contain systemsnot modified following the initial design and which wereevaluated under the 1971 edition:
Pr
Pre-Action
Pre-Action
Net-Pipe
3.4A.2 Assumptions
32
58
Drum Storage Area
Aux. Bldg. Crane Bay(High Roof) Area
Unit 2 Control RoomCable Vault
The following assumptions have been made for the evaluationof NFPA 13.
l. The fire protection systems at the D. C. Cook Plant arenot "subject to earthquakes" as it pertains to NFPAcodes.
2. The wet-pipe sprinkler system in the control room cablevault was installed per 1971 specifications.
Impell Report No.09-0120-0123
3-32 Revision 0Hay, 1988
3. The High Roof Area and the Drumming Area are assumed tohave smooth ceiling construction.
3.4A.3 Deviations and Recommendations/Justifications
The sprinkler systems evaluated are in compliance withNFPA 13 — 1971 except as identified by the open items anddeviations in Table 3.4A-1. The table also providesrecommendations/justifications for these items.
Deviation:There are no checklists forany test procedures regard-ing the control room cablevault sprinkler system.
Open Item:The instructions charts orcare maintenance pamphlets(NFPA 13A) are not providedfor the C.R. cable vault.
Justification:The fire hazards analysis does notrely upon the wet-pipe sprinklersystem for controlling fires inthe C.R. cable vault. Althoughthe sprinkler system is stillfunctional, any deviations fromthe code do not impact the safetyfeatures of the area since bothhalon and C02 systems are alsoprovided.
Justification:See response to code section 1041.
1141
1412
1511163116321700
1611
. 1971
1971
1971
1971
Open Item:Documentation could not befound to verify if theflooring is watertight.
Open Item:No documents stating thatall materials and devicesinstalled for the sprinklersystems were new or consideredsatisfactory for reuse.
Open Item:There are no documentsstating that the installa-tion and testing of thesprinkler systems have beencompleted.
Deviation:There are no certificates ofacceptance for all systems.
AEP to provide )ustification. Thecriteria used in an 83-41 study ismore applicable to D.C. Cook.
Justification:The materials and devices specifiedin the 1971 piping and installationspecification are in accordancewith this standard and thereforeacceptable.
Justification:See response to code section 1412.
Justification:Test procedures show that thesystems are operable. Also, seeresponse to code section 1041.
1620 1971Deviation:Installation specificationsdo 'not require 1 ead-inconnections to be flushed.
Justification:No action is required since thetest procedure (12 OHP4030.STP.120) requires periodicflushing of all systems.
Impell Report No.09-0120-0123
3-39 Revision 0May, 1988
(Continued)
DEVIATION AND RECOMMENDATIONS/JUSTIFICATIONNFPA 13 - Installation of Sprinkler Systems (1971)
Deviation:The lower riser gage for thehigh roof area has an upperlimit that is not compatiblewith the normal workingpressure. Presently, thegage limit is 200 psi whilethe system working pressureis 150 psi.
Justification:The intent of this code requi rementis to establish gage accuracy onsystems which are normallyinstalled on systems subject tolarge fluctuations in pressure.The water .system at D.C Cook is notsubject to large pressure surgesand therefore the gage isacceptable.
3051
30913092309330943095
32113213
1971
1971
1971
Deviation:The drumming area drawing(46-032-71M-16) shows 8sprinklers on one branch linewhere only 6 are allowed.
Open Item:There are no documents toverify proper installationof pipe fittings and joints.
Open Item:There are no documents toverify whether the pipingfor the C.R. Cable Vault isproperly pitched to drain.
Justification:The maximum of 6 sprinklers iscontained in the code section.The pipe schedule table; however,indicated that up to 8 spri nklersmay be supplied by 2" pipe in thehazard classification. The pipesupplying the 8 sprinklers is 2"size and the plant has an adequatewater supply. Therefore, thisinstallation is acceptable.
Justification:See response to code section 1412.
Justification:See response to code section 1041.
3212 1971Open Item:There are no documents toverify all piping installedwere straight.
Justification:See response to code section 3091.
32413783
1971Deviation:At the C.R. Cable VaultRiser, the retard chamberdischarges to the floorcontaining numerous unsealedpenetrations.
AEP to provide justification.
Impell Report No.09-0120-0123
3-40 Revision 0Hay, 1988
T 4-(Continued)
DEVIATION AND RECOMMENDATIONS/JUSTIFICATIONNFPA 13 - Installation of Sprinkler Systems (1971)
Deviation:Numerous hangers in theC.R. Cable Vault are tooclose to the sprinklerheads.
Deviation:Drawings show that 250 Frated sprinklers are usedfor the high roof anddrumming areas where 175 F
to 225'F sprinklers shouldbe used.
Justification:See response to code section 1041.
Justification:Code section 3654 allows using hightemperature rated sprinklers forspecial hazards.
36&136823683
3691
3761
1971
1971
1971
Open Item:Due to the congestion andlack of accessibility,sprinklers could not beverified to be free ofpaint and ornamentalfinishes.
Open Item:There are numerous obstaclesunder sprinklers in the C.R.Cable Vault.
Deviation:The electrically operatedattachments do not meet allof the referenced NFPA codes.
AEP to provide justification.
Justification:See response to code section 1041.
Justification:Refer to NFPA 72D (1967) CodeCompliance Summary-Code Section2032.
3762 1971Deviation:The procedures do not verifyall of the necessary testingsteps for the water flowalarms.
Justification:Refer to NFPA 72D (1967) CodeCompliance Summary-Code Section2034.
40114032
1971Open Item:There are no documents toshow whether the authorityhaving jurisdiction wascontacted for the C.R. CableVault (4011) and the drummingarea (4032).
Justification:See response to code section 1041for the control room cable vault.See response to code section 1412for the drumming area.
Impell Report No.09-0120-0123
3-41 Revision 0Hay, 1988
(Continued)
DEVIATION AND RECOMHENDATIONS/JUSTIFICATIONNFPA 13 - Installation of Sprinkler Systems (1971)
1971Deviation:The 130 ft2/pilot headspacing indicaged by drawingsand the 100 ft~/sprinklerspacing indicated by spegifi-cations exceed the 90 ft~/sprinkler spacing requiredfor extra hazard occupancy.
Justification:There is no action required sincea review of the drawings show thatthe sprinkler spyci ng does notexceed the 90 ft4/sprinklercriteria.
4143 1971Deviation:Branch lines are not placedmidway in each bay or spacein the C.R. Cable Vault.
Justification:See response to code section 1041.
4156 1971421142314316
Deviation:There are numerous sprinklerdeflectors which are tooclose to beams in the C.R.Cable Vault.
Justification:See response to code section 1041.
4221 1971Deviation:The sprinkler nozzles forall three systems evaluatedunder this code edition arein excess of 12" from thecei 1 ing.
Justification:The control room cable vault justi-fication is identified in theresponse to code section 1041.
Justification:The ceiling in the high roof areais so high that a thermal effectmay occur. Additionally, smokedetectors are installed whichprovide alarm in the control roomfor response to fires in the area.
Justification:The pilot lines in the drummingarea are located such that thepilot nozzles are placed inaccordance with this codesection. Their actuation causesalarm in the control room forresponse. Therefore, theinstallation is acceptable.
Open Item:Due to congestion and lackof accessibility, the impactof lighting fixtures on thesprinkler systems could notbe assessed.
Deviation:The actual pre-action pipingfor the systems protectingthe high roof and drummingarea are not supervised andN.E.P.I.A. has not approvedthe systems.
Justification:The control room cable vault)ustification is identified in theresponse to code section 1041.
Justification:The remaining 2 zones have highroof areas. The location of thelights could not seriously affectthe pattern of spray from nozzles.
Justification:The intent of this code section isto provide a means of alarm in theevent of damaged system piping/nozzles. The systems in the highroof and drumming area are highenough and located such that theyare not easily damaged. Therefore,the installations are acceptable.
Impell Report No.09-0120-0123
3-43 Revision 0Hay, 1988
3.4B NFPA 13-1983 Sprinkler Systems
3.48.1 Scope of Evaluation
The systems at D. C. Cook were originally designed under thejurisdiction of the 1971 Edition of NFPA 13. Over the
. course of D. C. Cook's history, modifications to thesprinkler systems were performed. The last of thesemodifications were completed under the )urisdiction of the1983 Edition of NFPA 13. For the purpose of this evaluationonly the original <1971) and last (1983) Editions of NFPA 13in effect during the system design/installation phase wereutilized. Systems which had no modifications following theinitial design were evaluated against the requirements ofthe 1971 Edition. Systems which were modified following theinitial design, or designed after the initial design,regardless of what year, were evaluated against therequirements of the 1983 Edition. Changes in the codeeditions between 1971 and 1983 were not substantial towarrant a separate evaluation for each edition.Additionally, the deviations/open items identified in theevaluation could not be fully addressed by utilizing interimcode editions. The systems specifically evaluated againstthe 1983 Edition protect the following areas:
Het-Pipe
Het-Pipe
Het-Pi pe
Het-Pipe
Pre-Action
Pre-ActionPre-Action
ZEK17C, 17E,
17F
79
85
105
1,5,6H,6N,6S
62A,62B,62C,
63A,63B,63C
64A,64B,65A'5 658
44N, 44S
51, 52
Unit 1 and Unit 2 TDAFW Pump
and AFH Pump CorridorUnit ¹1 Emergency Diesel
Generator Ramp and CorridorUnit ¹2 Emergency Diesel
Generator Ramp and CorridorContractor's Access Control
Bui 1 dingElevations 570'-0" and
587'-0"
Elevation 609'-0"
Elevation 633'-0"
Impell Report No.09-0120-0123
3-44 Revision 0Hay, 1988
3.4B.2 Assumptions
The following assumptions have been made for the evaluationof NFPA 13.
1. The referenced drawings, documents, and hydrauliccalculations are the latest revisions and they theyreflect the as-built condition of the plant.
2. The sprinkler piping for systems protectingsafety-related areas. except the Contractor's Access isseismically supported. Evaluation of the seismic hangersystem is outside the scope of NFPA criteria.
3.48.3 Deviations and Recommendations/Justifications
The sprinkler systems evaluated under this report complywith the requirements of NFPA 13 - 1983 except as identifiedby the open items and deviations in Table 3.48-1. The tablealso provides recommendations/justifications for these items.
contractor's access area isunavailable for review.
Justification:This system is sized in accordancewith ordinary hazard pipe schedulesystem, uses the appropriate typeof material and sprinklers, and isproperly supported based on awalkdown review. The informationfrom the system drawings shows thesystem to be adequate with thenoted exceptions in other coderequirements.
1-8.1.23-14.2.13-14.2.23-17.3.13-17.3.3
1983Deviation:Jamesbury butterfly isola-tion valves for wet pipesystems and the Hercoidpressure switches on allsystems are not U.L. listedfor fire service use.
Justification:The Jamesbury butterfly valve,although not listed, is adequatefor the intended service. Valveposition is indicated by an arrowon the valve body and is cast ofthe appropriate materials for theclass of service. The Hercoidpressure switch will be evaluatedunder NFPA 72D - Code Section 2032.
1-9.2Deviation:
1983 Hydraulic design data is notprovided on the sprinklerdrawings.
AEP to provide )ustiflcation.
1-11.1.1 19831-11.1.21-11.1.3
Open Item:Test certificates or docu-mentation that lead in mainshad been flushed at the properflow rates was not available.
Justification:Plant procedures (STP.120)requires a 2-inch main drainflush of all the fire systems.In addition, strainers areprovided on the fire pumpdischarge outlets to preventdebris and silt build-up.
Impell Report No.09-0120-0123
3-52 Revision 0Hay, 1988
(Continued)
DEVIATION AND RECOMMENDATIONS/JUSTIFICATIONNFPA 13 - Installation of Sprinkler Systems (1983)
1983Open Item:Test certificates or docu-mentation of system hydro-static tests was not availablefor review.
Justification:Although test certificates werenot available for the hydrostatictest of the given systems, theRequest For Change (RFC) packagesfor the sprinkler modificationsevaluated contained eitherpre-operational test procedures orreferences to work ordersrequiring hydrostatic testing. Itis assumed that those tests wereconducted.
2-2.1.2.4 19832-2.1.2.5
Deviation:Exterior fire hose demandswere not added to thehydraulic sprinkler systemcalculations.
AEP to provide justification.
3-9.1.1 1983
Impel.l Report No.09-0120-0123
Deviation:Cross mains at El. 633'avewelded caps on them whichprohibit flushing.
Open Item:Documentation is not avai 1-able to show that inspector'stest connection orifices areequivalent to one sprinklerfor the contractor's accessand the AFH Pump Room.
3-53
Justification:Current plant surveillanceprocedures and system pre-operational procedures requirethat a 2-inch main drain test beperformed for the preactionsprinkler system. This flushingcoupled with the strainersprovided on the plant fire pumpsensure that any debris or silt isremoved from the lead-ins to thesystem prior to its operation. Nocorrection is necessary.
Justi ficati on:Although a one sprinkler headequivalent is not provided on thecontractor's access area and Unit2 TDAFH pump room systems, fittingscan be installed on the inspector'stest pipes which wi 11 accommodatea sprinkler head. In addition,the reason behind this coderequirement is to ensure an alarmwill sound in a timely manner withone sprinkler flowing. Given theextremely small size of thesystems in question, this is not asigni,ficant concern.
Revision 0May, 1988
'(Continued)
DEVIATION AND RECOMMENDATIONS/JUSTIFICATIONNFPA 13 -'nstallation of Sprinkler Systems (1983)
3-12.1.2 1983Open Item:Documentation is not avai 1-able to verify that allthreaded fittings were cutto ANSI Standard 82.1.
Justification:The intent of this code requirementis to ensure that the waterway isnot blocked. Since preparationaltest procedures were performed toshow adequate flow, the systemsare considered operable.
3-12.1.3 1983Open Item:No documentation was foundto verify that joint compoundor tape was applied only tothe pipe threads.
Justification:The intent of this code section isto prevent the tape or jointcompound from clogging the pipeduring installation. Sincepre-operational tests wereperformed to show no blockage, allsystems are considered adequate.
3-15.3.1
3-16.8
1983
1983
Open Item:No documentation could befound to indicate that thematerials and tools usedfor installing power drivenstuds and welding studs werelisted.
Deviation:Various sprinklers underducts at El. 587, 609 and633 are not guarded.
Justification:The intent of this code require-ment is to ensure adequate studinstallation. Procedures werein place to test these installa-tions and certify them asadequate.
AEP to provide justification.
3-17.4.5 1983Deviation:The alarm test bypass valves AEP to provide justification.and the alarm pressure switchisolation valves are globevalves which are non-indicating.
4-1.1.14-1.1.4
1983Deviation:Sprinklers were foundobstructed in the followinglocations:
AEP to provide justification.
— Zone 6N: North area nearcolumn lines WL-L and WL-4,four consecutive sprinklersare blocked by piping.
Impell Report No.09-0120-0123
3-54 Revision 0May, 1988
(Continued)
DEVIATION AND RECOMMENDATIONS/JUSTIFICATIONNFPA 13 — Installation of Sprinkler Systems (1983)
16 and HL-L, sprinkler isobstructed by ductwork. Nearcolumn lines 15 and HL-L,sidewall sprinkler is blockedby fire main.~i'Sidewal 1 sprinkler heatcollection plates will inter-fere with discharge patterns.
— At column lines HL-L andHL-5, a heat collection plateis distorted such that thesprinkler discharge patternwill be blocked.
—At column lines WL-L.5 and WL-8,sprinkler water discharge isobstructed by numerous conduit.
— At column lines WL-L.5 andHL-8.5, a temporary curtain isinstalled too close to asprinkler head and willobstruct discharge.
P— In corridor area, an upright
sprinkler is obstructed bypiping.
— In Zone 17E, AFH Pump Rooman upright sprinkler isobstructed by conduit.
4-2.1.4 1983
Impell Report'o.09-0120-0123
Deviation:The pilot head in the SEcorner of Zone 44N (Col.HL-6.5 and HL-N) is too farfrom the east wall.
3-55
Justification:The pilot head in question wasestimated to be ten (10) to twelve(12) feet from the east wall;however, the overall area ofcoverage of the pilot head is farless than the 130 sq. ft.maximum. This coupled with thelack of any significantcombustible loading in the areaprotected does not indicate thatthis spacing would cause a delayin system response time to actualfire conditions.
Revision 0May, 1988
TA .48-1(Continued)
DEVIATION AND RECOMMENDATIONS/JUSTIFICATIONNFPA 13 - Installation of Sprinkler Systems (1983)
corner of the lowerelevation are too closeto a beam.
ELMS'Sprinklers at N end ofZone 52 (Col. HL-L) arerunning too close to abeam.
AEP to provide Justification.
4-2.3.14-3.1
Deviation:1983 Sprinklers at El. 570, 587
and 633 are greater than 12"below the ceiling.
Justification:The design was mandated andaccepted by the NRC in their SERand is therefore adequate for theApp. R protection being provided.
O Deviation:4-4.8.1.1 1983 EI. 633' There is no
sprinkler in the elevatorshaft.
Justification:Although outside NFPA 13 require-ments, this area does not needautomatic sprinkler protectionbased on the following features:'he elevator shaft is enclosed
by 3-hr. fire rated walls and1 1/2 hr. fire rated doors.
The combustible loading in thearea is negligible.
Sprinkler protection is providedad]acent to the elevator shaft.
4-4.13 1983Deviation:El. 633' Zone 52(Col. HL-L.5 between HL-3.5and HL-4.5). There are nosprinklers under a 6'ideduct.
AEP to provide justification.
4-4. 19 1983Deviation:El. 633'Col. HL-K.5 AEP to provide justification.and HL-3.8). Sprinklersunderneath duct work are lessthan 12" apart with no baffles.
Impell Report No.09-0120-0123
3-56 Revi si on 0May, 1988
(Continued)
DEVIATION AND RECOMMENDATIONS/JUSTIFICATIONNFPA 13 - Installation of Sprinkler Systems (1983)
data is not included in thehydraulic summary sheet.
Justification:Hydraulic design is adequatelycontrolled under engineeringresponsibilities. Design placardswould not enhance systemprotection or configurationcontrol of design modifications.
Justification:The system design criteria isincluded as part of the specifica-tions in the RFC package for thesesystems.
Justification:Hinimum design density, area, andflow parameters are included inthe calculation. Addition of thisinformation provides nosignificant benefit.
7-3.4Deviation:
1983 Hater supply graph sheets are AEP to provide Justification.not provided with the hydrauliccalculations.
Impell Report No.09-0120-0123
3-57 Revision 0Hay, 1988
'
3.5 NFPA 14 - Installation of Standpipe and Hose Systems
3.5.1 Scope of Evaluation
The evaluation of the standpipe and hose systems included therev1ew of these systems under three ed1tions — 1971, 1978 and1986. The initial edition year selected was based on theedition that was in effect at the time the original systemwas specified on April 2, 1971. All. subsequent edition yearsreviewed were applicable only to those areas wheremodifications occurred as identified in Calculation0120-108-005.
The modifications made in l980 were not evaluated against the1980 code edition as this edition was not adopted untilNovember 1980, after the modifications were completed. Theapplicable edition in effect at the time of the 1980modification was the 1978 edition.
3.5.2
The evaluation of the standpipe and hose systems verified thefollowing features:
l. Size and arrangement of standp1pes and hose outlets.
2. Number and location of standp1pes.
3. Adequate support of piping.
4. Adequate water supplies.
5. Arrangement of piping, valves and fittings.Assumptions
The follow1ng assumpt1on has been made for the evaluation ofNFPA 14.
l. The intent of the standpipe service at the plant was toprov1de Class II serv1ce for those stations wh1ch have asingle l-1/2 inch hose valve and Class III service atthose stat1ons wh1ch have both 2-1/2 inch and 1-1/2 inchhose valves.
3.5.3 Deviations and Recommendations/Justifications
The hose stat1ons provided at the plant have been labeled"for use by tra1ned ind1viduals only". Th1s el1minates therequirement for pressure reducers to restrict pressures to amaximum of 80 ps1 for the Class II and III stations. Thisalso eliminates all Class II and III service which, bydefi n1tion, is for use by building occupants.
Impell Report No.09-0120-0123
3-58 Revision 0May, 1988
- For the purposes of the code compliance evaluation the lackof pressure reducers and signs indicating that hose stationsare for use by building occupants is treated only as adeviation to the Class II requirements. The requirementsconcerning hydraulic demands at those stations, which wereoriginally intended as Class II, remain per the respectivecode section(s).
The standpipe and hose systems at the plant are in compliancewith NFPA 14 except as identified by the open items anddeviations in Table 3.5-1. The table also providesrecommendations/)ustifications for these items.
3.5.4 References
3.5.4.1
, 4
10
12
13
14
15
Oocument
0120-108-005A
0120-108-0058
0120-108-005C
0120-108-0050
0120-108-005E
0120-108-005F
0120-108-005G
0120-108-005H
0120-108-0053
0120-108-005K
0120-108-005L
0120-108-005M
0120-108-005N
0120-108-0050
0120-108-005P
Walkdown Verification Checklists
Unit 1 - '71, Elev.573'nit
1 - '7l, Elev.587'nit
1 - '71, Elev.609'nit
1 — '71, Elev.620'nit
1- - '7l, Elev.633'nit
2 - '71, Elev.573'nit
2 — '71, Elev.587'nit
2 - '71, Elev.609'nit
2 - '7l, Elev.620'nit
2 - '71, Elev.633'nits
1 & 2 — '71, Elev.573'nits
1 5 2 - '71, Elev.587'nits
1 h 2 - '7l, Elev.609'nits
1 h 2 - '71, Elev.650'nit
1 — '78, Elev.
620'evision
N /0
0 12/22/87
0 12/22/87
0 12/22/87
0 12/22/87
0 12/22/87
0 12/22/87
0 12/22/87
0 12/22/87
0 12/22/87
0 12/22/87
0 12/22/87
0 12/22/87
0 12/22/87
0 12/22/87
0 12/22/87
Impell Report No.09-0120-0123
3-59 Revision 0May, 1988
.4 References (Continued)
Document~Rf. R
RevisionM
16
17
18
19
20
21
0120-108-005Q
0120-108-005R
0120-108-005S
0120-108-005T
0120-108-005U
0120-108-005V
Units 1 & 2 — '78, Elev.633'nits
1 & 2 - '78, Elev.650'nit
1 - '86, Elev.591'nit
1 — '86, Elev. 625'
Unit 2 - '86, Elev.591'nit
2 - '86, Elev. 625'
12/22/87
0 12/22/87
0 12/22/87
0 12/22/87
0 12/22/87
0 12/22/87
3.5.4.2
12QHP 4030STP.007
12QHP 4030STP.006
12QHP 4030STP.003
Procedures
Monthly Visual Inspectionof the Plant Fire HoseStandpipe Connections
Visual Inspection and Re-Rackof Fire Hoses
Standpipe Operability Test
1 02/21/86
0 11/06/85
0 07/18/85
3.5.4.3
DCCPM102QCS
OCCFP103QCS
DCCPM104QCS
OCCPVllOQCS-F
SD-OCC-FP103
RFC-DC-12-2740
Technical Data
Shop and Field Fabricationand Erection
Fire Detection/SuppressionEquipment and Systems
Material Specification
Shop and Field Fabrication andErection of Fire ProtectionPiping
b. Isolation valve FP-263is not an indicating type.
Justification:a. Reel construction is the same
as a listed non-automatic reel.Also, hoses are used by trainedpersonnel only. Inconsideration of theseconditions the existing reelsare acceptable.
b. AEP to provide justification.
171Open Item:
1971 There is no record that theplans and specifications weresubmitted to authority havingjurisdiction.
Justification:Although these documents could notbe verified for approval, AEP (A/E)has plans and specifications forthese systems in their files.These diagrams and specificationsare controlled documents and aremaintained up to date by AEP.
Open Item:Documentation could notbe found to verify thatClass I and III stand-pipes are sized for minimumflow of 500 gpm plus 250gpm for each additionalstandpipe to maximum 2500gpm for a minimum 30 minutes.
AEP i s to provi de justi fication.
212a 1971Open Item:Not all standpipeminimum 4 inch inThe 'hose stationsare as follows:
E A
202E62B208
201E200E204E205E
risers are AEP is to provide justification.diameter.affected
596'09'20'96'96'96'96;
Impell Report No.09-0120-0123
3-63 Revision 0Hay, 1988
(Continued)
DEVIATION AND RECOHHENDATIONS/JUSTIFICATIONSNFPA 14 — Standpipe and Hose System
Open Item:1971 Class II standpipes shall be AEP is to provide justification..1971 sized for minimum flow of 1001978 gpm for a minimum 30 minutes.1986
321
322
1971
1971
62 & 62A41 & 41A
211 & 211A203 & 203A
58 & 58S45 & 45S82 & 82A65 & 65A
609'09'12'12'87'87'33'33'pen
Item:All areas of buildingprotected by Class II hosestations shall be within20 ft. of a nozzle attachedto not over 75 ft. of hose.
Deviation:Several areas which areserved by Class III hosestations are not within 30ft. of a nozzle attached tonot more than 100 ft. ofhose. These hose stationsinclude:
KLEV632K
Justification:Class II hose stations are for useby trained personnel. Coderequirements to limit the lengthof hoses to 100 ft. are primarilyintended to eliminate the problemsassociated with kinks occurring inexcessively long lengths of hose.With trained firefighters using thehoses with a minimum 5 persons inin attendance at any fire there arelong lengths of hose. With trainedfirefighters using the hoses witha minimum 5 persons in attendanceat any fire there are sufficientpersonnel available to assure thatkinking will not occur when extrahoses must be added to reach theremote areas.
Justification:In later edition code years anincrease to 30 ft. and 100 ft. ofhose, respectively, is permitted.For those zones that still donot comply (with the 30 ft. and100 ft.), AEP will provide.
Impell Report No.09-0120-0123
3-64 Revi sion 0Hay, 1988
(Continued)
DEVIATION AND RECOMMENDATIONS/JUSTIFICATIONSNFPA 14 — Standpipe and Hose System
216 1971Deviation:The auxiliary bui lding hosesystem at elevation
587's
not normally pressurized.
Justification:The hose system is arranged toactivate two motor operated valveson either end of the auxiliarybuilding supply main viaelectrical manual stations. Thesemanual stations are located ateach hose station in the auxiliarybuilding. Upon activating themanual stations the hose systemwill be pressurized. The systemsare pressurized upstream of themotorized valves. Therefore theintent of the code section isbeing met.
1-11.3 1978Open Item:As-built calculations were AEP to provide justification.not available for the Phoenixhose systems for review.
4134-1.2622
197119781971
Open Item:Approved valves are notprovided at the main riserto branches of hose outletsor at each riser controllingmore than two hose stations.
Justification:The intent of these code sectionsis to provide a means for isolatingbranches of hose stations or hosestation risers in the event thatduring a fire a portion of thebuilding collapses thus breakingeither the branch or riserscontrolling the hose stations.The valves permit shutting offthis portion of the standpipesystem in order to conserve waterfor the effective use of thefirefighters.
Because the Auxiliary Building isconstructed of reinforced concreteand seismically supported, thepotential for collapse due to fireis virtually non-exi stent, thusmaking these code sectionsaddressed not a concern.
Impell Report. No.09-0120-0123
3-65 Revision 0May, 1988
(Continued)
DEVIATION AND RECOMMENDATIONS/JUSTIFICATIONSNFPA 14 — Standpipe and Hose System
421 1971Open Item:Each hose outlet on Class IIstations should have amaximum of 75 ft. of hose.These hose stations include:
EUZIIIGR
Justification:In later edition years thisrequirement is changed to100 ft. of hose.
209 & 209A207 & 207A212 & 212A210 & 210A
650'12'12'50'32
4424-7.11-6.2
443
511524525
1971197119861986
1971
197119711971
Deviation:Hose for building occupantsshould have a sign sostating and pressureexceeding 100 psi should bereduced to maximum 80 psi.
Deviation:Hoses on wet systems shouldbe equipped with an open orautomat) c drip valve tocarry off slight leakagespast the hose valves toprevent wetting the hose.
Open Item:The adequacy of the watersupply for the hose systemcannot be verified.
Justification:Hose stations are marked "ForTrained Personnel Only" andpressures exceed 100 psi.Trained firefighters canhandle high pressure hose.
Justification:In 1971 the predominant hosein was linen hose. Nhenlinen hose became wet, itdeteriorated rapidly. Toprevent this deterioration,these valves were recommended.Linen hose is not provided at thisplant.
AEP to provide justification.
624Deviation:
1971 . An approved indicator valve AEP to provide justification.for valve no. FP 263 shouldbe provided.
Impell Report No.09-0120-0123
3-66 Revision 0May, 1988
(Continued)
DEVIATION AND RECOMMENDATIONS/JUSTIFICATIONSNFPA 14 - Standpipe and Hose System
Deviation:Approved hangers shall bearranged to securelyrestrain piping. Thispiping includes the AuxiliaryBuilding supply pipe valvein the main aisle atelevation 587'.
Deviation:A 3-1/2 inch dial springpressure gage is notprovided at the top of eachstandpipe.
Deviation:Haterflow alarms are notprovided on the standpipesystem controlled by valvesZHO-10 and ZH0-20.
Open Item:No information is availableon the original acceptancetests to verify that thehydrostatic tests wereconducted at pressures 50 psiabove normal pressures fortwo hours on the systemsincluding the underground.
Open Item:No information was availableon the original acceptancetests to verify that theleakage in underground pipingwas measured from a calibratedcontainer.
AEP to provide )ustification.
Justification:Standpipes located in firezones 55 and 60 have thesegages installed.AEP will provide )ustification forstandpipes that do not have thesegages.
Justification:See response to NFPA 72D,1967, section 3431.
Justification:Although these testdocuments were not avai lablefor review, the NRC regulatoryrequirements dictate thatsurveillance testing of thefire main system be performedto verify their operability.Therefore, the performance ofthese surveillance tests willprovide all equivalency for thiscode section.
Justification:Reference 711 above.
Impell Report No.09-0120-0123
3-67 Revision 0May, 1988
(Continued)
DEVIATION AND RECOMMENDATIONS/JUSTIFICATIONSNFPA 14 — Standpipe and Hose System
Open Item:No information was availableon the original acceptancetest to verify that theleakage at joints does notexceed 1-oz. per hour perinch of pipe diameter perjoint for lead or leadsubstitute joints. Or, 2quarts per hour per 100 jointsirrespective of pipe diameterfor gasketed joints.Deviation:The valves ZHO-10 and ZH0-20,are not open at all times toprovide a pressurized system.
Justification:Reference 711 above.
Justification:The valves ZHO-10 and ZHO-20are tested by procedure 12-OHP4030.STP. 120 every six months, inthe automatic mode to assure thatthey will open when required.This satisfies the intent ofhaving a pressurized system at alltimes.
724Deviation:
1971 Hoses are not removed andreracked at least annually.Also new gaskets are notinstalled in the couplingsboth at the hose valves andat the nozzles unless theexisting gaskets are degraded.
Justification:Fire hoses are inspectedmonthly for verification ofequipment present andidentification of any damage.If damage is noted, the hoseis replaced. At 18 monthsintervals all hoses are removed;inspected for damage anddegradation of gaskets;corrections made, if necessary;and reracked.
This dual checking of hoses at oneand 18 month frequencies satisfiesthe intent of the code to identifyand correct damaged equipment.
Impell Report No.09-0120-0123
3-68 Revision 0Hay, 1988
T .-1(Continued)
DEVIATION AND RECOHHENDATIONS/JUSTIFICATIONSNFPA 14 — Standpipe and Hose System
b. Several areas which areserved by Class II hosestations are not within30 feet of a nozzleattached to a maximum 100feet of hose. Referencecode section 421, 1971edition for deficienthose stations.
Justification:a. All hose stations at this plant
are restricted for use bytrained persons only, thusremoving them from a Class IIdesignation which are for useby building occupants.
b. Reference code section 421,1971 edition for justification.
8-1.2Deviation:
1986 A flow test to verify thatstandpipe systems can achievethe requi rements of Section5-3.2 is not required to beconducted by specificationDCCPH110QCS.
AEP to provide justification.
Impell Report No.09-0120-0123
3-69 Revision 0Hay, 1988
3.6 NFPA 15-1973 Hater Spray Systems
3.6.1 Scope of Evaluation
The water spray systems evaluated for the D. C. Cook NuclearPlant are limited to the systems protecting the charcoalfilters and the auxiliary building hydrogen cylinder storagetanks. These systems were evaluated using the requirementsof the 1973 edition of NFPA 15 which was the current editionduring system installation. These systems are located asfollows:
The following assumptions have been made for the evaluationof NFPA 15.
1. Due to ALARA (high radiation) concerns, only one charcoalfilter unit was made accessible during the walkdowns.Therefore, the water spray nozzle arrangements within thefiltration units are assumed similar for all units.
2. The fire protection systems at the D. C. Cook Plant arenot subject to earthquake" as it pertains to NFPA codes.
3. The water spray systems were installed per 1971specifications.
3.6.3 Deviations and Recommendations/Justifications
The water spray systems are in compliance with NFPA 15 withthe exception of the open items and defi ci enci es identifiedin Table 3.6-1. The table also provides recommendations/justifications for these items.
1061 1973Open Item:Documents verifying the certi-fications of all water spraysystems involved are notprovided.
Justification:The requirements of this codesection are covered in detail inother parts of the code.Therefore, the individualrequirements will be addressedwithin each applicable codesection.
2012 1973Open Item:There are no documents whichshow that all materials anddevices installed for thewater spray systems werenew or considered satisfactoryfor reuse.
Justification:It is assumed that all materialsand devices installed for thewater spray systems are inaccordance with standard install-ation practices under the guidanceof the 1971 piping andinstallation specifications.
2031 19734072
Deviation:The support plates holding AEP to provide Justification.the charcoal filters obstructthe water discharge to someof the filters. See Assump-tion 3.6.2.1. The pilot linefor the hydrogen cylinder systemwill interfere with the dis-charge pattern of one nozzle.
2082 1973Deviation:The ASCO Sol. ¹HT8300861Fand J830081F for thethermistor wires are notapproved.
Justification:Refer to the NFPA 72D CodeCompliance Summary — Code Section2212.
2111
4011
1973
1973
Deviation:Pipeline strainers are notprovided for the H2 storagetank pumps.
Open Item:Working plans, specificationsand hydraulic calculationsare not provided for thecharcoal filter systems.
Justification:No action i s requi red sincestrainers are provided at thepumps
AEP to provide Justification.
Impell Report No.09-0120-0123
3-78 Revision 0May, 1988
(Continued)
DEVIATION AND RECOMMENDATIONS/JUSTIFICATIONNFPA 15 — Hater Spray Fixed Systems
Open Item:There are no documents forthe adequacy of the waterspray nozzles within eachfilter unit.
Open Item:There are no documents show-ing that adequate provisionsfor drainage of the affectedarea upon system actuationis provided.
AEP to provide justification.
Justification:Due to radiation, concerns, it isdesirable to contain the waterwithin each filter unit to limitthe possibility of contaminationupon actuation of the suppressionsystem.
4063 1973Deviation:There are no drains providedat the elbows entering thefilter units.
Justification:Drainage at the valve, opennozzles, and pneumatic drainingcan be performed to satisfy thiscode section.
4081 1973Deviation:3/4" pipe is used for filter AEP to provide justification.unit 12-HV-SATFU where a 1"pipe is required.
4081 19734082(d)410141024103
4082(d) 1973
Open Item:There are no documents/drawings available for thecharcoal filters to verifythe adequacy of the pipesupports, nozzles, gageconnections, or pipingarrangements.
Deviation:There are no test gageconnections provided for thecharcoal filter systems.
AEP to provide justification.
AEP to provide justification.
410141024103
1973Open Item:A pipe, supplying water tofilter unit 1-HV-CIPX-1, issupported by a rod welded tothe pipe itself. No approvalor evaluation could be foundfor this assembly.
AEP to provide justification.
Impell Report No.09-0120-0123
3-79 Revision 0May, 1988
T(Continued)
DEVIATION AND RECOMMENDATIONS/JUSTIFICATIONNFPA 15 - Hater Spray Fixed Systems
Deviation:There are no pressure gages AEP to provide justification.installed for the water spraysystems.
Open Item:There is no documentation to AEP to provide justification.to verify that the hose hook-up system was tested.
5023 1973Open Item:There are no test results for AEP to provide justification.the discharge pressure at themost remote nozzle of eachsystem.
50115031
60026003601360146015601660176018
1973Open Item:Charcoal filter unit12-HV-SATFU is not includedin any of the proceduresreviewed.
AEP to provide justification.
7000 1973
7010 1973
Deviation:There are no plant drawings AEP to provide justification.which show the hose hookupsystem or the configurationof the nozzles within eachfilter unit. Not all requiredinformation appears on thedrawing for the hydrogen cylindersystem.
Open Item:There are no hydraulic calcu- AEP to provide justification.Iations for the charcoalfilter water spray systems.
Impell Report No.09-0120-0123
3-80 Revision 0May, 1988
»I(Continued)
DEVIATION AND RECOMMENDATIONS/JUSTIFICATIONNFPA 15 - Water Spray Fixed Systems
in the hydraulic calculationfor the H2 tank system.
AEP to provide justification.
8051Deviation:
1973 The response time of thethermistor wire detectors isnot acceptable.
Justification:The response time has beenpreviously evaluated and acceptedby AEP.
Impell Report No.09-0120-0123
3-81 Revision 0Hay, 1988
3.7 NFPA 72D - PROPRIETARY SIGNALING SYSTEMS
3.7.1 Scope of Evaluat1on
The evaluat1on of the proprietary signaling system includedthe review of this system under two ed1tions. The init1aled1t1on year selected was based on the edit1on that was ineffect at the time the system was specified on April 2,1971. The edition that was applicable was 1967.Modif1cations were performed later during 1983 and 1985 timeperiod and the edition in effect at that time was l979. Theportions of the systems addressed under the applicableedition, are as follows:
1 7Ei i
c
Pyralarm System
a. Unit l L 2 "EFR" Panels
b. Unit 1 "GRC" Panel
Alison Control, Inc.
a. Model A924, Charcoal Filter Unit Panels
b. Model A909 D1esel Generator Room Detection Panels
c. Model 7035, Cable Vault Halon Release Panels
d. Model 6007, Containment Alarm Panels
Chemetron Corp. (Cardox)
a. C02 Control Panels
Rochester Annunciator System
a. Unit 1 5 2 "EF" Panels
l. Unit 1 5 2 "Plant Fire System" Annunc1ator
2. Unit l 5 2 "M1sc. Area Fire System" Annunciator
b. This annunciator mon1tors all sprinkler, f1re pumpand hose stat1on waterflow and superv1sory s1gnalingdevices. In add1t1on, they also monitor all C02and halon l301 suppression system actuat1on andsupervisory signals.
Impell Report No.09-0120-0123
3-82 Revision 0May, 1988
1 7
Pyrotronics "System 3" panels
a. ESH Pump Cubicle Panel
b. Unit 1 Transformer Room/Diesel Corridor/AuxiliaryFeed Hater Vestibule Panel.
c. Unit 2 Transformer Room/Diesel Corridor Panel.
d. Unit 1 & 2 Main Steam Line, Main Steam ValveEnclosure & NESH Value Area Panels.
e. Unit 1 & 2 Computer Room Detection Halon Panel.
Alison Control, Inc.
a. Model A700-9, Unit 1 & 2 RCP Pump Detection Panels.
The areas of the plant where these systems monitor alarmdevices, has been addressed under Section 2.1 of thisreport. In addition sprinkler system riser and fire pumpalarm initiating devices were verified during the walkdownphase were located outside the areas referenced. Thesedevices were located as follows:
m T
(3) Electric Fire Pumps
(1) Electric Jockey Pumps
~r~ %B'av~
573'73'2)
Diesel Driven Fire Pumps 28 & 30587'4)
Sprinkler System. Headers 79, 80, 84 & 85587'2)
Sprinkler System Headers 31 & 96609'he
evaluation of the functional capabilities of theproprietary signaling system included the verification of themonitoring- of sprinkler system waterflow and supervisorysystem signaling, fire pump system signaling, halon and C02system signaling, supplemental manual station signaling andfire detection system signaling. The interface between theproprietary system and the control room operators was .
evaluated to confirm compliance for the actions taken uponreceipt of signals. The Surveillance Program was also
'valuatedto determine compliance.
Impell Report No.09-0120-0123
3-83 Revision 0May, 1988
Certain scope limitations are identified in the report whichare not verified due to their non-applicability. Thelimitations are as follows:
a. The proprietary signaling system has not been designed toperform Manual Fire Signaling Services as outlined inNFPA 72D, Article 310. This is based on code section3010 which states that the signaling services may beapplied individually or in any combination of differenttypes of systems. Therefore, the requirements of codesection 3113 are not applicable. However, code sections
,3321 and 3421 requires manual fire stations to be locatedwhere designated by the authority having jurisdiction.These devices have been provided as required.
b. The intent in the design of proprietary signaling systemat D.C. Cook was to be a "Class B" (two wire) system inaccordance with the requirements of code section 4011.Therefore, the requirements of code sections 4012, and4080 which address "Class A" systems are not applicable.
c. The review of the line-type heat detector configurationsfor the RCP pump (ACI A700-9) and containment alarmsystems (ACI 6007) are not included in this review.
3.7.2 Assumptions
The following assumption has been made for the evaluation ofNFPA 72D.
1. For the purpose of this report, it is assumed that undermost conditions the authority having jurisdiction was thearchitect/engineer (A/E) for the plant who is AmericanElectric Power Service Corporation (AEPSC) unlessotherwise indicated.
3.7.3 Deviations and Recommendations/Justifications
The plant proprietary signaling system is in compliance withNFPA 72D except as identified by the open items anddeviations in Table 3.7-1. The table also providesrecommendations/justifications for these items.
Impell Report No.09-0120-0123
3-84 Revision 0Hay, 1988
3.7.4 References
Document~ ~~ll f. Ti 1
3.7.4.1 720 Halkdown Verification Checklists
RevisionN ./Oa
1 0120-108-007A
2 0120-108-007B
Fire Zone
Fire Zone
l-lH, 29G29A-F, 7thru ll,1,3,4,5,6N,6H,6S,13,15,16,18,19,21 anda portion of79 & 85.
1967Deviation:The Alison Control, Inc.panels (models A909, A924,A700-9 and 7035), the sprink-ler waterflow and supervisorydevices (Mercoid pressureswitches and Snap Lock tamperswitches), the Rochesterannunciator panel ("EF" panel)and the Pyralarm detectionpanels (FIU/ZIU panels), themanual alarm stations (ACIstart/stop stations, hosesystem break glass stations)are not approved or listedfor the application in whichthey are used.
Justification:a. An engineering analysis
was performed to deter-mine if the devices thatwere not approved forthe application,functionally operate asan approved or listeddevice would. The deviceswere evaluated againstUnderwriters Laboratory(UL) Standards of Safetyto confirm that theperformance characteristics of the deviceswould be acceptable toU.L. and therefore complywith the code section.The devices evaluated and,found to be equivalent,are listed below:
Alison Control Inc. Panels:A909A924A700-96007Sprinkler Alarm Devices:"Mercoid" pressure typeHaterflow switches."Automatic Switch Co."filter unit delugesystem solenoids."National Acme Co."Control Valve TamperSwitches.Pyralarm Control PanelsFIU/ZIU Control Panels.
Impell Report No.09-0120-0123
3-112 Revision 0Hay, 1988
(Continued)
DEVIATION AND RECOMMENDATIONS/JUSTIFICATIONNFPA 72D - Proprietary Protective Signaling System
Deviation:Acceptance tests for the sig-naling system were not per-formed in the presence of theauthority having jurisdiction.
Open Item:Data was not available toconfirm compliance forthe Alison Control, Inc.panels, the Chemetronpanels, "EF" annunciatorsand the Pyrotronics systemshalon panels.
b. AEPSC to provide)ustification for thefollowing devices:
Rochester Instruments"EF" AnnunciatorPanels.Hose System ManualStationsACI Model 446002Hanual Start/StopStations.
Justification:The NRC regulatory require-ments dictate that survei 1-lance tests be performed toconfirm the operability ofthe signaling system. Theperformance of thesesurveillances incorporate thetest requirements of NFPA 72D themanufacturer's recommendations.Pre-operational testdocumentation is available toverify that the systems weretested for their operabilityprior to the turnover to AEPSC.Therefore, this conditon isacceptable.
Justification:Although data is notavailable the )ustiflcationreferenced above, stillappl i es.
Impell Report No.09-0120-0123
3-113 Revision 0May, 1988
(Continued)
DEVIATION AND RECOMMENDATIONS/JUSTIFICATIONNFPA 72D - Proprietary Protective Signaling System
Deviation:The procedures do not performsurveillance tests or verifythe receipt of alarm or super-visory signals at the controlroom from sprinkler system,fire pump supervisory signalsand hose system manualstations alarm initiat)ngdevices to confirm theiroperability.
Open Item:Data was not available toconfirm that the "EF" panels,
. ACI panels or C02 panelswould operate under 85 percentto 110 percent of rated inputvoltage.
Deviation:The procedures do not verifythe reset of signals receivedby the control room forsprinkler system and firepump signals.
Deviation:The al arm initiating circuitcables are exposed to poten-tial hazards at elevations587', 609', 624'nd 650'.
D VIa. Sprinkler alarm flex
conduit is not water tighttype for all riser alarmdevices at the rises inzone 79, 80,84 & 85 El.587'; 96 5 31,E1. 609';49, El. 633';Unit 1 char-coal filter risers,El. 650'.
Justification:Procedure 12 OHP 4030.STP. 120 verifies monthlythe position of thesprinkler system risercontrol valves whichsatisfies the intent of thevalve tamper switches.
AEP to provide justificationsfor fire pump and hose system.
Justification:These panels are connected tothe 250VDC plant emergencypower system. This system isregulated such that fluctuationsof the input voltage to thesepanels is unlikely, thereforethis condition is acceptable.
AEP to provide )ustification.
Justification:a. The alarm circuits may be
inadvertantly operated,however, their onlypurpose is to initiatean alarm to the "EF"panel in the control andwi 11 not actuatesuppression systems.Therefore, thiscondition is acceptableand no further action isrequired.
Impell Report No.09-0120-0123
3-114 Revision 0Hay, 1988
(Continued)
DEVIATION AND RECOMMENDATIONS/JUSTIFICATIONNFPA 72D - Proprietary Protective Signaling System
b. Open junction boxes werenoted for smoke detectorsthe conduit system atEl. 624',zone 57 atdetector no. 18-18 &18-25. Open junctionboxes with exposed cableprotruding from them werealso noted, at the halonpanel for zones 71 & 72at El. 650'.
Justification:b. These items are consider-
ed isolated maintenanceissues which are beingresolved by the plant.The alarm system wasproperly installedin conduit throughoutthe area reviewed toprevent exposure tohazards.
c. The solenoid circuit flexconduit for unit 2 computerroom (zone 72) halon tankis damaged exposing thecircuit conductors.
Justification:c. This item is considered
an isolated maintenanceissue which is beingresolved by the plant.
2154 1967Open Item:Data was not available toconfirm compliance for cablesto meet maximum fault current,noninterchangeable overcurrentprotection, energy limitationcriteria and approved foruse as a limited energy cable.
AEP to provide justification.
2221Deviation:
1967 The ACI panels (models A909,A924, A700-9 & 7035) and theChemetron C02 control panelsare not provided with theproper connection to an inde-pendent trouble power source.
Justification:NFPA 72D, 1967 Edition codesection 4121.d, indicatesthat the secondary powersource may be used for thetrouble signaling source.
The secondary source of powerfor the ACI A700-9 panels isprovided by standby batteriesand will operate the troublecircuitry.
Impell Report No.09-0120-0123
3-115 Revision 0Hay, 1988
(Continued)
DEVIATION AND RECOMMENDATIONS/JUSTIFICATIONNFPA 72D - Proprietary Protective Signaling System
The secondary source of powerfor the other panels areindependant of other sources(diesel generators, plantbatteri es or offsite emergencysource) but are transmitted overthe same conductors for theprimary power. Failure of thiscircuit will prevent operation ofthe system.
These panels, however, willtransmit a system "abnormal"condition to the "EF" panel uponloss of power which wi 11 causecompensatory action to be takenby the control room operators.In addition, manual mechanicalmeans for actuating the cablevault halon system via the AnsulAutoman IIC cabinet, at the pilotcabinets for the C02 systemsand at the pneumatic deluge valveof the charcoal filter spraysystems as discussed in procedure12-OHP 4022.066.001 are providedshould the need arise.Therefore, this condition isacceptable.
Impell Report No.09-0120-0123
3-116 Revision 0Hay, 1988
(Continued)
DEVIATION AND RECOMMENDATIONS/JUSTIFICATIONNFPA 72D — Proprietary Protective Signaling System
Deviation:The power cables connected tothe ACI A924 panels from powerpanel l-DAB, circuit 5 & 2-DABcircuit 5, are under sized forthe 35 AHP breakers provided.
Deviation:The overcurrent device on thesupply side of the Pyralarm(FIU) power supply is greaterthan 150 percent of the ratingof the control unit.
AEP to provide )ustification.
Justification:The load demand for the FIUunit is 475ma versus a 5 amp.fuse. This panel, however,has been tested under therequirements of UL Standard ¹864and has been found to beacceptable for over-current & voltage variations andis approved for NFPA 72A thru 72Csignaling system services.Therefore, this condition isacceptable.
Open Item:Power supply data for the ACI AEP to provide justification.panels was not released toImpell by Alison Control, Inc.Therefore confirmation ofcompliance of this equipmentwas not possible.
2341 1967Open Item:Continuous duty rating datafor the power supply trans-formers was not availablefrom all the manufacturers ofthe alarm system.
AEP to provide justification.
2411 & 19672422
Deviation:a. The alarm initiating
circuits for. the "EF"panels are not electri-cally supervised to indi-cate a trouble conditionat the "EF"annunciatorupon a circuit fault.
Justification:a. AEP to provide )ustification..
b. The NRC reviewed thesystem elementary drawing inthe 53 question response(Question 45) which clearlyindicated the CO2 manualstations were unsupervised.
Impell Report No.09-0120-0123
3-117 Revision 0Hay, 1988
(Continued)
DEVIATION AND RECOMMENDATIONS/JUSTIFICATIONNFPA 72D - Proprietary Protective Signaling System
CODE CODESECTION EDITION DEVIATION/OPEN ITEH RECOMMENDATION/JUSTI F ICATION
2431 5 19672631
2432 1967
b. The C02 and hose systemmanual stations are notconnected to electricallysupervised circuits.
Deviation:The audible devices for the"EF" annunciator are commonto all alarm types. Alsolocal panel fire alarm andtrouble conditions are trans-mitted over the same circuitand are not distinctive as tothe type received.
Deviation:A trouble silence switchvisual indicator is not pro-vided for the ACI A700-9panels.
The NRC approved the C02system in the Appendix A SER.AEPSC to provide justifica-tion for the hose systemmanual stations.
Justi fication:The commn audible is accept-able since distinctive visualindications are provided forsupervisory, fire alarm andtrouble conditions at the"EF" annunciator with theexception of the combinedfire/trouble signals from the ACIA924 and A700-9 panels. ThePyralarm "EFR" panels provideredundant initiating circuitalarm and trouble lamps at the"EFR" and "EF" vertical boardannunciation. The "EFR" panelalso transmits a commonfire/trouble signal to the "EF"annunciator panel. in addi tion tothe annunciaton discussed above.The annunciator responseprocedures (1 & 2 OHP 4024.100and .200 series) require theoperators actions to verify thesealarms as fire conditions.
Justification:Since the control room "EF"panels indicate a troublecondition, the appropriateaction will be taken toinvestigate the condition.trouble audible wi 11 not reset orclear the condition. The troublecondition must be corrected priorto reset. Therefore, thiscondition is acceptable.
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3-118 Revision 0May, 1988
(Continued)
DEVIATION AND RECOMMENDATIONS/JUSTIFICATIONNFPA 72D — Proprietary Protective Signaling System
Deviation:Several manual stations havenot been properly mounted with-in the mounting height require-ments specified. These manualstations are as follows:
EUMIItLa. Sprinkler system
609'anualstationare mounte
4'bovethefinished floorin zone 44N,44S & 32.
b. C02 Manual620'tationsare mounted
4'bovefinished floorin zones 40A & B thru42D, 45 thru 47B,38 & 39.
Justification:a. 3112 - The mounting location
of the manual stations doesnot deviate drastically fromthe minimum 4.5'ountingheight required or mountedsuch that the device cannotbe properly operated. Inaddition, NFPA 72D, 1979Edition lowered the minimumcriteria to 3.5 AFF.Therefore, this condition isacceptable.
b. See Justification for3112 above.
c. C02 manualstation at zone44N is mounted4'bove finishedfloor.
d. ACI charcoalfilter manualstations aremounted 4'bovefinished floor.
620'50'.See Justification for3112 above.
d. See Justification for3112 above.
e. (2) halon manual650'tationsare
mounted5.5'bovefinished
floor in zones71 & 72.
Justification: 3-3.1.2e. The halon manual stations
for zones 71 & 72 do notdeviate drastically from the5'aximum criteria and willnot impact the operation ofthe device. Under the 1967Edition of NFPA 72D, thisinstallation would have beenacceptable.
Impell Report No.09-0120-0123
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T(Continued)
DEVIATION AND RECOMMENDATIONS/JUSTIFICATIONNFPA 72D — Proprietary Protective Signaling System
3423 1967Devi ati on:The sprinkler system low airpressure and valve tampersupervisory devices are con-nected to the same initiatingcircuit and will not indicatethe element of the sprinklersystem which is inoperative.The sprinkler systems includedare as follows:
~EL VAT N
Preaction sprink-609'er
risers forAuxiliary Bldg.located in zone 96.
Preaction sprink-609'er
risers locatedin zone 31 AuxiliaryBldg. High Roof Ul,H2 storageTanks & Drum-ming Area.
Justification:The "EF" annunciators indicatecate a sprinkler system "ab-normal" condition. The an-nunciator response procedures(1&2 OHP 4024.100 & .200 series)indicate the potential problemsand directs the operators to takethe appropriate correctiveactions.
3424 '1 967Deviation:The alarm initiating circuitsfor the devices connected tothe "EF" annunciator can bereadily tampered with and atrouble signal will not beproduced.
Justification:Reference the results ofCode Section 2411 and 2422.
Impell Report No.09-0120-0123
3-120 Revision 0May, 1988
(Continued)
DEVIATION AND RECOHHENDATIONS/JUSTIFICATIONNFPA 72D - Proprietary Protective Signaling System
1967 Haterflow alarm devices arenot provided for the charcoalfilter unit risers and theAuxiliary Building ZHO-10 & 20hose system supply piping.
Justification:The charcoal filter unit risersare provided with individualalarm annunciation to the "EF"panels via the ACI A924panels. In addition, thesuppression systems are actuatedby manually opening the riserisolation valve. Therefore,waterflow signaling does notprovide significant increase inthe level of fire protectionfeatures. The justification forthe waterflow signaling theAuxiliary building hose systemsupply will be provided by AEPSC.
3441, 19673442 &3443
Impell Report No.09-0120-0123
Deviation:a. The valve tamper devices
for the ZHO-10 & 20 andthe charcoal filter unitisolation valves, areinstalled on the valvesbut are not connected tothe alarm systems.
b. Also, low air pressuresupervisory devices arenot provided for the pre-action sprinkler systempiping in zone 31,elevation 609'.
3-121
Justification:a. The isolation valves are
chained and sealed in theappropriate positionwhich is a satisfactorymethod of supervisingsprinkler valves inaccordance with NFPA 13,1983 Edition, codesection 3-14.2.3.d.Although weeklysurveillances are notperformed as required,the intent of the code isbeing met by the performanceof monthly survei llancesunder procedure 12-OHP4030.STP.120. Therefore,this condition is acceptable.
Justification:b. The intent of the low air
pressure supervisorydevices is to indicate afailure in the sprinklerpiping due to mechanicaldamage. The piping for Zone3 and 32 have extremely highceiling and the probabilityfor damage is low.Therefore, this condition forZones 3 and 32 is acceptable.
Revision 0Hay, 1988
(Continued)
DEVIATION AND RECOMMENDATIONS/JUSTIFICATIONNFPA 72D — Proprietary Protective Signaling System
3541 1967Deviation:Several smoke detectors onelevations 587' 609're notreadily accessible due to con-
duitt
congestion.
The sprinkler piping for theH2 storage tanks also isnot provided with pressuresupervision, however, sinceonly open head sprinklers areprovided, this supervision isnot required.
Justification:Although these devices arenot readily accessible, sur-vei llances are performed onall these devices to conformtheir operability under pro-cedure 12THP 6030 IMP.142 and.051 which meets the intentof the code. This condition isacceptable.
3542 1967Deviation:Detector ¹3-29 in zone 44S isnot accessible for testing dueto sprinkler piping obstruc-tion.
AEP to provide )ustification.,
Deviation:3543 1967 The fire detections, halon and
C02 system control are notinspected monthly.
Justification:The systems controls are verifiedfor operability typically semi-annually wi th C02 system valvepositions verified monthly.Since the D.C. Cook plantspecifically indicated that thetesting frequencies required byNFPA 72D wi 11 not be met in theirresponse to Appendix A to BTP/APSCB 9.5-1. Therefore,thismonthly surveillance is notrequired.
4011 1967Deviation:The intent of the alarm systemis to be a "Class B" system.The "EF" panels, however donot provide electrical super-vision of the alarm initiatingcircuits connected to them.
Justification:Reference the results of codesection 2411 and 2422 NFPA72D, 1967 Edition.
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(Continued)
DEVIATION AND RECOHHENDATIONS/JUSTIFICATIONNFPA 72D - Proprietary Protective Signaling System
Deviation:A reliable means of transmit-ting alarm signals to the off-site fire department is notprovided.
Deviation:a. Automatic recording devices
for documenting alarmsreceived by the "EF"panels are not provided.
b. Transmission of signals tothe fire department arealso not provided.
Justification:A (5) member fire brigade ismaintained on site at all timesand are trained in the useand placement of the firefighting equipment and thestrategy for fighting a fire inthe plant. Off site firedepartments are called viatelephone from the SecondaryAlarm Station as directed by theShift Supervisor when required.Therefore, the direct transmissionof via alarms is not required.
Justification:a. Based on the review of
the AEPSC response toAppendix A to BTP/APCSB9.5-1 Section II.B.1 andclarification statementsin NRC 53 question(Questions 16 and 48)clearly do not committo providing a printer and istherefore not required.
4051 1967Deviation:Daily tests of the alarm sys-tem circuits, are not per-formed.
Justification:The response to Appendix A to9-5.1 has indicated that testingfrequencies will not be performedin accordance with NFPA 72D. Thecircuits are verified duringtesting performed in accordancewith the fire protection program.
4053, 19674101 &4111
Deviation:The procedures do not requirethe documenting of supervisoryor trouble conditions.
Justification:Reference the results of code
Section 4041 & 4042a. forjustification.
Impell Report No.09-0120-0123
3-123 Revision 0Hay, 1988
. 7-1(Continued)
DEVIATION AND RECOMMENDATIONS/JUSTIFICATIONNFPA 72D — Proprietary Protective Signaling System
Deviation:The "EF" panels do not indi-cate trouble conditions uponcircuit faults. Also remotesignaling from the ACI/Pyro-tronics panels to the "EF"/"EFR" panels do not providedistinguishable alarms betweenfire and trouble conditions.
Open Item:Data was not avai lable toconfirm automatic transferof power from primary tosecondary within 30 seconds.
Open Item:Data was not available toconfirm compliance of theACI A700-9 panelsfor environmental operability.
Deviation:The RCP pump suppression sys-tem supervisory devices arewired in series in the initi-ating circuits. Supervisoryalarms are not distinguishablefrom circuit fault conditions.
Reference code section 2431and 2631 NFPA 72D, 1967, forprocedure actions requiredupon receipt of these signals.
Justification:The power supplies for thedetection and suppressionsystems are the discussedand accepted by the NRC asdocumented in the Appendix A SER.
Justification:These panels are located infire zone 52, elevation
633'f
the Auxiliary Building.The maximum temperature to beachieved in this zone is104'F. The minimum is60 F. Based on this data,the ambient conditions forthe ACI A700-9 panels, iswell within the limitingcriteria of 120'F - 32 F.
Justification:The arranagement of the circuitvill always indicate a sprinklersystem impairment which willrequire the operators to verifythe closure of the isolationvalve. Upon determining acircuit fault condition,compensatory actions would berequired until the faultcondition is corrected. Thiscondition is acceptable.
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3-124 Revision 0May, 1988
q 3.8 NFPA 728 — Automatic Fire Oetectors
3.8.1 Scope of Evaluation
The evaluation of the installation and maintenance of theautomatic fire detectors included the review of the devicesunder four editions. The initial edition year selected wasbased on the edition that was in effect at the time alarmsystem was specified on April 2, 1971. Since NFPA 72E wasnot adopted until 1974, this edition was used as the basisfor the initial installation of the devices. All subsequentedition years were reviewed for compliance with theapplicable areas modified as identified in Impell CalculationNo. 0120-108-008.
The areas of the plant where these devices are installed, hasbeen addressed under Code Section 2.1 of this
report.'he
evaluation of the functional testing of detection deviceswas also reviewed for compliance with the standard.
Scope limitations have been identified as follows:
a. The space above Unit 1 IIt 2 Control Rooms could not beverified for compliance during the walkdown phase due tothe units operating.
b. The detection arrangement for the charcoal filter unitswas verified for compliance by the review of two charcoalunits only (1 5 2-HV-ACRF). This was due to the otherunits within our scope, operating and/or contaminated.
n
c. Some detectors on elevations 587', 609'nd 650'ouldnot be verified for placement due to conduit congestion.These detectors are listed as follows:
~v~n2-13, 2-14,2-33, 2-34,2-35 & 2-47
3-6, 3-7,3-22 3-37.3-38 5 3-39
7-1
2-2
4-19 5 4-27
5
44N
38
39
52
587'09'09'09'50'mpell
Report No.09-0120-0123
3-125 Revision 0May, 1988
d. Although NFPA 72D reviewed the ACI A700 — 9 and 6007panels (RCP pump detection and containment alarm system)for compliance, the verification of the arrangement ofthe detectors was outside the scope of this evaluation.The verification of the detector arrangement withinfilter Units 1 & 2-HV-CFT-1 5 2 is also outside the scopeof this evaluation.
3.8.2 Assumptions
The following assumptions have been made for the evaluationof NFPA 72E.
l. It is assumed that the detection arrangements for thespace above the control room ceilings are as depicted inthe walkdown data sheet sketch so as to confirmcompliance.
2. It is assumed that the detection arrangement for thecharcoal filter units are typical with exception ofchange in the number of charcoal filter beds.
3. It is assumed that the detectors identified in item3.8.1.c are installed and are verified for operability asindicated in the Survei lliance Procedures.
3.8.3 Deviations and Recommendations/Justifications
The plant fire alarm system is in compliance with NFPA 72fwith the exception of the open items and deviationsidentified in Table 3.8-1. The table also providesrecommendations/justifications for these items.
3.8.4 References
See Section 3.7.4 of this report.
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DEVIATIONS AND RECOMMENDATIONS/JUSTIFICATIONSNFPA 72E — Automatic Fire Detectors
signaling system were notperformed in the presenceof the authority havingjurisdiction.
b. Open Item:Data was not availableto confirm compliancefor the ACI panels andthe "EF" annunciatorpanels.
Deviation:Several detectors areexposed to mechanical damageon elevations 587', 609',625'nd 633'.
Justification:a. The NRC regulatory requirements
dictated that surveillancesurveillance tests be performedto confirm the operability ofthe signaling system. Theperformance of thesesurveillances incorporate thetest requirements of NFPA 72Dand the manufacturer'srecommendations.
Justification:b. Although this data was not
available for review, thejustification statement notedabove still applies.
Justification:Detectors 4-9A (zone 106) and4-33A (zone 107) are located in anormally locked room, located overbatteries which is not a normalpath of travel through the room.
Justification:AEP to provide justification forremaining devices listed.
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3-127 Revision 0Hay, 1988
. -1(Continued)
DEVIATIONS AND RECOMMENDATIONS/JUSTIFICATIONSNFPA 72E — Automatic Fire Detectors
Air Movement5 Det. 1-1 For Beam ConstrThroughout ZoneDeep Bay 9Hest EndDet. 2-25 5 2-3, For BeamAir movement,inadequateDet. spacing.I.R. Det. obst-ructions. Beamconst. 8 centerof zone.I.R. Det. obstr.5 air movement.I.R. Det. obstr.5 air movement.I.R. Det. obstr.I.R. Det. obstr.h air movement.I.R. Det. obstr.h air movement.I.R. Det. obstr.h air movement.Typical of zone 8.Typical of zone 11.Det. not installed8 cei ling.Det. not installed8 ceiling.Air movement.Typical of zone 11.Typical of zone 11.Det. 3-4, beam constr.Det. 3-27 & 3-28 8bot. of beam.Air movement hbeam constructi on.Air movement 5beam construction.
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(Continued)
DEVIATIONS AND RECOMMENDATIONS/JUSTIFICATIONSNFPA 72E — Automatic Fire Detectors
ceilings &beam construction.Air movement.Air movement.Air movement &beam construction.Air movement.Det; 13-9(41) &8-9 & 8-7 (45)do not cover entirearea. I.R.obstructions.Det. 18-10 & 1B-12within 4" of deepbeam.Deep bay const. eeast end of room.Deep beam const. 8east end and for8" beam const.throughout eachzone ~
Deep beam const. 8northeast & south-east end of zone.Det. not spacedfor deep & 8" beamconst. 8 north &south end of zone.Typical of zone 10.Typical of zone 10.Typical of zone 32.
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IL
1
T -1(Continued)
DEVIATIONS AND RECOMMENDATIONS/JUSTIFICATIONSNFPA 72E — Automatic Fire Detectors
Deviation:The fixed temperature portionof the heat detectors inzones 106 and 107 does notprovide adequate coverage.
Deviation:Smoke detectors in zones 29Athru D, 32 thru 34, 44N, 49,52 thru 54, 57 and 69 areinstalled at the bottom ofdeep beams or installedgreater than 12" from thecei ling.The devices are as follows:
b. The discussion inRFC ¹-1-2679 & 02-2694adequately evaluates the lackof ceiling mounted detectorsin zones 33A & 34A.
Justification:The heat detectors are combinationrate-of-rise/fixed temperatureunits. The rate-of-rise portionof the detector is more thanadequate for the coverage of theroom and will respond promptlyupon a fire condition.
,Justification:
a. AEP to provide justificationfor remaining zones.
s5-29 8 bottomof beam.
4-13 8 bottomof beam.
Zona F~v.c ~
32650'9
633'hedetectors located in zones
53 and 54 are installed belowthe ceiling system- due to theresults of fire testingperformed by ProfessionalLoss Controls in their reportdated 10/13/83.
4-26 installedwithin 4" of18",beam.
52
633'-1
thru 5-3 &5-10 thru 5-.12approx. 4'ownfrom the ceiling.
69
650'8-10
& 18-12 are 57625'nstalledwithin
4" of a deep beam.
d.
e.
Detector 18-30 has been inZone 57 located at the bottomof a 6" deep beam. Theplacement of this device isacceptable in accordance with4-3.2 72E, 1984 Edition.
Detectors No. 2-6 & 3-6 inzones 29A thru D are installedat the top of open grateddoorways leading out of thesezones. The placement of thesedevices are adqeuatelyevaluated in RFC¹01-2679 and02-2694.
Impell Report No.09-0120-0123
3-131 Revision 0Hay, 1988
(Continued)
DEVIATIONS AND RECOMHENDATIONS/JUSTIFICATIONSNFPA 72E — Automatic Fire Detectors
4-3.5.1.1 1984Deviation:Detectors provide in zones40A & B, 41, 45, 47A & B,52, 55 and 60 do notadequately cover allportions of the zone within0.7 times the listedspacing. These detectorsinclude the following:
f. Detector No. 23-10 located inzone 44N (Equip. DecontaminationRoom) has been installedapproximately 2.5'own from theceiling due to conduitcongestion. This room haspartion barriers which stop belowthe congestion. Ceiling mountedsmoke detectors from zone 44Nwill adequately provide detectionover the congestion of this room.
properly prov1ded in zones7, 27, 32, 33, 34 and 69due to high ce111ngs.
b. Device placement in zone 43are too close to supply aird1ffusers.~Dv~i
Justification:a. AEP to provide )ustification.
b. AEP to prov1de justification.
e
23-4, 23-14 43thru 23-19,23-21 & 23-22
c. Conduit congestion 1n zones5, 6N, 6H and 6S mayprevent detector actuationof devices installed abovethe congestion to a firecondit1on at the floor.
c ~ Dry pilot heat actuatedsprinklers actuate the pre-action sprinkler systemsinstalled in these zones.Upon actuat1on of the drypilot sprinkler, a low pressuresupervisory signal will betransmitted to the control roomw1th a waterflow alarm signalfollowing immediately. Sincethese devices are providedthroughout the zone under thecongest1on and transmit signalsto the control room, thesedevices will meet the intent ofthe code to provide rapiddetection in congested areas.This condition is acceptable.
4-4.2 1974Deviation:The operator's area (zone 53& 54), the vestibule area(zone 53) and the toilet(zone 54) are not providedwith detection at thesuspended ceiling.
Justification:a. The operator's
area of the control rooms arecontinuously manned and allparts of the area are visiblefrom the control boards.Therefore, a f1re would bedetected in the early stages inthis area.
Impell Report No.'09-0120-0123
3-l 33 Rev1sion 0Hay, 1988
(Continued)
DEVIATIONS AND RECOMMENDATIONS/JUSTIFICATIONSNFPA 72E — Automatic Fire Detectors
1974Deviation:The field of vision forseveral infrared detectorswere obstructed by conduit/cable tray systems, structureand equipment. In severalcases the arrangement of thedetector was not appropriate.The deficient detectors arelisted as follows:
AEP to provide ) us tificati on.
7 17-2
7 17-3
8 18-5
Zone Device
7 17-1 Obstruction bycable trays.
Hisalignment forthe combustiblespresent.
Obstructed byconduit.
Misalignment andobstructed.
8 18-1 Obstructed.
10 14-2 Obstructed.
10 14-1 Obstructed.
ll 13-3 Obstructed.
25 19-3 Obstructed.
26 22-4
26 22-5
Misaligned andobstructed.
Hisaligned andobstructed.
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3-135 Revision 0Hay, 1988
~j'
TA -1(Continued)
DEVIATIONS AND RECOMMENDATIONS/JUSTIFICATIONSNFPA 72E — Automatic Fire Detectors
are provided as local unitsunits for the Control Roomventilation only and spot typesmoke detection is provided inzones 53, 54, 70 & 73 whichannunciate in the ControlRoom. Upon a receipt of analarm from the air ductdetectors the proceduresrequire the operators tomanually shutdown the fanunits.Based on the discussion fromthe exemption request for (22)undampered duct penetrations(NRC Letter dated 8/28/85),the lack of provision of airduct detection and automaticshutdown of HVAC units is anacceptable deviation from codesection 8-1.2.1. The HVACunits include the following:1&2-HV-AX 1&21&2-HV-AS 1&212-HV-AFS-lthru 412-HV-ACA-1 & 4
c. Automatic shutdown of HYACunits by means of automaticfire detection has not beenproperly provided for theHVAC units referenced initem b. as required by NFPA90A, Section 4-3, 1978Edition.
C. Reference item b. above forHVAC units without shutdown ordetection features.Charcoal filter units areprovided with heat detectionand automatic shutdown of thethe fans in accordance withthe ANI criteria and do meetthe intent of the code. Thiscondition is thereforeacceptable. These unitsinclude the following:12-HV-SATFU12-HV-AFX1 & 2-HV-AES-1&2
Impell Report No.09-0120-0123
3-138 Revision 0May, 1988
Section 4.0
Supplemental Justifications
Section 4.0 of the NFPA Code Compliance Evaluation Report 09-0120-0123 has beenadded by AEPSC. The report was originally prepared by ABB Impell. This sectionwas added by AEPSC in order to keep the entire report and its final)ustifications and recommendations together as a complete package. Thesesupplemental justifications have been prepared to remove prior recommendationsfrom the "Deviation and Recommendations/Justifications" Tables found in Sections3.1-1 to 3.8-1 of the report.
The following technical justifications have been prepared in response to NFPAcode compliance deviations identified in ABB Impell Report 09-0120-0123.
A number of the justifications were prepared by ABB Impell for AEPSC. Thesejustifications are contained in a package dated June 17, 1988 from D.E. Kipleyto J.A. Kobyra.
The remaining justifications were prepared by AEPSC and appear in chronologicalorder. The attached Table 4.1 identifies the NFPA code sections for whichjustifications have been provided and the justification letter date. Ininstances where a justification could not be provided, reference -is provided toa design'hange package (RFC) or identified as a maintenance item which willbring the system into compliance with the applicable NFPA Code section.Table 4.1 provides a "cross reference for all deviations, justifications.,andcorrective actions which have been taken for those code sections identified inTables 3.1-1 through 3.8-1 of Report 09-0120-0123.
4-2
Table 4.1
Cross Reference ToNFPA Code Deviations Identified by
Impell Technical Report No. 09-0120-0123Tables 3.1-1 Through 3.8-1
NFPA Code CodeCode Edition Section
Number of JustificationJustifications Letter Date Remarks
10 1984 1-6. 2 NA 5-17-88 Revised FireFacility Drawings
10 1984
10 1984
10 1984
12 1968
12 1968
12 1968
12 1968
12A 1977
3 1 ~ 23-1 ~ 2.2
3-2.13-3.13 3 ~ 3
4-3.2
122
134165254255
143616321634
1716
1-5.41-7.4
NANA
40NAN/A
NA
NA
NA
1-23-891-29-90
1-24-8911-30-8911-18-91
1-23-89
5-17-88
3-31-91
6-17-88
6-17-88
6-17-88
9-6-90
6-17-88
Revised FireFacility Drawings.
Several ExtinguishersReplaced as MaintenanceItems.
Revised FireFacility Drawings.
Procedure Changed-12SHP2270 FIRE.001,Rev. 2.
Procedure Changed
12A 1977
12A 1977
12A 1977
1-8.3.6
1-8.5.1
1-9.5.6
1-25-89
6-17-88
11-14-91 Maintenance Item
13
13
1971
1971
1141
32413783
6-17-88
6-17-88
13 1971
13 1983
368136823683
1-9.2
NA 9-6-90
6-17-88
Procedure Changed
4-3
Table 4. 1
Cross Reference ToNFPA Code Deviations Identified by
Impell Technical Report No. 09-0120-0123Tables 3.1-1 Through 3.8-1
NFPACode
13
13
13
13
CodeEdition
1983
1983
1983
1983
CodeSection
2-2. l. 2. 42-2.1.2.5
3-16.8
3-17.4.5
4-1.1.14-1.1.4
Number ofJustifications
NA
JustificationLetter Date
11-13-91
11-18-91
6-17-88
6-17-88
Remarks
RFC 12-3065
Maintenance Item
13
13
13
13
13
14
i4
14
1983
1983
1983
1983
1983
1971
1971
1978
1986
1971
1978
1986
4-1.1.14-1.1.44-2.4.6
4-2.4.6
4-4.13
4-4.19
7-3.4
151
212212A217531541551
1-11.35-3.15-3.25-4.25-5.2
2-1. 3
322421
1-11.33 2 ~ 24-2.14-3.2
4-4.3.1
2-8-898-20-90
6-17-88
6-17-88
6-17-88
11-13-91
11-19-91
9-20-88
6-17-88
RFC 12-3003
RFC 12-3065
14 1971
14 1971
14 1971
511524
525
624
6-17-88
11-13-91
11-19-91
RFC 12-3065
Table 4.1
Cross Reference ToNFPA Code Deviations Identified by
Impell Technical Report No. 09-0120-0123Tables 3.1-1 Through 3.8-1
To NFPA Code Compliance Report 09-0120-0123, Section 4.0
ABB Impell code compliance review for NFPA 14 identified the followingcode deviation.
NFPA 14 1971 Edition Sections 151 and 624
Deviation: Existing valve 12-FP-263 is not an approved indicator valve.
An engineering review of this deviation has been performed and theresulting justification for acceptance of the NFPA code deviation isgiven below.
Justification: The existing valve is Manufactured by Centerline. A joborder (No. A17791) has been written to replace this valve with a ULListed/FM Approved Grinnell butterfly valve.
This valve is being replaced as part of an ongoing program to replacethe unapproved fire protection valves with UL Listed/ FM Approved fireprotection valves. The unapproved valves are replaced as they requiremaintenance or repair.The unapproved valves generally do not provide visual indication as towhether the valve is open or closed. The isolation valves are normallyopen (as is the case with valve 12-FP-263) and only closed when repairsare needed to the fire protection system. All repairs are done inaccordance with plant procedures. personnel performing repairs arehighly trained and must adhere to all procedures. We have no reason tobelieve that an isolation valve would remain in the closed position oncework is completed. Additional assurance that these valves have notchanged position is provided through the monthly fire protection valvelineups performed at the plant per procedure 12 SHp 4030 STp.011, "FireProtection Valve Lineup Verification." Plant personnel are required tocheck these valves monthly to assure that they are in their normalposition and that the valve seal remains intact.Based on the replacement of valve 12-FP-263, the requirements of NFPA 14will be met. The above general discussion provides justification forthe continued use of other unapproved valves until they are replacedwith an approved valve.
To P. Carteaux — Br idgmanJ. Sampson - BridgmanT. Beilman — Br idgman
The NFPA Code Compliance reviews performed by ABB Xmpell, Report No.09-0120-0123 and 09-0120-0381, identified procedures which equiredrevision to incorporate surveillance and testing issues. A review ofthese plant procedures shows that several of the previous'y identifiedchanges under Report No. 09-0120-0123 have not been incor=orated aspreviously requested. The required changes are given belcw. Pleasedirect this listing to the appropriate personnel for incorporation ofthese surveillance requirements.
These procedural changes are being committed to the NRC and requirecompletion by the end of 1992. Zn reviewing the changes wt th thevarious departments, the end of 1992 date has been agreed to due to thetwo unit refueling outages occurring in 1992, and the add't'onalprocedural burden associated with the outages. Each department alsoindicated that they should be able to better this date. P'ease advisethe writer in writing when the procedures have been revised.
NFPACode Edition
CodeSection Procedure Deviation/Requirement
1973 501150215031
6001-60036013-6018
12MHP4030.STP.020Series
Deviation: Charcoal filter unit12-HV-SATFU is nct included in anyof the procedures.
Re irementt The charcoal filterunit 12-HV-SATFU fire protectionsystem is to be tested. Nozzleoperability should be confirmed.
NOTE: The 12-HV-SATFU water spraysystem is supplied water throughHose Station No. 4. Hose StationNo. 4 angle valve operability, ZMO-
)0 and ZMO-20 operability and,connecting fire hose operabilityare already being performed underseparate procedures which can beused to satisfy the first part ofthis requirement.
Intta-Satcm
NFPACode Edition
CodeSection Procedure Deviation/Requirement
72D 1967 203440522047
12SHP2270.FIRE.0041620HP4030. STP. 121Series
Deviation: The procedures do notperform surveillance tests orverify the receipt of alarm orsupervisory signals at the controlroom from fire pump supervisorysignals and hose system manualstations alarm initiating devicesto confirm their operability.
Re irement: The procedures shouldbe enhanced to verify the receiptof all required signals at thecontrol room. Each hose stationdevice should also be activated toverify operability of the deviceand its circuit.Deviation: The procedures do notverify the reset of signalsreceived by the control room fromthe fire pumps.
Re irement: The surveillance testshould be revised to verify thereset of each signal prior tocontinuing the test.
12THP4030.STP.223 Deviation: Air flow testing is notperformed for the Unit 1 and 2
containment CFT charcoal filterunits.
72D72E
19671974
35427-3.1.4
12THP4030.STP.239
Reauirement: Incorporate the airflow testing of the Unit 1 and 2
CFT charcoal filter units into theplant procedures.
Deviation: Loop resistance testingfor the Unit 1 and 2 reactorcoolant pumps (RCP) thermistor linetype detectors is not performed.
Reauirement: Incorporate loopresistance testing of the Unit 1
and 2 RCP detection systems intothe plant procedures.
NFPACode Editi
CodeS Procedure Deviation/Requirement
72E 1974 5-5.2 12THP6030.ZMP.153 Deviation: The procedures do notconfirm the changes in thealignment of the infrared flamedetectors.
Re irement: The procedures shouldbe revised to verify the alignmentof the flame detectors.
Deviation: The line type heatdetectors for the RCP pumps are notverified for their operability byloop resistance testing.
Reauirement: The procedures shouldbe 'revised to ver'fy theoperability of the line type heatdetectors as reauired.
Please call if you have any questions.
B.J. Gerwe
BJG/gh
CC E.E. FitzpatrickA.A. Blind — BridgmanP.H. Jacaues — BridgmanA. Arent - BridgmanT. Walsh - BridgmanC. Miles - BridgmanR.L. ShobergJ.D. Grier/B.J. GerweFile: NFPA Code Compliance Report 09-0120-0123
NFPA Code Compliance Report 09-0120-0381MF: N
'I "1
INDIANAMICHtQANPOWER
Date
Subject
November 18, 1991
Fire Protection Code Compliance Review
From
To
P.H. Jacques
B.J. Gerwe
Per your request I have reviewed the status of Plantimplementation of maintenance items and procedure revisionsas outlined in the'ode Compliance Review, Expanded CodeCompliance Review, NFPA 30 Compliance Review and ESW PumpRoom Area Extinguishers. With the exception of the itemslisted below all maintenance items and procedure revisionshave been completed.
NFPA 30 Code Com liance
P.J. Russell memo dated June 29, 1990
Status
Complete
P.J. Russell memo dated July 2, 1990
Status
To be completed by Operations Department per yourdiscussion with A. Puplis.
P.J. Russell memo dated July 10, 1990
Status
In some fire zones there are more than three flammableliquid cabinets. In these areas flammable liquidcabinets are used to store Class A combustibles such ascleaning materials, aerosols, grease, etc. We considerthis to be an acceptable practice and monitor theadditional cabinets on a regular basis.
B.J. GerweNovember 18, 1991Page 2
Code Com liance Review — Im ell Re ort No. 09-0120-0123I 2.A
NFPA ~, Paragraph 1-9.5.6ir-zo-tg
Status
Signs will be made for the Unit 1 and Unit 2 Halonsystems by December 31, 1991.
NFPA 72D, Paragraph 2034, 4052
Status
NFPA
Plant procedures will be revised or new proceduresdeveloped to verify that alarms are received in theControl Room from those Auxiliary Building standpipesthat are fed from piping equipped with a flow alarm orare controlled by ZMO-10 and ZMO-20 by June 1, 1992.
12, Paragraph 1625
Status
The vent lines referred to in this item were not partof the original installation and will not. bereinstalled for safety reasons. In the event of ablockage in any part of the vent line pressure can backup through the back side of the pilot valves openingthe valves and allowing an uncontrolled discharge ofC02 into all of the areas connected to the vent line.
This item will be completed with the Expanded CodeCompliance review items.
NFPA 72D, Paragraph 2042 Item b.Status
Relocation of fire detectors or installation ofprotective guards will require a design change.~ <~>««+~~~CP+ <F YHia l~ SCK Lh- L4-RL KE'Hp'a.a'su.sos. ~~zr- ~-wr
B.J. GerweNovember 18, 1991Page 3
Ex anded Code Com liance ReviewIm ell Re ort No. 09-0120-0381
NFPA 10, Paragraph 4-3.2
Status
Procedure 12 SHP 2270 FIRE.001 has been revised toverify that fire extinguishers are clear. On fireextinguishers the operating instructions are applied by.the manufacturer as is the hanging bracket. Since theextinguisher can only be hung one way we will notchange the procedure. The monthly inspection is thedocument that verifies that the extinguisher has beeninspected. The inspection procedures meet NFPAcriteria.
NFPA 13, Paragraph 1041
Status
A walk down of the sprinklers will be completed and thesprinklers realigned as needed by December 31, 1992.
Valve 1-FP-196 was installed without a hand wheel. Adetermination will have to be made on whether one canbe added without a design change.
Paragraph 3612
Status
A field walk down will be conducted and sprinkler headschanged as recpxired by December 31, 1992.
Paragraphs 3681, 3682, 3683
Status
This item will be completed in 1992 or 1993 dependingon budget allocation.
Paragraph 4143
Status
A walk down will be completed and sprinklers installedper applicable drawings by December 31, 1992.
B.J. GerweNovember 18, 1991Page 4
NFPA 72D, Paragraphs 2034, 4052
Status
Procedures for the testing of the CFT Charcoal FilterUnits will be completed by the start of the 1992refueling outages 'for each unit.
ESW Extinguishers
Status
Per your request we have verified that the fireextinguishers in the ESW Pump Room area are all ABC DryChemical extinguishers.
P.H. Jacques
c: P.F. CarteauxFile
Table 4.1
'ross Reference ToNFPA Code Deviations Identified by
Impell Technical Report No. 09-0120-0123Tables 3.1-1 Through 3.8-1
NFPA CodeCode Edition
CodeSection
Number of JustificationJustifications Letter Date Remarks
72E 1974
72E 1974
72E 1974;1982
5-3.25-4.15-4.25-F 1
5-5.2
7-3.1.48-3.2 '
814
1NA
NA
6-17-884-26-89
6-17-8811-18-91
11-18-91
RFC 12-3004
Procedure needs to bechanged.
Procedural ChangeRequired.
4-7
AMERICANEMCTRICPOWER
Date November 15, 1991
Subject Donald C. Cook Nuclear PlantNFPA Code ComplianceImpell Report No. 09-0120-0123
ABB Impell code compliance review for NFPA 14 identified the followingcode deviation.
NFPA 14 1986 Edition Section 8-1.2
Deviation: The specification used for installation of hosestation and standpipe systems does not specify arequired flow test.
An engineering review of this deviation and the resulting justificationfor acceptance of the NFPA code deviation is given below.
Justification: Specification DCC-QV110-QCF is a generic specificationfor the design, installation and testing of fireprotection systems. The specification has alwayscontained the requirement that, "All testing of thefire protection systems shall be in accordance withthe applicable NFPA Standards." While thisspecification does not specifically state theindividual testing requirements of each of the NFPAStandards it covers, the statement was'ntended toencompass all the testing requirements of eachstandard. Therefore, the flow test requirements ofNFPA 14, Section 8-1.2 are part of and have alwaysbeen part of the specification.
In certain situations, it may not be prudent toperform a full flow test due to ALARA concerns. Waterdischarged within the Auxiliary Building requirestreatment to remove radioactive contaminants which isa concern in both the management of this large volumeof water and the costs involved with its treatment.In addition, due to the location of some of thestandpipes and hose stations there may be no easy wayto discharge such a large volume of water withoutraising other safety concerns. Therefore, in thesesituations,a limited flow tested is a more reasonablealternative and the adequacy of the water supply atthe hose station will be demonstrated by hydrauliccalculation.
Based on the above evaluation, the code requirementfor flow testing has always been part of thespecification and does not require revision of thespecification to make specific reference to thisrequirement.
Subject Donald C. Cook Nuclear PlantNFPA Code Compliance ReviewImpell Report No. 09-0120-0123
From B.J. Gerwe
To NFPA Code Compliance Report 09-0120-0123, Section 4.0
ABB Impell Code Compliance review for NFPA 72E had identified variouscode deviations. A number of these deviations were further reviewed andjustified in the June 17, 1988 memo from D.E. Kipley of Impell to J.A.Kobyra of AEPSC. Many of the remaining deviations were also reviewedand justified in the April 26, 1989 memo by P.J. Russell to the NFPACode Compliance Report. In reviewing the documents, three errors werefound.
First, Table 3.8-1 of the NFPA Code Compliance Report 09-0120-0123 (pg.3-130, NFPA 72E Code Sections 2-6.5, 2-6.7 and 4-1.2) contained twotypographical errors. The wrong Fire Zone number was referenced, FireZone 56 instead of Fire Zone 57, and the wrong detector and circuitnumber was given, 10-12 instead of 18-12. In support of the fact thatan error exists the next page of the Report,. pg. 3-131, correctly statesthe same deviation in Fire Zone 57 and detector circuit-detector number18-12 for Code Sections 4-3.1 and 4-3.2. In addition, a check of thedetector circuit numbers, detector numbers and the Fire Zone numbers wasperformed to confirm the correct identification. These typographicalerrors have been corrected in the report.
The second error was noted in the April 26, 1989 memo, where thejustification incorrectly lists detectors 18-10 and 18-12 in Fire Zone58 instead of 57. Fire 58 is the Unit 2 Control Room Cable Vault, whileFire Zone 57 is the Unit 1 Control Room Cable Vault. The April 26, 1989memo has been corrected to reference the correct fire zone.
The third error was found in a June 17, 1988 justification which wasalso performed for these detectors under a code deviation for Code
Sections 4-3.1 (1974 Edition) and 4-3.2 (1978 and 1982 Edition). Thisjustification however, did not make reference to the same deviationnoted under Code Sections 2-6.5, 2-6.7 and 4-1.2. This justificationstates that after a second field review, the detectors were found to beinstalled 6 inches away from the sides of the beams and not 4 inchesaway as stated in the Report. Therefore, it was concluded that thedetectors were correctly installed to meet NFPA 72E and there was nocode deviation. This memo serves to provide the additional reference tothe June 17, 1988 justification for Code Sections 2-6.5, 2-6.7 and 4-1.2of NFPA 72E (1974 and 1978 Editions).
Concurrence: //-/5 —9 fP.J. Russ 1, Fire Protection Engineer
Deviation: Several detectors'are exposed to mechanical damage andrequire protective guards as follows:
Fire Zone 33 - Detectors 3-26 and 3-27Fire Zone 34 - Detector 3-27Fire Zone 39 — Detector 2-7
FireZone
Fire ZoneEvaluation Device
33
34
609'09'mokedetector 3-26 and 3-27 are located under a
platform at elevation 646'-9" at 6.5'bove theplatform elevation 639 '-4" floor. These devicesare located in the normal access path to thisplatform and are exposed to damage.
Smoke detector 3-27 is arranged as discussed forFire Zone 33.
39 609'moke detector 2-7 located at the reactor cabletunnel penetration mezzanine is installed at5.75'bove the mezzanine floor and located inthe normal path of travel in this mezzanine.
Intra4ystem
November 14', 1991Page 2
An engineering review of this deviation has been performed and theresulting justification for acceptance of the NFPA code deviation isgiven below.
Justifications Even though the above smoke detectors are located in"normal access paths", the areas where they are located are notfrequently occupied. In addition, these detectors are not in the normaltravel routes through the area. They are instead located off the maintravel routes where only a person with a specific purpose would enter.
In Fire Zones 33 and 34, the detectors are located beneath platformswhere valves, instrumentation and piping are located. The detectors arelocated in small beam pockets formed by the structural steel memberssupporting the platforms. These steel beams provide protection fromactivity outside the small beam pockets.
In Fire Zone 39, detector 2-7 is located in the mezzanine area of thezone. Access to the mezzanine is by a ladder. While a door is providedat the end of the mezzanine, the door is only used in an emergency.This door separates a radiologically controlled area from a non-controlled area. The detector is also located towards the end of themezzanine away from the ladder. The mezzanine contains cable trays andconduits which pass through the area.
Historically, these detectors have not been a source of problems andhave never been known to suffer damage due to their location.
Based on the above evaluation, the protection of these detectors willnot be required and are considered to be acceptable as installed.
References: O ABB Impell NFPA 72E (1974 Edition) Section 2-6.1 CodeCompliance Evaluation dated June 17, 1988 from D.E.Kipley (Impell) to J.A. Kobyra.Engineering judgement based on field review.Conversation with Plant Fire Protection Coordinator.
Concurrence: /I-I>=5 /P.J. Ru ell, Fire Protection Engineer
B.J. Gerwe
BJG/gh
cc: J.D. Grier/B.J. GerweP.H. Jacques — BridgmanMF:
To NFPA Code Compliance Report No. 09-0120-0123, Section 4.0
ABB Impell code compliance review for NFPA 12A identified the followingcode, deviation.
NFPA 12A Edition 1977 Section 1-9.5.6
Deviation: A system nameplate is not provided for any of theareas/systems which were evaluated.
An engineering review of this deviation has been performed and itsresulting resolution and justification for acceptance of the NFPA codedeviation is given below.
Resolutiont Nameplates are being provided for the Unit 1 and 2 ControlRoom Cable Vault halon systems. These halon systems are the onlyTechnical Specification halon systems installed at the plant.Nameplates will not be provided for the non-Technical Specificationhalon systems.
Justifications A halon essential use study has been conducted for thehalon systems installed at the plant to determine their need in light ofthe environmental concerns surrounding the continued use of this firesuppression agent. This study evaluated each halon system and madedeterminations as to whether the system should remain, be replaced withan alternate suppression system (e.g., water or carbon dioxide) or beremoved with no alternative suppression system provided. Thereplacement and removal of these systems is scheduled to occur over thenext several years. At this time, only the Control Room Cable Vaulthalon systems are to remain.
Prior to system removal, all work performed on the halon systems is donein accordance with plant procedures and the appropriate drawings. Inaddition, the halon cylinders are located outside the area beingprotected and, therefore, can be readily identified and would not leadto confusion between systems. Members of the fire brigade are alsotrained and knowledgeable in the operation of halon systems and in theirlocations throughout the plant.
IntraSystcm
November 14, 1991Page 2
Based on the above evaluation, the lack of system nameplates for thenon-Technical Specification halon systems is considered acceptable.
Refereacess Halon Essential Use StudyLesson Plan FF-C-AS19 Miscellaneous Fire ProtectionFire Facility DrawingsRFC-12-3082 Design Change
Concurrence: //-/5= (P.J. Russ , Fire Protection Engineer
B. . Gerwe
BJG/gh
cc: J.D. Grier/B.J. GerweP.H. Jacques — BridgmanR.L. ShobergFile: Halon Essential Use StudyMF: Y N
To NFPA Code Compliance Report No. 09-0120-0123, Section 4.0
NFPA Code Compliance Report No. 09-0120-0123 identified severaldeviations to NFPA 13, 14 and 15 concerning confirmation of hydraulicsupply and demands. The 1mpell-identified deviations and AEPSCresolution are noted below.
(1) NFPA 13 1983 Edition Sections 2-2.1.2.4 and 2-2.1.2.5
Deviation: Exterior fire hose demands were not added to thehydraulic sprinkler system calculations.
(2) NFPA 14 1971 Edition Sections 525
Deviation: Water supply requirements for both sprinklers andinterior hose stations are to be considered.
Deviation: Water supply graph sheets are not provided for thewater suppression system calculations.
Resolution: As a result of the new fire protection water supply systemcurrently being installed (RFC-12-3065), new hydraulic calculations arebeing prepared to demonstrate the adequacy of the new water supply inmeeting the demands of the existing water suppression systems andstandpipe systems.
Intra4ystcm
November 13, 1991Page 2
The calculations will be complete from the fire pumps up to the demandpoints and include the requirements of the applicable referenced codesections. This will ensure that an adequate water supply and pressurewill be available to meet all system demands. Since the calculationswill be complete back to the water source, i.e., fire pumps, there willbe no need for the development of water supply graphs.
References! RFC-12-3065 Design Change
Concurrence:P.J. R ll, Fire Protection Engineer
B:J. Gerwe
BJG/gh
cc: J.D. Grier/B.J. GerweFile: RFC-12-3065MF: QY N
Data August 19, 1991
swan~ Cook Nuclear PlantFire Alarm Circuit SupervisionCloseout of App. R Action Item 1.26
APPAL, 7gg\ l4 l KbLYioA
840, 44AZ,
From
To
2) S.J. Brewer
The following discussion provides PHGF's response to the identifieddiscrepancies made by the NRC in their April 26, 1990 SER concerningfire alarm system circuit supervision. The issue was stated in Section2.3.1 of the SER and the response was given in Section 2.3.2. Thisdiscussion is based on the results of the Impell review and write-up ofthis problem in their July 6, 1990 letter by Mr. D. Kipley. A spotcheck of some of the procedures referenced in the Impell letter was
performed to verify that the activity was still being performed.
Sections 2.3.1 and 2.3.2 of the SER addressed compliance of the plantalarm signaling system with the requirements of the NFPA 72D. A reviewof the statements made in Section 2.3.2 indicates that the NRC is of theunderstanding that all plant fire alarm system initiating circuits areelectronically supervised in accordance with the requirements of NFPA
72D with the exception of two circuits. These two circuits are withinthe control room between the plant fire input panels and the EmergencyFire (EF) annunciator panel on the main control board. This supervisionstatement could be interpreted as including all waterflow and sprinklersupervisory alarm initiating circuits as well as fire detection andsuppression actuation and initiating circuits. Under thisinterpretation, the statement is only partially correct in that not allof the plant alarm signalling system circuits are supervised inaccordance with NFPA 72D. Secondly, this statement is incorrect withrespect to the number of unsupervised circuits within the control room.
It should be noted that the following response is based on the 1986Edition of NFPA 72D. This Edition was in force at the time of theNovember 1 and 2 meeting in 1989 between AEPSC and the NRC at the CookNuclear Plant. The following response is also based on only thosesystems reviewed under the NFPA Code Compliance Reports, which includesthe Technical Specification systems and those systems in areas of theplant which contain safety related and safe shutdqwn components and/orcables.
Intra-Systaa
August 19, 1991Page 2
Zn addressing the portions of the syst: em outside the control rooms whichare not supervised in accordance with NFPA 72D, these circuits includewaterflow and sprinkler supervisory alarm initiating circuits and alarmsignals between the local control panels and the control room. As
documented in the NFpA 72D Code Compliance Report, the following alarmsignals are not supervised to the requirements of NFPA 72D.
~ CO System Cardox and Alison control panel alarm and trouble.2signals,
~ Reactor Coolant Pump (RCP) panel alarm and trouble signals,~ Containment cable tray detection panel alarm and trouble
signals,~ Halon Syst: em Alison and Pyrotronics control panel alarm and
trouble signals~ alarm initiating circuits for waterflow,~ sprinkler supervisory (valve tamper and low air pressure
switches) signals, and~ fire pump signals
The detection system alarm and trouble signals of the CO+, RCP andContainment cable tray systems interface with the control room viaAlison control panels. The suppression system alarm and trouble signalsof the CO systems interface with the control rooms via Cardox controlpanels. The control room cable vault Halon systems signals interfacewith the control rooms via Alison control panels. The plant computerroom Halon system signals interface with the control rooms via
4
Pyrotronics low voltage System 3 control panels.
The NFPA Code Compliance Report also documents that the fire detectionsystem alarm initiating circuits and the CO and Halon suppressionsystem actuation (i.e., solenoids) circuits are properly supervised asrequired by their respective local control panel.
A properly supervised circuit as defined by NFPA 72D, Sections 3-9 and3-10, is a circuit that verifies operability of the circuit byindicating a trouble condition at the associated control panel for bothopen circuit and ground fault conditions. The NFPA Code Compliancereview identified that the annunciator circuits associated with the EF
panels are not electrically supervised to detect open circuits or wirebreaks. These annunciator circuits are properly supervised fordetecting ground fault conditions. A review of our licensing documentsindicates that we have committed to comply with the requirement tosupervise for open circuits for only the fire detection systems. TheNRC accepted this position in their SER for Appendix A to BTP APCSB 9 ~ 5-1, dated July 31, 1979.
August 19, 1991Page 3
Two of the fifty-three Appendix A follow-up questions posed by the NRC
addressed circuit supervision. These questions were Numbers 16 and 53.Information was presented which identified which portions of the overallfire alarm system were supervised. The Appendix A requirement forcircuit supervision is limited to fire detection systems only. This was
the commitment position taken by AEPSC as given in the response toQuestion 16b. The Appendix A SER also refers to only circuitsupervision in the context of fire detection systems. The Appendix A
SER states that the NRC "reviewed the fire detection system' designcriteria and the basis to ensure that it conforms to the applicablesections of NFPA 72Dg for Class B supervised circuits". Therefore, it isinterpreted that the only NFPA 72D requirements for circuit supervisionto which Cook Nuclear plant is committed are for fire detection systems.
Again, the initiating device circuits on the high and low voltagePyrotronics (smoke and flame detection) and Alison (thermistor heatdetection) local control panels are Class B supervised circuits. The
high voltage Pyrotronics panels, referred to as the Emergency Fire Rear(EFR) panels, are located in each control room behind the main controlboard containing the EF panel. The high voltage panel monitorsdetection circuits as well as input signals from some of the otherPyrotronics low voltage panels. The Technical Specification requiredlow voltage Pyrotronics detection panels transmit alarms back to thecontrol room on supervised high voltage Pyrotronics initiating devicecircuits. These EFR panels transmit duplicate alarm signals to thefront of the EF panels. These alarm signals are unsupervised. However,they are considered to be in accordance with Section 2-7.1 of NFPA 72Dsince these circuits are contained within the enclosure of the controlroom horseshoe control panel. Section 2-7.1 does not requiresupervision of wiring within a common enclosure. Since the control roomhorseshoe panel is considered to be a common enclosure, this wiring neednot be supervised.
For the Alison local detection control panels, they transmit signals toannunciator logic cabinets located behind the main control boardcontaining the EF panel. The Cardox suppression system control panelsand the Pyrotronics System 3 control panels for the computer rooms, alsotransmit signals to the annunciator logic cabinets located behind themain control board. These annunciator logic cabinets transmitunsupervised alarm signals to the front of the EF panels. Since thesignals between the logic cabinets and the EF panels run through thecommon enclosure of the control room horseshoe panel, they are notrequired to be supervised per Section 2-7.1.
The routine surveillance testing performed for the detection andsuppression actuation and initiating circuits described above, alsocomply with the requirements of NFPA 72D Section 2-4.3.d with theexception of the RCP systems. Section 2-4.3.d requires testing to beperformed every six months. Alarms sent to the control rooms which arenot electrically supervised are checked every six months. The RCP
systems are functionally tested every 18 months due to the fact that the
August 19, 1991Page 4
detection and suppression actuation devices are located withinContainment and are normally not accessible during plant operation. The
function tests include checking for alarms at the local control panelsand those sent to the control rooms. Operations also performs a once-per-shift visual examination of all fire panels. This examinationincludes checking for alarms and actuations which may have occurred.During 'a meeting held on November 1 and 2, 1989, at the Cook NuclearPlant, Messrs. D. Kubicki of the NRC and B.J. Gerwe of AEPSC discussedthe surveillance testing program. Mr. Kubicki indicated that thecurrent surveillance practices being implemented for the fire detectionand suppression systems met the intent of the code and were consideredacceptable.
I
Although the fire detection ancl suppression systems are being properlysurveilled, all waterflow and sprinkl'er supervisory devices (valvetamper and low air pressure switches) are not being verified as requiredby NFPA 72D. Justification for acceptance of these conditions arediscussed below.
1) All of the waterflow alarm devices and circuits, with theexception of the Training Buildings and Technical Support Center(TSC), are verified for operability by simulated or actual flowtest methods in accordance with plant procedures. The TrainingBuildings and TSC are non-safety related areas of the plant andhave no impact on the operation of the plant.
2) The valve tamper alarm signals are not verified for receipt ofa trouble signal in the control room during the performance of thevalve cycling testing. However, the valves are inspected forcorrect position monthly by procedure. This inspection fulfillsthe intent of the valve tamper switch trouble signal.
3) The low air pressure supervisory alarm devices and theircircuits are not verified for operability with the exception ofthe RCP low air alarm devices. However, this is not viewed as anegative factor based on the reliability of the plant air supplysystem and the inspection of dry pilot preaction sprinkler systempiping by plant procedure.- Zn addition, the plant proceduresprohibit the indiscriminate changing of valve positions. Valvepositions may only be changed under the umbrella of a plantprocedure or job order. The plant air supply is consideredreliable due to the redundant plant air compressors which serveboth units. Should a low air pressure condition occur within oneof the dry pilot piping systems located in the Auxiliary Building,the preaction valve would operate resulting in a waterflow alarmsignal being sent to the control room. Since the dry pipe systemsuse closed head sprinklers, no water would be discharged. Theensuing investigation of the spurious water flow alarm would pointto the loss of pilot air pressure condition.
August 19, 199 1Page 5
4) The fire pump supervisory devices are connected to the EF
panels and are verified for operability under plant procedures.
Section 2.3.2 of the SER also states that there are only twounsu rvised circuits within the control room to the annunciator panelson the main control board. This is not correctly stated. The statementshould have said that there are two cases of unsu ervised circuitswithin the control room. These two cases were discussed previously andinclude the transmittal of signals from the EFR panels and annunciatorlogic panels to the main control board EF panels in each unit. However,these circuits are judged to be in accordance with NFPA 72D; Section 2-7.1, which states that circuit wiring contained within a common
enclosure need not be supervised. The wiring between the EFR and logicpanels to the EF„panels are considered to be within the common enclosureof the control room horseshoe panel.
B.J. Gerwe
cc: R.L. Shoberg/E.A. Taylor (App. R Action Item 1.26)J.D. Grier/B.J. Gerwefile: NFPA 72D Code Compliance
App, R Continuing ComplianceMF: Yes
SLIT BY: 9" C-80 : 8:274'9
L Ikik'LI11
ASEA BROWN SOVERI
Inter-Office Correspondence
MEMO TO: Bruce Gerwe
File: 0120-158M-018
Copy: GAWMJSSJCDEK
FROM! David E. Kipley
DATE: September 6, 1990
SUBJECT: NFPA Code Compliance Evaluation Review
REFERENCE: Memo from S. J. Brewer to A. A. Blind Et.AI.,Re: "Action Item Assignments', Rev. 2, Dated 4/26/90
This memo is being issued to document ABB Impell's review of Station's procedureswhich close out deficiencies identied in ABB Impell Report No. 09%120-0123.These procedures include:
All other procedure deficiencies still remaining open from those identified in the report,have been detailed in memo no. M%13, dated 8/31/90.
ANERICAN.ELECTRlCPOWER
Oate September 5, 1990
Subject Donald C. Cook Nuclear PlantImpell Code Compliance Review
From P.J. Russell
To
The Cook Nuclear Plant was identified as not being in compliance withthe following section of NFPA 72D (1967 edition).
o Section 3542 "Suitable and practical facilities shall be providedto permit periodic testing for sensitivity". Specifically, detectornumber 29 located in Fire Zone 44S was the detector identified asbeing deficient in this compliance.
Plant Procedure 12-THP6030.IMP.051 currently tests all detectors locatedwithin Fire Zone 44S. This procedure has not identified any detectorlocated within this fire zone as being inaccessible. While we agreethat some obstructions exist to easily test this detector, we feel thatpast performance testing proves that this detector can be tested andmaintained. Therefore, we feel that this detector meets the intent ofsection 3542 of the 1967 edition of NFPA 72D. No modification will bemade to this fire detector.
PJR/j mf
cc: R.L. ShobergJ.D. Grier/B.J. ~Gerwe/P.J. RussellFile: Appendix R Audit
Intra.System
ANKRlCANKLKCTRlCPO%VER
o~t0 September 4, 1990
Sttbi00t Cook Nuclear PlantRFC-DC-12-3003S&ADNS's Review of Open Items
( Yt-M ~~gt= ocrf oF
l~>~ ~<~tomC~4
Ff0m
To P. J. Russell
RFC-DC-12-3003 requi.red Structural & Analytical Design NuclearSection (S&ADNS) to review:
1. Impact of piping changes on Auxiliary Building (AB) supportsystem.
2. Fire protection main on EL. 587'or lateral restraints andcompli.ance with NFPA 814, section 651.
S&ADNS has reviewed above items and has concluded as noted below:
Item 1
Piping changes generally comprise of adding and/or revisi.ngsprinkler heads i.n an exi,sti.ng Fire Protection (FP) system, whichhave been effected by addi.tion of small pipe sections (1" dia. x 4"to 6" long). These changes are insignificant and would have nosignificant effect on the FP system.
Item 2
We understand that the review of item 2 is required to close outImpell's finding which stated that the 6" FP main at 587'-0"elevation lacked lateral supports and might not remain i.n placeunder flow condition.
As per discussion with you, NED had confirmed that this FP syst: emhas been in operation for a number of years and has been testedunder flow conditions numerous times in accordance with existingplant procedures such as 12-0HP-4030.STP.124. During this time,S&ADNS has not been informed of any vibration related and/or pipedisplacement related problem for this system under flow condition.Site Design's inspection of this specific pipe section did notreveal any visible wear (see Attachment 1) indicating significantdisplacements. Zn addition, sufficient number of pipe supports arein place for this Seismic Class ZZZ system and the installation oflateral restraints is not a specific requirement of NFPA g14,section 651.
Intra-System
RFC-DC-12-3003September 4, 1990Page 2
We therefore believe NFPA requirements have been met and noadditional changes are required to close out this open item.
If you have any questions, please contact the writer at extension3862.
A. K D
AKD/dmREF: 12-3003/RFC90
Attachment
xc: J. A. Kobyra/D. J. Petro —w/attachmentN. Ruccia —
.~I
File: RFC-DC-12-3003
5lNDCANANlCHlGANlIOWKR
Oate March 7, 1989
FWR III766-SM587'-W Hal.lway 6" Fire Protection Main
THC.003
Frrrm T. H. Cummings
To A. K. Dey
As per your request, the 587'-W hallway 6" fire protection main wasreviewed to determine if the system had adequate lateral support torestrain the pipe from movement during the operation of the system.
The results of this review are as follows:
1. There is no existing lateral supports on the 220 feetof straight pipe running through the 587'-W AuxiliaryBuilding hallway.
2. Even though there is no lateral support on this 6"piping system, there was no visible wear seen on thepipe or supports reviewed which would indicate systemmovement during operation.
If you have any questions or coments, please contact the undersigned.
Thomas H. CumtingsSite Mechanical E ineer
/Jc
A—, ( A, C, H ME.N 'l — 1
hAp~o pa.o~ A-K.top io I T. Bursa~)ph~C.~ g. y. igloo, <F <- >
Several generic deficiencies were identified by ABB Impell's review'fAEPSC's NFPA Code Compliance Verification reports and closeouts. Anumber of these deficiencies impacted documents prepared by the PH&FSection. Our response to the ABB Impell comments are as follows.
NFPA 20 - FIRE PUMP CODE COMPLIANCE REPORT
Item C.l
Sections 41a and 41b. The compliance statement indicated that the firepumps are isolated in separate fire zones. Although this may be truefor the two diesel driven fire pumps, the three electric driven firepumps are all located within the same fire zone (Fire Zone 2). Furtherclarification should be provided to address the concern of theinstallation of these pumps within the same fire zone.
~Res onse
Our response to Sections 41a and 41b have been revised forclarification.
Item C.2
Section 143b. The compliance statement has indicated that the unlinedsteel suction pipes installed for the fire pumps has not experiencedexcessive friction loss. The basis for this statement should beindicated (i.e., flow testing). Also, the statement that the internalpainting of the suction piping is an "unnecessary expense" should not beprovided as a part of any justification. This statement should bedeleted.
~Res onse
Our response to Section 143b has been revised to delete the "unnecessaryexpense" comment. We also added the Performance testing procedures astechnical reference for the basis of our statement that excessivefriction loss through the suction pipe is not a problem.
Intra-System
September 4, 1990Page 2
Item C.3
Section 222a. This section has been listed as not applying; however,this section is an extension of Sections 222b and 222c and should beaddressed accordingly.
~Res onse
Our response to Secti.on 222a has been revised so that there will be nomisunderstanding in our complete compliance with Section 222 of NFPA 20.
The following is the PHGF Section's response to ABB Impell's commentsconcerning AEPSC's memos dated February 8, 1989 and April 26, 1989.
Item A
A hydraulic analysis should be performed to verify the adequacy of theexisting water supply system to support the demands of the existing andany new suppression systems installed.
~Res onse
A computerized program has been purchased for the purpose of evaluatingexisting as well as new fire suppression systems. This program is beinginstalled onto the AEPSC computer system by calculation numberDCC-FP-12-MC05-S.
Item B.l
These memos further discuss justifications made for deficienciesidentified in Impell's Report No. 09-0120-0123. The evaluationsprovided in these memos should identify the technical data used insupporting the conclusions made (i.e., AEPSC memo dated June 17, 1988).
~Res onse
These memos are based on the engineering judgement of a qualified fireprotection engineer. The, justifications were written upon thecompletion of a field walkdown conducted by the author. Thisinformation is contained within these documents.
September 4, 1990Page 3
Item B.2
The memo dated April 26, 1989 made numerous references to the cost ofretrofitting certain features of a system as part of the justification.The reference to the cost for not installing equipment for complianceshould not since it is believed that the NRC would not consider this areasonable answer. Therefore, it is recommended that all references tocost be deleted from these justifications. The sections in questioninclude Fire Zones 1, 32, 43, 48, 51, 42, 58 and 69.
~Res ense
All references to the cost of retrofitting certain features of the firedetection systems have been deleted from this memo.
SIIbjeot Response to Impell ' Review of Our NFPA 20 Code Compliance Report
From
To
J.D. Markham
P.J. Russell
As you requested, the following are our comments to the Impell's reviewcomments of our NFPA 20 Code Compliance Report related to electricalsections:
Comment a and b:
Attached is updated NFPA Code Compliance review Sections 4, 5, and 7with Technical Data references which were used as a basis for specificconclusion or" justification. Also, attached is a listing of REFERENCES(Electrical/Instrumentation & Controls). In addition, the followingshould be added to the introduction: "A field walkdown was made bycognizant Electrical/I&C Engineering personnel to review the arrangementof equipment, installation details, and to obtain other equipmentdetails such as ratings, model numbers, etc. that was not available inreference technical data. This information was used as a basis forthose conclusions or justifications marked as VALKDOVN (V)."
l'1 e
IV ~
Comment 64s
Our reply was based on our interpretation of the NFPA 20 requirementsand applicability which is noted "Comply".
I,
Comment d5:
The statement 'Comply" is correct. The fire pump motors have NEC CodeLetter G. The reason for the statement of "comply with intent ofrequirement" is that the table listing NEC Code Letter requirements doesnot list motors above 200HP. The high demand fire pump motors are300HP.
Comment 'd6:
Section 455b applies to the 300HP (high demand) motors since they aredrip-proof motors, but this section does not apply to the 75HP (lowdemand) motor since it is totally enclosed. However, the requirementsof Section 455b (and 455a) is not applicable (as noted) since the hosevalves are located outside the pump room.
Section 455d applies to the 75HP (low demand) motor since it is totallyenclosed, but this section does not apply to the 300HP (high demand)
Intra System
J.D. MarkhamAugust 23, 1990Page 2
motors since they are drip-proof. As noted, the 75HP motor compliesvith the requirements.
Comment 7:
The compliance statement "Comply" is correct. Hovever, the additionalexplanation is a typographical error. The technical data reference hasbeen indicated in the revised checklist as - "Technical Data - VendorInformation'.
C.~comment
The incomplete sentence resulted in improper copying. Nev'page has beenmade available.
REFERENCE: Memo from S. J. Brewer to A. A. Blind Et.AI.,Re: "Action Item Assignments", Rev. 2, Dated 4/26/90
This memo is being issued to document ABB lmpell's review of the NFPA codecompliance evaluations performed by AEPSC. The evaluations and associateddocuments reviewed have been listed below. The completion of this review processcloses out Action Item No. 21 of the referenced memo.
PH&FP Memo from B. Gerwe to J. Kobyra/A. Auvil for NFPA 720 Code ComplianceSoctions 2032, 2212, & 3111, dated 11/30/88.
PH&FP Memo from P. Russell to Impell Code Compliance Walkdown, "AutomaticSprinkler Systems", dated 2/8/89.
PH&FP Memo from P. Russell to Impell Code Compliance Walkdown, "Automatic FireDetection System", dated 4/26/89.
Code Compliance Verlcation Checklist for NFPA 20-1969 "Standard for the Installationof Centrmcal Fire Pumps".
ABB Impell's review of the Code Compliance Verification Checklist for NFPA 20identmed several generic deficiencies which are detailed below,
Numerous code sections and Justification statements have not provided atechnical reference to provide a basis for the conclusion made in thecompliance statement. The code sections noted, but not limited to,. includeSections 243 through 531 and 666c through 934. The technical references areessential for supporting the respective compliance statement or justiTication.
B.
C.
Numerous "Comply" or "Does not Apply" statements made to documentcompliance to code section requirements, did not indicate the basis for why thesystem is in compliance. These code sections include Sections 443, 454a,456c, 456d, 511e, 512c, 513d1, 513d2, 514b2 thru 514b9, 514c1, 514c2, 515d4,515e, 525 thru 528, 712a thru 712c, 713e2 thru 713g, 714a2, 714a3, 714b1,714b3, 715b1 thru 715c2, 715d4, 714e3 thru 715f3. The applicable supportingstatements should be provided to document why compliance or non-applicability is true.
Inconsistencies were noted in a number of statements raised questions whichrequires additional clarifications. These sections include the following:
Sections 41 a and 41b. The compliance statement indicated that the firepumps are isolated in separate fire zones. Although this may be true forthe two diesel driven fire pumps, the three electric driven fire pumps areall located within the same fire zone (Fire Zone 2). Further clarmcationshould be provided to address the concern of the installation of thesepumps within the same fire zone.
- SEN1'Y:IMPELL/Lincolnshires ILi 8-31-90 i ll:230
7088317346 614 223 3594
Memorandum01 20-158-M-013August 31, 1990Page Three
2.
3
4
5.
6.
7.
8.
Section 143B. The compliance statement has indicated that the unlinedsteel suction pipes installed for the fire pumps has not experiencedexcessive friction loss. The basis for this statement should be indicated(i.e., flow testing). Also, the statement that the internal painting of the
'uction piping is an "unnecessary expense" should not be provided as apart of any justification, This statement should be deleted.
Section 222a. This section has been listed as not applying, however, thisection is an extension of the Sections 222b and 222c and should beaddressed accordingly.
Section 440. This section may not apply since this facility is a powerplant and does not have a transformer specifically provided for the firepulTlps.
Section 451c. The compliance statement made for this section impliesthat there is a non~ompliance with the system however, a detailedjustification has not been provided. This justmcation should be provided,
Sections 455b and 455d. The compliance statements for these sectionsseem to be incomplete since the statements only make reference toeither the high or low demand fire pumps. Further clarification should beprovided to indicate that all electric driven pumps have been reviewedagainst the requirements of these sections.
Section 513d3. The compliance statement does not adequately addressthe code section requirements. The compliance statement shouldaddress whether the pump controller components {i.e., power supplies,fuses) have been rated for continuous duty. This system should beevaluated against this code section's requirements.
Section 514a. The last sentence in the justification statement providedhas not been completed. This statement should be completed.
k
SEMT BY: IMPELL/Lincoinshire IL: 8-31-90 '1:24
Memorandum0120-158-M%13August 31, 1990Page Four
7088317346~614 223 3594 sC 5
/~me~'TP>P ~
ABB Impell's review of several station surveillance procedures to verify if that theprocedural deficiencies noted in Impell's Report 0&41204123, have identified severalunresolved issues. These issues include the following:
NFPA Code
72D
Procedure Requiredfor Revision
12 MHP 4030 STP. 020SERIES
„12 SHP 2270 FIRE.004182 OHP 4030 STP.121SERIES
12 THP 6030 IMP.153
Requirement
The filter unit 12-HV-SATFUnozzle system is not verifiedfor operability.
The fire pump and hosesystem manual station alarmsignals are not verified fortheir operability.
The verification of thealignment of Ultravioletdetectors to confirm properprotection.
ABB Impell's review of numerous evaluations performed by AEPSC to showcompliance with deficiencies identified in lmpell's Report 094120-0123, indicated thefollowing open items.
A.
B.
A hydraulic analysis should be performed to verify the adequacy of the existingwater supply system to support the demands of the existing and any newsuppression system installed,
The review of AEPSC's memos dated 2/8/89 (NFPA 13) and 4/26/89 (NFPA72E) indicated the following open items.
These memos further discuss Justifications made for deficienciesidentified in ABB Impell's Report 09412M)123. The evaluations providedin these memos should identify the technical data used in supporting theconclusions made (i.e., AEPSC memos dated 6/17/88).
SEQT BY: IMPELL/'LincoInshire IL'-31-90;,11:35
Memorandum0120-1 58-M@13August 31, 1990Page Five
A-~ckn
P~ cg~
2. The memo dated 4/26/89 made numerous references to the cost ofretrofitting certain features of a system as part of the justification. Thereference to the cost for not installing equipment for compliance, shouldnot since it is believed that the NRC would not consider this a reasonableanswer. Therefore, it is recommended that all references to cost bedeleted from these justiTications. The sections in questions include: FireZone 1, 32, 43, 48, 51, 52, 58 and 69.
AMERICANELECTRICPOWER
August 20, 1990
Cook Nuclear PlantAutomatic Sprinkler System
P.J. Russell rurt 8 Z.~
70 Impe 1 1 Code Comp 1 iance Walkdown
This memorandum is to be used as a supplement to our February 8, 1989memo (P.J. Russell to Impell Code Compliance Walkdown) regardingautomatic sprinkler system code compliance. This previous memo waswritten by a qualified fire protection engineer based on the fieldconditions encountered during a walkdown of the Impell identifieddeviations. All evaluations were based on the engineering judgements ofthe author. In this previous memo, a justification was written for thefact that the sprinklers protecting Fire Zone 105 were not installed inaccordance with Sections 4-1.1.1, 4-1.1.4 and 4-2.4.6 of the 1983edition of NFPA 13, "Automatic Sprinkler Systems." Since the occupancyof Fire Zone 105 has been changed, the previous evaluation is no longervalid. Following is a new evaluation, for this area.
It was stated in the Impell Report that sprinklers in the Southwestcorner of the lower level of the Contractors Access Area are installedtoo close to a beam. It is agreed that looking at these sprinklersindividually a problem with compliance to NFPA 13 exists. However,since this area (approximately 16 ft. by 14 ft.) contains foursprinklers, it is felt that the area should be reviewed as a whole. Itappears that the sprinkler contractor took into consideration theobstruction problem caused by the beam and compensated by placingsprinklers on each side of the beam. Currently, the Southwest corner ofthis room contains no permanent combustibles. In fact, this entire firezone contains very few permanent combustibles. This room is now used asa wrapping and temporary storage area for radiologically controlledscaffolding. Material is not typically stored here. Any storage thatdoes exist remains under stringent control by Plant Procedure PMI-2270.The four sprinklers installed in this area more than adequately coverthe floor space below. It is this author's belief that the intent ofSections 4-1.1.1, 4-1.1.4 and 4-2.4.6 of NFPA 13 are met by the existingsprinkler configuration. It is felt that the existing sprinklers areadequate and no changes need to be made.
Recommended Justification of the Alarm Circuit Supervisionfor the Donald C. Cook Nuclear Plant in Response to theNRC's Safety Evaluation Reported Dated April 26, 1990
REFERENCE: Memo from S. J. Brewer to A. A. Blind Et. Al.,Re: "Action Item Assignments", Rev. 2, Dated 4/26/90
The purpose of this memo is to report on ABB Impell's assessment of the subjectreport Sections 2.3.1 and 2.3.2 to provide input for addressing discrepancies identified~ ~ ~
~
~
in the NRC statements of this report. This item is listed as Action Item No. 21 in thereferenced memo.
On April 26, 1990, the NRC issued a Safety Evaluation Report (SER) which discussedthe fire protection features installed at the D.C. Cook Plant. Section 2.3.1 and 2.3.2 ofthe SER addressed compliance of the Plant Alarm Signaling System with therequirements of National Fire Protection Association (NFPA) Standard 72D. A reviewof Section 2.3.1 indicates that it is the NRC's understanding that all plant fire alarmsystem alarm initiating circuits are electrically supervised in accordance with NFPA 72Drequirements with the exception of two circuits within the main control boards. Thisstatement is not entirely accurate in that all plant fire system circuits could beinterpreted to include all waterflow and sprinkler supervisory alarm initiating circuits aswell as fire detection/suppression actuation and initiating circuits.
ABB Impell's NFPA 72D Code Compliance review', documented in Report No. 09-0120-0123 indicates that the fire detection system alarm initiating circuits andCO,/Halon suppression system actuation (i.e., solenoid) circuits installed throughoutthe plant were properly supervised as required by the respective local alarm panel.However, the alarm initiating circuits for waterf low, sprinkler supervisory signals, CO,panel alarm/trouble signals, RCP Pump alarm/trouble panel signals, Alison cable traydetection panel alarm/trouble p'anel signals, Halon panel alarm/trouble signals and fire
pump signals connected to the control room main control board (EF) panels via alarmsignaling line circuits are not properly supervised.
Memorandum120-158-M@07
July 6, 1990Page Two
A properly electrically supervised circuit as defined by NFPA 72D Sections 3-9 and 3-
10 would be a circuit which verifies the operability of a circuit by indicating a troublecondition at the associated control panel for an open circuit and ground faultconditions. These properly supervised circuits installed at the D.C. Cook Plant includethose circuits between the local control panels and alarm initiating devices.
Improperly supervised circuits are defined as those circuits which are supervised forground fault conditions, however do not indicate an open circuit trouble condition as
required by NFPA 72D, Section 3-10. These improperly supervised circuits installed at
the D.C. Cook Plant includes the circuits between the local control panels and the EF
panels.
Review of the responses made by AEPSC for APCSB BTP 9.5-1, Appendix A Section
E.1(a) and the NRC's 53 follow-up Questions indicate that Cook Nuclear Plantcommitted to complying to the applicable sections of NFPA 72D for the firedetection/suppression system control circuits only [Question 16b of the NRC 53Questions] ~ The plant fire detection (EFR) panels located within the control room
~
~
control board, properly supervise their associated detection system circuits locatedthroughout the plant. The local control panels for the RCP pump, Charcoal filter unit,
CO, and Halon systems, located near their respective hazard, properly supervise theirrespective actuation circuits. The EFR panels however, transmit signals to the EF
panels via signaling line circuits which are considered equivalent to properly supervisedcircuits as defined by NFPA 72D Section 2-7.1, since these circuits are containedwithin the enclosure of the control room control board. Although the local controlpanels of the suppression systems are not monitored via properly supervised signalingline circuits, the actuation devices for these local systems are connected to properlysupervised actuation circuits. Therefore, these local actuation devices are in
compliance with the commitment made in the Appendix A document.
The routine surveillance testing performed for the detection/suppression actuation and
initiating circuits described above, also comply with the requirements of NFPA 72DSection 2-4.4.d (every six months) with the exception of the frequency for performingthe surveillance on the RCP pump systems (every eighteen months). This is primarilydue to the fact that all RCP pump detection/suppression actuation devices are locatedwithin the containment structures and these areas are normally not accessible duringplant operation. During a meeting held in November of 1989 at the plant, Messrs.Dennis Kubicki of the NRC and Bruce Gerwe of AEPSC discussed the surveillancetesting program. Mr. Kubicki indicated that the current surveillance practices beingimplemented for the fire detection/suppression actuatiori systems met the intent of thecode and was considered acceptable [Ref. AEP memo from L. A. Bilionis to T. H.
Bestrom dated 10/31/89]. The plant procedures utilized for performing these
Although the fire detection/suppression actuation systems are being properlysurveilled, all waterflow and sprinkler supervisory devices (valve tamper and low airpressure switches) are not being verified as required by NFPA 72D. Additionaljustifications for why these conditions are considered acceptable are discussed below:
a. All of the waterflow alarm devices and circuits, with the exception of the Trainingand TSC Buildings are verified for the operability by simulated or actual flow testmethods under the following procedures: 12 OHP 4030 STP.125CV, 12 OHP 4030STP.125NS, 12 OHP 4030 STP.125TS, 12 OHP 4030 STP.120SF, and 1&2 OHP4030 STP.123.
4
b. The valve tamper alarm signals are not verified for their receipt in the control roomduring the performance of valve cycling testing under procedure 12 OHP 4030STP.120VC. However, the intent of the valve switches for verifying the respectivevalve's position is inspected under procedures 12 OHP 4030 STP.120VV andSafety 8 Assessment Office Guide No. 21.
c. The low air pressure supervisory alarm devices and their circuits are generally notverified for their operability with the exception of the RCP pump low air alarmdevices.
Based on the reliability of the plant air supply system due to the provision ofredundant air compressors and the adequate supporting of the air system piping[Flow Diagram No.-12-5120-17], and the verification of the Dry Pilot piping systemperformed under procedure 12 OHP 4030 STP.125TS, it is believed that adequatemeasures have been taken to insure the operability of suppression systems.However, should a low air pressure condition occur within the Dry Pilot pipingsystem(s) located in the Auxiliary Building the preaction valve would operate whichwould result in transmitting a waterf low alarm signal to the control room. Since theDry Pilot system employ's closed head type sprinkler's water discharge would notresult. Thus an investigation of the spurious water flow alarm would point to theloss of pilot air pressure condition.
Memorandum0120-158-M@07July 6, 1990Page Four
d. The fire pump supervisory devices and circuits are connected to the EF panels andare verified for their operability under procedure 12 THP 4030 STP.223.
In Section 2.3.2 of the SER, it was noted that only TWO improperly supervised circuitsexist within the main control boards. This is not a true statement since all the circuitsbetween the fire detection (EFR) panels and the main control board annunciator (EF)panels are not properly supervised. as required by NFPA 72D. However, an exceptionnoted in NFPA 72D (Section 2-7.1) indicates that the circuit wiring be contained withina common enclosure (i.e., EF/EFR panel), are considered equivalent to an electricallysupervised circuit. As discussed in the SER, since these circuits are verified for theiroperability during the performance of the respective surveillances, this condition
is'onsideredacceptable.
Rec mm nd ti n for Alarm S stem Su ervisi n Res on e
AEPSC should provide clarification of the following statements documented in theSER:
a. Section 2.3.2 should indicate that all fire detection/suppression actuation andinitiating circuits are properly supervised by their respective local alarm systempanels and that the circuits between the local alarm panels and the main controlboard annunciators (EF) do not provide supervision in accordance with NFPA 72D.However, this is considered acceptable based on the supervision of the local alarmsystem circuits and the verification of the associated EF panel circuits duringsurveillance testing.
b. In the case of the loss of supervisory air pressure to Dry Pilot systems, a diversealarm source is provided in the form of a waterf low alarm signal to the controlroom. The transmission of this signal and the subsequent investigation of thecause of the alarm will lead the operating personnel to identify the failure of the air
pressure and take the appropriate corrective action (i.e., fire watch). Based on theavailability of an alternate alarm source and the verification process performedunder the existing surveillance testing, this condition is considered acceptable.
-" )ij .~gS RECT
'0&+ 0
I.:~'(I oVl0V
o~ »e«~
UNITED STATESNUCLEAR REGULATORY COMMISSION
WASHINGTON, O. C. 20555
April 26, 1990
Docket Nos. 50-315and 50-316
Mr. Milton A lex i chIndiana Michigan Power Companyc/o American Electric Power
Service Corporation1 Riverside PlazaColumbus, Ohio 43216
Dear Hr. Alexich:
@MA, 72 5h%C.q W<WoQCacw<oaS ~41>, 242 <
The enclosed safety evaluation documents the staff's evaluation of IHPC'sFebruary 21, 1990 response to unresolved issues related to post-fire safeshutdown methodology. Sixteen of the twenty-five issues are considered closed.Four of the remaining open items (8, ll, 20, and 23) will be addressed by theNRC inspection team during the upcoming fire protection audit. Two of the openitems involve incorporation of TS for Appendix A fire barriers (1) and hatchsurveillance (21). The staff requests that IMPC respond to open items 1 and 21by August 1, 1990. Items 2 and 17 will remain open pending submission of theresults of IHPC's NFPA code review. IHPC has previously stated that the resultsof their NFPA code review would be available by mid-summer, 1990 . The last openitem (10) should be resolved on a schedule negotiated with the Project Manager.
S incere ly,
p 44D6Joseph G. Giitter, Project ManagerProject Directorate III-IDivision of Reactor Proiects - ill,
IV, 'l 5 Special ProjectsOffice of Nuclear Reactor Regulation
cc: See next page
-3-
2.1.3 Status:
This issue is open pending submittal and approval of TS for Appendix A firebarriers.
2.2.1 Issue:
NFPA Code Conformance. The staff was concerned that fire protection features inthe plant (sprinkler systems, detection systems, etc.) were not designed andinstalled in accordance with the applicable NFPA codes.
~2.. 2
This issue was raised with IMPC in a meeting at the plant on November 1 5 2,7989. IYPC responded that a code conformance appraisal had been performed butonly for areas containing safe shutdown systems. The staff responded that itwould be necessary for If1PC to extend this review to all safety related areas oithe plant. The staff suggested that It1PC take the results from the initialreview and focus the followup review on those areas where sionificantdeficiencies were identified. The staff also indicated that the results of thisreview would have to be evaluated and reflected in a safety evaluation.
2.2.3 Status:
This issue i. open pending submission of the results of It'iPC's NFPA code reviewto the staff for evaluation.
2.3.1 Issue:
Fire alarm system circu it supervision. The staff was ccrcerned that all circuits(including fire suppressicr. system trip actuatirg circuits) were not electricallysupervised in accordance with t;FFA standard 72D.
!~IIHPC responded in the November i989 meeting that all circuits were supervised inaccordance with the referenced cnde with the exception of two circuits withinthe contro', room to the annunciator panels on the main control board. Theviability of these unsupervised circuits is confirmed in conjunction with testsof the local alarm panels. Written confirmation of this should be contained inthe NFPA code conformance review. During the discussions of this issue thestaff inquired if the alarm system had a "reflash" capability. IHPC respondedthat although this capability did not at that time exist, a ref lash capabilitywould be installed by December, 1991. On the basis that all but two circuitsare electrically supervised in accordance with NFPA 72D and those two circuitsare regularly tested to confirm operability the staff considers this issueresolved.
2.3.3 Status:
Closed
SNfRAhNNfCHNhMfPONQN
DONALDC COOK NUCLEAR PLANT1
PROCEOURE COVER SHEET
I,'."i> ' Jl
12 SHP 2 FIRPox:educ Ha
PORTABLE FIRE EXTINGUISHER INSPECTIONS
SCOPE OF REVSKNRevision 2: Ninor revision. Marginal markings used. Updated
references. Added references to Halon extinguishers,requirements for verifying clear access to extinguishersand updated Attachments 3, 4, 5 and 6 to reflect currentextinguisher locations. Reworded body paragraph 8.1.3to require verification that access to fire extinguishersis clear during monthly inspection and verification thatextinguishers have not passed there hydrostatic testdate on semiannual inspections. Updated hydrostatic testfrequencies for pressurized dry chemical extinguishers inAttachment No. 2.QA/NSDRC Audit No. QA-90-27/NSDRC 176.
SIGNATURES REVISION NUMBER
PREPARED SY
REVISION 2
DEPARTMENT HEADAPPROVAL
INTERFACINO DEPARTMENTHEAD CONCURRENCE
Hr~P/<,+
QUALITYASSURANCESUPERVISOR APPROVAL
PLANT NUCLEARSAFETY COMMITTEE
PLANT MANAGER APPROV
&Feed~~2-+'0
APPROVAL DATE
EFFECTIVE DATE
~j(q(g(
12 SHP 2270 FIRE.001
INDIANA MICHIGAN POWER COMPANYDONAID C. COOK NUCLEAR PLANT
1.0 TITLE: Portable Fire Extinguisher Inspections
2.0 OBJECTIVE
2.1 To establish the criteria by which the Safety andAssessment Department will perform inspections of theportable fire extinguishers (excluding the new TrainingFacility).
2.2 To assure that all the portable fire extinguishers arein operable condition and are in their proper locations.
3.0 REFERENCES
3.1 PMI-2270, Fire Protection.
3.2 12 PMP 6010 RAD.001 and .002 Radiation ProtectionManual.
3.3 Fire Facilities Plan — Drawing Numbers 12-5265, 12-5266,12-5267, 12-5268, 12-5268A, 12-5269, 12-5270 and12-5271. Service Building extension 12-4510, 12-4511,12-4512 and 12-4513. Security Control Center - 12-4507.
3.4 NFPA-10.
3.5 QA Audit 86-21-4A — Requires inspection of all FireExtinguishers that are assigned to the F'e Watches.
3.6 QA Audit/NSDRC Audit No. QA-90-27/NSDRC 176.
4.0 PREREQUISITES PRECAUTIONS INITIAL CONDITIONS
4.1 The following equipment and supplies are necessary:
From P.J. Russell g~"" '~ jTo P.H. Jacques - Bridgman
All of the portable fire extinguisher changes that were required per theImpell Code Compliance Walkdown have been veri, fied complete with oneexception. Please verify that the three (3) portable P-K dry chemicalextinguishers that are mounted outside of Fire Zones 29A through 29Fhave been changed to ABC dry chemical type extinguishers.
Please respond in writing by December 15, 1989, as to the status of thisopen item. If you should have any questions, please contact me atextension 2532.
Upon reviewing the prints concerning the Alison panel alarm annunciatorcircuits, it is my opinion that the recommendation to perform the monthlysurveillance program for the Technical Specification-required panel isnot necessary.
Operations performs a once-per-shift visual examination on all firepanels. This examination, using procedure 1 OHP 4030.001.001 consistsof checking for alarms and actuations that may have occurred.
The alarms to the Control Rooms which are not electrically supervised arechecked every six months by the Z&C Department using procedures 12 IHP6030 IMP.334, .151, and .251.
A functional test to the Reactor Coolant Pumps fire system is conductedby Performance every 18 months using STP.239. This procedure checksalarms to the panels and to the Control Rooms.
wc.<.C. /"1'A. Bilionis
/mmp
cc: T. P. BeilmaB. Gerwe - AEPSCFile
Intra-System
ANERICAN'LECTRfC
POWER
Date April 26, 1989
Subject Donald C. Cook Nuclear PlantAutomatic Fire Detection System
From
To
P.J. Russell~Impell Code Compliance Walkdown
Impell Corporation has identified several areas of the plant that arenot in strict compliance with NFPA 72E, "Automatic Fire Detectors".Following is a description of the violations for each identified areaand recommendations/justifications for each area. Specifics on the codedeviations can be found in the Impell Code Compliance Report, No.09-0120-0123.
These evaluations (justifications) are written against the specificdeviations stated in each fire zone's opening paragraph. Thesejustifications are primarily based on the engineering judgement of theauthor. The author (a qualified fire protection engineer) conducted afield walkdwon of these areas to evaluate the deficiencies. Thejustifications should be used in conjunction with the existingevaluations performed by Impell Corp. Given the defense-in-depth fireprotection philosophy used at D.CD Cook many of the same justificationsused by Impell to evaluate other code deviations in a particular firezone can be used to back up the justifications used in this report. TheImpell evaluations are contained in their Report and in June 17, 1988memo from D.E. Kipley of Impell to J.A. Kobyra, both of which can befound in Volume 1 of the Code Compliance Evaluation Report. Inaddition, partial detection/suppression evaluations may already existfor a particular fire zone. These evaluations may also be looked at inconjunction with the evaluations written in this report. The partialdetection/suppression evaluations can be found in the FPPM Section 10.
Finally, the air flow calculation that Impell used in their air movementdeviations can be found in the Impell Code Compliance
Report'CalculationNo. 0120-108-009).
Fire Zone 1
The Impell report identifies this area to be deficient in full detectorcoverage due to high air movement. Code Sections, 2-6.5, 2-6.7, 4-1.2,4-4.6, 4-3.7.2 and 4-3.7.3 (1974 and 1978), 4-4.2 (1974).
Intra System
The Auxiliary Building - Basement is a non-sprinklered area of lowcombustible loading. The Impell calculations lead one to believe thatthis area has significantly high air movement. In reality, while theair change rate is high there is very little forced air movement. Thisis true due to the extremely large diffusers used as well as the factthat all diffusers are utilized for exhaust ventilation. It should alsobe noted that most diffusers exhaust air from this fire zone into theContainment Spray and RHR Pump Rooms which have adequate detection.Since virtually no forced air flow exists we can space detectors per thegoverning rule of every 30 feet. This rule (which is only arecommendation by the NFPA 72E committee 1974 edition) has been compliedwith. No new detectors will be installed for this area.
Fire Zone 3
The Impell report identifies this area to be deficient in full detectorcoverage since detectors are not provided in each bay as required fordeep beam construction greater than eighteen inches. Code Sections2-6.5, 2-6.7, 4-1.2, 4-.4.6, 4-3.7.2 and 4-3.7.3 (1974 and 1978).
The Drumming/Drum Storage area is considered a high radiation area;therefore, access and work activity is controlled. Placing additionaldetection within this room is undesirable from an ALARA standpoint.From a fire protection standpoint, two ionization detectors do existover the drumming area (work area). In addition, a preaction sprinklersystem exists throughout (all bays) the drumming area (but not over thedrum storage area). The sprinkler system can be considered a firedetection system as it too will transmit alarms back to the continuouslycontrolled fire alarm board upon actuation. Since combustible loadingin this controlled access room is low and sprinklers and detection existin the area where these combustibles could be exposed, it is felt thatthe existing detection system is adequate. No new detectors arerequired to be installed.
Fire Zone 4
The Impell report identifies this area to be deficient in full detectorcoverage since detection does not exist in the deep west end ceilingbay. code Sections 2-6.5,'2-6.7 and 4-1.2 (1974 and 1978).
The Sampling Room is a non-sprinklered area of low combustible loading.The said bay is extremely deep and could prevent detection of a fire fora fairly long time. Since some combustibles do exist under this bay, anew detector should be installed for this area. This detector will beinstalled by RFC-12-3004.
Fire Zone 5
The Impell report identifies this area to be deficient in full detectorcoverage since detection does not exist in two areas of deep bayconstruction (near existing detectors 2-25 and 2-3). Code Sections2-6.5, 2-6.7, 4-1.2, 4-4.6, 4-3.7.2, and 4-3.7.3 (1974 and 1978).
-2-
The Auxiliary Building - Elevation 587 is a partially sprinklered areaof low combustible loading. The bay near detector 2-25 is actually anequipment hatch. No detection can be placed here since this hatch willbe used in the future. It should be noted that adequate detection andsuppression exist in all adjacent areas. Since combustible loading islow and the hatch may need to be removed in the future, no additionaldetection will be installed here.
The bay near detection 2-3 is actually a stairwell. This bay isextremely deep and may cause a fire to burn undetected for quite sometime. A detector should be installed at the top of this stairwell.This detector will be part of RFC-12-3004.
Impell also had a concern with a lack of reduced detector spacing ingreater than eight inch but less than eighteen inch deep bays. Whilethis situation is correct, one must look at the automatic suppressionsystems also installed in these areas. In the unlikely event that theionization detectors do not alarm during a fire, the dry pilot preactionsprinkler system which also acts as a heat detection system, would soundalarms at the central control board once the system is activated.Because of this existing suppression system, no new detectors arerequired for these areas. It is felt that the two systems combined(sprinklers and detectors) provide overall system reliability fargreater than what can be achieved by a single detection system installedwithin strict compliance of NFPA 72E.
Fire Zone 6N
The Impell report identifies this area to be deficient in full detectioncoverage due to high air movement and inadequate spacing. Code Sections2-6.5, 2-6.7, 4-1.2, 4-4.6, 4-3.7.2, and 4-3.7.3 (1974 and 1978), 4-4.2(1974).
This area is of low combustible loading and is partially sprinklered.Areas where either detection or suppression do not exist are radiationareas. Placing additional detectors within these area would beundesirable from an ALARA standpoint. It should be noted that theexisting dry pilot preaction sprinkler system also acts as a heatdetection system by sounding alarms at the central control board uponactivation. This sprinkler system is located throughout all normallyaccessible areas of the fire zone. Since the sprinklers also act as adetection system, there is no need to install additional ionizationdetectors in this area. It is felt that the two systems combined(sprinklers and detectors) provide overall system reliability far greaterthan what can be achieved by a single detection system installed withinstrict compliance of NFPA 72E.
Fire Zone 6M
The same arguments justifying Fire Zone 6N are applicable for this firezone. No changes are needed for this fire detection system.
-3-
Fire Zone 6S
The same arguments justifying Fire Zone 6N are applicable for this firezone. No changes are needed for this fi're detection system.
Fire Zone 7
The Impell report identifies this area to be deficient in full detectorcoverage since detection is not provided for each bay as required fordeep beam construction greater than eighteen inches. The report alsoidentifies infrared detectors as being blocked by obstructions. CodeSections 2-6.5, 2-6.7 and 4-1.2 (1974 and 1978), 4-4.1, 4-4.5.2, 4-5.1.5and 9-3.3 (1974 and 1982), 4-4.6, 4-3.7.2, and 4-3 '.3 (1974 and 1978),5-3.2, 5-4.1, 5-4.2, and 5-5.1 (1974).
It should be noted that infrared detectors do respond to reflectedradiation. Keeping this in mind, the location of the infrared detectorsare adequate. Due to the inherent characteristics of this cable tunnel,obstructions to the detectors would occur in any location. It is feltthat these detectors would alarm when subjected to either direct orreflected infrared radiation emitted from a fire in any location. Nochanges need to be made to the infrared detectors.
The area lacking detectors within deep beam pockets has a ceiling heightof 38 feet. This area is protected by ionization and infrareddetectors. If in the unlikely event that the ionization detectors donot alarm, the infrared detectors would sound an alarm as soon asflaming combustion begins. Sufficient infrared detectors exist to senseany fire within this area. Since infrared detectors exist along withthe ionization detectors, no additional ionization detectors need beinstalled within this fire zone.
Fire Zone 8
The Impell report identifies this area to be deficient in detectorcoverage since the infrared detectors are obstructed and not enoughionization detectors exist for the high air flow conditions within thisarea. Code Sections 2-6.5, 2-6.7 and 4-1.2 (1974 and 1978), 4-4.2,5-3.2, 5-4.1, 5-4.2 and 5-5.1 (1974).
It should be noted that infrared detectors do respond to reflectedlight. Keeping this in mind, the location of the infr'ared detectors areadequate. Due to the inherent characteristics of this goom, theinfrared" detectors would have obstructi,ons no matter where they wereinstalled. Since no object completely blocks the existing infrareddetectors, the existing, detectors would respond to any fire in itsrespective area.
The Impell calculations show that due to high air movement within thisroom, eight ionization detectors should be installed. Currently, sixionization detectors exist. It should be noted that besides the sixionization detectors, there are five infrared detectors installed inthis area. Since two zones of detectors exist, a more than adequatenumber of detectors are already installed. No new detectors need beadded as it is felt that the two systems combined provide overall systemreliability far greater than .what can be achieved by a single zone ofdetectors installed within strict compliance of NFPA 72E.
Fire Zone 10
The Impell report identifies this area to be deficient in full detectorcoverage due to infrared detector obstructions and not enough existingionization detectors for the current high air flow movement within thisarea. Code Sections 2-6.5, 2-6.7 and 4-1.2 (1974 and 1978), 4-4.2,5-3.2, 5-4.1, 5-4.2 and 5-5.1 (1974).
The same arguments justifying the existing condition for Fire Zone 8
apply to this zone. No new detectors need be added.
Fire Zone 11
The Impell report identifies this area to be deficient in detectorcoverage since the infrared detectors are obstructed. Code Sections2-6.5, 2-6.7, and 4-1.2 (1974 and 1978), 5-3.2, 5-4.1, 5-4.2 and 5-5.1(1974).
It should be noted that infrared detectors do respond to reflectedlight. Keeping this in mind, the location of the infrared detectors areadequate. Due to the inherent characteristics of this room, theinfrared detectors would have obstructions no matter where they wereinstalled. Since no object completely blocks the existing infrareddetectors, the existing detectors would respond to any fire in itsrespective area. Thus, no changes need to be made to this firedetection system.
Fire Zone 23
The Impell reports identifies this zone to be deficient in full firedetection coverage due to infrared detector obstruction. Code Sections2-6.5, 2-6.7 and 4-1.2 (1974 and 1978)
The same justifications used in Fire Zone 11 are applicable for thisfire zone. No new detectors need to be added.
Fire Zone 24
The Impell report identifies this zone to be deficient in full detectioncoverage due to infrared detector obstructions and not enough ionizationdetectors for the high air flow conditions of the zone. Code Sections2-6.5, 2-6.7 and 4-1.2 (1974 and 1978).
-5-
The same justifications used in evaluating fire detection coverage inFire Zone 8 are also applicable for this fire zone. No new detectorsneed to be added.
Fire Zone 25
The Impell report identifies this zone to be deficient in full detectioncoverage due to infrared detector obstructions. Code Sections 2-6.5,2-6.7, and 4-1.2 (1974 and 1978), 5-3.2, 5-4.1, 5-4.2 and 5-5.1 (1974).
The same justifications used in evaluating fire detection coverage inFire Zone ll are also applicable for this fire zone. No new detectorsneed to be added.
Fire Zone 26
The Impell report identifies this zone to be deficient in full detectorcoverage due to infrared detector obstructions and not enough ionizationdetection for the high air flow conditions of the zone. Code Sections2-6.5, 2-6.7, and 4-1.2 (1974 and 1978), 4-4.2, 5-3.2, 5-4.1, 5-4.2 and5-5.1 (1974).
The same justifications used in evaluating fire detection coverage inFire Zone 7 are also applicable for this fire zone. No new detectorsneed to be added.
Fire Zone 27
The Impell report identifies this zone to be deficient in full detectorcoverage due to infrared detector obstruction. Code Sections 2-6.5,2-6.7 and 4-1.2 (1974 and 1978), 4-4.1, 4-4.5.2, 4-5.1, 4-5.1.5, 9-3.3(1974 and 1982), 4-4.6, 4-3.7.2 and 4-3.7.3 (1974 and 1978), 5-3.2,5-4.1, 5-4.2 and 5-5.1 (1974).
The same arguments justifying Fire Zone 11 are applicable .for this firezone. No changes are needed for this fire detection system.
Fire Zone 32
The Impell report identifies this zone to be deficient in full detectioncoverage due to high ceilings and lack of detection in all the beampockets. Code Sections 2-6.5, 2-6.7, 4-1.2, 4-4.6, 4-3.7.2, 4-3.7.3(1974 and 1978), 4-3.1, 4-3.2 (1974, 1978 and 1982), 4-4.1, 4-4.5.2,4-5.1, 4-5.1.5 and 9-3.3 (1974 and 1982).
The Cask Handling area is a fully sprinklered area of low combustibleloading. Sprinklers, which also act as a heat detection system, existin all beam pockets. In the unlikely event that the ionizationdetectors do not alarm during a fire, the suppression system wouldsound an alarm once the sprinklers were actuated by heat. Onlyionization and heat detectors can be used in this area due to the large
-6-
industrial cranes that are located at the roof. These cranes have thepotential of blocking the sight of infrared detectors. Since theexisting suppression system is installed in all ceiling pockets and sixionization detectors are already installed for this area, no newdetectors need to be added. It is felt that the existing fireprotection equipment already meets the intent of the code.
Fire Zone 33
The Impell report identifies this area to be deficient in detectorcoverage since detectors are not installed on the ceiling. CodeSections 2-6.5, 2-6.7 and 4-1.2 (1974 and 1978) 4-4.1, 4-4 ' ', 4-5.1,4-5.1.5 and 9-3.3 (1974 and 1982), 5-3.2, 5-4 ', 5-4.2 and 5-5.1 (1974).
The ceiling height for the Unit 1 Main Valve Enclosure is extremely highand mostly inaccessible. Due to the inherent characteristics of thisroom, the upper portions often have elevated temperatures. Placingionization detectors in strict compliance with NFPA 72E would causedelays in detector actuation due to stratification, dissipation andhorizontal movement of the smoke. Hence, detectors were located at thevarious elevations within the fire zone so as to be as close as possibleto the combustibles. In addition, there are twenty ionization and fourinfrared detectors already existing in this fire zone which wasapproximately 1,000 sq. ft. of floor area. It is felt that the highnumber of detectors combined with the strategic existing locationsprovide the best fire detection coverage. No additional detectors willbe added.
Fire Zone 34
The same arguments justifying Fire Zone 33 are applicable for this firezone. No changes are needed for this fire detection system.
Fire Zone 38
The same arguments justifying Fire Zone 11 are applicable for this firezone. No changes are needed for this fire detection system.
Fire Zone 39
The same arguments justifying Fire Zone 11 are applicable for this firezone. No changes are needed for this fire detection system.
Fire Zone 40A
The Impell report identifies this zone to be deficient in full firedetector coverage due to beam construction and an insufficient number ofionization detectors for the high air movement conditions within thezone. Code Sections 2-6.5, 2-6.7, 4-1.2 (1974 and 1978), 4-3.5.1.1(1984), 4-4.2 (1974).
-7-
It should be noted that the infrared detectors located within this roomare not affected by high air movement. The Impell report states thatthree ionization detectors are needed for this room. Currently, the twoionization detectors combined with the three infrared detectors providemore than adequate coverage. It should also be noted that the twoionization detectors (one in each beam pocket) provide adequate coverageper NFPA 72E for no air flow conditions. Therefore, no new detectorsneed be added to this zone. It is felt that the two systems combinedprovide overall system reliability far greater than what can be achievedby a single zone of detectors installed within strict compliance of NFPA72E.
Fire Zone 40B
The same deviations and justifications identified in Fire Zone 40A areapplicable for this fire zone. No new detectors will be added to FireZone 40B.
Fire Zone 41 & 45
These zones are said to be deficient in full detector coverage due todetection not being in all areas of the zones. Code Sections 2-6.5,2-6.7, 4-1.2 (1974 and 1978), 4-3.5.1.1 (1984), 5-3.2, 5-4.1, 5-4.2 and5-5.1 (1974).
Since the Impell walkdown, these fire zones have had their detectionsystems completely revised by RFC-12-2868. New detectors have beenadded so that now all areas are covered by fire detection equipment. Noadditional changes are necessary. The new detection systems for thesefire zones meet the requirements of NFPA 72E, 1987 Edition. See AEPSCcalculation Nos. DCC-FP12-DT09F and DCC-FP01-DT10F.
Fire Zone 42A
This zone is said to be deficient in full detection coverage due to airmovement within the zone. Code Sections 2-6.5, 2-6.7, 4-1.2 (1974 and1978) 4-4.2, 5-3.2, 5-4.1, 5-4.2 and 5-5.1 (1974).
Since the Impell walkdown, this fire zone's detection system has beenrevised by RFC-12-2868. New detectors have been added to compensate forhigh air flows. No additional'hanges are needed. The new detectionsystem meets the requirements of NFPA 72E, 1987 edition. See AEPSCcalculation No. DCC-FP01-DT10F.
Fire Zone 42B
This area is said to be deficient in full detection coverage due to airmovement within the zone. Code Sections 2-6.5, 2-6.7, 4-1.2 (1974 and1978), 4-4.2, 5-3.2, 5-4.1, 5-4.2 and 5-5.1 (1974).
-8-
According to the Impell calculations, five ionization detectors areneeded for this fire zone during full air flow conditions. There arenow two ionization detectors and one infrared detector for this zone.The two ionization detectors are adequate for minimal air flowconditions, and the infrared detector is adequate under any air flowcondition. In addition, RFC-12-2868 has installed new ionizationdetectors just outside the normal vent path (door opening) from thisroom. If in the unlikely event that the two ionization detectors withinthe zone do not alarm during the incipient stages of a fire, theinfrared detector would alarm shortly after flaming combustion begins.Once the infrared detector alarms, the fire brigade would be summoned tothe scene where they would assist the fixed pipe carbon dioxide fireextinguishing system in suppressing the fire. Combustible loading inthe fire zone is very low, making it highly unlikely that a fire couldspread into adjacent fire zones prior to detection and extinguishmen't.Since two separate types of fire detectors are installed and theinfrared detector is not affected by air flow, it is felt that theexisting fire detection system is more than adequate for this zone. Noadditional detectors will be installed for this zone.
Fire Zone 42C
This area is said to be deficient in full detection coverage due to airmovement within the zone. Code Sections 2-6.5, 2-6.7, 4-1.2 (1974 and1978), 4-4.2, 5-3.2, 5-4.1, 5-4.2 and 5-5.1 (1974).
According to the Impell calculations, four ionization detectors areneeded for this fire zone during full air flow conditions. There arenow three ionization and two infrared detectors for this zone. Thethree ionization detectors are adequate for minimal air flow conditions,and the infrared detectors are adequate under any air flow conditions.In addition, RFC-12-2868 has installed new ionization detectors justoutside the normal vent path (open passageway) from this room. If inthe unlikely event that the ionization detectors within the zone do notalarm during the incipient stages of a fire, the infrared detector wouldalarm shortly after flaming combustion begins. Once the infrareddetector alarms, the fire brigade would be called to the scene wherethey would assist the fixed pipe CO suppression system in extinguishingthe fire. Combustible loading in tkis fire zone is extremely low,making it highly unlikely that a fire could spread into adjacent firezones prior to detection and extinguishment. Since two separate typesof fire detectors are installed and the infrared detectors are notaffected by air movement, it is felt that the existing fire detectionsystem is more than 'adequate for this zone. No additional detectorswill be installed for this zone.
Fire Zone 43
The Impell report identifies this area as being deficient in fulldetector coverage due to high air movement within the zone. CodeSections 2-6.5, 2-6.7, 4-1.2 (1974 and 1978), 4-4.1, 4-4.5.2, 4-5.1,4-5.1.5, 9-3.3 (1974 and 1982), 4-4.2 (1974).
-9-
The Access Control Area is a non sprinklered area of moderatecombustible loading. The Impell calculations show that the CountingRoom within this zone needs an additional ionization detector.Currently this 212 sq. ft. room has one ionization detector in it andadequate ionization detectors in all adjacent areas. Since this room isextremely small and forced air movement would move smoke out into theadequately protected hallways no additional detectors will be installed.It is apparent that if in the unlikely event that the detector withinthe Counting Room does not actuate during a fire, the detectors in theadjacent corridors would alarm with very little delay.
Impell also has a concern with detectors being located too close to airsupply diffusers, in all the identified cases the detectors are locatedin extremely small areas (ie: offices). To move the detectors may helpa little, but some delay could still be expected due to the proximity tothe diffusers. It is felt that the existing fire protecton equipmetn isadequate and meets the intent of the code.
Fire Zone 44N
The Impell report identifies this area to be deficient in full detectorcoverage since detection does not exist in a deep bay near detector 3-4.Code Sections 2-6.5, 2-6.7, 4-1.2 (1974 and 1978).
The Auxiliary Building - Elevation 609 is a partially sprinklered areaof low combustible loading. The bay near detector 3-4 is actually anequipment hatch. No detection can be placed here since this hatch willbe used in the future. It should be noted that adequate detection andsuppression exist in all adjacent areas. Since combustible loading islow and the hatch may need to be removed in the future, no additionaldetection will be installed here.
Fire zone 44S
The Impell report identifies this zone to be deficient in full detectorcoverage due to detectors 3-27 and 3-28 being located on the bottom ofceiling beams rather than in the beam pockets. Code Sections 2-6.5,2-6 ', 4-1.2 (1974 and 1978).
The Auxiliary Building - Elevation 609 is a partially sprinklered areaof low combustible loading. Sprinklers, which also act as a heatdetection system, also exist in the bays surrounding detectors 3-27 and3-28. In the unlikely event that the ionization detectors do not alarmduring a fire, the dry pilot preaction sprinkler system would soundalarms at the central alarm board once the sprinklers were actuated byheat. Because of the existing suppression system in these bays, no newdetectors need be added to these areas. It is felt that the two systemscombined provide overall system reliability far greater than what can beachieved by a single zone of detectors installed within strictcompliance of NFPA 72E.
-10-
Fire Zone 46A & 46B & 46C
The Impell report identifies these zones to be deficient in fulldetector coverage due to high air movement. Code Sections 2-6.5, 2-6.7,4-1.2 (1974 and 1978), 4-4.2 (1974).
The same justifications used in evaluating fire detection coverage inFire Zones 42A, 42B and 42C are applicable for these fire zones. No newdetectors need to be added. However, for Fire Zone 42A the calculationNo. is DCC-FP01-DT09F.
Fire Zone 47A & 47B
The Impell report identifies these zones to be deficient in fulldetector coverage due to high air movement and beam construction. CodeSections 2-6.5, 2-6.7, 4-1.2 (1974 and 1978), 4-3.5.1.1 (1984), 4-4.2(1974).
The same justifications used in evaluating fire detection coverage inFire Zones 40A and 40B are also applicable for these fire zones. No newdetectors need to be added.
Fire Zone 48
The Impell report identifies this zone to be deficient in full firedetector coverage due to the fact that detection is not installed withinevery deep beam pocket. Code Sections 2-6.5, 2-6.7, 4-1.2, 4-4.6,4-3.7.2 and 4-3.7.3 (1974 and 1978) ~
The New Fuel Storage room has no combustibles within i'ourionization detectors do exist for this approximately 1,7000 sq. ft.room. It is felt that no new detectors are needed for this area sincethe combustible loading is zero.
Fire Zone 49 & 50
The Impell report identifies these areas to be deficient in fulldetection coverage due to lack of fire detection within each deep beampocket. Code Sections 2-6.5, 2-6.7, 4-1.2, 4-4.6, 4-3.7.2, 4-3.7.3(1974 and 1978) 4-3.1, 4-3.2 (1974 and 1982).
Impell has already written a justification for the existing detectionconditions. Their conclusion is that no new detectors need beinstalled. A review of the area by this author was performed and it wasdetermined that the Impell Evaluation was correct.
Fire Zone 51
The Impell report identifies this zone to be deficient in full detectorcoverage due to lack of detection within two deep beam pockets. CodeSections 2-6.5, 2-6.7, 4-1.2 (1974 and 1978).
-11-
It is recognized that both of the identified areas do not have firedetection installed within the pockets. It should be noted, however,that a dry pilot preaction sprinkler system is installed in these areas.The sprinklers, which also act as a heat actuated detection system, willsound alarms at the central panel once heat from the fire actuates thesprinklers. Since sprinklers are already installed within theseextremely small pockets, no additional detection will be installed.
Fire Zone 52
The Impell report identifies this zone to be deficient in full detectorcoverage due to poor detector spacing. Code Sections 2-6.5, 2-6.7,4-1.2, 4-4.6, 4-3.7.2, 4-3.7.3 (1974 and 1978), 4-3.5.1.1 (1984), 4-3.1,4-3.2 (1974, 1978 and 1982).
It is recognized that the areas in question do not have optimum detectorspacing. However, it should be noted that all identified areas alsocontains a dry pilot preaction sprinkler system. The sprinklers, whichalso act as a heat actuated detection system, will sound alarms at thecentral panel once heat from a fire actuates a sprinkler. Sincesprinklers are already installed within these identified areas, noadditional detectors will be installed.
Fire Zones 55 & 60
The Impell report identifies these zones to be deficient in fulldetection coverage due to infrared detector obstructions and high airmovement within the zones. Code Sections 2-6.5, 2-6.7, 4-1.2 (1974 and1978), 4-4.2, 5-3.2, 5-4.1, 5-4.2 and 5-5.1 (1974) 4-3.5.1.1 (1984).
It should be noted that infrared detectors do respond to reflectedinfrared radiation. Keeping this in mind, the location of the infrareddetectors are adequate. Due to the inherent characteristics of thesecable vaults, obstructions to the detectors would occur in any location.It is felt that these detectors would alarm when subjected to eitherdirect or reflected infrared radiation emitted from a fire in anylocation. No changes need to be made to the infrared detectors.
We agree with all other identified deficiencies and will install newdetectors via RFC-12-3004.
Fire Zone MS'7 ~iy-~o-e~The Impell report identifies this area to be deficient in full detectorcoverage since two detectors are located too close to a ceiling beam.Code Sections 2-6.5, 2-6.7, 4-1.2 (1974 and 1978), 4-3.1, 4-3.2 (1974,1978 and 1982).
-12-
There are 65 ionization detectors located in this 4,410 sq. ft. zone.More than ample, detection exists so that no delay will occur in,detecting a fire in its incipient stage. One must remember that twocomplete zones of detectors exist in this room. No changes will be madeto this zone.
Fire Zone 69
The Impell report identifies this zone to be deficient in full firedetection coverage due to high ceilings and lack of detection within alldeep beam pockets. Code Sections 2-6.5, 2-6.7, 4-1.2, 4-4.6, 4-3.7.2,4-3.7.3 (1974 and 1978), 4-4.1, 4-4.5.7, 4-5.1, 4-5.1.5, 9-3.3 (1974 and1982), 4-3.1, 4.3.2 (1974, 1978 and 1982).
The Auxiliary Building - Elevation 650 ft. is a non-sprinklered area ofextremely low combustible loading. Currently 28 ionization detectorsexist for this area (approximately 1 detector every 650 sq. ft.). Theceiling height for this area is extremely high. Infrared detectors cannot easily be installed on the ceiling due to the large industrialcranes located in this area. These cranes would have the potential toblock the view of infrared detectors. Additional ionization or heatdetectors give us no more assurance that a detector will alarm in a firescenario. This is true because of the extremely high ceiling heightsand the expected horizontal movement of smoke due to stratification anddissipation. Since the combustible loading is low (complete combustionof exposed combustibles has an equivalent fire severity of less thanfour minutes) no new detectors are to be installed.
Patrick J. Russell
Concurre e: B.J. GerweFire Protection Engineer
PJR/jmf
cc: J.D. Grier/J.A. Kobyra/B.J. Gerwe/P.J. Russell (PHF 89-0060)File: RFC-12-3004
-13-
ANKRINI.
ELECTRICPOIIAiR
pate February 8, 1989
SUbJQQ Donald C. Cook Nuclear PlantAutomatic Sprinkler Systems
From P.J. Russell
To Impell Code. Compliance Valkdown
Impell Corporation has identified several areas of the plant that arenot in compliance with NFPA 13 "Sprinkler Systems", sections 4-1.1.1,4-1.1.4 and 4-2.4.6. These sections require that the water dischargepattern of the sprinklers be clear from obstructions. Following is alist of all identified fire zones and our (AEPSC)recommendations/justifications for each zone.
1. Fire Zone 6N:
Convert the four identified sprinklers from upright heads topendant heads. This work should be accomplished byRFC-12-3003.
2. Fire Zone 44N:
Currently a sidewall sprinkler located near column lines 15and WL-L is blocked by a fire main. Extend this sprinkler out(horizontally) six inches so that the head clears the fireprotection cross main.
Currently an upright head located at column lines WL-L and 16has its'heoretical water discharge pattern obstructed byductwork. While this condition remains true, it should benoted that a sidewall head exists approximately 7 ft. to theEast of this head. This sprinkler will more than adequatelyprovide coverage to the floor space that would receive amarginal supply of water. from the obstructed head. Thisexisting condition will adequately protect this area from thespread of fire. It is therefore felt that strict complianceto the code for this particular sprinkler is not necessary andno changes will be made.
Fire Zone 52:
The Impell Report states that the sidewall sprinkler heatcollection plates will interfere with discharge patterns.
FebruaryPage 2
8, 1989
This condition is being extended by AEPSC to include allsidewall sprinkler heat collection plates in the plant (notjust Fire Zone 52). This condition will be fixed by modifyingthe heat collection plates. This work will be performed inRFC-12-3003.
The Impell Report identified a distorted heat collection plateat a sidewall sprinkler located at WL-5 and WL-L. Thiscondition will no longer be the case once the modifications tothe heat collection plates are performed under RFC-12-3003
'herefore,no work need be performed for this identifieddeviation.
The Impell Report stated that a sprinkler located at columnlines WL-L and WL-8 will have sprinkler discharge obstructedby numerous conduits. This sprinkler is located near theceiling in an extremely congested area. It was noted that thesaid conduits are located below the head. These conduits donot form a concealed space therefore, we can expect water todrop onto the floor area below. It is agreed that atheoretical discharge will not be achieved from this sprinklerbut it is noted that the best available location has beenchosen for this head. Therefore, it is felt that thissprinkler is within the guidelines of NFPA 13 and no changesneed to be made,
The Impell Report identified a temporary curtain installed tooclose to a head at column lines WL-L.5 and WL-F 5 't wasnoted that this curtain is no longer installed. Therefore, nosprinkler discrepancies exist at this location and no changesneed be made.
The Impell Report identifies sprinklers located at the Northend of this fire zone (at column line WL-L) as being too closeto a beam. This author recognized the sprinklers in this areato be marginally close to a beam. Due to the construction ofthis area's ceiling (beam construction) a more than adequatenumber of sprinklers are located in this area, as each bay hasa branch line of heads. Since the branch lines (located oneach side of the beam) are spaced close together the floorarea below would receive total coverage regardless of themarginal spacing of each individual head to the ceiling beams.It appears that the sprinkler contractor took intoconsideration the obstruction problem caused by the beams andcompensated by placing a row of heads on each side of thebeam. It is concluded that the existing sprinkler system forthis area is adequate and no additional changes need be made.
February 8, 1989Page 3
4. Fire Zone 17C:
It was reported that a sprinkler was installed too close to apipe. This condition was verified to be true and will be fixedby installing a four inch nipple for the sprinkler. This workwill be accomplished in RFC-12-3003.
5. Fire Zone 17E:
It was reported that an upright sprinkler in this room wasobstructed by conduit. This author noticed a 3/4 inch conduitin the vertical position located approximately 8 inches Southof the head. This conduit (which supplies a cable to a lightin this room) will provide only minimal interference. It isstated in NFPA 13 section 4-2.4.5 that sprinklers shall be atleast 6 inches laterally from web members not exceeding 1 inchin diameter. It is recognized that the conduit is not a webmember but the same rules can be applied. It is also notedthat a sprinkler located approximately 10 feet to the Southwill more than adequately cover any area missed by theobstructed sprinkler. Therefore, this area is adequatelycovered by the existing sprinkler system and no changes willbe made.
6. Fire Zone 105
It was stated in the Impell Report that sprinklers in the SW
corner of the lower level of the Contractors Access Area areinstalled too close to a beam. It is agreed that looking atthese sprinklers individually a problem with compliance toNFPA 13 exists. Since this area (approximately 16 ft. by 14ft.) contains four sprinklers it is felt that the area shouldbe reviewed as a whole. It appears that the sprinklercontractor took into consideration the obstruction problemcaused by the beams and compensated by placing sprinklers oneach side of the beam. The SW corner of this room containsvery few combustibles. It acts as a passageway into thestorage area of A~ti-Cs. Due to radiological concerns (allpersonnel must be frisked in the SW corner) it is believed thatthis area will remain low in combustibles as friskingequipment is installed in this corner. The four sprinklersinstalled in this area more than adequately cover the floorspace below. It is felt that the existing sprinklers areadequate and no changes need to be made.
February 8, 1989Page 4
This author identified the area above the non-combustible shedinstalled in this area to be deficient in sprinkler coverage.Since the area above this shed is used for storage, sprinklersare required per NFPA 13. Sprinklers will be installed perRFC-12-3003.
SUb)QQt Donald C . Cook Nuc lear PlantImpell Code Compliance WalkdownsNFPA-14 "Standpipes and Hose Stations"
~~p, g4 5K~to~ +5[
Fram P.J. Russell(g/P~ ~-QQSaE 5-0-Ro ~~o a.a.~y
To M.J. Noronha
The Impell Report identifies the lack of lateral restraints for the sixinch fire protection main located in the Auxiliary Building, elevation587 feet, as a deficiency to NFPA 14. It is Impell's belief thatwithout these restraints, the fire protection main would not remain inplace under water flow conditions.
,0
Please verify that the existing conditions are adequate to support andretain the pipe securely in position or provide us with a suitabledesign. We can place the new hangers (if needed) in with openRFC-12-3003.
If you should have any questions, please contact me at extension 2532.
Snbjppt D . C . Cook Nuclear P lantNFPA 12A Code Compliance WalkdownImpell Report No. 09-0120-0123
f(pm P.J. Russell
To RFC-3003
Impell Report No. 09-0120-0123 identified the Unit 1 and 2 Control RoomCable Vault Halon Systems to be deficient with section 1-8.3.6 of NFPACode No. 12A "Halon 1301 Fire Extenguishing Systems". This sectionrequires all automatically operated valves controlling agent release anddistribution be provided with an independent means for emergency manualoperation. The following report will show that the system as designedwill perform as expected. In addition, it will be shown that thisdeviation is a calculated one, and one that need not be changed.
The fire protection requirements needed for the Control Room CableVaults are unique. First of all, it is readily appearant that the mostlikely fire to occur in these rooms would be a Class A type fire. Ithas long been a practice of the fire protection community to use wateror Halon as an extinguishing mechanism for Class A type fires. In thiscase, Halon is by far the more appropriate choice since it isnon corrosive, non conductive, and in some cases non life threatening.In fact, the only negative aspect of the installation of a totalflooding Halon system for these rooms is that due to the inherentcharacteristics of the rooms (spreading area for thousands of cables)the very real possibility of a deep-seated fire exists. Per NF$ '12A,the use of a Halon 1301 system for control or extinguishment of adeep-seated fire is unattractive.
A deep-seated fire is defined in NFPA 12A as a fire that stillexists after a 5 percent concentration of Halon 1301 has been 'appliedfor 10 minutes. It is for this reason that NFPA 12A requires a test tobe performed for all Halon 1301 systems to prove that the protected areacan hold a 5% concentration for 10 minutes. During startup of thissystem, tests proved that the original design would provide a 5%
concentration almost immediately, but the room would not hold it for theentire 10 minutes. It is for this reason that the extended dischargecylinders were installed. They are designed to provide a concentrationboost into the room three minutes and forty-five seconds after initialdischarge. Tests since the installation of these cylinders have provedthat a 5-percent concentration will now be held within the Cable Vaultsfor the required ten minutes.
January 25, 1989Page 2
If for some reason the automatic actuation of the Halon 1301 systemdid not work~then it could be manually set off by the fire brigade. Itis true that they then would not be able to set off the extendeddischarge cylinders. This is true, because if the extended cylinderswere tripped (accidentally or purposely) with the original cylinders, adesign concentration of greater than 7 percent would exist within theroom. Xf personnel were within the room at the time of discharge, theywould not be able to exit within one minute. Halon concentrations ofgreater than 7% will render an individual unconscious within 1 minute.This then could possibly lead to death by fire or asphyxiation.Therefore, installation of a manual switch on the extended dischargecylinders is unacceptable.
Therefore, the acceptable fire protection for this area is theexisting fire protection. The existing conditions will extinguish anyClass A fire (smoldering or flaming) with a "controlled" dump of Halon1301. If a deep seated fire was to occur then C02 could be manuallydumped into the area to extinguish this type of fire. Also availablefor fire fighting is manual equipment (water hose stations as well asportable extinguishers).
Based on the above, it is felt that the existing fire protection .equipment protecting these rooms is adequate to protect the fire safetyof the plant. Installation of a manual discharge for the extendeddischarge cylinders can not possibly be justified due to the potentiallife safety concerns of plant personnel.
Attached Please find three (3) letters which collectively close out theremaining NFPA 10 open items contained in Impell Report No.09-0120-0123.
If you should have any questions, please contact me at extension 2532.
P.J. Russell/kk
cc: R.L. ShobergJ.D. Grier/J.A. Kobyra/B.J. Gerwe/P.J. Russell
ZAMERICAN .
ELECTRICPOWER
p>~< January 24, 1989
SU/IgQ) Dona 1d C ~ Cook Nuclear P 1antPortable Fire Extinguishers
f(pm P . J . Russell
fp Impell Code Com'pliance Walkdown
Impell Corporation has identified several areas of the plant that arenot in compliance with NFPA 10, "Portable Fire Extinguishers," Sections3-1.2 and 3-1.2.2. These sections require that all fire zones withClass A occupancies have suitable Class A extinguishers. Following is alist of all identified fire zones and our (AEPSC)recommendations/j ustifications for each zone.
1. Fire Zone 112
Replace a BC dry chemical extinguisher with an ABC dry chemicalextinguisher.
2. Fire Zone 113
Replace a BC dry chemical extinguisher with an ABC dry chemicalextinguisher.
3. Fire Zone 29G
Replace a BC dry chemical extinguisher with an ABC dry chemicalextinguisher.
4. Fire Zone 22
Revision 2 of the Fire Hazard Analysis added an ABC dry chemicalextinguisher within this fire zone. This extinguisher, coupledwith hose station number 215, assures us of extinguishing apostulated Class A type fire. This manual fire fighting equipmentis installed per NFPA 10; therefore, no new extinguishers need beinstalled.
January 24, 1989Page 2
5. Fire Zone 12
Revision 2 of the Fire Hazard Analysis added an ABC dry chemicalextinguisher 'within this fire zone. This extinguisher, coupledwith hose station number 213, assures us of extinguishing apostulated Class A type fire. This manual fire fighting equipmentis installed per NFPA 10; therefore, no new extinguishers need beinstalled.
6. Fire Zone 111
Revision 2 of the Fire Hazard Analysis added an ABC dry chemicalextinguisher within'this fire zone. This extinguisher meets allrequirements of NFPA 10; therefore, no new extinguishers need beinstalled.
7. Fire Zone 18
Revision 2 of the Fire Hazard Analysis added an ABC extinguisher tothis fire zone. This extinguisher meets all requirements of NFPA10; therefore, no new extinguishers need be added to this zone.
8. Fire Zone 19
Replace a BC dry chemical extinguisher with an ABC dry chemicalextinguisher.
9. Fire Zone 20
Revision 2 of the Fire Hazard Analysis added an ABC extinguisher tothis fire zone. This extinguisher meets all requirements of NFPA10; therefore, no new extinguishers need be added to this zone.
10. Fire Zone 21
The ABC extinguisher installed in Fire Zone 19 also meets all NFPA10 requirements for this fire zone. Therefore, no newextinguishers need be added to this zone.
11. Fire Zone 13
The ABC extinguisher installed in Fire Zone 15 also meets all NFPA10 requirements for this fire zone. Therefore, no newextinguishers need be installed in this zone.
January 24, 1989Page 3
12. Fire Zone 14
Replace a BC dry chemical extinguisher with an ABC dry chemicalextinguisher.
13. Fire Zone 15
Replace a BC dry chemical extinguisher with an ABC dry chemicalextinguisher.
14. Fire Zone 110
Revision 2 of the Fire Hazard Analysis added an ABC extinguisher tothis fire zone. This extinguisher meets all requirements of NFPA10; therefore, no new extinguishers need be added to this zone.
15. Fire Zone 64A
Revision 2 of the Fire Hazard Analysis added an ABC extinguisheroutside of this fire zone. This extinguisher meets all requirementsof NFPA 10 for Fire Zone 64A; therefore, no new extinguishers needbe added to this zone.
16. Fire Zone 64B
See the letter from P.J. Russell to Impell Code ComplianceWalkdown, dated January 24, 1989, for the justification againstinstallation of a portable extinguisher within this fire zone.
17. Fire Zone 6N
See the letter from P.J. Russell to Impell Code ComplianceWalkdown, dated January 24, 1989, for the justification againstinstallation of additional portable extinguishers within this Eirezone.
18. Fire Zone 17A-17G
Replace three BC type Eire extinguishers with ABC type Eireextinguishers.
January 24, 1989Page 4
19. Fire Zone 29A-29F
Replace three BC type fire extinguishers with ABC type fireextinguishers.
20. Fire Zone 40A
Replace a BC type fire extinguisher with an ABC type fireextinguisher.
21. Fire Zone 40B
Revision 2 of the Fire Hazard Analysis added an ABC extinguisher toFire Zone 42A. This extinguisher also meets all requirements ofNFPA 10 for Fire Zone 40B; therefore, no new extinguishers need beadded to this zone.
22. Fire Zone 41
Revision 2 of the Fire Hazard Analysis added an ABC extinguisher toFire Zone 42A. This extinguisher also meets all requirements ofNFPA 10 for Fire Zone 41; therefore, no new extinguishers need beadded to this zone.
23. Fire Zone 42A
Revision 2 of the Fire Hazard Analysis added an ABC extinguisher tothis fire zone. This extinguisher meets all requirements of NFPA10; therefore, no new extinguishers need be added to this zone.
24. Fire Zone 42B
Revision 2 of the Fire Hazard Analysis addedFire Zone 42A. This extinguisher also meetsNFPA 10 for Fire Zone 42B; therefore, no newadded to this zone.
an ABC extinguisher toall requirements ofextinguishers need be
25. Fire Zone 42C
Revision 2 of the Fire Hazard Analysis addedFire Zone 42A. This extinguisher also meetsNFPA 10 for Fire Zone 42C; therefore, no newadded to this zone.
an ABC extinguisher toall requirements ofextinguishers need be
January 24, 1989Page 5
26. Fire Zone 42D
Revision 2 of the Fire Hazard Analysis added an ABC extinguisher toFire Zone 42A. This extinguisher also meets all requirements ofNFPA 10 for Fire Zone 42D; therefore, no new extinguishers need beadded to this zone.
27. Fire Zone 45
Revision 2 of the Fire Hazard Analysis added an ABC extinguisher toFire Zone 46A. This extinguisher also meets all requirements ofNFPA 10 for Fire Zone 45; therefore, no new extinguishers need beadded to this zone.
28. Fire Zone 46A
Revision 2 of the Fire Hazard Analysis added an ABC extinguisher tothis fire zone. This extinguisher meets all requirements of NFPA10; therefore, no new extinguishers need be added to this zone.
29 'ire Zone 46B
Revision 2 of the Fire Hazard Analysis addedFire Zone 46A. This extinguisher also meetsNFPA 10 for Fire Zone 46B; therefore, no newadded to this zone.
an ABC extinguisher toall requirements ofextinguishers need be
30 'ire Zone 46C
Revision 2 of the Fire Hazard Analysis addedFire Zone 46A. This extinguisher also meetsNFPA 10 for Fire Zone 46C; therefore, no newadded to this zone.
an ABC extinguisher toall requirements ofextinguishers need be
31. Fire Zone 46D
Revision 2 of the Fire Hazard Analysis addedFire Zone 46A. This extinguisher also meetsNFPA 10 for Fire Zone 46D; therefore, no newadded to this zone ~
an ABC extinguisher toall requirements ofextinguishers need be
January 24, 1989Page 6
32. Fire Zone 47A
Replace a BC dry chemical extinguisher with an ABC dry chemicalextinguisher.
33. Fire Zone 47B
Revision 2 of the Fire Hazard Analysis added an ABC extinguisher toFire Zone 46A. This extinguisher also meets all requirements ofNFPA 10 for Fire Zone 47B; therefore, no new extinguishers need beadded to this zone.
34. Fire Zone 108
Revision 2 of the Fire Hazard Analysis added an ABC extinguisher tothis fire zone. This extinguisher meets all requirements of NFPA10; therefore, no new extinguishers need be added to this zone.
35. Fire Zone 109
Revision 2 of the Fire Hazard Analysis added an ABC extinguisher tothis fire zone. This extinguisher meets all requirements of NFPA10; therefore, no new extinguishers need be added to this zone.
36. Fire Zone 53 and 54
Revision 2 of the Fire Hazard Analysis added Halon 1211extinguishers to this fire zone. These extinguishers have beenshown to extinguish small Class A fires. Because of the inherentcharacteristics of the Control Rooms, it has been policy not toinstall liquid (because of its conductivity) or dry chemical(because of its corrosive properties) in these areas. No newextinguishers will be installed in these fire zones.
37. Fire Zone 70
Revision 2 of the Fire Hazard Analysis added an ABC extinguisher tothis fire zone. This extinguisher meets all requirements of
NFPA'0;
therefore, no new extinguishers need be added to this zone.
January 24, 1989Page 7
38. Fire Zone 71
Revision 2 of the Fire Hazard Analysis added an ABC extinguisher toFire Zone 70. This extinguisher also meets all requirements ofNFPA 10 for Fire Zone 71; therefore, no new extinguishers need beadded to this zone.
39 'ire Zone 72
Revision 2 of the Fire Hazard Analysis added an ABC extinguisher toFire Zone 73. This extinguisher also meets all requirements ofNFPA 10 for Fire Zone 72; therefore, no new extinguishers need beadded to this zone.
40. Fire Zone 73
Revision 2 of the Fire Hazard Analysis added an ABC extinguisher tothis fire zone. This extinguisher meets all requirements of NFPA10; therefore, no new extinguishers need be added to this zone.
Donald C. Cook Nuclear PlantPortable Fire Extinguisher Code Compliance
From P.J. Russell
To Impell'.*Cade'ompliance'-'ValkcSwn.
Impell Corporation has identified several areas of the plant that arenot in compliance with NFPA-10, "Portable Fire Extinguishers," sections3-2.1, 3-3.1 and 3-3.3. These sections require that all areas be within75 feet of a Class A extinguisher and 50 feet of a Class B extinguisher.The fire zones identified to be deficient in these requirements are 4,5, 6N, 6S, 62B, 62C, 63C, 64B, 37 and 44N. The following evaluations(performed by AEPSC) are to determine if, in fact, new portableextinguishers are necessary for the identified fire zones.
1. Fire Zone 4 "Sam lin Room"
According to Impell Report ¹09-0120-0123, Fire Zone 4 is said to bedeficient to section 3-2..1 of NFPA 10. Section 3-2.1 requires thatthe maximum travel distance to a Class A extinguisher be 75'rless.
According to the Fire Facility Drawings and Plant Procedure12SHP2270FIRE.001, Revision 1, a 20 lb. ABC extinguisher is locatedon the south side of the sampling room's east fire door. Ourcalculations show this extinguisher to be well within 75'f themost remote area of this fire zone. In addition, two extinguishersrated for Class B or C fires are located within this 40'y25'room. While these extinguishers are not rated for Class Afires, they do provide the ability to knockdown and under certainconditions extinguish a small Class A type fi,re Therefore, no newextinguishers need to be added to this room.
2. Fire Zone 5 "Auxiliar Buildin - El. 587'"
The Impell Report identified two areas of this fire zone (SpentResin Storage Tank Area and 2 GPM Waste Evaporator Area) to bedeficient in the fire extinguisher placement criteria as defined inNFPA 10.
January 23, 1989Page 2
According to the Fire Facility Drawings and Plant Procedure12SHP2270FIRE.001, Revision 1, a 20 lb. ABC extinguisher is locatedwithin 50'f the most remote section of the 2 GPM Waste EvaporatorRoom. Therefore, no new extinguishers need be added to protectthis area as it already meets the distribution criteria set forthin NFPA 10.
The Spent Resin Storage Tank Room is classified as an "Extreme HighRadiation Area." Access to this area is under strict control.Placing an extinguisher within this room is undesirable from anALARA standpoint. According to the Fire Facility Drawings andPlant Procedure 12SHP2270FIRE.001, Revision 1, a 20'b. ABCextinguisher is located within 75'f the most remote section ofthis room. This extinguisher does meet distribution requirementsfor Class A type protection, but exceeds the distance requirementsfor Class B, C protection. Because this room contains no exposedcombustibles and placement of a B, C extinguisher within this roomis an ALARA concern, it is felt that the existing extinguishers areadequate. No new extinguishers will be added to this room.
3. Fire Zone 6N "Auxilia Buildin - El. 587'"
The Impell Report identified two areas of this fire zone (Gas DecayTank Area and the area which contains the concentrate filters andthe boric acid evap. feed ion exch. filters) to be deficient in thefire extinguisher placement criteria as defined in NFPA 10.
According to the Fire Facility Drawings and Plant Procedure12SHP2270FIRE.001, Revision 1, a 20 lb. ABC extinguisher is locatedwithin 50'f the most remote sections of the room containing theconcentrate and boric acid filters. The pipe tunnel behind theserooms exceeds the distance limitations for B, C extinguishers byapproximately 20'. Very few combustibles exist in the pipe tunnel,and all combustibles that do exist are Class A. Therefore, thepossibility of a Class B or C fire in this area is extremely low.The above mentioned ABC extinguisher is within 75'the distancerequired for a Class A type fire) of the most remote section of thepipe tunnel. In addition, this area is considered a high radiationarea and placement of a portable extinguisher within this area isundesirable from an ALARA standpoint. No new fire extinguishersneed be added to this area as it is felt that the existingextinguishers are adequate to extinguish a normally postulatedfire.The Gas Decay Tank Area is not lit so the installation of a newextinguisher is undesirable as it would not be easily located in afire scenario. The probability of a fire in this area is extremelylow since no exposed combustibles exist in this room.
January 23, 1989Page 3
In addition, this area is considered a high radiation area andplacement of a portable extinguisher within this area isundesirable from an ALARA standpoint. It is felt that the two B, C
type extinguishers located at the entrance to this room provideadequate protection even though the distance requirements per NFPA10 are exceeded. Therefore, no new extinguishers will be added tothis room.
4, Fire Zone 6S "Auxilia Buildin - El. 587'"
The Impell Report identifies the Gas Decay Tank Area of this firezone to be deficient in the fire extinguishers placement criteriaas defined in NFPA 10.
For the same reasons explained in the evaluation of the Gas DecayTanks in Fire Zone 6N, no new extinguishers will be added to thisroom.
5. Fire Zones 62B 62C and 63C "Centrifu al Char in Pum Room"
The Impell Report identifies these three Charging Pump Rooms asbeing deficient in the fire extinguisher placement criteria asdefined in NFPA 10.
Due to the inherent purpose of these pumps (pumping radioactivefluids), these rooms tend to become contaminated while the unitsare "on-line." Placing a portable fire extinguisher within theserooms is undesirable from an ALARA standpoint. According to theFire Facility Drawings and Plant Procedure 12SHP2270FIRE.001,Revision 1, an ABC extinguisher is located outside the accessway tothis room. Since very few exposed combustibles are within theserooms and access is controlled because of ALARA concerns, it isfelt that the existing extinguishers are adequate. No newextinguishers will be added to these fire zones.
Fire Zone 64B "Safet In ection Pum Room"
The Impell Report identifies this zone to be deficient in the fireextinguisher placement criteria as defined in NFPA 10.
Fire Zone 64B is classified as a Radiation Area. Placing a fireextinguisher within 50'f all portions of this room is undesirablefrom an ALARA standpoint. According to the Fire Facility Drawingsand Plant Procedure 12SHP2270FIRE.001, Revision 1, sufficient fireextinguishers are located outside the accessway to this room.
January 23, 1989Page 4
Since very few exposed combustibles are within this room and accessis controlled because of ALARA concerns, it is felt that theexisting extinguishers are adequate. No new extinguishers will beadded to this fire zone.
7. Fire Zone 37 "Valve Galler - El. 617'"
The Impell Report identifies this zone to be deficient in the fireextinguisher placement criteria as defined in NFPA 10.
Fire Zone 37 is classified as a High Radiation Area. Placing fireextinguishers within this room is undesirable from an ALARAstandpoint. According to the Fire Facility Drawings and PlantProcedure 12SHP2270FIRE.001, Revision 1, sufficient fireextinguishers exist outside the accessway to this room. Since thisroom contains no combustibles and access is controlled because ofALARA concerns, it is felt that the existing extinguishers areadequate. No new extinguishers will be installed in this firezone.
8. Fire Zone 44 N "Auxilia Buildin North - El. 609'"
The Impell Report identifies the Waste Gas Compression Area of thisfire zone to be deficient in the fire extinguisher placementcriteria as defined in NFPA 10.
This portion of Fire Zone 44N is classified as a Radiation Area.Installation of a fire extinguisher within strict compliance ofNFPA 10 is undesirable due to ALARA concerns. According to theFire Facility Drawings and Plant Procedure 12SHP2270FIRE.001,Revision 1, sufficient fire extinguishers exist outside theaccessway to this room. Since this room contains very few exposedcombustibles and access is controlled because of ALARA concerns, itis felt that the existing extinguishers are adequate. No newextinguishers will be installed in this fire zone.
Patrick J. Russell
PJR/gf
cc: FHA Rev. 4 File nPJ.D. Grier/J.A. Kobyra/B.J. Gerwe/P.J. Russell
ZANERECANELECTRECPOWER
Oate
Subject
From
To
January 23, 1989
Donald C. Cook Nuclear PlantPlant Portable Fire Extinguishers
In order to meet the NFPA 10 "Portable Fire Extinguisher" placementcriteria for Class A type fires, the following eleven extinguishers(shown on the attached drawings) should be changed from Type BC drychemical to Type ABC. If you should have any questions, please contactme at extension 2532.
This memo is intended to complete the closeout of Item 4 of my July 18,1988 memo to you on NFPA 72D Code Compliance deviations. My memo ofNovember 29, 1988 to Messrs. Kobyra/Brewer/Auvil/Smith, Jr. on thesubject of "NFPA 72D Circuit Supervision Requirements" provides thebalance of the closeout for Item 4.
Item 4 concerned the deviations found by Impell in their code compliancereview of NFPA 72D. The Impell identified deficiencies included lack ofan automatic means to record alarm signals received by the EF panel andthe lack of a UL listing for certain manual alarm stations. Theattached technical justification provides the basis for our acceptanceof the above deficiencies.
BJG/bma
cc: S. J. BrewerW. G. Smith, Jr. - BridgmanJ. R. Sampson/P. H. Jacques - BridgmanM. Gallagher, Operations - BridgmanP. G. Schoepf (MED 88-20-10 completion)J. A. ~ra/J D ~Gr ~/B. J. Gerwe/Code ComplianceFile: Appendix Audit Preparation
TECHNICAL JUSTIFICATION FOR NFPA 72D
1967 EDITION CODE SECTIONS 2032, 2212 & 3111
Deviations
The unapproved fire alarm devices have been compared against theapplicable Underwriters Laboratory (U.L.) Test Standard to verify ifthese devices would meet the requirements of the applicable standard andcould therefore be considered equivalent to a U.L. Listed device. Basedon the evaluation performed, the devices listed did not meet therequirements of the applicable standard for the following reason(s):
Device Deviation
Rochester "EF"AnnunciatorPanel
NFPA 72D requires that an automatic means ofrecording si,gnals be provided to record all signalsreceived by the central supervising station controlpanel. Since this panel is not provided with thisrecording device, it cannot be considered equivalentfor use as an NFPA 72D fire alarm signaling system.
Hose SystemManual Stationsand the ACIModel 446002Manual Start/Stop Stations forthe charcoalfilter units
These manual stations did not meet the requirementsof this U. L. Test Standard due to the lack of alatching feature of the alarm contacts and theactivation mechanism to provide a positiveindication that the device has been activated.
The U.L. Test Standards referenced include the following:
a. U.L. Standard 864 for the Rochester "EF" Panel.
b. U.L. Standard 38 for the Manual Alarm Stations:
Justifications
1. The automatic recording of all signals is required by the code inorder to provide a permanent record of all signals as well as ameans of reconstructing the series of events during a fire whensignals may be received very rapidly. While these are importantfeatures, the lack of automatic recording of all signals received bythe central supervising station control panel (the Emergency Fire(EF) panel located in each control room) does not jeopardize thesafety of the plant. The control rooms are constantly manned areas.As fire, system actuation or system failure signals are received,under plant administrative procedure OHI-2211 the control roomoperators manually log the incoming signals. An incoming signal
Page 1 of 3
provides both a visual and audible alarm. The visual alarm isdisplayed on the EF panel annunciator. A unique audible alarm islocated in each control room. In addition, the EF panel has a redlamp above each group of annunciator windows. This lamp lightswhenever any alarm appears on the panel. Upon acknowledging thealarm, this lamp goes off.The plant has advised that certain incoming signals are not logged.These include situations where an investigation of a fire detectionsignal shows no evidence of a fire, when there are repeated problemswith a detection signal (this type of signal problem is passed ontothe next shift in turnover information), or during surveillancetesting of a system when many testing signals are received in thecontrol room (Note: the start and stop of the surveillance testingis logged).
Under an existing standing (previously acknowledged) fire detectionalarm signal, a new incoming fire detection alarm signal will bevisually annunciated on the EF panel but will not provide theaudible alarm. In these instances, the control room operatorsvisually check the EF panel'every half hour. This check isperformed under plant administrative procedures, in order to verifythat no new signals have been received and gone unnoticed while thestanding fire detection alarm exists.
We believe our present arrangement for the recording of signals isan acceptable alternative to the NFPA 72D code requirement.
This situation of not having an automatic means of recording allsignals received by the'F panel is not unique to only Cook NuclearPlant. Other plants of similar age also lack this automaticrecording function. They have also taken a similar position toours. In at least one instance, this position appears to have beenacceptable to the NRC.
2. The lack of a latching feature for the alarm contacts and activationmechanism for the auxiliary building hose system manual stations andAlison manual start/stop stations does not jeopardize the safety ofthe plant.. While the noted deficiency is an important feature, itwas probably intended for more commercial operations where a lesscomplex fire logic system would exist and a staff of plantoperators, who also double as fire brigade personnel, are not onduty 24 hours a day.
The function of the auxiliary building hose system manual stationsis to send a command signal to open two isolating valves and wasnever intended to be for alarm signaling purposes. Therefore, themanual stations do not require the latching feature of the alarmcontacts and activation mechanism. These manual stations are of thebreakglass momentary push button design. Operation .of these manual
Page 2 of 3
stations will actuate the auxiliary building fire header isolationvalves, ZNO-10 and ZMO-20. Operation of these valves willpressurize the header and give alarm annunciation on the EF panelswhich includes header pressurization and valves open. Upon receiptof these signals, the operators would begin the necessary fireinvestigations and dispatch the fire brigade. Annunication of theZMO valve operation on the EF panels provides the required positiveindication in the control room that the device has sent the requiredcommand signal and that the system has been activated. This remoteindication. in the control room is over and above the localindication given by the breaking of the glass plate and flow ofwater through the hose. In addition, because of the design of theannunciation system, these alarms cannot be removed without operatoraction to close the valve control switches. Closure of thesecontrol switches would only occur after confirmation that the dangerof fire no longer exists. Additionally, signs at each hose stationwarns against their use by people other than the fire brigade, whichis comprised of plant operators. In these instances, only a firebrigade member should be actuating the manual stations who wouldinsure that proper fire suppression activities are undertaken nomatter what the circumstances.
The Alison manual start/stop stations for the charcoal filtersuppression systems are remote monemtary push button stationslocated near each of the protected charcoal filter units. They areintended for manual operation of the suppression system by the fire,brigade. The water suppression systems must be manually operatedafter receipt of a fire signal in the control room from the charcoalfilter unit's thermistor detection system. Operation requires themanual opening of the system controlling valve upstream of thesystem air operated three-way valve. The three-way valve is openedautomatically by the thermistor detection system or by operation ofthe Alison stare/stop stations. Since a fire brigade member must beon hand to open the system controlling valve, the rush of watertraveling through the piping downstream of the three-way valve will,be heard. The water discharge is designed to shut off at apredetermined time in order. to minimize the amount of water whichmust be treated following extinguishment. It is for this reasonthat the start/stop station must be of the non-latching design. Alatching type design would automatically restart the discharge cycleand increase the volume of water that must be treated. The presentdesign allows complete freedom of action that the fire brigade mustuse in extinguishing the fire. As the three-way valve is closed,water can be seen draining through the drain line sight glass Theabove methods provide positive indication that the Alison start/stopstation has sent the required command. Also, the necessity ofmanual action by the fire brigade member ensures that proper firesuppression activities are undertaken no matter what thecircumstances.
Page 3 of 3
ZAMERICAN
ELECTPOWER
Date November 29, 1988
IFrom B. J. Gerwe
/
Subject DONALD C. COOK NUCLEAR PIANTNFPA 72D Circuit Supervision Requirements M~V~ Vah
~~tom<~C~~~ csI4'tX, k4'ZA
To 1) J. A. ~ragfdirsms's2) S. J. Brewer/A. B. Auvil3) W. G. Smith, Jr., - Bridgman
~Summa
The NFPA code compliance review conducted by Impell identified adeficiency in that the annunciator circuits associated with the EFpanels are not electrically supervised to detect wire breaks. A reviewof our licensing documents indicates that we have committed to complywith this requirement only for fire detection systems and the NRC
accepted this position in the Appendix A SER. We are not currently infull compliance with this licensing basis. Therefore, a monthlysurveillance program for the technical specification required Alisonpanel alarm annunciator circuits is recommended to be established assoon as possible. No interim corrective action is required at thistime.
Licensin Chronolo
Paragraph II.E.1.(a) of Appendix A to BTP 9.5-1 (Attachment 1) requiresthat fire detection systems comply with NFPA 72D, and that deviations beidentified and justified. The AEP response to Appendix A (Attachment 2)stated that the fire detection systems at Cook complied with NFPA 72Dexcept for testing frequencies for fire detectors inside containment.
Two of the fifty-three Appendix A follow-up questions posed by the NRCaddressed circuit supervision. Question 16b (Attachment 3) specificallyasked whether the complete fire alarm system, including valve and waterflow supervision, conformed with NFPA 72D with respect to fire detectionsystems and that our compliance would be limited to "firedetection/suppression system control." NRC question 48 (Attachment 4)addressed circuit supervision associated with the EF panel annunciators.NFPA 72D circuit supervision includes detection of open circuits (wiringbreaks) and ground faults preventing required circuit operation. The EF
panel annunciator circuits are supervised for ground faults as discussedin the response, but not for open circuits as identified by Impell as acode deficiency.
November 29, 1988Page 2
The Appendix A SER (Attachment 5) states that the NRC "reviewed the firedetection system's design criteria and the basis to ensure that itconforms to the applicable sections of NFPA 72D, for Class B supervisedcircuits."
Discussion of Licensin Basis
Statements are made in the AEP responses to NRC questions and theAppendix A SER which are ambiguous if taken out of context. It wouldcertainly appear that sufficient information was presented to the NRC
for them to determine which portions of the overall fire alarm systemwere supervised.
The Appendix A requirement for circuit supervision is limited to firedetection systems, and this was the position taken by AEP. The AppendixA SER refers to circuit supervision only in the context of firedetection systems. It is, therefore, our interpretation that NFPA 72Drequirements for circuit supervision are only committed to for firedetection systems.
Conformance
The initiating device circuits on the high and low voltage Pyrotronics(smoke and flame detection) and Alison (thermistor heat detection) localcontrol panels are Class B supervised circuits as documented in theImpell code compliance review. The Technical Specification required lowvoltage Pyrotronics detection panels transmit alarms back to the controlroom on supervised high voltage Pyrotronics initiating device circuits.NFPA 72D also requires the signalling circuits which transmit adetection alarm from the local panel to the control room annunciatorpanel to be supervised. The high voltage Pyrotronics local controlpanels are mounted in the back plane of the EF panel, and the zoneindicating lamps are duplicated on the front of the vertical board.This wiring is not supervised; however, Paragraph 2-7.1 of NFPA 72D-1986does not require supervision of wiring within a common enclosure. Sincewe consider the control room horseshoe panel to be a common enclosure,this wiring need not be supervised.
The Alison local panels transmit to annunciator logic cabinets locatedwithin the control room horseshoe panel enclosuie. As discussedearlier, the annunciator field circuits are supervised for groundfaults, but not for open circuits (wire break). A program should beimplemented to provide assurance that annunciator field circuits servingTechnical Specification thermistor circuits are intact. An unsupervisedprewired jumper runs from the annunciator logic cabinet to theannunciator drop lamps mounted on the front of the EF panel verticalboard. This jumper runs through the common enclosure of the controlroom horseshoe panel and is therefore not required to be supervised.
November 29, 1988Page 3
Corrective Action
Monthly surveillances should be implemented to test the integrity ofunsupervised annunciator circuits serving Technical Specificationthermistor fire alarms. (Note: Electrical supervision ofabnormal/trouble alarms is not required by NFPA 72D). The testing wouldentail jumpering the alarm relay contacts and verifying that theannunciator registers on the EF panel. Annunciator circuits to betested would include the diesel generator rooms, fuel oil transfer pumproom, charcoal filter units and containment 100 point panel commonalarm, for each unit. All of the panels are located in the ReactorCable Tunnels, Turbine Building or general floor areas of the AuxiliaryBuilding. In order to satisfy our regulatory commitment, we requestthat the plant implement a monthly surveillance program as soon aspossible for the Technical Specification required Alison panel alarmannunciator circuits: Table 1 identifies the required systems.
Bruce J Gerwe
BJG/bma
Attachments
cc: P. G. Schoepf (MED 88-20-10 Partial) - w/o attachmentJ. A. Kobyra/J. D. Grier/B. J. GerweM. P. Alexich - w/o attachmentFile: NFPA 72D Code Compliance
TABLE IALISON CONTROL PANEL AIARM ANNUNCIATORS
NFPA 72D CIRCUIT SUPERVISION REQUIREHENTS
Item Area Protected
1-HV-AES-1
1-HV-AES-2
1-HV„-ACRF
1-HV-CPR
1-HV-CIPX
Unit
98 101
87 101
99 101
85 101
Annunciatorpro Panel
97 101
Reference Drawin s
95909, 98969, 92003
95909, 98969, 92003
95910, 98969, 92003
95910, 98969, 92003
95911
1- HV-CFT- 1
1-HV-CFT-2
2-HV-AES-1
2-HV-AES-2
2-HV-ACRF
2-HV»CPR
2-HV-CIPX
91,95
91,96
97
98
87
99
85
101
101
201
201
201
201
201
95926, 98978
95926
95909, 98969, 92003
95909, 98969, 92003
95910, 98969, 92003
95910, 98969, 92003
95911
2-HV-CFT-1
2- HV-CFT- 2
Diesel Gen. 1AB
Diesel Gen. 1CD
Diesel Gen. 2AB
Diesel Gen. 2CD
Fuel Oil Trans.Pump Room AB
Fuel Oil Trans.Pump Room CD
53 101
52 101
53 201
52 201
51,54 101
51,54 101
91,95 201
91,96 201
95926, 98978
95926
98981, 95936
98981, 95936
98981, 95936
98981, 95936
98981, 95936, 98982, 95937
98981, 95936, 98982, 95937
Item Area Protected
Fuel Oil Trans.Pump Room AB
Fuel Oil Trans.Pump Room CD
Containment 100 Pt.Panel
Containment 100 Pt.Panel
UnitAnnunciator
~Dro Panel Reference Drawin s
51,54 201 98981, 95936, 98982, 95937
51,54 201 98981, 95936, 98982, 95937
92,93 101 98977, 92335
92,93 201 98977, 92335
Reactor CoolantPumps Nos. 11, 12,13 & 14
94 101 98612, 98979
Reactor CoolantPumps Nos. 21, 22,23 & 24
94 201 98612, 98979
'
h3FPp 7Kb Cg~iY 6&PBzVL,S (oa ~~vi=H-~523
APPLICATION DOCKETED BUT CONSTRUCTION
PE"'fIT NO RECEIVED AS OF 7/I/76PLANTS UNDER CONSTRUCTION AND
OPERATING PL<iTS
Suitable s . sled beam bat terypovered portable hand ligl~ tsshould be provided for emergencyuse+
(c) Faced emergency communication .
should use voice povered headsecs at pre-selected stations.
(d) Fixed repeatez's installed to per-mit use of portable zadio communi-cation un'ts should be protectedfrom exposure fire damage.
f. Fire Detection aad Suppression
1. Fire Deteccion l. Fire Deteccion
(a) Fire decectioa systems should'sa minimum comply vith NFPA 72D,"Standard for the Iasc Llacion,~iwintenance ann Use oi Propr etaryProtective Signaling Systems."
SA'K; Deviations from therequirements oz NAPA 723 shoulbe identified and )ustified.
Fire detection system should giveaudible and visual alarm aadannunciation in the control room.Local audible alazm should alsosound at the location of the fire.
(c) Fire alarms should be distinctiveand unique. They should aoc becapable of being coafused vithany ocher plant system alarms.
(d)
2. Fire
Fire deteccion and actuatioasystems should be connected tothe plant emergency paver supply.
Protection Vater Su ol S stems\
2. Fire Protection Mater Suool~Ss tens
(a) An underground yazd fire main loopshould be installed to furnishanticipated Eire water require-ments. NFPA 24 - Standard forOutside Proi ection — gives nec-essary guidance for such insta11a-tion. It references other design
(a) SAY . Visible locac'onmarking signs for under-ground valves is accep-
tablee.
Alte ma tivevalve posicion ind ica torsshould also. be provided.
V+PA",7AS C. i%co< i 5 VP=-RV l,S~ S~ 4~~~~~5E. Fire Detection and Su ression
l. Fire Detection
(a) Fire detection systems at the Cook Plant conform to the
appalicable port1ons of NFPA 72D except for the testing
frequency specified in Paragraph 1232. The requirements
for testing in certain areas, particularly in-conta1nment, must conform to accessibility when
radiation levels are within allowable limits. In
such cases, the test frequency may be less than that
specified by NFPA 72D.
(b) All fire detection system alarms sound and are
visually displayed on the emergency fire panel in the
respective control room. Local alarms are furnished
only where the detection also actuates a gas-type
suppression system.
(c) Bells are used for such local alarm of actuation
of gas-type systems and are the only bells used forany alarm function. The overall plant fire alarm
system employs motor-operated horns which is the only
use of this type device.
(d) All fire detection and suppression system power supplies
are from the plant batteries, which are redundant,
or from the batteries through inverters which are also
redundant.
49
gyp'g Q g (gc.gi ( g~p~ gi5<ow ~ g+u< RE H,&39
a. Provide the. results of system tests or analyses which sub-stantiates that 'the sensitivity of fire aetection devices.and that the number and placemert of detectors are suffic'entto provide a prompt alarm a..a/or actuation of the automatic .
fire protection systems
b. Show that the complete fire alarm system> including waterflowand valve supervision, conforms to applica'ole guidance inNFPA 729.
c. Describe the detector system circu~try (from the detectors tothe main control room fire panel) ~ Supplement this descr'ptionwith selected elementary 'wiring drawings and typical cablerouting diagrams. Also, provide an electrical single linediagram which shows the main source and if applicable thealternate source of power-for thes -systems.
1
d. Identify any significant differences between the Unit 1 firedetection system and the Unit 2 fire detection system.
s t 0 st 6':
Each ionization detector in Unit 1 was checked for propersensitivity, followi.".g 'ns al'at'on, by Ic"-'4 relay ergireers and atechnical representative of the supplier. This latter check alsoincluded cleaning and ve ificat'on of opera-ion ef each detec"cr.This will be done on Unit 2 once the ins tallation is complete.
Following the check oy 0he suppl'er, 'onizat'on detec-orsare cleanea twice yea"'y ar." checked =or sensi-ivity and opera-ionyearly by I~~ personnel who have attenaea Pyra arm service ccu" eand are qualified by Pyralarm to service such systems. Manu actu"e"technicians may. oe callea 'n for assistance at ary t~e, ifrequirea.
Thermistor detection systems i'n Unit 1 were checked fo"proper sensitivi y and operation, following installation, byrelay engin ers. This will also be done cn Unit 2 orce instal"at"'c"is complete. Following the aoove initial check, yearly operational
'hecksare performed by IM personnel who are thorougnly zamiliarwith the equipment. Hanufacurer technicians may be called in for'assistance at any 'time, if required.
Ionization and thermistor detectors have been located bythe supplier's engineers, in quantities and spacing to agree as aminimum with NFPA 72E and the UL listing for these devices. Nerely, as do other utilities ard inaustr" es, on the results of ULand/or FM testing to determine the effectiveness of a device orsystem, the parameters affecting its use, and the quantities to beused.
t u t 6b:
Me feel that NFPA 72D 's an xtremely poor guide to beused for nuclear power plants s-'nce ~t is much too general in nature.However, we recognize that it is, at this time, the only guidanceavailable.
We also note that this question has apparently expandedin scope to include waterflow ard valve supervision, whereasAppendix A to B.T.F. APCS3 9.5-l only referrea to NFFA 72D ir.'tem E.l.(a) for fire de-. ction. Zn responai..g to Appendix A toB.T.P. APCSB 9.5-1 we cc"pared the requirements of NZi.A 729 to thefire detection/suppression system control at the Cook Nuclear Plant.As stated therein we are in agreement with all the applicableportions of NFPA 72D except for the testing frequency.
s o to Ou stion 6c:
The detector system circuit y is described below for thetwo types of fire detection in use at the Cook Nuclear Plant.
du t '"~ D tc ct
The ionization detector utilizes the principle wherein airXs maae electrically conductive (ionized) by exposure to aminute source of alpha rad ation mitt''rg material, Mericium241. The ionizirg ma erial is locatec ir. he outer or detecti~chamber of the aetector :.nich is open to the at-cspnere, anaan inner or .compensating cha"oer or the detector @rich, excep-for a .small vent to co=pe. sate for temperature ana press"rechanges, is essentially clcsed to prevent entra;.ce of cc=busproaucts ~ The ou er 8 d ~-er' ~oe s a e c ~ ec 2d .n pa awitn the anode a.".a ca hcae cf a s"ec='a gas aisci a"g (co "cathode) tuoe. The junction oetween the outer ana 'nrerchamoers is cor .-ectea to a starte" electrode o= the colacathode tube.
A voltage is applied across the outer ana inner 'onizaticnchambers causirg a m'nute electrical cur ent flc'.;. 'rQ'enproducts of combustioh nier the exposed outer chamber, -i eresistance to current flow increases ana the voltage oetween thecold cathode tube starter lectroae and the cathode increasesand fires the tuoe. The current wnich then passes between theanode and cathoae of the tube is sufficient to energize a zonerelay and a'orresponding alarm relay in the main ionizati,oncontrol unit.
The zone relay is a special 3-position relay incorporatedin the detector circuit to give an alarm in case of fire and tosupervise the system against defective detector heads, brokenwires, or a similar failure that would make the system inopera-tive. Such a failure will de-energize the relays and close
contacts to energize an ax="liary relay -h t:(1) lights an amber lamp on tne Emergency Fire
Panel (M') ir. the Control Room and on themain ionizatior. control unit.
(2) energizes an ar~unciator, "Pyr-A-Larm SystemTrouble-Fire"'n the Emergency Fire Panelin the Control Room.
{3) lights a white lamp on th Emergency FirePanel in t~e Control Room and the ZoneRelay Unit which will identify the protectedzone in which the failure'ccurred. If thefailure occurs in the power supply portion,none of the white -lamps vill light-
In the normal position of the supervisory relay, a low... current flows through-its coils due.. to a resistor in its circuit
This low current is sufficient,. to partially pick up the relay ',...and keep the contacts, which energize the auxiliary
relay'escribedabove, from making contact. 'f a fire occurs, the~ resistor is bypassed and a 'larger current flows through the
relay coil causing it to pick up completely. Then othercontacts close to energiz'e a second, auxiliary relay which:
{l) lights red lamps on the Emergency Fire Panel inthe Control Room and on the main ionizationcontrol unit.
(2) again erergi"es the "Pyr-A-Law System Troubl-rire" am~unciatcr on the "--er=ency Fire Panein the Control Room.
(3) lights the ap= cpr ate white la-g pnBnergercy Fir rm~.el in tne Contio Room a"dQn the Zo..e -.e 1ay Uni ". to ider r. ' y the zonefn which the fire occurred.
(4) operates any'o."@ected C02'" avalon 1301 F'"eextinguishir g system.
The Emergency Fire Panel in each Control Room is eauippedwith green, red and amoer lamps for Fyr-A"Larm systems ih'hindicate respectively'; power available, fire, and trouole.There are also groups of white lamps to indicate the individualPyr-A-Larm zones.
A fire condition would be indicated hyMighting one ofth d lamps ard QDeration of the annunciator "Pyr-A-LarmSystem Trouble-Fire" plus lighting one or more of ~h
e rethe white
indicating lamps for the respective zone.
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A trouble condition would be indicated by lighting oneof the amber lamps and operation of the annunciator "Pyr-'A-LarmSystem Trouble-Fire" plus 1'ghting one, or more, of the whiteindicating .lamps for the respective zone.
A reset switch is located directly below the green, red,and, amber lamps on the Bnergency Fire Panel. Once a troubleor a fire alarm has beer. received, it is necessary to operatethe switch to reset the system, but- as long as the trouble orfire condition remains, the system, ca~ot 'oe reset. Followingthe fire, there may be a period during which the system cannotbe reset due to the residua'roducts of combustion in the roomor in the exposed air chamber of the detector. Mhen theatmosphere is cleared, the system can be. reset in the normalmanner.
The reset switch is duplicated on the main ionizationcontrol unit and serves also as the. main power switch. This isthe location'from which the system would normally be turnedItOnlt and itOff}i
I
.'Fire and Trouble alarm silencing switches are also locatedon this unit from which the audible alarms can be silenceduntil the system is reset or, the trouble corrected.
These switches are supervised in such a manner that theannunciator and indicating lamps cannot be cleared until theswitches a e returned to their normal position.
There is a neon pulse lamp on the s'de of each detectobase. )Jhen a aetector operates, the pulse la"p on its oasewill fla 'na'at'ng that it 's the aevice which has cperated.The pulse c'rcuit is co trolled from the main ioni-ation con.roluni t ~
The ionization. fire detection system power supplies a asfollows:
(a) Unit lTo. l ard Au~liary Buildi.".g - 120 vacdistrioution cabinet 1-CMl, circuits 1 ana 3.
(b) Unit No. 2 - 120 vac distributicn cabinet 2-CRP1, circuits 1 and g.
(c) Office ard Service Building - 120 vac distributioncabinet 1-CHP2, circuits 15 and 20.
(ii) h rm st r e t S~ s n D tactic~:
Continous strip thermistor type sensing is adaptable tog neral area or specific eouipme"t aetection.t"'on. it can be maae
tive as desired .to suit the amo'ent co..aitions i. t:"edetection area and is used .wher rapidly a veloping
(hydro-carbons or gases) could be expected, such as oil roomsand transformers. It is also used where precise temperaturemeasurement is desired such as in cable trays and charcoalfilters.
The continuous t ~" ~st ~ s ~s consists of a smallcentered wire embedded in a ceramic thermistor core enclosedin either an inconel or a stainless steel tubing sheath. Thecentered wire and the outer sheath are connected at hermeticallysealed fittings used to join sections of the sensor. Electricalresistance..is.. measured across the centered wire and the sheaththrough the ceramic. core. As the ceramic core is heated, theresistance. between the centered wire and sheath decreases andthe current flow increases to the point where a relay isoperated. This relay, in turn, operates the fire extinguishingor alarm system. Heat detection can be achieved at any pointalong the thermistor sensor.
-.----The sensor has only two failure-modes, open circuit andshort circuit, both of which can be caused only by mechanicalmeans. Even though the above failure modes are unlikely tooccur, the sensor circuits are supervised for such situationsby relays in the control equipment.
Companion equipment for the sensor includes controlequipment mounting hardware of various types, junction(terminalI boxes, and electrical terminator for supervision.
When the alarm relay in the thermistor control is operateddue to heat from a fire lowering the r sistance between thecentral wire and outer sheath of the thermisto" sensor, acontact of the alarm relay 's closed to energize either therelease solenoid coil in the water deluge valve and the equip-ment rel"y in the deluge val;e elec"ric control panel in thecase of a." elect"ic ::ater s"ray de uge system or the haza""relay located in the COp relay cabinet in tne case of a lowpressure CO> protec'ted area.
When energized, the del"ge.valve release solenoid co'1operates the mechanical linkage causing ine valve c apper toopen, releasing the water. The equipment r lay 'n the delugevalve electric control panel when energized, operatesEmergency Pire Logic System to start fire pumps, sound thePlant Fire Horn Alarm System, and operate annunciators.
The'Cardox relay cabinet hazard relay, when energized,operates the predischarge alarm timer and the discharge tim~er;and auxiliary relays to open the master and selector valves,operate local and remote alar s and annunciators and, throughthe Logic System, operate the Plant Fire Horn Alarm System.
In the case of the Diesel Generator Rooms, t'«o thermistordetection circuits are used, to ni."ainiz the "ossibility of a
spurious operation. One circuit has an alarm setpoint of 190 Fand the ether, 250'F. The alarm relay cont cts in each circuitare wired in series so that both must operate before the ~CO2system hazard relay. can energize to release C02.
~ Th Containment Detection System control units monitorth mistor sensor circuits located in the containment ca le
eb e
trays and at the reactor coolant pumps. hach control uner it
monitors 100 zones for alarm and'short circuit conditions bymeans of combined alarm and short circuit printed circuitboards (PCB) which are adjustable. Each iCB must be individual1-,adjusted, in accordance with the suppli rs instructions, dueto varying sensor circuit lengths, alarm temperature setpoints,and short circuit setpoints.
Each control unit has 100 alarm and 100 trouble indicatinglights, one of each for every zone. The units are mounted onthe Containment Auxiliary Subpanels outside each Control Roomin the Auxiliary Building.
A group 'of 100 acknowledging switches correspondirg irlocation to the alarm and trouble irdicatirg lamps are locatedat the upper right hand corner of the .control u it. )ihen oneef these lamps is energized, the corresponding acknowledge switchshould be moved to the down positior.. This action clears th„control to receive additional alarm or trouble signals on theremaining indicating lamps but holds signals already received.All alarms should be .checked and acknowleag a promptly.
II
Directly below the ackrowledge switches is a group ofindicating lamps ard switches 'in the system cor trol section.The three green lamps indicate power avai a"'e. The "Q.".-Ofswitch is the inain po:.er s:ritcn. The "Lazy est" switch,operated verifies the condition of all no."mally-extinguisneainaicating lamps The Alar 'st switch il'" "nates al'aalarm indicat.-~g lamas 'n the u~oer left:-.~~d corner."Trouble Test" switch illuminates all a="er trouble inaica=="~lamps ~
When the thermistor sersor resistance falls be'ow thealarm setpoirt for a particular PC3, the ccrresponai. g rea a a"indicator will light and ar-z.ciatc 91 "Co.-.taizert Area .='"o"on the Emergency Fire Panel. will be energized. The operatorh uld then go to the control un't and turn the correspordi"g
acknowledge switch to the down position. his action wiT 'llenergize Annunciator 93 "Containment Area Alarm Acknowledgea"on the Emergency Fire Fanel. The operat"r shoula then resetthe Emergency Fire Panel ar~unciator to clear ~unciator 91for any subsequent alarm. After the alar" condition has bee.checked and cleared, the acknowledge switch must be returnedto the normal .up position a.".d the "=-ergency "'"o Pa elAnnunciator, reset to clear ~=.unciato 93.
A trouble condition sucn as an open or snort circuit inthe sensor or failure of the circuiting vill operate thecorresponding amber troub' indicator on tho control. unit andAnnunciator 92 "Cortairaent korea=:ire System abnormal" on theEmergency Fire Panel Op rator r sponse is identical to thealarm situation.
Selected electrical drawirgs, as ind'cated below, areattached and these drawings supplement the response to thisquestion. These drawirgs a"e:
. Figu" s 6C1 and 16C2 virirg diagramsshowing typical detector type.
. Figure 16C3 electrical single linediagram, showing main and alternateAC sources to the detector .relay .
circuits.. Figure 16C4 electrical single-. line
diagram showing sour'ce of power forbattery circuits.
. Figure 16C5 caole routirg diagramderived from physical drawings.
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There are no differences betwee Unit 1 and Urit 2 f'"edetection systems.
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Fbr the main control room(s) fire annunciator paneladdress or provide responses to the following items:
a. Provide a description of these panels and their associated elec-trical circuitry and devices. Supplement this description withelectrical schematics which show tne source of power for thesepanels and associated devices. (Also, include a wiring diagramwhich shows a tyuica1 circuit for this panel 'and includes thedetector element(s) and associated circuitry as well as thefinal indicating light and/or alarm.) This description shouldalso include a discussion of any form of supervisory circuitywhich is provided for this panel or its associated devices.
b. identify any differences in the associated electrical desimfor the fire system panel of Unit 1 and that of Unit 2.
The "FERE ANNUNCIATOR PANEL" consists of the annunciatorlogic cabinet and display panel. The logic cabinet and displaypanel are connected by prefabricated cables.
The logic cabinet contains the power supply unit, printedcircuit cards and .field connections.. The power supply unit is fedfrom the 250V dc system. Each power supply consists. of two inverter-rectifiers wired in series on the 250V dc side witn the output con-nected in paral'el. The output voltages are -12V dc, +12V dc and-28V dc which are used internally by tne solid state logic cards and125V dc wnich is used for field con:acts. No metalli c connectionexists between batteries and ~~~unciator vo'".ages ~".d therefore aground on the an"u.".ci-tor would not "esult in t:"e stat on c-t. =-ground.. Ground detectors are provided for 1257 dc output voltagewhich operate the annunciato" in .he even. of u @enunciator powersupply ground. The output voltage of the power supply is monitoredat window $ 60 of tne display panel.
The internal circuitry of the annunciator panel is allsolid state. Two annunciator points are arranged on each ci cuitcard. The output of the solid state circuitry for eacn poin. 'sconnected to its lamp on the fr'ont panel display unit. The l~pis lit for abnormal condition. Each annunciator can be either nonseal-in (auto reset on return to normal) or seal-in (alarm retainedon return to normal).
The display panel has 100 windows. Each window has itsown push button on it to acknowledge the alarm. 'lindow $ 50 is fortest purposes. Mhen the test button 's pressed ar'd held all thewindows light and the audible alarm sounds. On releasing the button,all non seal-in windo~s which did not have any actuation signal villgo off and the ones which have abnormal conditions would stay lit.A11 the seal-in windows would start flashinn. On pressina the resetbutton, the seal-in windows whi ch di d not have an al arm condi tionbefore the test would no off, the other windoijs with alarm condi tions
gould continue flashing. On acknowledqfno these windows lndkvfduallythey would stop flash)nn and stan lit.
Mindow ~0 is for res tt~~" t.". se '-'n alarms.other vindows when lit indicate an abnormal condition.
The display panel has a r„d 3.amp on top of it. Thislamp lights vhenever any alarm appears on tne panel. On acknow-ledging the alarm, this lamp goes off.
l~ o t a o
In the event of an "MklOR~" condition, the actuatingcontact in the annunciator circuit would close. P'e particularvindov would start flas~'n and the audible alarm would sound. Ifthe condition clears before the operator acknowledges it, the alarmand vindov would go off. If the operator acknowledges it, theaudible alarm would go off and the vindov vould stop flashing and-stay lit. When the condition clears, this vindov vould, resumeflashing and the audible alarm would sound. The operator wouldacknowledge it and the window and alrm would go off.
In the event of an "AMORHAL" condition, the actuatingcontact in tne. annunciator circuit would close, The particularvindov would start flashing and, the audible a1arm would sound. Theoperator would have to acknowledge it. It would not go off even ifthe condition clears before the operator acknowledges it. 'Ahen theoperator acknowledges it, the alarm vould go off, the window wouldstop flashing and stay lit. On pressing the reset button, if thecondition has cleared, the vindov vould resu-e flashing and theaudible alarm would sound. Qn aczrowledging it, the vindow andaudible alarm "ou'd go off. If the condi-io" '"as not cleared yet,the window would not resu-e "-shing but "ould stay li .
Figure 48Al prov'des t? electrical sche atic vh'chshows the oowe" feed or the a.""'.c'a.or oanel.
Fime.4"-~2 s?:o:.s the f"ont v'ev of the ":ireAnnunciator Display Panel." A list of arwun-ciators is orovided below.
Electrical Dwg. ~~2-98611 shovs the "~~ unciatorinterna1 diagrams" and also apolies to the "fireannunciator panel."
Elementary Dvg. 2-98612 is specifically for thefire annunciator panel. This drawing shows theactuating contacts for each annunciator.
.There is no difference in the associated electricaldesign for the fire system panel of Unit 1 and that of Unit 2.
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C. Fire Oetection S stems
A fire detection system consists of the detectors, associatedelectrical circuitry, electrical power supplies, and the fireannuniciator panel. The three types of detectors used at theCook Nuclear Plant are ionization {products of canhustion),infrared {flame), and thermistor {heat) detectors. Certainfire detection circuits provide automatic initiation of fireprotection systems. In addition, upon actuation of water flowdevices associated with both the wet pipe and pre-action systems,alarms are provided on the Fire Annunciator Panel and throughoutthe plant.
All of the Fire detection systems, whether used for protectionsystem automatic initiation or alarm only, provide an alarm onthe fire annunciator panel in the control roan of the affectedunit. The fire annunciator display panels and the associatedfire annunciator logic cabinet receive power fran a 250 voltd-c annunciator feeder cabinet which is powered by a batterycharger and battery. The battery charger' source of electricalpower is the offsite electrical power system through step-downtransformers, electrical circuit breakers, and a motor controlcenter.
All fire detection and protection functions are displayed on the'fire annunciator panel in the control roan. An alarm system ofmotor operated horns is provided throughout the plant to alertpersonnel that a fire has occurred. The alarms are soundedautomatically by actuation of any fixed fire protection systemand the alarms can also be manual1y initiated fran the controlrooms.
Appendix A to Branch Technical Position 9.5-1 contains guidelinesthat detectors be provided in control rocm cabinets so that firesoccurring in these cabinets may he detected rapidly. Almqst allof the cabinets used in the control rocms at the Cook Nuclear Plantare open on top and at the back, thus permitting direct ventingto existing ceiling detectors. We requested that detectors beplaced in the remaining cabinets that are closed. The licenseeshave stated that if detectors are installed in these cabinets,or if the cabinets are modified, the cabinet seismic or Class 1Equalification may be affected.
-10-
The licensees will develop and conduct a test program to deter-mine the response of the presently installed ceiling detectorsto a fire, simulated by smoke generated, in a closed cabinet.Should additional detectors prove necessary, based on theresults of this test, an engineered detector scheme will be pro-vided and implemented by the completion of the first refuelingoutage of Unit 2. We find this appr oach to be acceptable.
We have reviewed the fire detection systems to ensure that firedetectors are located to provide detection and timely alarm offires that could occur. We have also reviewed the fire detectionsystem's design criteria and the basis to ensure that it conformsto the applicable sections of NFPA 72D, for Class 8 supervisedcircuits.
We have requested, and the licensees have agreed, to install addi-tional detectors at various locations throughout the plant asidentified in the installation schedule in the Conclusions Sectionof this report. We conclude that; the design and installation ofthe fire detection system with the additional detectors to be in-stalled meets the guidelines of the applicable portions of NFPA72D, and Branch Technical Position APCSB 9.5-1 and is, therefore,acceptable.
ALTERNATE EMERGENCY SHUTDOWN METHOD
The licensee, in performing the Fire Hazards Analysis, recognized that afire occurring in the cable vault of Unit 1 or Unit 2 could prevent theunit involved frao being brought to a contro11ed safe shutdown condition.A system of local shutdown stations was installed and the procedures foroperating them were developed to ensure that the units could always bebrought to a controlled shutdown condition.
A separate control room cable vault is located beneath its respectivecontrol rocm and contains redundant divisions of safety related cabletrays. The cable vault also contains a large amount of non-safetyrelated cables which are resting on the floor.
The vault is a congested space with stacked cable trays making accessdifficult.An automatically actuated Halon 1301 System and a manually operatedcarbon-dioxide extinguishing system are installed in the cable vault.Additionally there is an automatic activated sprinkler system in theUnit 2 cable vault. We have provided an evaluation of these systemsin another section of this safety evaluation report.
?23(Q 83)ENGINEERING OEPT.
AMERICANELECTRIC POWER SERVICE CORP.1 RIVERSIDE PLAZACOLUMBUS, OHIO
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September 20, 1988
Subject Cook Nuclear PlantNFPA 14 Code ComplianceJustification for Reduced Hose Station Flow
From B.J. Gerwe
To 1) J.A. r/~~2) A.B. Auvil
This memo identifies the status of Item 2 of my July 18, 1988 memo toyou on two hydraulic calculations needed to support original NFPA 14hose station designs. The initial calculations demonstrated a designinadequacy that required plant testing of the fire hose nozzle dischargepatterns. The testing was necessary to make an evaluation that can helpprovide a basis for justification of our present design or if amodification to the low demand fire pump was required. It wasdetermined that this testing, in conjunction with other support data,will provide the needed justification.
The plant has recently completed the necessary testing using the NFPA 14code specified criteria of 100 gpm Q 65 psig inlet pressure through 100feet of hose. In the Fire Protection Coordinator's opinion, the testingdemonstrated an adequate nozzle discharge pattern for fire fightingpurposes at pressures of 65 psig and higher.
The attached justification provides the basis for the calculation usinga reduced, but safe, water flow requirement. The calculations arenumbered DCC-FP-12-HS33-F and DCC-FP-12-HS34-F. Justifications are alsoprovided for the remaining outstanding deviations to NFPA 14 noted byImpell.
BJG/gf
Attachment
cc: S.J. BrewerV.G. Smith, Jr. - Bridgman (w/o attachment)J.R. Sampson/P.H. Jacques - BridgmanP.G. Scho - -8
1. Documentation could not be found to verify that the Class IIIstandpipes are sized to flow 500 gpm at a residual pressure of 65
psig from the topmost outlet of the most remote standpipe and 250
gpm per minute flowing from the topmost outlet of each additionalstandpipe to a maximum of 2,500 gpm for a minimum of 30 minutes.
2. Not all Class III standpipe risers are a minimum of 4 inches indiameter.
Hose Station No. Elevation
62200, 201, 202, 204 & 205
208609'96'20'.
Documentation could not be found to verify that Class II hosestations are sized for a minimum flow of 100 gpm.
4. As-built calculations were not available for the hose stationsinstalled by Phoenix Contractors.
5. A 3 1/2 inch dial spring pressure gage is not located at the topof each standpipe.
Justifications'.
To satisfy the above code deviations 1 and 5, it was determinedwith Impell that two hydraulic calculations had to be performed.The hose stations were chosen as the worst case most remotesituation that would satisfy any other standpipe configurations.The hose stations used were FHC Nos. 223, and 83 in conjunctionwith 84. The FHC 83 and 84 combination demonstrates flow from thetopmost outlet of the most remote standpipes off Auxiliary Buildingdistribution header at El. 650'lus flow from the topmost outletof the other standpipe serving the same 650'levation. FHC 223demonstrates flow from the most remote hose station in theAuxiliary Building supplied from the Turbine Building distributionloop at El. 633.'. This hose station calculation is intended toconfirm the adequacy of the supply at the required flow andpressure.
The initial calculations were done in accordance with the criteriaof NFPA 14. Hose station outlets can have one of three designs.Cook Nuclear Plant uses two of these designs, designated as ClassII and Class III hose stations. A Class II hose station isintended for use by building occupants, while a Class III hosestation is intended to be used by fire department personnel. ClassII hose stations require a flow of 100 gpm Q 65 psig at the topmostoutlet of each standpipe. Class III hose stations require a 500gpm flow Q 65 psig at the topmost outlet of each standpipe. Inaddition, this flow and pressure is required at the most remotestandpipe with 250 gpm Q 65 psig at the topmost outlet of eachadditional standpipe. The number of additional standpipes used waslimited to only those which can also reach the same area beingprotected by the primary hose station. These initial calculationsusing the above NFPA 14 criteria failed to demonstrate that anadequate supply pressure was available to meet the demand.
In reviewing the calculations, it was obvious that our availablesupply could meet our demand by simply lowering the required flowfrom the first standpipe. Reduction in flow from 500 gpm to 350gpm for all Class III standpipes can be justified as follows:
(a) Each Class III hose station has two outlets; one 1 1/2 inchesand the other 2 1/2 inches. The 1 1/2 inch outlet is the samesize that is required for a Class II hose station. As statedabove, Class II hose stations are required to flow only 100gpm. The needed flow for fire fighting purposes from a 2 1/2inch outlet is normally projected to be between 250 gpm whenused with the other 1 1/2 inch outlet and 350 gpm when usedalone. The primary use for the 2 1/2 inch outlet at CookNuclear Plant is to supply long hose lengths with reducedpressure loss or in a catastrophic fire situation. Only a fewof the hose stations will have permanently mounted 2 1/2 inchhose (RFC-12-2983) and only when long hose lengths arerequired to protect an area. Under a normal fire scenario,after the 2 1/2 inch supply hose has been laid, it will befurther broken down into a 1 1/2 inch attack hose for use bythe fire brigade. This hose would then supply water in excessof the normal 100 gpm requirement for 1 1/2 inch hose.
(b) The fire brigade is not currently trained to discharge waterthrough a 2 1/2 inch nozzle inside the plant. As stated inNFPA 14, this size hose is intended for use by fire departmentpersonnel trained in the use of heavy hose streams.Additionally, no 2 1/2 inch nozzles are provided inside theplant at the hose stations.
(c) The NRC requirements given in BTP APCSB 9.5-1 only requirehose stations to be equipped with 1 1/2 inch fire hoses or aClass II standpipe system. Our Class III hose stations exceedthe NRC criteria. In addition, the size of the standpipepiping is required to be at least 4 inches in diameter formultiple hose connections and 2 1/2 inches for a single hoseconnection. Again, the piping for the Auxiliary Buildingstandpipes generally exceed or meet this requirement. Inthose situations where the NRC criteria for pipe sizes are notmet, hydraulic calculations have been performed to demonstratetheir adequacy.
(d) A catastrophic fire situation is not anticipated at CookNuclear Plant because the combustible loadings are generallylow and the high level of fire suppression and detectionsystems provided throughout the plant. Higher levels ofcombustibles are normally found only in areas containing oilhazards or heavy electrical cable installations. The oilhazards are located at the lower elevation and primarily inthe Turbine Building. Likewise, the heavy electrical cableinstallations are found at the lower and intermediateelevations in the Auxiliary Building cable spreading areas.When ignited, the cable insulation propagates at a generallyslow rate. The combustible loading values found in agenerating facility are generally not representative of thetypes of combustibles and the higher combustible loadingvalues upon which the NFPA 14 criteria for Class III hosestation was originally based. The fire detection andsuppression systems are provided throughout the plant whereverhazards warrant their protection, such as the oil hazard andheavy cable installation areas. Safe shutdown areas of theplant have also been evaluated for proper protection inaccordance with our Appendix R analysis, SSCA. In most areasof the plant, the hose stations only serve as a backup meansof manual suppression to the fixed fire suppression systemsinstalled.
Based on the above discussion, the physical configuration of thefire hose stations and standpipes for fire fighting activities areconsidered acceptable.
2. Deviation 2 requires Class III standpipe risers to be a minimum of4 inches in diameter. Hose Stations 62, 200, 201, 202, 204, 205
and 208 have been identified, as not meeting this requirement.However, Hose Stations 200, 201, 202, 204, 205 and 208 are allClass II hose stations fed from a standpipe that also serves ClassIII hose stations. The Class III hose stations on these same
standpipes are fed by piping at least 4 inches in size with theexception of Hose Station 62. Since the piping criteria for ClassII hose stations is satisfied, the requirements of NFPA 14 havebeen met. Additionally, calculations have been performed for eachof the above noted hose stations which demonstrates their abilityto meet the criteria given in NFPA 14 for Class II hose stations.,
Based on the above discussion, the physical configuration of thefire hose stations and standpipes for fire fighting activities areconsidered acceptable.
3. Deviation 3 and 4 are satisfied through the review of existinghydraulic calculations. These calculations show that Class II hosestations are provided with adequate water flows and pressures tosupport fire fighting activities. The calculations were performedfor only those hose stations and standpipes for which the pipingarrangement differed from the NRC criteria given underJustification 1, Item (c). Since the NRC criteria of 4 inch pipingfor multiple hose connections and 2 1/2 inch piping for a singlehose connection is in excess of the NFPA 14 criteria for Class IIhose stations and standpipes, the NFPA 14 criteria is automaticallysatisfied.
Based on the above discussion, the physical configuration of thefire hose stations and standpipes for fire fighting activities areconsidered acceptable.
NFPA 30 - 1987FLAMMABLE AND COMBUSTIBLE LIQUIDS CODE
CODE COMPLIANCE WALKDOWN CHECKLIST
CodeSection
No. Code Section Walkdown Remarks
4-5.2 Dwellings and Residential Buildings ContainingNot More Than Three Dwelling Units andAccompanying Attached and Detached Garages.
This chapter is not applicable to the DonaldC. Cook Nuclear Plant.
4-5.3 Assembly Occupancies, Buildings ContainingMore Than Three Dwelling Units, and Hotels.
This chapter is not applicable to the DonaldC. Cook Nuclear Plant.
4-5.4 Office, Educational, and InstitutionalOccupancies.
This chapter is not applicable to the DonaldC. Cook Nuclear Plant.
4-5.5 Mercantile Occupancies, Retail Stores, andOther Related Areas Accessible to the Public.
This chapter is not applicable to the DonaldC. Cook Nuclear Plant.
4-5.6 General Purpose Warehouses. (See 1-2,Definitions.)
This chapter is not applicable to the DonaldC. Cook Nuclear Plant.
4-5.7 Liquid Warehouses. (See 1-2, Definitions.) 7 i'<Lc-
NFPA 30 - 1987FLAMMABLE AND COMBUSTIBLE LIQUIDS CODE
CODE COMPLIANCE WALKDOWN CHECKLIST
CodeSection
No. Code Section Walkdown Remarks
4-5.7.1 Liquid warehouses shall be separate, detachedbuildings or shall be separated from othertype occupancies by standard 4-hr fire walls,with communicating openings protected on eachside of the wall with automatic-closing,listed 3-hr (A) fire doors. Fire doors shallbe installed in accordance with NFPA 80,"Standard for Fire Doors and Windows."
4-5.7.2 If the warehouse building is located more than10 ft (3 m) but less than 50 ft (15 m) from animportant building or line of adjoiningproperty that can be built upon, the exposingwall shall have a fire-resistance rating of atleast 2 hrs with each opening protected with alisted 1 1/2-hr (D) fire door.
pI
l]g
4-5.7.3 If the warehouse is located 10 ft (3 m) orless from an important building or line ofadjoining property that can be built upon, theexposing wall shall have a fire-resistancerating of 4 hrs with each opening protectedwith a listed 3-hr (A) fire door.
NFPA - 1987FLAMMABLE AND COMBUSTIBLE LIQUIDS CODE
CODE COMPLIANCE WALKDOWN CHECKLIST
CodeSection
No. Code Section Walkdown Remarks
4-5.7.4 An attached warehouse, having communicatingopenings in the required 4-hr fire wallseparation from the adjacent building area,shall have these openings protected by:
(a) Normally closed, listed 3-hr (A) firedoors on each side of the wall. These doorsmay be arranged to stay open during materialhandling operations, only if the doors aredesigned to close automatically in a fireemergency by provision of listed closuredevices.
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(b) Noncombustible, liquidtight raised sillsor ramps, at least 4 in. (10 cm) in height,or other design features to prevent flow ofliquids to the adjoining area.
~ I
I
4-5.7.5
4-5.7.6
Fire doors shall be installed in accordancewith NFPA 80, "Standard for Fire Doors andWindows."
The total quantity of liquids within a liquidwarehouse shall not be restricted. Themaximum pile heights and maximum quantity perpile, arranged as palletized and/or solid pilestorage, shall comply with Table 4-4.2.7, if
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NFPA 30 - 1987FLAMMABLE AND COMBUSTIBLE LIQUIDS CODE
CODE COMPLIANCE WALKDOWN CHECKLIST
CodeSection
No. Code Section Walkdown Remarks
4-5.7.6Cont'd
unprotected, or Table 4-6.1(a) if protected,in accordance with Section 4-6. The storageheights of containers on protected racks shallcomply with Table 4-6.1(b), as applicable.
Exception: An unprotected liquid warehouselocated a minimum of 100 ft (30 m) fromexposed buildings or adjoining property thatcan be built upon is not required to conformto Table 4-4.2.7, if there is protection forexposures. Where protection for exposures isnot provided, a minimum 200 ft (61 m) distanceis required.
4-5.7.7 Class I liquids shall not be permitted in thebasement areas of liquid warehouses. Class IIand Class IIIA liquids may be stored in base-ments provided that automatic sprinklerprotection and other fire protectionfacilities are provided in accordance withSection 4-6.
4-5.7.8 Limited amounts of combustible commodities,as defined in the scope of NFPA 231, "Standardfor General Storage," and NFPA 231C, "Standardfor Rack Storage of Materials," may be storedin liquid warehouses if protection is provided
NFPA 3 1987FLAMMABLE AND COMBUSTIBLE LIQUIDS CODE
CODE COMPLIANCE WALKDOWN CHECKLIST
0
CodeSection
No. Code Section Walkdown Remarks
4-5.7.8Cont'd
in accordance with Section 4-6, and theordinary combustibles, other than those usedfor packaging the liquids, are separated aminimum of 8 ft (2.4 m) horizontally, byaisles or open racks, from the liquids instorage.
4-5.7.9 Empty or idle combustible pallet storage shallbe limite$ to a maximum pile size of 2500 sqft (232 m ) and to a maximum storage height of6 ft (1.8 m). Idle pallet storage shall beseparated from liquids by at least 8 ft(2.4 m) wide aisles. However, pallet storagein accordance with NFPA 231, "Standard forGeneral Storage," shall be acceptable.
-p~.( l
4-5.7.10 Containers in piles shall be separated bypallets or dunnage to provide stability and toprevent excessive stress on container walls.
>Portable tanks stored over one tier high shallbe designed to nest securely, without dunnage.(See NFPA 386, "Standard for Portable ShippingTanks for Flammable and Combustible Liquids,"for information on portable tank design.)Materials handling equipment shall be suitableto handle containers and tanks safety at theupper tier level.
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<r=-4lg Pcs /is~~ e <cc.sxc~W~P c sg ~~ + g<c4
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NFPA 30 - 1987FLAMMABLE AND COMBUSTIBLE LIQUIDS CODE
CODE COMPLIANCE WALKDOWN CHECKLIST
CodeSection
No. Code Section Walkdown Remarks
4-5.7.11 No container or portable tank shall be storedcloser than 36 in. (0.90 m) to the nearestbeam, chord, girder, or other roof member inan unprotected warehouse.
~l$ I
4-5.7.12 Solid pile and palletized storage shall bearranged so that piles are separated from eachother by at least 4 ft (1.2 m). Aisles shallbe provided so that no container or tank ismore than 12 ft (3.6 m) from an aisle. Wherestorage on racks exists as permitted in thisCode, a minimum 4 ft (1.2 m) wide aisle shallbe provided between adjacent rows of racks andany adjacent storage of liquids. Main aislesshall be a minimum of 8 ft (2 .4 m) wide, andaccess shall be maintained to all doorsrequired for egress.
4-5.7.13 Mixed Storage. When two or more classes ofliquids are stored in a single pile, themaximum quantity permitted in that pile shallbe the smallest of the two or more separatemaximum quantities and the heights of storagepermitted in that pile shall be the least ofthe two or more separate heights as given inTables 4-4.2.7 or 4-6.1(a), as applicable.
NFPA 3 - 1987FLAMMABLE AND COMBUSTIBLE LIQUIDS CODE
CODE COMPLIANCE WALKDOWN CHECKLIST
CodeSection
No. Code Section Walkdown Remarks
4-5.7.13Cont'd
When two or more classes of liquids are storedin the same racks as permitted in this Code,the maximum height of storage permitted shallbe the least of the two or more separateheights given in Table 4.6.1(b).
4-6 Protection Requirements for Protected Storageof Liquids
'l i>)m
4-6.1 Containers and portable tanks storingflammable and combustible liquids may bestored in the quantities and arrangementsspecified in Tables 4-6.1(a) and 4-6.1(b),provided the storage is protected inaccordance with 4-6.2 and 4-6.5, asapplicable.
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4-6.1.1 Other quantities and arrangements may be usedwhere suitably protected and approved by theauthority having jurisdiction.
4-6.2 Where automatic sprinklers are used, theyshall be installed in accordance with NFPA 13,"Standard for the Installation of SprinklerSystems," and approved by the authority ha~ingjurisdiction. (For additional information,see Appendix D.)
NFPA 3 - 1987FLAMMABLE AND COMBUSTIBLE LIQUIDS CODE
CODE COMPLIANCE WAIKDOWN CHECKLIST
CodeSection
No. Code Section Walkdown Remarks
4-6.2.1 Other systems such as automatic foam-watersystems, automatic water-spray systems, orother combinations of systems may beconsidered acceptable if approved by theauthority having jurisdiction. (Foradditional information, see Appendix D.)
4-6.3 Racks storing Class I or Class II liquidsshall be either single-row or double-row asdescribed in NFPA 231C, "Standard for RackStorage of Materials."
4-6.4 Ordinary combustibles other than those usedfor packaging the liquids shall not be storedin the same rack section as liquids, and shallbe separated a minimum of 8 ft (2.4 m)horizontally, by aisles or open racks, fromliquids stored in racks.
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C qC
4-6.5 In-rack sprinklers shall be installed inaccordance with the provisions of NFPA 231C,"Standard for Rack Storage of Materials,"except as modified by 4-6.2. Alternate linesof in-rack sprinklers shall be staggered.Multiple levels of in-rack sprinkler headsshall be provided with water shields unlessotherwise separated by horizontal barriers, orunless the sprinkler heads are listed for suchinstallations.
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NFPA 3 - 1987FLAMMABLE AND COMBUSTIBLE LIQUIDS CODE
CODE COMPLIANCE WALKDOWN CHECKLIST
CodeSection
No. Code Section Walkdown Remarks
4-7 Fire Control
4-7.1 Suitable fire extinguishers or preconnectedhose lines, either 1 1/2 in. (3.8 cm) linedor 1 in. (2.5 cm) hard rubber, shall beprovided where liquids are stored. Where1 1/2 in. (3.8 cm) fire hose is used, it shallbe installed in accordance with NFPA 14,"Standard for the Installation of Standpipeand Hose Systems."
(~p+,r~a tie~.hi+s ~R. I (
a t. ~ i ~
4-7.1.1
4-7.1.2
At least one portable fire extinguisher havinga rating of not less than 20-B shall belocated outside of, but not more than 10 ft(3 m) from, the door opening into any separateinside storage area.
e
At least one portable fire extinguisher havinga rating of not less than 20-B shall belocated not less than 10 ft (3 m), nor morethan 50 ft (15 m), from any Class I or ClassII liquid storage area located outside of aseparate inside storage area.
4-7.1.3 In protected general purpose and liquid ware-houses, hand hose lines shall be provided insufficient number to reach all liquid storageareas.
~ /
NFPA 30 - 1987FLAMMABLE AND COMBUSTIBLE LIQUIDS CODE
CODE COMPLIANCE WALKDOWN CHECKLIST
CodeSection
No. Code Section Walkdown Remarks
4-7.1.4 The water supply shall be sufficient to meetthe fixed fire protection demand, plus a totalof at least 500 gal (1892 L) per minute forinside and outside hose lines. (See C-4-6.2.)
4-7.2 Control of Ignition Sources. Precautionsshall be taken to prevent the ignition offlammable vapors. Sources of ignition includebut are not limited to: open flames;lightning; smoking; cutting and welding; hotsurfaces; frictional heat; static, electrical,and mechanical sparks; spontaneous ignition,including heat-producing chemical reactions;and radiant heat.
4-7.3 Dispensing of Class I and Class II liquids ingeneral-purpose or liquid warehouses shall notbe permitted unless the dispensing area issuitably cut off from other ordinarycombustible or liquid storage areas, asspecified in Section 4-4, and otherwiseconforms with the applicable provisions ofSection 4-4.
~ I
4-7.4 Materials with a water reacticity degree of 2or higher, as outlined in NFPA 704, shall notbe stored in the same area with other liquids.
4-8 Outdoor Storage
NFPA 30 - 1987FLAMMABLE AND COMBUSTIBLE LIQUIDS CODE
CODE COMPLIANCE WALKDOWN CHECKLIST
CodeSection
No. Code Section Walkdown Remarks
Outdoor storage of liquids in containers andportable tanks shall be in accordance withTable 4-8, as qualified by 4-8.1.1 through4-8.1.4 and 4-8.2, 4-8.3, and 4-8.4.
When two or more classes of materials arestored in a single pile, the maximum gallonagein that pile shall be the smallest of the twoor more separate gallonages.
—4-8.1.2 No container or portable tank in a pile shallbe more than 200 ft (60 m) from a 12 ft(3.6 m) wide access way to permit approach offire control apparatus under all weatherconditions.
4-8 '.3 The distances listed in Table 4-8 apply toproperties that have protection for exposuresas defined. If there are exposures, and suchprotection for exposures does not exist, thedistances in column 4 shall be doubled.
4-8.1.4 When total quantity stored does not exceed 50percent of maximum per pile, the distances incolumns 4 and 5 may be reduced 50 percent, butto not less than 3 ft (0.90 m).
I ~
Ig
NFPA - 1987FLAMMABLE AND COMBUSTIBLE LIQUIDS CODE
CODE COMPLIANCE WALKDOWN CHECKLIST
CodeSection
No. Code Section Walkdown Remarks
4-8.2 A maximum of 1,100 gal (4163 L) of liquids inclosed containers and portable tanks may bestored adjacent to a building located on thesame premises and under the same managementprovided that:
(a) The building is limited to a one-storybuilding of fire-resistive or noncombustibleconstruction and is devoted principally to thestorage and handling of liquids, or
(b) The building has an exterior wall with afire-resistance rating of not less than 2 hrand having no opening to above grade areaswithin 10 ft (3 m) horizontally of suchstorage and no openings to below grade areaswithin 50 ft (15 m) horizontally of suchstorage.
4-8.2.1 The quantity of liquids stored adjacent to abuilding protected in accordance with 4-8.2(b)may exceed that permitted in 4-8.2, providedthe maximum quantity per pile does not exceed1,100 gal (4163 L) and each pile is separatedby a 10 ft (3 m) minimum clear space alongthe common wall.
NFPA 3 - 1987FLAl1MABLE AND COMBUSTIBLE LIQUIDS CODE
CODE COMPLIANCE WALKDOWN CHECKLIST
CodeSection
No. Code Section Walkdown Remarks
4-8.2.2 Where the quantity stored exceeds the 1,100gal (4163 L) permitted adjacent to thebuilding given in 4-8.2(a), or the provisionsof 4-8.2(b) cannot be met, a minimum distancein accordance with column 4 of Table 4-8 shallbe maintained between buildings and thenearest container or portable tank.
4-8.3 The storage area shall be graded in a mannerto divert possible spills away from buildingsor other exposures or shall be surrounded by acurb at least 6 in. (15 cm) high. When curbsare used, provisions shall be made fordraining of accumulations of ground or rainwater or spills of liquids. Drains shalltermi'nate at a safe location and shall beaccessible to operation under fire conditions.
4-8.4 The storage area shall be protected againsttampering or trespassers where necessary andshall be kept free of weeds, debris, and othercombustible materials not necessary to thestorage.
CHAPTER 5 OPERATIONS(See Appendix F for Cross-Reference Tables)
5-1 Scope
NFPA 30 - 1987FLAtNABLE AND COMBUSTIBLE LIQUIDS CODE
CODE COMPLIANCE WALKDOWN CHECKLIST
CodeSection
No. Code Section Walkdown Remarks
This chapter applies to operations involvingthe use or handling of liquids either as aprincipal or incidental activity, except ascovered elsewhere in this Code or in otherNFPA Standards.
5-1.2 The provisions of this chapter relate to thecontrol of hazards of fire involving liquids.These provisions may not provide adequateprotection for operations involving hazardousmaterials or chemical reactions nor do theyconsider health hazards resulting fromexposure to such materials.
5-2 GeneralLiquid processing operations shall be locatedand operated so that they do not constitute asignificant fire or explosion hazard to life,to property of others, or to importantbuildings or facilities within the same plant.Specific requirements are dependent on theinherent risk in the operations themselves,including the liquids being processed,operating temperatures and pressures, and thecapability to control any liquid or vaporreleases or fire incidents that might occur.The interrelationship of the many factorsinvolved must be based on good engineering andmanagement practices to establish suitablephysical and operating requirements. (See5-5.1.3.)
~ ( r f ~
NFPA 30 - 1987FLAMMABLE AND COMBUSTIBLE LIQUIDS CODE
CODE COMPLIANCE WALKDOWN CHECKLIST
CodeSection
No. Code Section Walkdown Remarks
5.3
5-3.1
5-3.1.1
Facility Design
Location
The minimum distance of a processing vessel toadjoining property or to the nearest importantbuilding on the same property shall be basedon the stability of the liquid and vesselcapacity and shall be in accordance with Table5-3.1.1, except as modified in 5-3.1 ~ 2.
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5-3.1.2 Where process vessels are located in abuilding and the exterior wall facing theexposure (line of adjoining property that canbe built upon or nearest important building onthe same property) is greater than 25 ft(7.6 m) from the exposure and is a blank wallhaving a fire-resistance rating of not lessthan 2 hrs, any greater distances required inTable 5-3.1.1 may be waived. Where a blankwall having a fire-resistance rating of notless than 4 hrs is provided, distance require-ments may be waived. In addition, when ClassIA or unstable liquids are handled, the wallshall have explosion resistance in accordancewith good engineering practice. (See 5-3.2.7relative to explosion relief of other walls ofthis building.)
NFPA 30 - 1987FLAMMABLE AND COMBUSTIBLE LIQUIDS CODE
CODE COMPLIANCE WALKDOWN CHECKLIST
0
CodeSection
No. Code Section Walkdown Remarks
5-3.1.3 Other liquid processing equipment, such aspumps, heaters, filters, exchangers, etc.,shall not be located closer than 25 ft (7.6 m)to property lines where the adjoining propertyis or can be built upon, or to the nearestimportant building on the same property thatis not an integral part of the process. Thisspacing requirement may be waived whereexposures are protected as outlined in 5-3.1.2.
~7( ) sl I ~
II
NOTE: Equipment operated at pressures over1000 psig (7000 kPa) may require greaterspacing.
5-3.1.4 Processing equipment in which unstable liquidsare handled shall be separated from unrelatedplant facilities that, use or handle liquids byeither 25 ft (7.6 m) clear spacing or a wallhaving a fire-resistance rating of not lessthan 2 hrs. The wall shall also haveexplosion resistance in accordance with goodengineering practice.
5-3.1.5 Each process unit or building containingliquid-processing equipment shall beaccessible from at least one side for firefighting and fire control.
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NFPA 3 - 1987FLAMMABLE AND COMBUSTIBLE LIQUIDS CODE
CODE COMPLIANCE WALKDOWN CHECKLIST
CodeSection
No. Code Section Walkdown Remarks
5-3.2
5-3.2.1
Construction
Processing buildings or structures shall be offire-resistive or noncombustible construction,except that combustible construction may beused when automatic sprinklers or equivalentprotection is provided, subject to approval ofthe authority having jurisdiction. (See NFPA220, "Standard on Types of BuildingConstruction.")
5-3.2.2 Where walls are required for separation ofprocessing operations from other occupanciesor property lines, they shall have a fire-resistance rating of at least 2 hrs. Inaddition, when Class IA or unstable liquidsare being stored or processed, the separatingwall shall have explosion resistance inaccordance with good engineering practice.(See 5-3.2.7 relative to explosion relief ofother walls of this building or area.)
5-3.2.3 Class I liquids shall not be handled or usedin basements. Where Class I liquids arehandled or used above grade within buildingswith basements or closed pits into whichflammable vapors may travel, such below gradeareas shall be provided with mechanical
NFPA 30 - 1987FLAt1MABLE AND COMBUSTIBLE LIQUIDS CODE
CODE COMPLIANCE WALKDOWN CHECKLIST
CodeSection
No. Code Section Walkdown Remarks
5-3.2.3Cont'd
5-3.2.4
5-3.2.5
ventilation designed to prevent the accumula-tion of flammable vapors. Means shall beprovided to prevent liquid spills from runninginto basements.
Provision for smoke and heat venting~madesirable to assist access for fire fighting.NFPA 204M, "Guide for Smoke and Heat Venting,"provides information on this subject.
Areas shall have exit facilities arranged toprevent occupants from being trapped in theevent of fire. NFPA 101, "Code for Safetyto Life from Fire in Buildings andStructures," provides information on thedesign of exit facilities. Exits shall notbe exposed by the drainage facilitiesdescribed in 5-3.4.
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X
5-3.2.6 Adequate aisles shall be maintained for un-obstructed movement of personnel and fireprotection equipment.
5-3.2.7 Areas where Class IA or unstable liquids areprocessed shall have explosion venting throughone or more of the following methods:(a) open air construction; (b) lightweight
NFPA 30 - 1987FLAMMABLE AND COMBUSTIBLE LIQUIDS CODE
CODE COMPLIANCE WALKDOWN CHECKLIST
CodeSection
No. Code Section Walkdown Remarks
4-5.7. 11 No container or portable tank shall be storedcloser than 36 in. (0.90 m) to the nearestbeam, chord, girder, or other roof member inan unprotected warehouse.
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4-5.7.12 Solid pile and palletized storage shall bearranged so that piles are separated from eachother by at least 4 ft (1.2 m). Aisles
shall'e
provided so that no container or tank ismore than 12 ft (3.6 m) from an aisle. Wherestorage on racks exists as permitted in thisCode, a minimum 4 ft (1.2 m) wide aisle shallbe provided between adjacent rows of racks andany adjacent storage of liquids. Main aislesshall be a minimum of 8 ft (2.4 m) wide, andaccess shall be maintained to all doorsrequired for egress.
4-5.7.13 Mixed Storage. When two or more classes ofliquids are stored in a single pile, themaximum quantity permitted in that pile shallbe the smallest of the two or more separatemaximum quantities and the heights of storagepermitted in that pile shall be the least ofthe two or more separate heights as given inTables 4-4.2.7 or 4-6.1(a), as applicable.
NFPA 30 - 1987FLAMMABLE AND COMBUSTIBLE LIQUIDS CODE
CODE COMPLIANCE WALKDOWN CHECKLIST
CodeSection
No. Code Section Walkdown Remarks
4-5.7.13Cont'd
When two or more classes of liquids are storedin the same racks as permitted in this Code,the maximum height of storage permitted shallbe the least of the two or more separateheights given in Table 4.6.1(b).
4-6 Protection Requirements for Protected Storageof Liquids
4-6.1
4-6.1.1
Containers and portable tanks storingflammable and combustible liquids may bestored in the quantities and arrangementsspecified in Tables 4-6.1(a) and 4-6.1(b),provided the storage is protected inaccordance with 4-6.2 and 4-6.5, asapplicable.
Other quantities and arrangements may be usedwhere suitably protected and approved by theauthority having jurisdiction.
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4-6.2 Where automatic sprinklers are used, theyshall be installed in accordance with NFPA 13,"Standard for the Installation of SprinklerSystems," and approved by the authority havingjurisdiction. (For additional information,see Appendix D.)
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4-6.2.1 Other systems such as automatic foam-watersystems, automatic water-spray systems, orother combinations of systems may beconsidered acceptable if approved by theauthority having jurisdiction. (Foradditional information, see Appendix D.)
4-6.3 Racks storing Class I or Class II liquidsshall be either single-row or double-row asdescribed in NFPA 231C, "Standard for RackStorage of Materials."
4-6.4 Ordinary combustibles other than those usedfor packaging the liquids shall not be storedin. the same rack section as liquids, and shallbe separated a minimum of 8 ft (2.4 m)horizontally, by aisles or open racks, fromliquids stored in racks.
4-6.5 In-rack sprinklers shall be installed inaccordance with the provisions of NFPA 231C,"Standard for Rack Storage of Materials,"except as modified by 4-6.2. Alternate linesof in-rack sprinklers shall be staggered.Multiple levels of in-rack sprinkler headsshall be provided with water shields unlessotherwise separated by horizontal barriers, orunless the sprinkler heads are listed for suchinstallations.
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NFPA 30 - 1987FLAMMABLE AND COMBUSTIBLE LIQUIDS CODE
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4-7 Fire Control
4-7.1
4-7.1.1
Suitable fire extinguishers or preconnectedhose lines, either 1 1/2 in. (3.8 cm) linedor 1 in. (2.5 cm) hard rubber, shall beprovided where liquids are stored. Where1 1/2 in. (3.8 cm) fire hose is used, it shallbe installed in accordance with NFPA 14,"Standard for the Installation of Standpipeand Hose Systems."
At least one portable fire extinguisher havinga rating of not less than 20-B shall belocated outside of, but not more than 10 ft(3 m) from, the door opening into any separateinside storage area.
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4-7.1.2
4-7.1.3
At lease one portable fire extinguisher havinga rating of not less than 20-B shall belocated not less than 10 ft (3 m), nor morethan 50 ft (15 m), from any Class I or ClassII liquid storage area located outside of aseparate inside storage area.
In protected general purpose and liquid ware-houses, hand hose lines shall be provided insufficient number to reach all liquid storageareas.
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4-7.1.4 The water supply shall be sufficient to meetthe fixed fire protection demand, plus a totalof at least 500 gal (1892 L) per minute forinside and outside hose lines. (See C-4-6.2.)
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4-7.2 Control of'Ignition Sources. Precautionsshall be taken to prevent the ignition offlammable vapors. Sources of ignition includebut are not limited to: open flames;lightning; smoking; cutting and welding; hotsurfaces; frictional heat; static, electrical,and mechanical sparks; spontaneous ignition,including heat-producing chemical reactions;and radiant heat.
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4-7.3 Dispensing of Class I and Class II liquids ingeneral-purpose or liquid warehouses shall notbe permitted unless the dispensing area issuitably cut off from other ordinarycombustible or liquid storage areas, asspecified in Section 4-4, and otherwiseconforms with the applicable provisions ofSection 4-4.
4-7.4
4-8
Materials with a water reacticity degree of 2or higher, as outlined in NFPA 704, shall notbe stored in the same area with other liquids.
Outdoor Storage
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4-&.l Outdoor storage of liquids ip containers andportable tanks shall be in accordance withTable 4-8, as qualified by 4-8.1.1 through4-8.1.4 and 4-8.2, 4-8.3, and 4-8.4.
4-8.1.1
4-8.1.2
When two or more classes of materials arestored in a single pile, the maximum gallonagein that pile shall be the smallest of the twoor more separate gallonages.
No container or portable tank in a pile shallbe more than 200 ft (60 m) from a 12 ft(3.6 m) wide access way to permit approach offire control apparatus under all weatherconditions.
llaw
4-8.1.3 The distances listed in Table 4-8 apply toproperties that have protection for exposuresas defined. If there are exposures, and suchprotection for exposures does not exist, thedistances in column 4 shall be doubled.
4-8.1.4 When total quantity stored does not exceed 50percent of maximum per pile, the distances incolumns 4 and 5 may be reduced 50 percent, butto not less than 3 ft (0.90 m).
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4-8.2 A maximum of 1,100 gal (4163 L) of liquids inclosed containers and portable tanks may bestored adjacent to a building located on thesame premises and under the same managementprovided that:
(a) The building is limited to a one-storybuilding of fire-resistive or noncombustibleconstruction and is devoted principally to thestorage and handling of liquids, or
(b) The building has an exterior wall with afire-resistance rating of not less than 2 hrand having no opening to above grade areaswithin 10 ft (3 m) horizontally of suchstorage and no openings to below grade areaswithin 50 ft (15 m) horizontally of suchstorage.
i~le
4-8.2.1 The quantity of liquids stored adjacent to abuilding protected in accordance with 4-&.2(b)may exceed that permitted in 4-8.2, providedthe maximum quantity per pile does not exceed1,100 gal (4163 L) and each pile is separatedby a 10 ft (3 m) minimum clear space alongthe common wall.
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4-8.2.2 Where the quantity stored exceeds the 1,100gal (4163 L) permitted adjacent to thebuilding given in 4-8.2(a), or the provisionsof 4-8.2(b) cannot be met, a minimum distancein accordance with column 4 of Table 4-8 shallbe maintained between buildings and thenearest container or portable tank.
4-8.3 The storage area shall be graded in a mannerto divert possible spills away from buildingsor other exposures or shall be surrounded by acurb at least 6 in. (15 cm) high. When curbsare used, provisions shall be made fordraining of accumulations of ground or rainwater or spills of liquids. Drains shallterminate at a safe location and shall beaccessible to operation under fire conditions.
4-8.4 The storage area shall be protected againsttampering or trespassers where necessary andshall be kept free of weeds, debris, and othercombustible materials not necessary to thestorage.
CHAPTER 5 OPERATIONS(See Appendix F for Cross-Reference Tables)
5-1 Scope
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5-1.1 This chapter applies to operations involvingthe use or handling of liquids either as aprincipal or incidental activity, except ascovered elsewhere in this Code or in otherNFPA Standards.
5-1. 2 The provisions of this chapter relate to thecontrol of hazards of fire involving liquids.These provisions may not provide adequateprotection for operations involving hazardousmaterials or chemical reactions nor do theyconsider health hazards resulting fromexposure to such materials.
5-2 GeneralLiquid processing operations shall be locatedand operated so that they do not constitute asignificant fire or explosion hazard to life,to property of others, or to importantbuildings or facilities within the same plant.Specific requirements are dependent on theinherent risk in the operations themselves,including the liquids being prqcessed,operating temperatures and pressures, and thecapability to control any liquid or vaporreleases or fire incidents that might occur.The interrelationship of the many factorsinvolved must be based on good engineering andmanagement practices to establish suitablephysical and operating requirements. (See5-5.1.3.)
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5.3
5-3.1
5-3.1.1
Facility Design
Location
The minimum distance of a processing vessel toadjoining property or to the nearest importantbuilding on the same property shall be basedon the stability of the liquid and vesselcapacity and shall be in accordance with Table5-3.1.1, except as modified in 5-3.1.2.
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5-3.1.2 Where process vessels are located in abuilding and the exterior wall facing theexposure (line of adjoining property that canbe built upon or nearest important building onthe same property) is greater than 25 ft(7.6 m) from the exposure and is a blank wallhaving a fire-resistance rating of not lessthan 2 hrs, any greater distances required inTable 5-3.1.1 may be waived. Where a blankwall having a fire-resistance rating of notless than 4 hrs is provided, distance require-ments may be waived. In addition, when ClassIA or unstable liquids are handled, the wallshall have explosion resistance in accordancewith good engineering practice. (See 5-3.2.7relative to explosion relief of other walls ofthis building.)
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5-3.1.3 Other liquid processing equipment, such aspumps, heaters, filters, exchangers, etc.,shall not be located closer than 25 ft (7.6 m)to property lines where the adjoining propertyis or can be built upon, or to the nearestimportant building on the same property thatis not an integral part of the process. Thisspacing requirement may be waived whereexposures are protected as outlined in 5-3.1.2.
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NOTE: Equipment operated at pressures over1000 psig (7000 kPa) may require greaterspacing.
5-3.1.4 Processing equipment in which unstable liquidsare handled shall be separated from unrelatedplant facilities that use or handle liquids byeither 25 ft (7.6 m) clear spacing or a wallhaving a fire-resistance rating of not lessthan 2 hrs. The wall shall also haveexplosion resistance in accordance with goodengineering practice.
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5-3.1.5 Each process unit or building containingliquid-processing equipment shall beaccessible from at least one side for firefighting and fire control.
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5-3.2 Construction
5-3.2.1 Processing buildings or structures shall be offire-resistive or noncombustible construction,except that combustible construction may beused when automatic sprinklers or equivalentprotection is provided, subject to approval ofthe authority having jurisdiction. (See NFPA220, "Standard on Types of BuildingConstruction.")
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5-3.2.2 Where walls are required for separation ofprocessing operations from other occupanciesor property lines, they shall have a fire-resistance rating of at least 2 hrs. Inaddition, when Class IA or unstable liquidsare being stored or processed, the separatingwall shall have explosion resistance inaccordance with good engineeriag practice.(See 5-3.2.7 relative to explosion relief ofother walls of this building or area.)
5-3.2.3 Class I liquids shall not be handled or usedin basements. Where Class I liquids arehandled or used above grade within buildingswith basements or closed pits into whichflammable vapors may travel, such below gradeareas shall be provided with mechanical
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5-3.2.3Cont'd
ventilation designed to prevent the accumula-tion of flammable vapors. Means shall beprovided to prevent liquid spills from runninginto basements.
5-3.2.4 Provision for smoke and heat venting may bedesirable to assist access for fire fighting.NFPA 204M, "Guide for Smoke and Heat Venting,"provides information on this sub)ect.
5-3.2.5 Areas shall have exit facilities arranged toprevent occupants from being trapped in theevent of fire. NFPA 101, "Code for Safetyto Life from Fire in Buildings andStructures," provides information on thedesign of exit facilities. Exits shall notbe exposed by the drainage facilitiesdescribed in 5-3.4.
5-3.2.6 Adequate aisles shall be maintained for un-obstructed movement of personnel -and fireprotection equipment.
5-3.2.7 Areas where Class IA or unstable liquids areprocessed shall have explosion venting throughone or more of the following methods:(a) open air construction; (b) lightweight
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walls and/or roof; (c) lightweight wall panelsand roof hatches; (d) windows of explosion-venting type. NFPA 68, "Guide for ExplosionVenting," provides information on this subject.
5-3.3
5-3.3.1
Ventilation
Enclosed processing areas holding or usingClass Ig liquids, or Class II or Class IIIliquids above their flash points, shall beventilated at a rate of not less than 1 cu jtper minute per sq ft (0.3 m ) per min per m )of solid floor area. This shall be accomp-lished by natural or mechanical ventilationwith discharge or exhaust to a safe locationoutside the building without recirculation.
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Exception: Recirculation is permitted where=it is monitored continuously using a fail-safesystem that is designed to automatically soundan alarm, stop recirculation, and provide fullexhaust to the outside in the event thatvapor-air mixtures in concentration over one-fourth of the lower flammable limit aredetected.
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Provision shall be made for introduction ofmake-up air in such a manner as to avoidshort-circuiting the ventilation. Ventilationshall be arranged to include all floor areasor pits where flammable vapors may collect.Where natural ventilation is inadequate,mechanical ventilation shall be provided andshall be kept in operation while flammableliquids are being handled. Local or spotventilation may be needed for the control ofspecial fire or health hazards. Suchventilation, if provided, can be utilized forup to 75 percent of the required ventilation.NFPA 91, "Standard for the Installation ofBlower and Exhaust Systems for Dust, Stock,and Vapor Removal or Conveying," and NFPA 90A,"Standard for the Installation of AirConditioning and Ventilating Systems," provideinformation on this subject.
5-3.3.2 Equipment used in a building. and the ventila-tion of the building shall be designed tolimit flammable vapor-air mixtures undernormal operating conditions to the interiorof equipment, and to not more than 5 ft(1.5 m) from equipment that exposes Class Iliquids to the air. Examples of suchequipment are dispensing stations, opencentrifuges, plate and frame filters, openvacuum filters, and surfaces of open equipment.
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5-3.4 Drainage
5-3.4.1 Emergency drainage systems shall be providedto direct flammable or combustible liquidleakage and fire protection water to a safelocation. This may require curbs, scuppers,or special drainage systems to control thespread of fire (see 2-2.3). Appendix A ofNFPA 15, "Standard for Water Spray FixedSystems for Fire Protection," providesinformation on this subject.
5-3.4.2 Emergency drainage systems, if connected topublic sewers or discharged into publicwaterways, shall be equipped with traps orseparators.
5-3.4.3 A facility shall be designed and operated toprevent the normal discharge of flammable orcombustible liquids to public waterways,public sewers, -or adjoining property.
5-3.5
5-3.5.1
Electrical Equipment
This section shall apply to areas where ClassI liquids are stored or handled and to areaswhere Class II or Class III liquids are storedor handled't a temperature above their flashpoints (see 1-1.3).
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5-3.5.2 All electrical equipment and wiring shall beof a type specified by, and installed inaccordance with, NFPA 70, "National ElectricalCode."
5-3.5.3 So far as it applies, Table 5-3.5.3 shall beused to delineate and classify areas for thepurpose of installation of electricalequipment under normal conditions. In theapplication of classified areas, a classifiedarea shall not extend beyond an unpiercedfloor, wall, roof, or other solid partition.The designation of classes and divisions isdefined in Chapter 5, Article 500, of NFPA 70,"National Electrical Code. (See NFPA 497A,"Recommended Practice for Classification ofClass I Hazardous (Classified) Locations forElectrical Installations in Chemical ProcessAreas," and 497M, Manual for Classification ofGases, Vapors, and Dusts for ElectricalEquipment in Hazardous (Classified)Locations," for guidance.)
5-3.5.4 The area classifications listed in Table5-3.5.3 are based on the premise that theinstallation meets the applicable requirementsof this code in all respects. Should this notbe the case, the authority having jurisdictionshall have the authority to classify theextent of the area.
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5-3.5.5 Where the provisions of 5-3.5.1, 5-3.5.2,5-3.5.3, and 5-3.5.4 require the installationof electrical equipment suitable for Class I,Division 1 or Division 2 locations, ordinaryelectrical equipment including switchgear maybe used if installed in a room or enclosurethat is maintained under positive pressurewith respect to the classified area. Ventila-tion make-up air shall not be..contaminated.NFPA 496, "Standard for Purged and PressurizedEnclosures for Electrical Equipment," providesdetails for these types of installations.
5-3.5.6 For marine terminals handling flammableliquids, Figure 5-3.5.6 shall be used as aminimum basis to delineate and classify areasfor the purpose of installation of electricalequipment.
5.4
5.4.1
5.4.1.1
Liquid Handling, Transfer, and Use
General
Class I liquids shall be kept in closed tanksor containers when not actually in use. ClassII and Class III liquids shall be kept. inclosed tanks or containers when ambient orprocess temperature is at or above their flashpoint.
5-4.1.2 Where liquids are used or handled, provisionsshall be made to promptly and safely dispose ofleakage or spills.
J (~ ~ chvl(~s ~M)5-4.1.3 Class I liquids shall not be used outside
closed systems where there are open flames orother ignition sources within the classifiedareas as set forth in Table 5-3.5.3.
5-4.1.4 Transferring liquids by means of pressurizingthe container with air is prohibited. Trans-ferring liquids by pressure of inert gas ispermitted only if controls, includingpressure-relief devices, are:provided to limitthe pressure so it cannot exceed the designpressure of the vessel, tank, container, andpiping system.
5-4.1.5 Positive displacement pumps shall be providedwith pressure relief discharging back to thetank, pump suction, or other suitablelocation, or shall be provided with interlocksto prevent overpressure.
5-4.1.6 Piping, valves, and fittings shall be inaccordance with Chapter 3, "Piping, Valves,and Fittings."
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5-4.1.7 Listed flexible connectors may be used wherevibration exists. Approved hose may be usedat transfer stations.
5-4.2 Equipment. Equipment shall be designed andarranged to prevent the unintentional escapeof liquids and vapors and to minimize thequantity escaping in the event of accidentalrelease.
5.4.3 Incidental Use of Liquids
5.4.3.1 This section shall be applicable where the useand handling of liquids is only incidental tothe principal business, such as automobileassembly, construction of electronicequipment, furniture manufacturing,'r othersimilar activities.
5.4.3.2 Class I and Class II liquids shall be drawnfrom or transferred into ~ vessels,containers, or portable tanks in the followingmanner only:
(a) from original shipping containers with acapacity of 5 gal (19 L) or less,
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(b) from safety cans,
(c) through a closed piping system,
(d} from portable tanks or containers bymeans of a device drawing through an openingin the top of the tank or container, or,
(e) by gravity through a listed self-closingvalve or self-closing faucet, or
(f) if hose is used in the transferoperation, it shall be equipped with a self-closing valve without a hold-open latch inaddition to the outlet valve. Only listed orapproved hose shall be used.
5-4.3.3 Except as provided in 5-4.3.4 and 5-4.3.5, allstorage shall comply with Chapter 4, "ContainerStorage."
~l,<~g)e Decl~~>
5-4.3.4 The quantity of liquid that may be locatedoutside of storage cabinets, inside storagerooms, cut-off rooms and attached buildings,general purpose warehouses, liquid warehouses,or other specific processing areas that are
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5-4.3.4Cont'd
cut off by at least a 2-hr fire-ratedseparation from the general plant area shallnot exceed the greater of the quantity ineither (a) or the sum of (b), (c), (d), and(e) below:
(a) A supply for one day, or
(b) 25 gal (95 L) of Class IA liquids incontainers,
(c) 120 gal (454 L) of Class IB, IC, II, orIII, liquids in containers,
(d) Two portable tanks each not exceeding 660gal (2498 L) of Class IB, IC, Class II, orClass IIIA liquids, and
(e) 20 portable tanks each not exceeding 660gal (2498 L) of Class IIIB liquids.
5-4.3.5 Where quantities or liquids in excess of thelimits in 5-4.3.4 are necessary, storage shallbe in tanks, which shall comply with theapplicable requirements of Chapter 2, "TankStorage," and Section 5.3, 5-4.1, and 5-4.2.
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5-4.3.6 Areas in which liquids are transferred fromone tank or container to another containershall be separated from other operations thatmight represent an ignition source by distanceor by fixe-resistant construction. Drainageor other means shall be provided to controlspills. Natural or mechanical ventilationshall be provided in accordance with 5-3.3,"Ventilation." NFPA 91, "Standard for theInstallation of Blower and Exhaust Systems forDust, Stock, and Vapor Removal or Conveying,"provides information on the design andinstallation of mechanical ventilation.
f~.~+i(c +ice M
5-4.4 Loading and Unloading Operations.This chapter is not applicable to the DonaldC. Cook Nuclear Plant.
5-4.4.2 Wharves.This chapter is not applicable to the DonaldC. Cook Nuclear Plant.
5-5
5-5.1
Fire Prevention and Control
General
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5-5.1.1 This section covers the commonly recognizedmanagement control systems and methods used toprevent or minimize the loss from fire orexplosion in liquid processing facilities.
NOTE: Other recognized factors of fireprevention and control, involving construction,location, separation, etc., are coveredelsewhere in this chapter.
5-5.1.2 The wide range in size, design, and locationof liquid processing facilities precludes theinclusion of detailed fire prevention andcontrol systems and methods applicable to allsuch facilities. The authority havingjurisdiction may be consulted on specificcases, where applicable; otherwise, qualifiedengineering judgment shall be exercised per5-5.1.3.
6) )5
5-5.1.3 The extent of fire prevention and control(provided for the liquid-processing facility
shall be determined by an engineeringevaluation of the operation, followed by theapplication of sound fire protection andprocess engineering principles. Theevaluation shall include, but not be limitedto:
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5-5.1.3Cont'
(a) analysis of fire and explosion hazards ofthe liquid operations,
(b) analysis of hazardous materials,hazardous chemicals, or hazardous reactions inthe operations and the safeguards taken tocontrol such materials, chemicals, orreactions,
(c) analysis of facility design requirementsin Section 5-3 of this chapter,
(d) analysis of the liquid handling,transfer, and use requirements in Section 5-4of this chapter,
(e) analysis of local conditions, such asexposure to and from adjacent properties,flood potential, or earthquake potential,
(f) consideration of fire department ormutual aid response.
5-5.2 Control of Ignition Sources
5-5.2.1 Precautions shall be taken to prevent theignition of flammable vapors. Sources ofignition include, but are not limited to:
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(a) open flames(b) lightning(c) hot surfaces(d) radiant heat(e) smoking(f) cutting and welding(g) spontaneous ignition(h) frictional heat or sparks(i) static electricity(j) electrical sparks(k) stray currents(1) ovens, furnaces, and heating equipment
5-5.2.2 Smoking shall be permitted only in designatedand properly identified areas.
5-5.2.3 Welding, cutting, and similar spark-producingoperations shall not be permitted in areascontaining flammable liquids until a writtenpermit authorizing such work has been issued.The permit shall be issued by a person inauthority following his/her inspection of thearea to assure that proper precautions havebeen taken and will be followed until the jobis completed. (See NFPA 51B, "Standard forFire Prevention in Use of Cutting and WeldingProcesses.")
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5-5.2.4 Static Electricity. All equipment such astanks, machinery, and piping where anignitable mixture may be present shall bebonded or connected to a ground. The bond orground or both shall be physically applied orshall be inherently present by the nature ofthe installation. Electrically isolatedsections of metallic piping or equipment shallbe bonded to the other portions of the systemor individually grounded to prevent hazardousaccumulations of static electricity. NFPA 77,"Recommended Practice on Static Electricity,"provides information on this subject.
5-5.3 Inspection and Maintenance
5-5.3.1 All fire protection equipment shall beproperly maintained and periodic inspectionsand tests shall be done in accordance with
,both standard practice and equipmentmanufacturer's recommendations.
5-5.3.2 Maintenance and operating practices shallcontrol leakage and prevent spillage offlammable liquids.
5-5.3.3 Combustible waste material and residues inoperating areas shall be kept to a minimum,stored in covered metal containers, anddisposed of daily.
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5-5.3.4 Ground areas around facilities where liquidsare stored, handled, or used shall be keptfree of weeds, trash, or other unnecessarycombustible materials.
5-5.3.5 Aisles established for movement of personnelshall be maintained clear of obstruction topermit orderly evacuation and ready access formanual fire fighting activities.
5-5.4
5.5.4.1
Emergency Planning and Training
An emergency action plan, consistent with theavailable equipment and personnel, shall beestablished to respond to fire or otheremergencies. This plan shall include thefollowing:
(a) Procedures to be used in case of fire,such as sounding the alarm, notifying the firedepartment, evacuating personnel, andcontrolling and extinguishing the fire.
(b) Appointment and training of persons tocarry out fire safety duties.
(c) Maintenance of fire protection equipment.
(d) Holding fire drills.
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(e) Shutdown or isolation of equipment toreduce the escape of liquid.
(f) Alternate measures for the safety ofoccupants while any fire protection equipmentis shut down.
5-5.4.2 Personnel responsible for the use and operationof fire protection equipment shall be trainedin the use of that equipment. Refreshertraining shall be conducted at least annually.
5-5.4.3 Planning of effective fire control measuresshall be coordinated with local emergencyresponse agencies.
5-5.4.4 Procedures shall be established to provide forsafe shutdown of operations under emergencyconditions. Provisions shall be made forperiodic training, inspection, and testing ofassociated alarms, interlocks, and controls.
5-5.4.5 The emergency procedure shall be kept readilyavailable in an operating area and updatedregularly.
NFPA 30 - 1987FLPJMABLE AND COMBUSTIBLE LIQUIDS CODE
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CodeSection
No. Code Section Walkdown Remarks
5-5.4.6
5-5.5
Where premises are likely to be unattended forconsiderable periods of time, a summary of theemergency plan shall be posted or located in astrategic and accessible location.
Detection and Alarm 7ir(g5-5.5.1 An approved means for prompt notification of
fire or emergency to those within the plantand to the available public or mutual aid firedepartment shall be provided.
5-5.5.2 Those areas, including buildings, where apotential exists for a flammable liquid spill,shall be monitored as appropriate. Somemethods may include:
(a) Personnel observation or'atrol;
(b) Process monitoring equipment that wouldindicate a spill or leak may have occurred;
(c) Provision of gas detectors tocontinuously monitor the area where facilitiesare unattended.
5-5.6 Portable Fire-Control Equipment
NFPA 30 - 1987FLAMt1ABLE AND COMBUSTIBLE LIQUIDS CODE
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CodeSection
No. Code Section Walkdown Remarks
5-5.6.1 Listed portable- fire extinguishers shall beprovided for facilities in such quantities,sizes, and types as may be needed for thespecial hazards 'of operation and storage asdetermined per 5-5.1.3. NFPA 10, "Standardfor Portable Extinguishers," providesinformation on the suitability of varioustypes of extinguishers.
5-5.6.2 When the need is indicated per 5-5.1.3,water may be utilized through standpipe andhose systems (see NFPA 14, "Standard for theInstallation of Standpipe and Hose Systems" ),or through hose connections from sprinklersystems using combination spray and straightsteam nozzles to permit effective fire control(see NFPA 13, "Standard for the Installationof Sprinkler Systems" ).
5-5.6.3 When the need is indicated per 5-5.1.3, mobilefoam apparatus shall be provided. NFPA llC,"Standard for Mobile Foam Apparatus," providesinformation on the subject.
5-5.6.4 Automotive and trailer-mounted fire apparatus,where determined necessary, shall not be usedfor any purpose other than fire fighting.
NFPA 30 - 1987FLAMMABLE AND COMBUSTIBLE LIQUIDS CODE
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CodeSection
No. Code Section Walkdown Remarks
5-5.7
5-5.7.1
Fixed Fire Control Equipment
A reliable water supply or other suitable firecontrol agent shall be available in pressureand quantity to meet the fire demandsindicated by the special hazards of operation,storage, or exposure as may be determined by5-5.1.3.
5-5 '.2 Hydrants, with or without fixed monitornozzles, shall be provided in accordance withaccepted practice. The number and placementwill depend on the hazard of- the liquid-processing facility, storage, or exposure asmay be determined by 5-5.3.1. See NFPA 24,"Standard for the Installation of Private FireService Mains and Their Appurtenances," forinformation on this subject.
5-5.7.3 Where the need is indicated by the hazards ofliquid processing, storage, or exposure asdetermined by 5-5.1.3, fixed protection may berequired-utilizing approved sprinkler systems,water spray systems, deluge systems, fireresistive materials, or a combination ofthese. See NFPA 13, "Standard for theInstallation of Sprinkler Systems," and NFPA15, "Standard for Water Spray Fixed Systemsfor Fire Protection," for information on thesesubj ect.
NFPA 30 - 1987FLAMMABLE AND COMBUSTIBLE LIQUIDS CODE
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CodeSection
No. Code Section Walkdown Remarks
5-5.7.4 The following fire control systems may beappropriate for the protection of specifichazards as determined per 5-5.1.3. Ifprovided, such systems shall be designed,installed, and maintained in accordance withthe following NFPA standards:
NFPA 3 - 1987FLAMMABLE AND COMBUSTIBLE LIQUIDS CODE
CODE COMPLIANCE WALKDOWN CHECKLIST
CodeSection
No. Code Section Walkdown Remarks
Chapter 6 Referenced PublicationsThis chapter is for information purposes only.Therefore, it is removed from this report.
MISCELLANEOUS OIL STORAGE ROOM
WALKDOWN CHECKLIST
CONDUCTED BY: P.J. RUSSELL
NFPA 30 - 1987FLAMMABLE AND COMBUSTIBLE LIQUIDS CODE
CODE COMPLIANCE WALKDOWN CHECKLIST
L -ZP4a," lncx4o~Cg = ( <v ~oar y~>f-) Qy H~DomhlD/g = ~z- +plica.l.J~v = <a~PA ~~ccQ = PJc u C'omp/gAWC'e
CodeSection
No. Code Section Walkdown Remarks
CHAPTER 1 GENERAL PROVISIONS
Scope and Application
1-1.1 This code applies to all flammable andcombustible liquids except those that aresolid at 100 F (37.8 C) or above.
1-1.2 Requirements for the safe storage and use ofthe great variety of flammable and combustibleliquids commonly available depend primarily ontheir fire characteristics, particularly theflash point, which is the basis for theseveral classifications of liquids as defineQin Section 1-2. It should be noted that theclassification of a liquid can be changed bycontamination. For example, filling a ClassII liquid into a tank which last contained aClass I liquid can alter its classification,
, as can exposing a Class II liquid to thevapors of a Class I liquid via an inter-connecting vapor line (see 2-2.6.4 and2-3.5.6). Care shal'. be exercised in suchcases to apply the requirements appropriateto the actual classification.
NFPA 30 - 1987FLAtMABLE AND COMBUSTIBLE LIQUIDS CODE
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No. Code Section Walkdown Remarks
1-1.3 The volatility of liquids is increased byheating. When Class II or Class III liquidsare exposed to storage conditions, useconditions or process operations where theyare naturally or artificially heated to orabove their flash points, additional require-ments may be necessary. These requirementsinclude consideration for such items asventilation, exposure to ignition sources,diking, and electrical area classification.
1-1.4 =- Additional requirements may be necessary forthe safe storage and use of liquids that haveunusual burning characteristics, that aresubject to self-ignition when exposed to theair, that are highly reactive with othersubstances, that are subject to explosivedecomposition, or have other specialproperties that dictate safeguards over andabove those specified for a normal liquid ofsimilar flash point classification.
1-1.5 In certain installations the provisions ofthis code may be altered at the discretion ofthe authority having jurisdiction afterconsideration of the special features such astopographical conditions, barricades, walls,adequacy of building exists, nature of
NFPA 30 - 1987FLAMMABLE AND COMBUSTIBLE LIQUIDS CODE
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CodeSection
No. Code Section Walkdown Remarks
1-1.5Cont'd
occupancies, proximity of buildings oradjoining property and character ofconstruction of such buildings, capacity andconstruction of proposed tanks and characterof liquids to be stored, nature of process,degree of private fire protection to beprovided, and the adequacy of facilities ofthe fire department to cope with flammable orcombustible liquid fires.
1-1.6 Existing plants, equipment, buildings,structures, and installations for storage,handling, or.use of flammable or combustibleliquids that are not in strict compliance withthe terms of this code may be continued in useat the discretion of the authority havingjurisdiction provided they do not constitute arecognized hazard to life or adjoiningproperty. The existence of a situation thatmight result in an explosion or suddenescalation of a fire, such as inadequateventilation or confined spaces, lack ofadequate emergency venting of a tank, failureto fireproof the supports of elevated tanks,or lack of drainage or dikes to control spillsmay constitute such a hazard.
NFPA 30 - 1987FLAEfABLE AND COMBUSTIBLE I;IQUIDS CODE
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CodeSection
No. Code Section Walkdown Remarks
This code shall not apply to: i r r~(-
Transportation of flammable and combustibleliquids. These requirements are contained inthe U.S. Department of Transportati'on regula-tions or in NFPA 385, "Standard for TankVehicles for Flammable and CombustibleLiquids."
1-1.7.2 Storage, handling, and use of fuel oil tanksand containers connected with oil burningequipment. These requirements are coveredseparately in NFPA 31, "Standard for theInstallation of Oil Burning Equipment."
Storage of flammable and combustible liquidson farms and isolated construction projects.These requirements are covered separately inNFPA 395, "Standard for the Storage ofFlammable and Combustible Liquids on Farmsand Isolated Construction Projects."
.L
1-1.7.4 Liquids without flash points that can beflammable under some conditions, such ascertain halogenated hydrocarbons and mixturescontaining halogenated hydrocarbons. (SeeNFPA 321, "Standard on Basic Classification ofFlammable and Combustible Liquids.")
V
NFPA 30 - 1987FLAMMABLE AND COMBUSTIBLE LIQUIDS CODE
CODE COMPLIANCE WALKDOWN CHECKLIST
CodeSection
No. Code Section Walkdown Remarks
1-1.7.5
1-1.8
Mists, sprays, or foams. (Except flammableaerosols in containers, which are included inChapter 4.)
Installations are made in accordance with theapplicable requirements of standards of theNational Fire Protection Association: NFPA32, "Standard for Drycleaning Plants;" NFPA 33,"Standard for Spray Application Using Flammableor Combustible Materials;" NFPA 34, "Standardfor Dipping and Coating Processes UsingFlammable or Combustible Liquids;" NFPA 35,"Standard for the Manufacture of OrganicCoatings;" NFPA 36, "Standard for SolventExtraction Plants;" NFPA 37, Standard for theInstallation and Use of Stationary CombustionEngines and Gas Turbines;" NFPA 45, "Standardfor Fire Protection for Laboratories UsingChemicals; and Chapter 10 of NFPA 99,"Standard for Health Care Facilities," shallbe deemed to be in compliance with this code.
p fp
Metrication. If a value for measurement asgiven in this standard is followed by anequivalent value in other units, the firststated is regarded as the requirement. Thegiven equivalent value may be approximate.
NFPA 30 - 1987FLAMMABLE AND COMBUSTIBLE LIQUIDS CODE
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CodeSection
No. Code Section Walkdown Remarks
1-2 DefinitionsThe scope of this chapter is not included inthis report. Definitions are placed withinNFPA 30 for information purposes only.
1-3 StorageLiquids shall be stored in tanks or in con-tainers in accordance with Chapter 2 orChapter 4.
1.4 Pressure VesselAll new pressure vessels containing liquidsshall comply with 1-4.1, 1-4.2, or 1-4.3,as applicable.
1-4.1 Fired pressure vessels shall be designed andconstructed in accordance with Section 1(Power Boilers), or Section VIII, Division 1or Division 2 (Pressure Vessels), asapplicable, of the 1983 ASME Boiler andPressure Vessel Code.
1-4.2 Unfired pressure vessels shall be designed andconstructed in accordance with Section VIII,Division 1 or Division 2, of the 1983 ASMEBoiler and Pressure Vessel Code.
NFPA 30 - 1987FLAEfABLE AND COMBUSTIBLE LIQUIDS CODE
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CodeSection
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1-4.3 Fired and unfired pressure vessels that do notconform to 1-4.1 or 1-4.2 may be used providedapproval has been obtained from the state orother governmental jurisdiction in which theyare to be used. Such pressure vessels aregenerally referred to as "State Special."
1.5 ExitsEgress from buildings and areas covered bythis code shall be in accordance with NFPA101, "Life Safety Code."
Chapter 2 Tank StorageThe scope of this entire chapter is notincluded in this report. No permanentflammable liquid tanks exist within thesecurity fence.
Chapter 3 Piping, Valves, and FittingsThe scope of this entire chapter is notincluded in this report. No flammable liquidpiping systems are installed within the DonaldC. Cook Nuclear Plant.
Chapter 4
4.1
Container and Portable Tank Storage
Scope
7i</e
/((LL
NFPA 30 - 1987FLAMMABLE AND COMBUSTIBLE LIQUIDS CODE
CODE COMPLIANCE WALKDOWN CHECKLIST
CodeSection
No. Code Section Walkdown Remarks
This chapter shall apply to the storage ofliquids, including flammable aerosols, indrums or other containers not exceeding 60gal (227 L) individual capacity and portabletanks not exceeding 660 gal (2498 L)individual capacity and limited transfersincidental thereto. For portable tanksexceeding 660 gal (2498 L), Chapter 2 shallapply.
4-1.2 This chapter shall not apply to the following:
(a) Storage of containers in bulk plants,service stations, refineries, chemical plants,and distilleries.
1 >TLQ
7
(b) Liquids in the fuel tanks of motorvehicles, aircraft, boats, or portable orstationary engines.
(c) Beverages, when packaged in individualcontainers not exceeding, a capacity of onegallon.
NFPA 30 - 1987FLAMMABLE AND COMBUSTIBLE LIQUIDS CODE
CODE COMPLIANCE WALKDOWN CHECKLIST
CodeSection
No. Code Section Walkdown Remarks
4-1.2Cont'd
(d) Medicines, foodstuffs, cosmetics, andother consumer products containing not morethan 50 percent by volume of water-miscibleliquids and with the remainder of the solutionnot being flammable when packaged inindividual containers not exceeding one gallonin size.
(e) The storage of liquids that have no firepoint when tested by ASTM D 92-78, theCleveland Open Cup Test Method, up to theboiling point of the liquid, or up to atemperature at which the sample being testedshows an obvious physical change.
(f) The storage of distilled spirits andwines in wooden barrels or casks.
4-1.3 For the purpose of this chapter, unstableliquids and flammable aerosols shall betreated as Class IA liquids.
4-2 Design, Construction, and Capacity ofContainers I (rLC
NFPA 3 - 1987FLAMMABLE AND COMBUSTIBLE LIQUIDS CODE
CODE COMPLIANCE WALKDOWN CHECKLIST
CodeSection
No. Code Section Walkdown Remarks
4-2.1
4-2.2
Only approved containers and portable tanksshall be used. Metal containers and portabletanks meeting the requirements of, and con-taining products authorized by, Chapter I,Title 49 of the "Code of Federal Regulations"(DOT Regulations), or NFPA 386, "Standard forPortable Shipping Tanks for Flammable andCombustible Liquids," shall be acceptable.Polyethylene containers meeting the require-ments of, and containing products authorizedby, DOT Specification 34, and polyethylenedrums authorized by DOT Exemption Procedures,shall be acceptable. Plastic containersmeeting the requirements of ANSI/ASTMD 3435-80, "Plastic Containers (Jerry Cans)for Petroleum Products," used forpetroleum products within the scope of thatspecification shall be acceptable.
Each portable tank shall be provided with oneor more devices installed in the top withsufficient emergency venting capacity to limitinternal pressure under fire exposureconditions to 10 psig (68.9 kPa), or 30percent of the bursting pressure of the tank,whichever is greater. The total ventingcapacity shall be not less than that specifiedin 2-2.5.4 or 2-2.5.6. At least one pressure-
7-g (5 ~a ~/ )i'o7 Ml'~CQ,
CX~ ~ CC>~~lW~,+( f (/ ~~ ~~~ ~~EQ (~
yr=~Q approeecP
~/g ~~ p p~41e s~kg/
NFPA 30 - 1987FLAMMABLE AND COMBUSTIBLE LIQUIDS CODE
CODE COMPLIANCE WALKDOWN CHECKLIST
CodeSection
No. Code Section Walkdown Remarks
4-2.2Cont'd
4-2.3
actuated vent havigg a minimum capacity of6.000 cu ft (170 m ) of free air per hour(14.7 psia (760 mm Hg) and 60 F (15.6 C) shallbe used. It shall be set to open at not lessthan 5 psig (34.5 kPa). If fusible vents areused, they shall be actuated by elements that
0operate at a temperature not exceeding 300 F(148.9 C). When used for paints, drying oils,0
and similar materials where plugging of thepressure-actuated vent can occur, fusiblevents or vents of the type that soften tofailure at a maximum of 300 F (148.9 C) under0 0
fire exposure may be used for the entireemergency venting requirement.
Containers and portable tanks for liquidsshall conform to Table 4-2.3 except asprovided in 4-2.3.1 or 4-2.3.2.
jI Al5+0''v M~
4-2.3.1 Medicines, beverages, foodstuffs, cosmetics,and other common consumer products, whenpackaged according to commonly acceptedpractices for retail sales, shall be exemptfrom the requirements of 4.2.1 and 4.2.3.
NFPA 30 - 1987FLAEfABLE AND COMBUSTIBLE LIQUIDS CODE
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No. Code Section Walkdown Remarks
4-2.3.2 DOT Type III polyethylene nonreusable con-tainers, constructed and tested in accordancewith DOT specification 2U, treated ifnecessary to prevent permeation, may be usedfor storage of Class II and Class III liquids,in all capacities not to exceed 2 1/2 gal..
4-2.3.3 Class IA and Class IB liquids may be stored inglass containers of not more than one galloncapacity if the required liquid purity (suchas ACS analytical reagent grade or higher)would be affected by storage in metal con-tainers of if the liquid would cause excessivecorrosion of the metal container.
4.3 Design, Construction, and Capacity of StorageCabinets 7 grcF
4.3-1 Not more than 120 gal (454 L) of Class I,Class II, and Class IIIA liquids may be storedin a storage cabinet. Of this total, not morethan 60 gal (227 L) may be of Class I andClass II liquids and not more than three (3)such cabinets may be located in a single firearea, except that, in all industrial occupancy,additional cabinets may be located in the samefire area if the additional cabinet, or groupof not more than three (3) cabinets, isseparated from other cabinets or group ofcabinets by at least 100 ft (30 m).
NFPA 30 987FLAEfABLE AND COMBUSTIBLE LIQUIDS CODE
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No. Code Section Walkdown Remarks
4-3.2 Storage cabinets shall be designed andconstructed to limit the internal temperatureat the center, 1 in. (2.5 cm) from the top tonot more than 325 F (162.8 C) when subjected
0 0
to a 10-minute fire test with burnerssimulating a room fire exposure using thestandard time-temperature curve as given inASTM E 152-8la. All joints and seams shallremain tight and the door shall remainsecurely closed during the fire test.
"p~. ~ I-Ao~K+
The cabinet is not required to be vented forfire protection purposes; however, thefollowing shall apply:
(a) If the cabinet is vented for otherreasons, the cabinet shall be vented outdoorsin such a manner that will not compromise thespecified performance of the cabinet, asacceptable to the authority havingjurisdiction.
(b) If the cabinet is not vented, the ventopenings shall be sealed with properly fittedmetal bung.
NFPA - 1987FLAMMABLE AND COMBUSTIBLE LIQUIDS CODE
CODE COMPLIANCE WALKDOWN CHECKLIST
CodeSection
No. Code Section Walkdown Remarks
4-3.2.1
4-3.2.2
Metal cabinets constructed in the followingmanner are acceptable. The bottom, top, door,and sides of cabinet shall be at least No. 18gage sheet steel and double walled with 1 1/2in. (3.8 cm) air space. Joints shall beriveted, welded, or made tight by some equallyeffective means. The door shall be providedwith a three-point latch arrangement and thedoor sill shall be raised at least 2 in.(5 cm) above the bottom of the cabinet toretain spilled liquid within the cabinet.
Wooden cabinets constructed in the followingmatter are acceptable. The bottom, sides, andtop shall be constructed of exterior gradeplywood at least 1 in. (2.5 cm) in thickness,which shall not break down or delaminate underfire conditions. All joints shall berabbetted and shall be fastened in twodirections with wood screws. When more thanone door is used, there shall be a rabbettedoverlap of not less than 1 in. (2.5 cm).Doors shall be equipped with a means oflatching and hinges shall be constructed andmounted in such a manner as to not lose theirholding capacity when subjected to fireexposure. A raised sill or pan capable ofcontaining a 2 in. (5 cm) depth of liquidshall be provided at the bottom of the cabinetto retain spilled liquid within the cabinet.
A
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NFPA 3 - 1987FLAMMABLE AND COMBUSTIBLE LIQUIDS CODE
CODE COMPLIANCE WALKDOWN CHECKLIST
CodeSection
No. Code Section Walkdown Remarks
4-3.2.3 Listed cabinets that have been constructedand tested in accordance with 4-3.2 shall beacceptable.
4-4 Design, Construction, and Operation ofSeparate Inside Storage Areas(See Section 1-2, "Definitions.) (Foradditional information, see Appendix C.)
~ i76C
4-4.1
4-4.1.1
Inside Rooms
Inside rooms shall be constructed to meet theselected fire-resistance rating as specifiedin 4-4.1.4. Such construction shall complywith the test specifications given in NFPA251, "Standard Methods of Fire Tests ofBuilding Construction and Materials." Exceptfor drains, floors shall be liquidtight andthe room shall be liquidtight where the wallsjoin the floor. Where an automatic fireprotection system is provided, as indicatedin 4-4.1.4, the system shall be designed andinstalled in accordance with the appropriateNFPA standard for the type of system selected.
NFPA 3M 1987FLAMMABLE AND COMBUSTIBLE LIQUIDS CODE
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No. Code Section Walkdown Remarks
4-4.1.2 Openings in interior walls to adjacent roomsor buildings shall be provided with:
(a) Normally closed, listed 1 1/2 hr (B) firedoors for interior walls with fire-resistancerating of 2 hr or less. Where interior wallsare required to have greater than 2 hr fire-resistance rating, the listed fire doors shallbe compatible with the wall rating. Doors maybe arranged to stay open during materialhandling operations if doors are designed toclose automatically in a fire emergency byprovision of listed closure devices. Firedoors shall be installed in accordance withNFPA 80, "Standard for Fire Doors andWindows."
(b) Noncombustible liquidtight raised sillsor ramps at least 4 in. (10 cm) in height orotherwise designed to prevent the flow ofliquids to the adjoining areas. A permissiblealternative to the sill or ramp is an open-grated trench, which drains to a safelocation, across the width of the openinginside of room.
NFPA 1987FLAMMABLE AND COMBUSTIBLE LIQUIDS CODE
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No. Code Section Walkdown Remarks
4-4.1.3 Wood at least 1 in. (2.5 cm) nominal thicknessmay be used for shelving, racks, dunnage,scuffboards, floor overlay, and similarinstallations.
4-4.1.4 Storage in inside rooms shall comply with thefollowing: T]pLL
AutomaticFireProtection+ FireProvided Resistance
MaximumFloorArea
Total AllowableQuantities--Gallons/Sq Ft/Floor Area
YESNO
YESNO
2 hr2 hr1 hr1 hr
500 sq ft 10500 sq ft 4~150 sq ft 5
150 sq ft 2
SI Units: 1 sq ft 0.09 m , 1 gal - 3.8 L.2
*Fire protection system shall be sprinkler,water spray, carbon dioxide, dry chemical,halon, or other approved system.**Total allowable quantities of Class IA and-1B Liquids shall not exceed that permitted inTable 4-4.2.7 and the provisions of 4-4.2.10.
Q~~,q $ (,~ (~ . ~dt~
ca~[<a ~e cf I< yWa~ld/~
f (~std
NFPA 30 - 1987FLAMMABLE AND COMBUSTIBLE LIQUIDS CODE
CODE COMPLIANCE WALKDOWN CHECKLIST
CodeSection
No. Code Section Walkdown Remarks
4-4. l. 5 Electrical wiring and equipment located ininside rooms used for Class I liquids shall besuitable for Class I, Division 2 classifiedlocations; for Class II and Class III liquids,shall be suitable for general use. NFPA 70,"National Electrical Code," providesinformation on the design and installation ofelectrical equipment.
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WPAA tP ~~+,~>~m g <S S~~iar >~
4-4.1.6 Every inside room shall be provided witheither a gravity or a continuous mechanicalexhaust ventilation system. Mechanicalventilation shall be used if Class I liquidsare dispensed within the room.
(a) Exhaust air shall be taken from a pointnear a wall on one side of the room andwithin 12 in. (30 cm) of the floor with oneor more make-up inlets located on the oppositeside of the room within 12 in. (30 cm) fromthe floor. The location of both the exhaustand inlet air openings shall be arranged toprovide, as far as practicable, air movementsacross all portions of the floor to preventaccumulation of flammable vapors. Exhaustfrom the room shall be directly to theexterior of the building withoutrecirculation.
NFPA 3 - 1987FLAtiHABLE AND COMBUSTIBLE LIQUIDS CODE
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CodeSection
No. Code Section Walkdown Remarks
4-4.1.6Cont'd
Exception: Recirculation is permitted whereit is monitored continuously using a fail-safesystem that is designed to automatically soundan alarm, stop recirculation, and provide fullexhaust to the outside in the event thatvapor-air mixtures in concentration over one-fourth of the lower flammable limit aredetected.
If ducts are used, they shall not be used forany other purpose and shall comply with NFPA91, "Standard for the Installation of Blowerand Exhaust Systems for Dust, Stock, and VaporRemoval or Conveying." If make-up air to amechanical system is taken from within thebuilding, the opening shall be equipped with afire door or damper, as required in NFPA 91,"Standard for the Installation of Blower andExhaust Systems for Dust, Stock, and VaporRemoval or Conveying." For gravity systems,the make-up air shall be supplied from outsidethe building.
NFPA 3 - 1987FLAMMABLE AND COMBUSTIBLE LIQUIDS CODE
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4-4.1.6Cont'd
4-4.1.7
(b) Mechanical ventilation systems shallprovide at least one cubic foot per minute3ofexhaust per square foot of floor area (1 yper 3 m ), but not less than 150 cfm (4 m ).The mechanical ventilation system fordispensing areas shall be equipped with anair flow switch or other equally reliablemethod that is interlocked 'to sound an audiblealarm upon failure of the ventilation system.
In every inside room, an aisle at least 3 ft(0.90 m) wide shall be maintained so that nocontainer is more than 12 ft (3.6 m) from theaisle. Containers over 30 gal (113.5 L)capacity storing Class I or Class II liquidsshall not be stored more than one containerhigh.
~ ( ( ~p~ Q~(&~a'l3yC
of ~~g gr /c cfog&+;
4-4.1.8 Where dispensing is being done in insiderooms, operations shall comply with theprovisions of Chapter 5.
4-4.1.9 Basement Storage Areas. Class I liquids shallnot be permitted in inside storage rooms inbasement areas.
4-4.2 Cutoff Rooms and Attached Buildings
NFPA 3 - 1987FLAMMABLE AND COMBUSTIBLE LIQUIDS CODE
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No. Code Section Walkdown Remarks
4-4.2.1 Construction design of exterior walls shallprovide ready accessibility for fire fightingoperations through provision of accessopenings, windows, or lightweight non-combustible wall panels. Where Class IA or-IB liquids are dispensed, or where Class IAliquids are stored in containers larger thanone gallon, the exterior wall or roofconstruction shall be designed to includeexplosion-venting features, such as light-weight wall assemblies, lightweight roofassemblies, roof hatches, or windows of theexplosion-venting type. NFPA 68, "Guide forExplosion Venting," provides information onthis subject.
pr~ii-C k r~~Jgr&r i~c ~ 5J
4-4.2.2 Where other portions of buildings or otherproperties are exposed, each opening in theexposing wall shall be protected with alisted 1 1/2 hr (D) fire door installed inaccordance with NFPA 80, "Standard for FireDoors and Windows," and the walls shall have afire-resistance rating of not less than 2 hrs.
j,t~~c ~ (z( pe ~~+re ecg~/4 o. rc'~P~'7
p +,my) I 5 Prnvlk4.
)~~~ (o ~5'f7 cc CQ~~
NFPA 30 - 1987FLAMMABLE AND COMBUSTIBLE LIQUIDS CODE
CODE COMPLIANCE WALKDOWN CHECKLIST
CodeSection
No. Code Section Walkdown Remarks
4-4.2.3 Except as noted in 4-4.2.6, interior walls,ceiling, and floors shall have a fire-resistance rating of not less than 2 hrs wherefloor area gf the room or building exceeds 300sq ft (27 m ) or a fire-resistance rating ofnot less
thorn one hour for a floor area of 300sq ft (27 m ) or less. Such constructionshall comply with the test specificationsgiven in NFPA 251, "Standard Methods of FireTests of Building Construction and Materials."Walls shall be liquidtight at the floor level.
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4-4.2.4 Openings in interior walls to adjacent roomsor buildings shall be in accordance with4-4.1.2(a).
4-4.2.5 Curbs, scuppers, special drains, or othersuitable means shall be provided to preventthe flow of liquids under emergency conditionsinto adjacent building areas except where theindividual container capacity is 5 gal(18.9 L) or less or if the liquids stored areonly Class III liquids. The drainage system,if used, shall have sufficient capacity tocarry off expected discharge of water fromfire protection systems and hose streams.
~ <r4, c~ axceptvo~aQ cd~+a.i<c~4 5
+~/ Qp 44< Wg~IcyIc g ~ (,~ ~((CcQc/ f~fh
p, ) j).,-,,~ 5(@57 c-n appc'a.(s fa)L.
NFPA 30 - 1987FLAMMABLE AND COMBUSTIBLE LIQUIDS CODE
CODE COMPLIANCE WALKDOWN CHECKLIST
CodeSection
No. Code Section Walkdown Remarks
4-4.2.6 Roofs of attached buildings, one story inheight, may be lightweight noncombustibleconstruction if the separating interior wallas specified in 4-4.2.3 has a minimum 3 ft(0.90-m) parapet.
4-4.2.7 Unprotected storage in cutoff rooms andattached buildings shall comply with Table4-4.2.7. (See 4-4.2.10 for mixed storage ofliquids.)
4-4.2.8 Protected storage in cutoff rooms and attachedbuildings shall comply. with Section 4-6 asapplicable. (See 4-4.2.10 for mixed storageof liquids.)
c p(~ 9 ppJi cc-41~
4-4.2.9 Wood at least 1 in (2.5 cm) nominal thicknessmay be used for shelving, racks, dunnage,scuffboards, floor overlay, and similarinstallations.
4-4.2.10 Where two or more classes of liquids arestored in a single pile or rack section, themaximum quantities and height of storagepermitted in that pile or rack section shallbe the smallest of the two or more separatequantities and heights. The maximum total
NFPA 30 - 1987FLAMMABLE AND COMBUSTIBLE LIQUIDS CODE
CODE COMPLIANCE WALKDOWN CHECKLIST
CodeSection
No. Code Section Walkdown Remarks
4-4.2.10Cont'd
quantities permitted shall be limited to asum of proportional amounts that each classof liquid present bears to the maximum totalpermitted for its respective class; sum ofproportional amounts not to exceed 100percent.
4-4.2.11 Dispensing operations of Class I or Class IIliquids are not permitted in cutoff rooms orattac)ed buildings exceeding 1000 sq ft(93 m ) floor area. In rooms where dispensingof Class I liquids is permitted, electricalsystems shall comply with 4-4.1.5, exceptthat within 3 ft (0.90 m) of a dispensingnozzle area, the electrical system shall besuitable for Class I, Division I; ventilationshall be provided per 4-4.1.6; and operationsshall comply with the provisions of Chapter 5.
~~I~ e>c & y) ~ ~,p
c4+VI 8
4-4.2.12 Basement Storage Areas. Class I liquids shallnot be permitted in the basement areas of cut-off rooms and attached buildings. Class IIand Class IIIA liquids may be stored in base-ments provided that automatic sprinklerprotection and other fire
protection'acilitiesare provided in accordance withSection 4-6.
+/P c'o m ~ ~c~:I -+ '+~'.) .
.j
4.5 Indoor Storage <~l.a
NFPA 30 - 1987FLU%ABLE AND COMBUSTIBLE LIQUIDS CODE
CODE COMPLIANCE WALKDOWN CHECKLIST
CodeSection
No. Code Section Walkdown Remarks
4-5.1
4-5.1.1
Basic Conditions
The storage of any liquids shall notphysically obstruct a means of egress.Class I liquids in other than separate insidestorage areas or warehouses shall be so placedthat a fire in the liquid storage would notpreclude egress from the area.
(~(W
4-5.1.2 The storage of liquids in containers orportable tanks shall comply with 4-5.2 through4-5.7, as applicable. Where separate insidestorage areas are required, they shall conformto Section 4.4. Where other factorssubstantially increase or decrease the hazard,the authority having jurisdiction may modifythe quantities specified.
4-5.1.3 Liquids used for building maintenance paintingor other similar infrequent maintenancepurposes may be stored temporarily in closedcontainers outside of storage cabinets orseparate inside storage areas, if limited inamount, not to exceed a 10-day supply atanticipated rates of consumption.
4-5.1.4 Class I liquids shall not be stored in abasement, except as provided in 4-5.5.
Attached are the corrective action (Attachment 1) and maintenance(Attachment 2) recommendations prepared by Impell under Contract C-6945.Please coordinate the maintenance items identified in both attachments.
NFPA 12ANFPA 13NFPA 72DNFL 72E
1-9.5.63-16.82122/40612-6.1 (For detectors3-26 6 3-27 in FZ 33;3-27 in FZ 34; and 2-7in FZ 39 only. Theremaining detectorshave been justified.)
Attachment 1 contains several actions which shouldas maintenance items. These maintenance items arecode and code section numbers.
have been designatednoted below by NFPA
~GALFlcPc&oIJr c.~~HW~ll-'lh~t
ll- i< -'tl
Not mentioned in either list are the two missing sprinkler heads in theUnit 2 control room cable vault. These two sprinklers are located inthe same ceiling bay on the same branch line. They are approximatelytwelve inches from smoke detectors 12-28 and 12-30.
Several fire zonesexceeded the maximumtravel distance forextinguishers.
Extingui shers located in thefollowing zones are not within75ft. of a Class A hazard or50 ft of a Class 8 hazard.Either additional extinguishersshould be provided or existingexti ngui shers relocated to meet thetravel distance requi rements.
1-6.24-3.2
All extinguishers are notprovided in their desig-nated places per the firefaci 1 i ti es drawings.
The fire faci 1 i ti es drawings shouldbe revised to show actual placementand types of exti ngui shers.The procedures should be enhancedto reference this fire facilitiesdrawings for locating equipment.
01-1
FPA DE DEVIATI / P ITERE MMEND D RE TIVE A TI N
(continued)
DE/ E I N D VIATI N/ PEN ITE R MMENDA I N
PA12 — 1
122<
134 J
165/254'55
Locations of the pilotcabinets are such thatleakage of C02 from theprotected areas may causethe oxygen concentrationto fall below acceptablelimits.
No hydraulic calculationsor test data were availablefor review for the newhalon/C02 nozzles in theC.R. cable vaults.
Perform an engineering evaluationto address the endangermentof personnel due to leakage ofC02 outside the protected area.
Perform hydraulic calculationsfor the system or an engineeringevaluation to show the adequacy ofthe new nozzles.
1632-'634
1436
No documentati on wasavailable to verify thehydrostatic test pressureor equivalent length ofthe valves used in thesystem.
Documentation to verifythat manual controls shallnot require a pull of morethan 40 lbs. nor movementof more than 14 inches wasnot available for review.
Perform an engineering evaluationto address the acceptabi 1 i ty ofthe valves used in the system.
Obtain vendor data for thesecomponents to verify that theallowable limits are not exceeded.
1716
NFPA12A — 1 77
No documentation wasavailable to verify thatthe liquid level gagesare checked annually.
Revise procedures to annually checkthe liquid level gages.
1-5.41-7.4
1-8.3. 6
The original test resultsfor the computer rooms(zones 71 and 72) wereunsatisfactory.
Operation of the extendeddischarge cylindersprotecting the C.R. cablevaults (zones 57 and 58)could not be verified inthe absence of electricity.
Per form an engineering eval uati onto address the reasons for the testfailures. A retest may be requi red.
Perform an engineering evaluationaddressing the adequacy of thisconfiguration and protection ofthe hazards in the absence ofelectricity. Incorporate resultsinto the system design documentation.
1-2
FPA DE DEVIATI N/ PEN ITER HMENDED RRE TIVE A TI N
(continued)~III
PA12A — 1 77 (cont.)
0 VIATI N/ PEN ITEH RE MHENDATI
1-8.5.1 No documentation to verify Refer to the NFPA 72D codethat alarms for the C.R. compliance summary.cable vaults (zones 57 and58) are provided in theprotected area to indicatesystem alarm, pre-discharge,and discharge.
1-9.5.6
NFPAl — 1 71
A system nameplate isnot provided for any ofthe areas/systems whichwere evaluated.
Provide system name plates at thecylinder locations for the evaluatedsystems. The nameplate should containthe information specified in the coderequirement. In addition, theprotected hazard should be identifiedon the nameplates.
1141 Documentation could not The criteria contained in an 83-41be found to verify whether study is more applicable to D.C.the flooring is watertight Cook.
324183
368136823683
At the C.R. cable vaultriser, the retard chamberdischarges to the floorcontaining numerousunsealed penetrations.
Due to the congestion andlack of accessibilitysprinklers could not beverified free of paint andornamental finishes.
Prov)de an engineering evaluationbased on AEP's response to questionson the suppression systems regarding:
'ormal'OperationInadvertent Actuation
'looding Study
These responses should address theleakage through the unsealedpenetrations.
Procedures outlining the replacementof sprinkler heads with paint orornamental finishes should bedeveloped.
1-3
NFPA D D VIATI N/ P ITERE MMENDED RRE TIVE A TI N
(continued)
C DE/SE TI N DEVIATI N/ PEN ITEM RE MMENDATI N
PAl - 1
1-9.2 Hydraulic design data isnot provided on thesprinkler drawings.
System drawings should be revisedto reference design calculationnumbers.
2-2.1.2.42-2.1.2.5
Exterior fire hose demands Revise calculations to includewere not added to the the exterior hose or perform ahydraulic sprinkler system flow test to prove that thecalculations. demand can be met.
3-16.8 Various sprinklers under Provide guards to prevent damageducts at el. 587, 609, and to the heads.633 are not guarded.
3-17.4.5 Non indicating valves areused.
The valves should be replaced.
4-1.1.14-1.1.44-2.4.6
4-4.13
Sprinklers were foundobstructed in numerouslocations.
There are no sprinklersunder a 6ft. wide duct inzone 52.
Modify the heat collection platesRelocate sidewall heads
Provide an engineering analysis todetermine if this protection isnecessary.
4.19 Spri nklers underneath duct Baffles should be installed or thework are less than 12" heads relocated.apart with no baffles.
7-3.4
NFPA14
Hater supply graph sheetsare not provided.
Provide water supply graph.
~171212212a217531541551
~178 ~165-3.1 2-1.35-3.25-4.25-5.21-11.3
Documentation could not Hydraulic calculations should bebe found to verify that performed to verify piping is ofClass I and III stand- sufficient size to supply thepipes are sized for minimum required water flows withoutflow of 500 gpm plus 250 excessive pressure loss.gpm for each additionalstandpipe to maximum 2500gmp for a minimum 30 minutes.
Class II standpipes shall besized for minimum flow of 100gpm for a minimum 30 minutes.
1-4
NFPA DE DEVIA I N/ PEN ITE
1 +PA14 (cont.)
MM D RR IV(continued)
D TI N/
A T
R MMN
~171322421
~173-2.2 4-4.3.14-2.14-3.21-11.3
Several Class II hosestations were providedwith hose lengths greaterthan 100'.
i nIlail M
EM�'
I~I
Hydraulic calculations should beperformed to verify adequate waterflows and pressures are availableat the nozzles when attached to hosesexceeding 100 ft. in length.The hose stations which do notsatisfy the 100ft. h 30ft.Requirements are:
An approved indicator valve The valve actuating mechanismfor valve no. FP 263 should should be changed from a leverbe provided. actuator to a gear driven actuator.
651 Piping was not properlysupported as required.
Additional hangers/supports shouldbe provided for the standpipe supplypiping. Zones in which insufficientsupports were noted are:
~Zn ~lva~i ~L~in5 591-587 Supply Main
1-5
NFPA D D VI I N/ P N ITEMR MME DED RR TIV A TI N
(continued)
D/ETIN D VIATI N/ P N ITEM R MM NDATI N
PA14 (cont.)
199'-1.
2 Standpipe specifications Specification ODPM110QCS should bedid not specify a required revised to require the contractor, toflow test. flow 500 gpm from the top-most outlet
of the standpipe system whilemaintaining a minimum residualpressure of 65psi at the standpipeoutlet.
511524
The adequacy of the water Hydraulic calculations should besupply for the hose system performed to verify the supply iscannot be verified. sufficient for the flows required.
671
PA1 -1 7
A 3-1/2 inch dial springpressure gage is notprovided at the top of eachstandpipe.
Hydraulic calculations should beperfor'med to verify that a minimumflow of 500 gpm for Class IIIor 100gpm for Class II/ standpipe servicesis available at a residual pressureof 65 psi at the top-most outlet fromeach standpipe riser.
20314072
4011
Hater discharge to thehazards are obstructed
Norking plans,specifications, andhydraulic calculationsare not provided for thecharcoal filter systems.
Provide an engi neering analysisto determine the adequacy of thecurrent configuration.
Provide or originate the necessarydocuments.
4032(b)7000
No documents to show the Provide an engineering analysisadequacy of the water spray to show the adequacy of the nozzlenozzles within each filter arrangement.uni t.
4081 A 3/4" pipe is used. Replace with a 1" pipe.
1-6
FPA DE DEVIATI N P ITEMM DD RRE I EA TIN
(continued)
PA1 — 1 7 (cont.)
/PN R MMN ATI N
4082(d)410141024103
410141024103
No documents were availablefor the adequacy of thesupports, nozzles,gage connections, or pipingarrangements.
A pipe supplying water tofi.lter unit 1-HV-CIPX-1 issupported by a rod weldedto the pipe itself.
Provide an engineering analysis toshow the adequacy of the componentsused, or produce documentsestablishing the adequacy of thecomponents used.
Perform an engineering analysis toshow the adequacy of the weldconfiguration.
4121
50215031
5023
11
There are no pressure gages Install pressure gages.installed for the waterspray systems.
No document were found to The system should be tested.verify that the hosehook-up system was tested.
No test results for the Provide an engineering evaluationdischarge pressure at the or test each system to verify thatmost remote nozzle of each the required pressure is
available'ystem.
Charcoal filter unit Revise procedures to include12-HV-SATFU is not included 12-HV-SATFU.in any of the procedures.
7010
NFPA72D — 1 7
No hydraulic calculationsfor the charcoal filterwater spray system.A graph sheet isnot included for theH2 tank system.
Originate hydraulic calculations
Originate graph sheet. (Supply-demandcurve).
203222123111
The following devices arenot approved for theirapplication
Rochester Instruments"EF" AnnunciatorPanels.'ose System ManualStations'CI Model 446002Manual Start/StopStations.
An equivalency for an approved/listeddevice can not be provided for thesedevices. AEPSC will be required toprovide a justification.
1-7
FPA DE DEVIATI N/ PEN ITER MMENDED RRE TIVE A TI N
(continued)
DE/ E TIN DV TIN/PNITE R MM NDATI N
A72D — 1 7 (cont'd)
20344052
The procedures do notperform surveillancetests or verify thereceipt of alarm orsupervisory signals at thecontrol room from firepump supervisory signalsand hose system manualstations alarm initiatingdevices to confirm theiroperabi lity.
The procedures should beenhanced to verify thereceipt of all required signals atthe control room. Each hose stationdevice should also be activated toverify operabi 1 i ty.
2047 The procedures do not The surveillance testverify the reset of should be revised to verify the resetsignals received by the of each signal prior to continuingcontrol room for sprinkler the test.system and fire pump signals.
21224061
The alarm initiatingcircuit cables are exposedto potential hazards atelevations 624'nd 650'.
a. Open junction boxes forsmoke detectors onEl. 624'one 57 atdetector no. 18-18 h18-25.
b. Two open junctionboxes had exposedcable protruding fromthem, at the halonpanel for zones 71 h72 at El. 650'.
Corrective actions should be takento prevent damage to the circuitconductors as follows:
a. Boxes should be properlycovered.
b. Cable should be insertedinto the panel and the boxesproperly covered.
c ~ ~ The solenoid circuitflex conduit for unit2 computer room(zone 72) halon tank isdamaged exposing thecircuit conductors.
c. Replace the flex conduit,'inspect conductors for abrasions,h reinstall all the conduit toprevent future damage.
1-8
NF DE DEVIATI N/ PEN ITER H NDED RRE TIVE A I
(conti nued)
DE/ E TIN DV TI N/ P N ITEM RE MM NDATI
PA72D — 1 7 (cont.)
2154
2223
23312251
Data was not availableto confirm compliancefor cables to meet maximumfault current, noninter-changeable overcurrentprotection, energy limit-ation criteria and approvedfor use as a limitedenergy cable.
The power cables connectedto the ACI A924 panelsfrom power panel l-DAB,circuit 5 & 2-DAB circuit5, are under sized for the35 AHP breakers provided.
Power supply data for theACI panels was not releasedto Impell by AlisonControl, Inc. Thereforeconfirmation of complianceof this equipment wasnot possible.
Continuous duty rating datafor the power supply trans-formers was not availablefrom all the manufacturersof the alarm system.
An engineering evaluationshould be performed to deter-mine compliance or obtainthe data required.
An engineering evaluationshould be performed toconfirm that these4-conductor cables have anequivalency of a ¹10 AWG
cable.
The data required should be providedto confirm compliance for thesesystems.
This continuous duty rating datashould be obtained if possible.
1-9
FPA DE DEVIATI N/ PEN ITEME NDD E IVEA TIN
(continued)
DE/ E TI
PA72D — 1 7 (cont.)
D VI TI N/ PEN ITEM RE MMENDATI N
24112422
a. The alarm initiating The surveillance procedurescircuits for the "EF" should be enhanced to verifypanels are not electri- the operability of the "EF"cally supervised to panel alarm initiating circuitsindicate a trouble by performing functional testscondition at the "EF" of each alarm initiating device.annunciator upon a This should be performed tocircuit fault. provide an equivalency for
electrically supervised circuits.b. The hose system
manual stations are notconnected to electricallysupervised circuits.
3431
3542
Haterflow alarm devicesare not provided for theAuxiliary Bui 1 ding ZMO-10& 20 hose system supplypiping.
Detector ¹3-29 in zone44S is not accessible fortesting due to sprinklerpiping obstruction.
Enhancement of the proceduresrecommended under code Section2411 & 2422 should be performed toprovide an equivalency for waterflowdevices.
This detector should be relocatedto provide adequate access forsensitivity testing.
2-6.1 Several detectors are ex- Protective guards should be installedposed to mechanical damage or the devices should be relocated.on elevations 587', 609',625'nd 633'.
The devices are as follows:
~Dv~i ~Zn ~E1 v.
Line Type Heat 5Det. 9 1-HV-SAT-FU Unit is exposedoutside unit approx-imately 8".
587'-17
thru 3-18,3-21, 3-25 thru3-28
33
609'-5,
7-716-3 & 16-4
38
609'-10
NFPA DE DEVIATI N/ PEN ITEMMHENDED RRE TIVE A TI N
(continued)
DE/ E TI
PA72E — 1 74 (cont.)
DEVIATI N/ P N ITEM
13-7 thru 13-9 41
3-16 thru 3-21, 343-26 5 3-27
RE MMENDATI N
609'09'FPA72E
— 1 74 1 7
8-7 thru 8-9
20-3 5. 20-4,2-5 & 2-7
27-2
1 2
45
39
60609'09'25'-3.1
4-3.2Smoke detectors in zones29A thru D, 32 thru 34,44N, 49,52 thru 54, 57and 69 are installed atthe bottom of deep beamsor installed greaterthan 12" from the ceiling.The devices are as follows:
The devices should berelocated as required.
Kana Xln.5-29 8 bottom 32
650'f
beam.
4-13 8 bottomof beam.
4-26 installedwithin 4" of18" beam.
5-1 thru 5-3 h5-10 thru 5-12approx. 4'ownfrom the ceiling.
49633'2
633'9
650'8-10
5 18-12 are 57625'nstalledwithin
4" of a deep beam.
1-11
D DVATIN/PNITEM DED R IV TI N
~IE T
PA72E — 1 74 1 7
D V
(continued)
N IT E MM DATI N
2-6.52-6.74-1.2
Detectors are not properly Engineering Evaluations should beprovided in all portions . performed to confirm complianceof a fire zone where or modifications should be performed.detection has been installed.
These zones are the following:
587
10
ll23
24
25
262733
34
37383944N44S
587
587
587587
587
587
587587612
612
609609609609609
Zone~N. ~vga
1 573
3 5874 587
5 5876N,6M,6S
~D~~ii~n
Air Movement& Det. 1-1 For Beam ConstructionThroughout ZoneDeep Bay 8Hest EndDet. 2-25 & 2-3, For Beam Construction587 Air movement &inadequatedet. spacing.I.R. Det. obst-ructions. Beamconst. 8 centerof zone.I.R. Det. obstr.& air movement.I.R. Det. obstr.& air movement.I.R. Det. obstr.I.R. Det. obstr.& air movement.I.R. Det. obstr.& air movement.I.R. Det. obstr.& air movement.Typcial of zone 8.Typical of zone 11.Det. not installed9 ceiling.Det. not installed8 ceiling.Air movement.Typical of zone 11.Typical of zone ii .Det. 3-4, beam constr.Det. 3-27 & 3-28 8bot. of beam.
1-12
NFPA DE D VIATI N/ P N IT HR HMENDED RRE TIVE A TI N
DE/ E TIN
(continued)
D VIATI N/ PEN ITEM RE MMENDATI N
PA72E — 1 74 1 7 (cont.)k
2-6.52-6.,4-1.2(Cont'd)
56 620
48 625
49 & 50 633
51 633
52 633
556069
620620650
40A 609
40B 609
32 609
42A-C 60943 60947A&B 609
46A-C 60941 & 45 609
Air movement &beam construction.Air movement &beam construction.High ceilings &beam construction.Air movement.Air movement.Air movement &beam construction.Air movement.Det. 13-9(41) &8-9 & 8-7 (45)do not cover entirearea. I.R.obstructions.Det. 18-10 & 10-12within 4" of deepbeam.Deep bay const. 8east end of room.Deep beam const. 8east end and for8" beam const.throughout eachzone.Deep beam const. 8northeast & south-east end of zone.Det. not spacedfor deep & 8" beamconst. 8 north &south end of zone.Typical of zone 10.Typical of zone 10.Typical of zone 32.
1-13
F DE D VIAT N/ ITEMRE MENDED RRE TIVE A TION
(conti nued)
DE/ ETI N
FPA72E — 1 4
4-3.5.1.1
DEV I PEN I E
Detectors provided inzones40A & B, 41, 45,47A & B,52, 55 and 60 donot adequately cover allportions of the zone with-in 0.7 times the listedspacing. These detectorsinclude the following:
~Dv~i
E MMENDATI N
An engineering evaluation shouldbe performed to determine theadequacy of the detection deviceswith the combustibles present.
a. Smoke detection is not- properly provided inzones 7, 27, 32, 33, 34and 69 due to highceilings.
b. Devices in zone 43 areplaced too close tosupply air diffusers.
~Dv~i
a. An engineering evaluation shouldbe performed to determine theadequacy of the detection deviceselection and coverage for thecombustibles present.
b. Detectors listed should berelocated.
23-4, 23-14thru 23-19,23-21 & 23-22
43
1-14
NFP DE DEVIATI N/ PEN ITER MM ND D RRE TIVE A TI N
(continued)
QLEEIE TILN
FPA72E — 1 74
4-4.2
1 2
DEVIATI N/ PEN ITEM
n
'he
vestibule area(zone 53) and the toilet(zone 54) are not providedwith detection at thesuspended ceiling.
RE MMENDATI N
An engineering evaluation should beperformed to determine the require-ment for smoke detectors in thevestibule and toilet.
Detectors are not properly Detectors should be provided asspaced for the air move- required for the air movementment in the zone. present in the space.
~Fi r ~n ~i~v~in
P — 1 4
1
6N, 6H 5 6S8510
2637
40A —408'2A
— 42C43
47A 5 47846A — 46C55 5 60
573587596587625609609609609609625
4-4. 64-3.7.24-3.7.3
Detectors are not properly An engineering evaluation shouldprovided in beam construe- be performed to determine thetion. adequacy of the detection coverage
for the combustibles present forzones 1, 3, 5, 6N, 6S, 48, 49, 50,52, 7, 27, 32, and 69.
~Dv~i
a 0
b.
C.
Deep equipment hatchin the ceiling maydelay detector responseand is not considered indetector placement.
Detectors not providedin each bay asrequired for deepbeam constructiongreater than 18".
Reduced spacing isnot provided ingreater than 8" butless than 18".
155
3752732 L 6948, 49
5 50
5, 6N
6S, 49,50 5 52
,1-15
NFPA DE DEVIATI N/ PEN ITEMMH NDED R TIVE A TI N
(continued)
DE/ E TI N
PA72E — 1 74
DEVIATI N/ PEN ITEM RE MMENDATI N
5-3.25-4.15-4.25-5.1
The field of vision for An engineering evaluation shouldseveral infrared detectors be performed to determine the mostwere obstructed by conduit/ advantageous detector arrangementcable tray systems, . for the obstructions and combustiblesstructure and equipment. present.In severalcases the arrange-ment of the detector wasnot appropriate. Thedeficient detectors arelisted as follows:
Zone Device~N. ~N. ~0f1 1 n
7 17-1 Obstruction bycable trays.
7 17-2 Misalignment forthe combustiblespresent.
7 17-3 Obstructed byconduit.
8 18-5 Misalignment andobstructed.
8 18-1 Obstructed.
10 14-2 Obstructed.
10 14-1 Obstructed.
11 13-3 Obstructed.
25 19-3 Obstructed.
26 22-4 Hisaligned andobstructed.
26 22-5 Hisaligned andobstructed.
1-16
NFP DE D VI TI N/ P ITEMR MMEND TIV TI N
(continued)
DE/ ETI N
PA72E — 1 74 n
'-3.2
5-4.15-4.25-5.1(Cont'd)
AT N/ P
27 21-3 Misaligned andobstructed.
E MM NDATI N
27 21-2
27 21-3
33 3-23 &3-24
34 3-23 &3-24
38 16-3 &16-4
39 20-3 &20-4
41 21-3,21-4 &21-5
42A 22-1
42C 22-3 &22-4
Misaligned forcombustibles present.
Obstructed bycable tray.
The alignment ofthe detectors forthe platform 9elev. 646'-9"Detector isobstructed byplatform.
Typical of zone 33.
Obstructed by cabletray. Hisalignmentdue to low ceilingfor 16-3.
Obstructed by cabletray. Misalignmentdue to low ceilingfor 20-3.
Det. 21-3 obstructedby MCC equipment.Detector 21-4 &21-5 mi salignedand obstructed.
Obstructed bystructure; doesnot provide properarea coverage.
5-5.2
NFPA7 - 1 74 1 2
60 27-1, Det. 27-3 obstructed27-2, by structure.27-3 5 Detector 27-1,27-4 27-2 and 27-4
misaligned &obstructed.
The procedures do not con- The procedures should be revisedfirm the changes in the to verify the impact of changes onalignment, physical con- the flame detectors.figurations or combustibleloading during surveillances.
7-3.1.48-2.1.2
The line type heat detectors The procedures should be revised tofor the RCP pumps are not verify the operability of the lineverified for their oper- type heat detectros as required.abi lity by loop resistancetesting as required.
1-18
.
TT HHENT 2
NFPA ' DEVIATI N/ PEN ITE
HAI TENAN RE MMENDATI N
~D/~ET~IN
NFP — 4
1-6. 6
DEVIATI N/ PEN ITEM
Three extinguisherswere not properlymounted in fireZones 33A, 38 and 43.
Fire~Dv~i
RE MMENDATI N
These extinguishers should berei nstalled properly.
33A A 15 lb. C02exting. at containmentaccess portal
38 A 20 lb. ABC exting.at RCT HEZZANINE
1-6.7
1-4.3
A 20 lb. BC exting.in access hallway.
A 20 lb. ABC extinguisherin fire zone 61 adjacentto spray additive tank 9center of room wasimproperly mounted andsubject to dislodgement.
Five C02 extinguisherswere not properlylabled as required.These devices are locatedas follows:
The extinguisher should bereins tal 1 ed properly.
These extinguishersshould be replacedwith approved devices.
573587587609612
WLL-WLM/WL7H/12.5WLK/5.5WLL/4.8WLR/18
2-1
N PA D DEVIATI N/ PEN ITEMMM NDATI
(continued)
i. DE/ TI
NFPA 12 — 1
1439
1625
431
NFPA 12A — 1 77
1-8.3.10
1-9.5. 5
NFPA 1 -1 71
2822
NFPA 1 - 1
3-16.2.23-16.3.53-16.9.2
NFPA 1 — 1 7
None
D V T N/ PEN ITE
The manual pull for firezone 38 is not labeled.
The pressure vent linesfrom the electro-pneumaticcabinets for the 4 mainheader valves and zones55-60 15 disconnected sothat excess C02 ventsinto the tank room.
Access to hose reel12-ZCH-2 is blocked.
The manual pull stations(Ansul Automan Cabinets)are not labeled for theControl Room Cable Vaults(Zones 57 and 58).
The cylinder racking tothe last line extendeddischarge cylinder for theUnit 2 C.R. Cable Vault(Zones 58) is loose.
The lower gage on theriser for the drummingarea is broken
A sprinkler head in zone52 at columns 12 and WL-His coated with red paint.
RE MMENDATI N
Provide a label for the manualpull which indicates the hazardin fire zone 38.
Reinstall the existing coppertube vent lines onto the mainvent line.
Relocate the storage areawhich is currently in frontof the hose reel.
Provide a label for the manualpull stations to the C.R. CableVaults (Zones 57 and 58).
Readjust the cylinder rackingto firmly hold the haloncylinder.
Replace the gage with one whichhas a maximum limit not less thantwice the normal workingpressure.
Replace the sprinkler head.
2-2
N PA D D VI TI N/ PEN ITEMAI T NAN R MMENDATI N
(continued)
E TI N DEVIATI / P N TE R MMENDA I N
NF
2042 Several detection devicesand manual alarm stationsare exposed to potentialaccidential operationa. Hose system
manual stationat El. 620'nzone 44N; twosprinkler systemmanual stationsin zone 32 at El.
609'heappropriate corrective
actionshould be performedas follows:
a. Securely mountthe device.
NFPA 72E — 1 74
b. Fire detectorsare exposed tomechanicaldamage.
c. The valvetamper switchfor valve¹12-FP-37(zone 96, El.609') is notproperly mounted.
b. Reference NFPA72E, 1974Section 2-6.1.
c. Repair orReplace thedevice.
7-1.1 Several detectors were noted The appropriate actionas requiring maintenance. should be taken to correctThese devices are as follows: the deficiency and perform
spot sensitivity testingwhere required to confirmoperability.
From David E. Kipley (Zmpell) ~Bruce J. Gerwe (PHGF )
Please find attached the discussion for why the "EF"panel and manual alarm stations could not be providedwith a justification of an equivalency for being U.L.listed. Based on this discussion, these deficienciesmay be addressed by AEPSC.
The unapproved fire alarm devices have been compared againstthe applicable Underwriters Laboratory (U.L.) Test Standardto verify if these devices would meet the requirements ofthe applicable standard and could therefore be consideredequivallent to a U.L. Listed device. Based on the evaluationperformed, the devices listed did not meet the requirementsof the applicable standard for the following reason(s):Device Deviation
Rochester "EF"AnnunciatorPanel
a. The alarm initiating circuits are notelectrically supervised to initiate atrouble signal at the control panelshould a fault condition occur on thecircuit.
b.NFPA 72D requires that an automaticmeans of recording signals be providedto record all signals recieved by thecentral supervising station controlpanel. Since this panel is notprovided with this recording device,it cannot be considered equivallentfor use 'as an NFPA 72D fire alarmsignaling system.
Hose SystemManual Stationsand the ACIModel 446002Manual Start/Stop Stations
These manual stations did not, meet thereqiurements of this U.L. Test Standarddue to the lack of a latching feature ofthe alarm contacts and the activationmechanism to provide a positiveindication that the device has beenactivated.
The U.L. Test Standards referenced include the following:a. U.L.Standard 864 for the Rochester "EF" Panel.
Please find attached the subject technical evaluations for your reviewand approval. These evaluations were performed to provide documentedjustifications for the deviations identified by Impell Corporationdur'ng the review of the fire protection systems installed at the CookPlant ~
This evaluation package includes the evaluations and a cover sheetwhich identifies the evaluations attached by'he NFPA Code and codesection deviated. This cover sheet also contains the "prepared by"and "reviewed by" signature spaces. As discussed previously, thedocuments will require the review and approval by the fire protectionstaff prior to being issued.
DEK/ems
Attached
cc: P. G. Schoepf - w/o attachmentA. B. Auvil - w/attachmentJ. D. Grier/B. J . Gerwe - w/attachmentFile: Appendix R Audit Preparation
TECHNICAL JUSTIFICATION PACKAGE
FOR NFPA CODE DEVIATIONS IDENTIFIED BY
IMPELL TECHNICAL REPORT NO. 09-0120-0123
This package includes the )ustifications for deviations to NFPA CodeSections identified during the review of the fire protection systems atthe D.C. Cook Nuclear Power Plant by Impell Corporation. These)ustifications include the following:
NFPACode
CodeEdition
CodeSection
Number ofEvaluations
12 1968 122
12 1968 134 g 165 g 254and 255
12 1968 1436, 16321634
12A 1977 1-5.4 and 1-7.4
12A 1977 1-8.5.1
13 1971 1141
13 1971 3241 and 3783
13 1983 1-9.2
13 1983 4-1.1.1 and 4-1.1.4
13 1983 4-2.4.6
13 1983 3-17.4.5
13 1983 4-4.13
13 1983 4-4.19
Page 1 of 3
NFPACode
CodeEdition
CodeSection
Number ofEvaluations
14 1971 322, 421
14 1978 3-2.2, 4-2.1,4-3.2 and 1-11.3
14 1986 4-4.3.1
14
15
1971
1973
511 and 524
2031 and 4072
15 1973 4011 g 4032bg 4081 g
4082dg 4101 g 4102 g
4103, 5023 fc 7000
15 1973 4081
15 1973 4101 ~ 4102 g 4103
15 1973 4121
72D 1967 2154
72D 1967 2223
72D 1967 2251 and 2331
72D 1967 2341
72E 1974 2-F 1
72E 19741978
2-6.5 and4-4.2
72E 197419781982
4-3.1 and 4-3.2
Page 2 of 3
NFPACode
CodeEdition
CodeSection
Number ofEvaluations
72E 19741978
2-6.5, 2-6.7 and4-1.2
72E
72E
72E
1984
1974
1974
4-3.5.1.1
4-4.1, 4-4.5.2,4-5.1, 4-5.1.5
4-4.6
72E 1978 4-3.7.2, 4-3.7 '
72E 1974 5-3.2, 5-4.1,5-4.2 and 5-5.1
72E 1974 5-5.2
PREPARED BY:
REVIEWED BY:
Page 3 of 3
CODE4-3.DEK
NFPA 12 1968 Edition Code Section 122
Deviation: The pilot cabinets (EMPC) for the C02 systems locatedin the diesel ramp corridors (Fire Zones 79 and 85)and outside of Fire zone 42A and 46A, may exposepersonnel operating the manual mechanical actuatorsduring a discharge, to a hazardous atmosphere by thereduction of the oxygen concentration in the area.
In addition, the vent lines at the EMPC cabinetslocated in the CO2 Tank Room (Fire Zone 44N) aredisconnected and vent C02 directly into this room.
Justification: The only time the manual actuators on the EMPCdevices would be used would be during the 18-monthsurveillance testing or during an actual firecondition. Both the CO2 system surveillanceprocedures and the fire brigade training proceduresrequire the appropriate monitoring of oxygen levelsand restriction of personnel access to areas adj acent to thespace where the CO system has discharged. These procedureshelp to minimize tie potential to de'crease personnelsafety. Therefore, the placement of the EMPC devicesare acceptable.
References:
A review .of AEPSC calculation DCCFP12C09F indicatesthat a minimal amount of C02 agent will be ventedinto the CO2 Tank Room during a single fire event dueto the vent lines being disconnected. Based on thiscalculation, however, this condition will not presenta hazardous environment for operating personnelentering the C02 Tank Room.
Justifications: The original CO system discharge nozzle configurationhas been modified to accommodate the connection of aHalon 1301 system. The Halon and CO systems sharecommon branch lines within each individual fire zone.Design Packet RFC 12-2624 deleted several nozzles andreplaced another five nozzles on these common branchlines with nozzles designed for use by both CO and Halon1301 systems. A review of successful pre-operationaltest results for the Unit 1 and 2 Control Room CableVaults, indicates that an additional amount of agent,approximately 2000 lbs. for Unit 1 and 1700 lbs. for Unit2, is being discharged into the cable vaults above 2745lbs. calculated to achieve the required concentration foreach individual unit. Although the nozzle quantity hasbeen modified slightly, the piping arrangement hasremained unchanged from when the pre-operational testswere performed. Therefore, the required agentconcentration will be achieved throughout the space asrequired. Zn addition, the CO systems are verified fortheir operability every 18 months by "Puff" tests.
NFPA 12 1968 Edition Code Section 1436 1632 and 1634
Deviation: Documentation for the equipment listed was not availablefor review to confirm compliance with the referenced codesections. The data required is the following:
1436 Documentation to verify that the Electric-MechanicalPilot Cabinet (EMPC) manual controls do not requirea force of 40 lbs. with a travel distance of 14" foroperation of the system.
1632 Documentation to verify that the hydrostatic test& pressures and equivalent lengths of valves installed
1634 are acceptable for use in the systems provided.
Justification: Based on the review of the Record of Conversation memodated 6/8/88 and the Factory Mutual (FM) System ApprovalGuide, the following conclusions verifying compliance ofthese devices with the applicable code sections are:
1436 Documentation was not available from themanufacturer to confirm that the EMPC cabinets metthe requirements of this code section. Thesecabinets however, are FM approved for use in thecarbon dioxide fire suppression system installed atthis plant. These cabinets have been tested by FMto verify that they will properly operate the COsystem in an emergency situation as required by kFPA12. Therefore, these cabinets are acceptable foruse in this system.
1632 Based on the data retreived and documented in the& Record of Conversation dated 6/8/88, the C02 system
1634 selector valves manufactured by ChemetronCorporation for use in their CO systems meet therequirements of these code sections for the minimumhydrostatic test pressures and equivalent lengthsfor use in these systems. Xn addition, these valveshave been tested and approved by FM for use in theseC02 systems. Therefore, these valves are consideredacceptable for use with the systems installed in theareas reviewed.
Based on the evaluation discussions above, these devicesare considered acceptable for use in the C02 systemsreviewed.
Reference: -Record of Conversation dated 6/8/88 between D. E. Kipley(Impell) and S. Dometravich (Chemetron)
-Factory Mutual System Approval Guide, 1987 Edition
CODE1-5
NFPA 12A 1977 Edition Code Sections 1-5.4 & 1-7.4
Deviation: Documentation reviewed for the results of theconcentration testing performed for the Halon 1301fire suppression systems installed for the Unit 1&2Computer Rooms (Fire Zones 71&72) at elevation
650'f
the Auxiliary Building, indicated that the testswere unsatifactory.
Justification: Based on the review of the letter from J.D. Grier toETC. Schimmel dicussing the results of the retestingof these systems to confirm that these systems arecapable of achieving and maintaing the requiredconcentration, are considered acceptable. Asdicussed in the letter, Unit 2 Computer Room (FireZone 72) succesfully passed the testing performed.Unit 1 Computer Room (Fire Zone 71) did not maintainthe concentration for the full ten minute periodthroughout the space. Based on the justificationdicussion however, this system is considered
acceptable'eference:
-Letter discussing Comput: er Room concetrationtest results from J.D.Grier (AEPSC) toE.C. Schimmel (?&M), dated 5/13/88
On February 29, 1988, the Halon Concentration Test vas conducted for theUnit 1 P-250 Computer Room Halon System. The results vere transmittedto AEPSC via a March 2, 1988 memo from E. C. Schimmel to J. D. Grier.The Unit 2 P-250 Computer Room Halon System Concentration Test wasconducted on April 12, 1988 and the results transmitted via a April 13,1988 memo from E. C. Schimmel to J. D. Grier.
The results of both concentration tests have been reviewed and foundacceptable.
Based on the following, it has been determined that even though theminimum criteria of maintaining a 5% Halon 1301 concentration for 10minutes was not met- at one of the probe locations in the Unit 1 test,both concentration tests are acceptable.
1) The results at the other probe locations surpassed the minimumcriteria.
2) The requirement to maintain the halon concentration for 10 minutesis derived from the NFPA Standard 12A guidance for control of adeep-seated fire.
3) It is considered highly unlikely that a deep-seated fire couldoccur at the location of the probe which did not meet the criteria.
4) Host surface fires are promptly extinguished by achieving therequired concentrations of Halon 1301.
5) Test results shov that the concentration was maintained for greaterthan 5 minutes which should be sufficient to allow the embers of asurface fire and even some deep-seated fires to be extinguished.
I discussed the results of the halon concentration tests withM. S. Broeker (ANI). He was aware of the concentration not beingmaintained at the one probe for 10 minutes. Mr. Broeker's initialresponse was agreement with the above, and he indicated he would let meknow after a further review if he did not agree.
J. D. Crier
JDG/ems
cc: M. S. Broeker - ANIP. G. Schoepf (MED 88-20-1)W. G. Smith, Jr. - Bridgman
CODE1-8.DEK
NFPA 12A 1977 Edition Code Section 1-8.5.1
Deviation: Documentation was not available to confirm the presenceof discharge alarm signaling devices within the Unit 1(Fire Zone 57) and Unit 2 (Fire Zone 58) Control RoomCable Vaults at elevation 625'-10" of the AuxiliaryBuilding.
Justification: The review of the Record of Conversation memo dated6/7/88 and drawings 12-5153L, 1&2-98982, 2-98981 and1&2-95937 verifies that the common CO2 and halon systemdischarge piping header pressure switches, interface withauxiliary alarm relays to activate alarm signalingdevices (alarm bell) installed within each individualfire zone referenced above.
Therefore, the alarm signaling required for alertingoperating personnel of an impending discharge of thehalon 1301 fire suppression system within Fire Zones 57and 58 has been provided and is considered acceptable.
Deviation: Documentation was not available to verify whether theflooring was watertight as required by this code section.
Justification: An evaluation (Inadvertent Actuation Study, InformationNotice 83-41) is currently being performed to identifyinadequacies in the design of fire suppression systemswith respect to causing damage to safety related systems.This evaluation will identify vulnerabilities to safetyrelated electrical equipment due to sprinkler sprayimpingement and flooding caused by sprinkler systems.Deficiencies identified during this evaluation will beaddressed by performing modifications where required tocorrect these items.
This evaluation is being coordinated by the NuclearSafety and Licensing Division of American Electric PowerService Corporation.
Based on the completion of this evaluation andmodifications as required, this condition will beconsidered acceptable.
Reference: -Inadvertent Actuation Study, Information Notice 83-41memo dated 2/2/88 from R. S. Papps/J . Belier toJ. A. Kobyra/A. B. Auvil
NFPA12.DEK
Vault (Fire Zone 58)automatic sprinkler riser, located at Column Lines WL-7.4and H, on elevation 609'-0" of the Turbine Building isprovided with a Viking Model B-3 retarding chamber whichdirectly discharges water onto the Turbine Building floorwhich contains numerous unsealed penetrations.
NFPA 13 1971 Edition Code Sections 3241 and 3783
Deviation: The Unit 2 Control Room Cable
Justification: The review of the manufacturer's data sheetindicates that an 1/8" orifice is provided for thedrain of the retarding chamber. Upon reviewing NFPA 13,1983 Edition, Appendix A, Section A-3-16.5 it can bedetermined that an 1/8" orifice at 100 psi will dischargeapproximately 7 GPM. Since safe shutdown cables andequipment are not located adjacent to the systemriser or directly below the riser on elevation587'-0", as verified by reviewing the Safe SystemShutdown Analysis (SSSA) and the amount of waterbeing discharged is minimal, this condition isconsidered acceptable.
References: -NFPA 13, 1983 Edition-SSSA Volume 1, Output 2-SSSA Volume 2, Output 7-Viking Data Sheet "Retarding Chamber Model B-3"
CODE1-9.DEK
NFPA 13 1983 Edition Code Section 1-9.2
Deviation: The hydraulic design density data required on thesprinkler system as-built drawings has not beenprovided.
Justification: A review of the as-built sprinkler installationdrawings indicates that some of these drawings doprovide the design data required. Where this data isnot provided on the drawings however, the drawingsreference the hydraulic calculations which indicatesthe design density data on the front cover sheet ofthe calculations. Therefore, this data has beenprovided as required by reference on the drawings tothe calculations.
Based on the review of evaluation discussion above,the drawings have provided the data as required bythis code section.
Reference: -Grinnell Hydraulic Calculations for Contract No.1463.032-B7 & 1463.032-137
Deviation: Non-indicating type isolation valves are used in thealarm test bypass and the waterflow alarm pressure switchtrim lines for the sprinkler system alarm valves of thesprinkler systems reviewed.
Justification: A review of the Record of Conversation Memo dated 6/7/88;indicates that a recent revision to surveillanceprocedure 12 OHP 4030 STP.120VV has incorporated therequirements to verify the position of these valvesduring the performance of the surveillance. The valveposition is verified by the valve being sealed in theappropriate position.
Based on the verification of the valve position duringthe performance of this surveillance, an equivalency forindicating type valves can be made due to the valvesbeing sealed in their appropriate position, thusproviding a method of indication.
Reference: -Record of Conversation between D. E. Kipley (Impell)and D. Bruck (I&M), dated 6/7/88
NFPA 13 (1983 Edition) Code Section 4-1.1.1 and 4-1.1.4
Deviation: A sidewall sprinkler water spray pattern is partiallyobstructed by fire main piping which is located directlybelow the sprinkler. The sprinkler is located in FireZone 44N at column lines WL-L.1 and HL-4.9 on Elevation609'f the Auxiliary Building.6
Justification: A walkdown of the plant the week of 4/4/88 was performedto confirm the deviation and combustible loadingconfigurations in Fire Zone 44N. The walkdown verifiedthat the sidewall sprinkler in question was installedsuch that the water spray of the sprinkler would notprovide protection for the area dizectly below thesprinkler. The intent of the sprinkler was to provideprotection in the immediate area in front of thesprinkler beneath the heavy conduit and HVAC ductcongestion. The sprinkler is located along the normalpath of egress out of the Auxiliary Building and isafforded mechanical damage protection by the fire mainconfiguration. The configuration of the fire main willrestrict storage of transient combustibles directly underthe sprinkler, therefore, limiting the potential of afire occurring there. A review of the data sheet for thesidewall sprinkler indicates that the water spray patternis primarily discharged up, out, and back toward thewall. This type of trajectory of the water will aid inproviding coverage for the limited area obstructed.
Currently there is some limited spray pattern obstructiondue to the heat collector side shields for thissprinkler. However, additional sprinklers have beeninstalled at the ceiling and beneath the heavy conduitand HVAC duct congestion to assist in providing adequatesprinkler protection for the area. The heat collectorside shields have been identified as an obstzuction andwill require a modification.
Based on the evaluation discussion above, the currentsprinkler installation is considered acceptable.
NFPA 13 (1983 Edition) Code Section 4-1.1.1 and 4«1.1.4
Deviation: Two (2) upright sprinkler water spray patterns arepartially obstructed by an HVAC duct at column lines WL-Land WL-4.4 and WL-K.7 and WL-4.4 in Fire Zone 44N onElevation 609'f the Auxiliary Building.
Justification: A walkdown performed the week of 4/4/88 at the plantverified that (2) sprinklers were installed at theceiling. The sprinklers are located 1'-6" and 2" awayfrom the side of a 6'ide duct. The HVAC duct islocated approximately 3'rom the wall. The water sprayfrom these sprinklers will provide protection in theimmediate area between the duct and the wall only. Therewere, however, (2) upright sprinklers located under the6'ide duct which are approximately 3.5'orizontallyfrom sprinklers in question. These sprinklers have aspray pattern which will adequately provide protection inthe immediate area in addition to the limited protectionprovided by the obstructed sprinklers. Additionalsprinklers were also installed at the ceiling on theopposite side of the duct which will provide additionalprotection in the immediate area.
Based on the review of the sprinkler protectionconfiguration, adequate protection is provided in thearea discussed and the sprinkler arrangement isacceptable.
Reference: -AEPSC Drawing 12-5717-8, 9/27/85
CODE4-1.DEK
NFPA 13 (1983 Edition) Code Section 4-1.1.1 and 4-1.1.4
Deviation: An upright sprinkler water spray pattern is obstructed bya 3/4" conduit drop in Fire Zone 17E on Elevation 587'tcolumn lines 6.9 and WL-5.9 of the Turbine Building.
Justification: A walkdown performed the week of 4/4/88 at the plant,confirmed the partial obstruction of the spray pattern bythe 3/4" conduit drop for a light fixture. The conduitwas measured to be 4" laterally from the sprinkler. CodeSection 4-2.4.5 of NFPA 13, 1983 Edition discusses barjoist web member obstruction limitations. Based on thediscussion, a 1/2" diameter web member would require thesprinkler to be spaced laterally at least 3" away and aweb member not exceeding 1" in diameter shall be spacedat least 6" laterally from the sprinkler. From thi.s datawe can assume that a 3/4" diameter web member wouldrequire a lateral sprinkler spacing from the member of 41/2". As determined by the walkdown, the sprinkler islaterally spaced 4". from the 3/4" conduit. Therefore,the, water spray obstruction will be negligible. Znaddition, the spri.nkler spacing is such that the waterspray from adjacent sprinklers will aid in providingadequate protection of area.
Based on the review of the evaluation discussion above,the configuration of the sprinklers in this fire zone isconsidered acceptable.
Deviation: The sidewall sprinklers that are installed 10'bove thefinished floor in Fire Zone 52 on Elevation 633'f theAuxiliary Building at column lines WL-L.3 and WL-7.7 toWL-8, have obstructed water spray patterns due tonumerous conduit and cable tray interferences. Thesesidewall sprinklers are located 6.75'nd 9'rom thesoutheast corner of the Unit 2 Control Room wall.
Justificat ion: A walkdown of the plant was performed the week of 4/4/88to confirm the combustible loading and sprinklerconfigurations in this area. The water sprayinterferences consist of MCC panel 2-AM-D which is
8'ighand is located 5.5'ast of the west wall of FireZone 52 at column line WL-L.3. Two cable trays have beenstacked on top of the MCC panel to increase theinterference height to 9'bove the finished floor (AFF).Numerous conduits have been routed along west wall ofFire Zone 52, from 9'FF to 11'FF. A 4'ide HVACduct with the bottom of the duct being 10'FF, islocated 5.25'ast of the west wall in Fire Zone 52 atcolumn line WL»L.3. The water spray interferences occurbehind the MCC panel where the sidewall sprinklers are located. Although NFPA 13, Section4-4.13 does not require protection under a 4'r lesswide duct, the water spray pattern interferences of thetwo sidewall sprinklers are such that protection may notbe provided in front of the MCC panel and under the ductin that immediate area. The sidewall spray pattern willprovide adequate protection behind the MCC panel wheredue to this panel placement, access to this area islimited. Upright automatic sprinklers are also installedat the ceiling directly over the top of the MCC panelwhich will provide protection for the for the MCC paneland cable trays in that immediate area. Since the MCC
panel is installed immediately ad)acent, the normal pathof travel in the fire zone and the area immediately infront of the MCC panel is identified as being a "ClearArea", storage of transient combustible in this areashould not occur. Therefore, exposure fires in front ofthe MCC panel from transient combustibles is highlyunlikely.
Based on the review of sprinkler configuration in thisarea, adequate sprinkler protection will be provided forthe combustibles present in this area.
Reference: -Viking Sidewall Sprinkler Model C-4 Technical DataSheet
-NFPA 13, 1983 Edition
NFPA13.DEK
NFPA 13 1983 Edition Code Section 4.2.4.6
Deviation: Upright sprinkler water spray patterns are partiallyobstructed by beam construction at two locations in FireZone 52 on Elevation 633'f the Auxiliary Building. Thefirst location is at column lines WL-K.6 and WL-3.5 andthe second location is at WL-K and WL-3.5.
Justification: A walkdown performed the week of 4/4/88 at the plantconfirmed the sprinkler and combustible loadingconfigurations in these areas. The upright sprinklerslocated at the .ceiling at column lines WL-K.6 and WL-3.5are installed within 3" of a 12" deep beam. Theseobstructed sprinklers are located above the HVAC unit1-HV-ASl.
Due to the location of the sprinklers with respect to thebeam, the beam will obstruct the sprinkler dischargepattern. However, to compensate for this obstruction,sprinklers were placed on the opposite side of the beam.The two branch lines are only 4 feet apart, therefore,providing adequate coverage to the area.
Obstructed upright sprinklers are also installed aboveHVAC unit 1-HV-AS2 near column lines WL-K abd WL-3,5.The sprinklers are located at the ceiling within 3.5" ofan 18" deep beam. The water spray pattern of thesprinklers will be obstructed by the beam due to thedepth of the beam and the distance of the sprinkler fromthe beam. Sprinklers were, however, installed on bothsides of the beams and two side wall sprinklers were alsolocated in this area approximately 10'bove the finishedfloor. The presence of these sprinklers will provideprotection required for this area.
Based on the evaluation discussion above, theconfiguration of the sprinklers provided are consideredto be acceptable.
Reference: -Viking sidewall sprinkler model C-4 technical datasheet.
Deviation: Automatic sprinklers have not been installed under a6'ide
HVAC duct at column lines WL-L.5, between WL-3.5 toWL-4.5 in Fire Zone 52 on Elevation 633'f the AuxiliaryBuilding.
Justification: A walkdown of the plant was performed the week of 4/4/88to verify the configuration of the combustible loadingand the automatic sprinklers for the area in question.The walkdown confirmed that sprinklers were not placeddirectly under the duct at column WL-L.5. There were,
. however, sidewall sprinklers installed along the westwall of Fire Zone 52 at column line WL-L.3. Thesesprinklers are located 9'bove the finished floor (AFF),10'n center and 13.5'ast of column line WL-L. Areview of Phoenix drawing No. A633N, Sheet 33 alsoverified the installation of a sidewall sprinkler underthe 6'idq duct. This sprinkler was locatedapproximately 13.5'orth of column line WL-4 and
17.25'astof column line WL-L. The spray trajectory will beprimarily under the duct. The HVAC duct bottom islocated 10.5'FF with the west side of the ductinstalled parallel with column line WL-L and 17.5'astof this line. The HVAC duct is installed directly overthe normal path of travel which will make the storage oftransient combustibles under this duct highly unlikely.
The area required to be provided with protection by thesidewall sprinklers will require a minimum water spraytrajectory of 10'. The review of the Viking Model C-4sidewall sprinkler Data Sheet indicates that the sidewallsprinklers will deliver a forward water spray trajectoryof 20'ased on 15 psi at the sprinkler. Zn addition,these sprinklers will also deliver a 16'ide trajectorywater spray pattern based on this pressure. The Phoenixcontractor's hydraulics calculation indicates that themost remote sprinkler will be provided with 16.1 psi.Therefore, the sidewall sprinklers will provide properprotection under the 6'ide duct with the water spraypattern that will be developed for the most conservativecondition.
Based on the discussion above, the area under the 6'ideduct is being properly protected and is considered to beacceptable.
Reference: -Viking sidewall sprinkler Model C-4 technical datasheet
Deviation: Two (2) sidewall sprinklers installed under a 6'-0" wideHVAC duct at column lines WL-K.5 and WL-3.9 in Fire Zone52 on Elevation 633'f the Auxiliary Building areinstalled 12" apart and are not provided with baffleplates.
Justification: The walkdown performed the week of 4/4/88 at the plant,verified the configuration of the sidewall sprinklers.The sprinklers are installed with the sprinklerdeflectors facing away from one another so that the waterspray pattern of one sprinkler will not wet the othersprinkler which cause a delayed response. Since thesprinkler configuration will not present this delayedresponsepotential, baffles will not be required and theinstallation is considered acceptable.
Reference: -Viking sidewall sprinkler Model C-4 Technical DataSheet.
Deviation: Several hose stations located within the AuxiliaryBuilding on elevations listed below, are providedwith hose lengths greater than the maximum length of100's required for Class II hose stations.
Zone Elevation Hose Station
33A34A130
5252
13097
12990
612'12'33'33'33'33'09'33'09'03
20781826567457958
Justification: Based on the revie~ of the hydrualic calculationsperformed by AEPSC, these hose statons are providedwith adequate waterflows and pressures required tosupport fire fighting activities with the exceptionof Hose Stations No. 65 & 82. These hose stationshowever, are being upgraded to provide 2 1/2"diameter hose on the spare hose reels, (65A & 82A)located adjacent to the primary hose reels, in lieuof the 1 1/2" hose existing. This upgrade, performedunder RFC No. 12-2983, will provide the waterflow andpressures required to support the fire fightingactivities necessary. Although this hose exceeds therequired diameter (1 1/2"), the justificationdiscussion for NFPA 14, 1971 Edition, Code Section321 that only trained personnel (fire brigade) usethis equipment, will also apply to the use of 2 1/2"diameter hose.
Based on the review of the evaluation discussionabove, the physical configuration of the fire hosestations for the fire fighting activities requiredare considered acceptable.
Deviation: Documentation was not available to verify theadequacy of the water supply for the hose stations.
Justification: Based on the review of the hydraulic calculationsperformed by AEPSC, the waterflows and pressuresrequired for fire fighting activities are adequatewith the exception of Hose Stations 65, 82, 209 &210. These hose stations however, are being upgradedto correct this deficiency under RFC No. 12-2983, byreplacing the existing 1 1/2" hose with 2 1/2". Thisupgrade will provide the waterflows and pressuresrequired to support fire fighting activities in theseareas.
Based on the review of the evaluation discussionabove, the ~ater supply provided for the hosestations is adequate and is considered acceptable.
DCCFP02HS01F, Revision 0, 2/24/88DCCFP01HS02F, Revision 0, 2/24/88DCCFP02HS03F through DCCFP02HS13F,
2/24/88DCCFP01HS14F through DCCFP01HS23F,
2/24/88DCCFP02HS24F through DCCFP02HS26F,
2/24/88DCCFP01HS27F through DCCFP01HS30F,
2/24/88
Revision 0,
Revision 0,
Revision 0,
Revision 0,
CODE2031. DEK
NFPA 15 1973 Edition Code Sections 2031 & 4072
Deviation: The inspection of the charcoal filter units reviewedfor compliance with this code, indicated that thewater spray system nozzle spray for the charcoalfitler beds are obstructed by the filter unit housingand will not discharge water onto all filters presentin the unit.
Justification: A walkdown of the plant: was performed the week of4/4/88 and included the inspection of the Unit. 1&2Control Room filt:er units (1&2-HV-ACRF-1) located atelevation 650'f the Auxiliary Building. AmericanAir Filter Company drawings 107D-890251H and107D-914184E were also reviewed to confirm theconfiguration of the charcoal beds with respect to
'l the sray nozzles installed.
The water spray system nozzle configuration withinthese units are arranged to discharge water acrossthe entire surface of the charcoal filter beds. Areview of the ANI recommendations for charcoal filterunit protection, indicates that the charcoal filterbeds are the only filters within this type filterunit that are required to be protected with a .watersray system. This is due to the charcoal filter bedsbeing the primary combustible within these units andthe primary source of a fire. Since the charcoalfilter beds are protected as required, the waterspray system configuartion is acceptable asinstalled.
Based on the review of the evaluation discussionabove, the ~ater spray systems installed within thecharcoal filter units reviewed, are consideredacceptable.
Deviation: Documentation was not available to confirm theconfiguration or the adequacy of the water spraysystems installed within the charcoal filter unitsreviewed.
Justif ication: A walkdown of the plant was performed the week of4/4/88 to confirm the configuration of the water spraysystems installed within the charcoal filter units.The only charcoal filter units that could be inspectedincluded the Unit 1 & 2 Control Room filter units(1-HV-ACRF-1 & 2-HV-ACRF-1). The inspection confirmed theconfiguration of the nozzles being properly placed todischarge water across the entire surface of the charcoalfilter beds as required by the ANI recommendation criteria.
The inspection of these units also verified thatpiping support configurations consisting of angle ironsupports attached primarily to the filter unithousing, with U-Bolt mechanical fasteners. The U-Boltfasteners fix the spray system piping to the angleiron supports to adequately support the piping system.Although only two units were accessible during thewalkdown, both units were typical of one anotherpresenting the evidence necessary to make the generalassumption that all the water spray piping systems forthe charcoal filter units are, typically supported in asimilar fashion.
Sketches of the Control Room water spray system pipingand support configurations have been prepared toprovide documentation for future reference. Inaddition, hydraulic calculations and sketches for thewater spray systems installed within the two largestcharcoal filter units (1-HV-AFX-1 & 2-HV-AES-1) havebeen prepared by AEPSC. Based on the review of thesecalculations, an adequate water supply with the properpressures available at all nozzles installed, isprovided for these water spray systems. Since thesewater spray systems are similar in configuration tothe larger systems being calculated, it can be assumedthat the water spray systems installed in smallerfilter units will provide the waterf low and pressuresrequired to provide adequate discharge patterns fortheir nozzles.
Based on the review of the evaluation discussionabove, the charcoal filter unit water spray systemconfiguration is considered acceptable.
-AEPSC System Description SD-DCC-FP101, Revision 1,2/19/87
CODE4081.DEK
NFPA 15 1973 Edition Code Section 4081
Deviation: The supply piping for the charcoal filter unit(12-HV-SATFU) for the Spray Additive Tank Room (FireZone 61) is a smaller diameter pipe (3/4") than theone inch minimum diameter required by this codesection. This filter unit is located on the elevatedplatform in the northeast corner of Fire Zone 5. FireZone 5 is located at elevation 587'f the AuxiliaryBuilding.
Justification: The review of Charcoal Service Corporation DrawingH8-1181, indicates that Charcoal Filter Unit12-HV-SATFU is provided with three charcoal filterbeds that are protected by a manually connected andactuated water spray system. The square foot area ofthe filter beds for filter unit 12-HV-SATFU are 6square feet as documented by the referenced drawing.This drawing also indicates that four spray nozzleshave been installed within this filter unit to providesuppression capabilities for the filter
beds'ased
on the review of the ANI criteria forprotecting charcoal beds, a density of .25 GPM/FT2 isre'quired to provide adequate protection of the filterbeds. Since each bed surface area is 6 FT2, than 1 ~ 5GPM of water is required for each spray nozzleinstalled. Since only four nozzles are providedwithin filter unit 12-HV-SATFU, than a total of 6 'GPM is required for the water spray system installed.A review of Automatic Sprinkler Hydraulic DataTable for Black Steel Pipe, indicates that a 3/4"black steel pipe can deliver a maximum flow of 31GPM. Therefore, this 3/4" supply pipe will adequatelyprovide the waterflow required to control a firewithin this filter unit.
Based on the review of the evaluation discussionabove, the installation configuration of the waterspray system for Charcoal Filter Unit 12-HV-SATFU isconsidered acceptable.
Deviation: The inspection of charcoal filter unit 1-HV-CIPX-1located in Fire Zone 33A at elevation 612'f theAuxiliary Building, identified an improper pipesupport installation of the water spray system pipingto the filter unit.
Justification: A hanger rod for the water spray piping system waswelded directly to the system piping to act as amethod of supporting the pipe". A walkdown of the Unit1 & 2 Control Room filter units performed the week of4/4/88, indicated that this pipe supportconfiguration is not consistent for all the filterunits and is considered an isolated condition.
A review of the Fire Hazards Analysis, has indicatedthat this filter unit is not required for safeshutdown of the plant and is considered to beNon-Safety Related equipment. Therefore, therequirement seismic supporting of the piping is notrequired. In addition, the Fire Hazards Analysis alsoindicates that the filter unit water spray system ismanually operated thus preventing the potential for anuncontrolled activation of the system where the systempiping may be damaged by a water hammer effect. Should anunlikely failure of the piping system occur, operatingpersonnel will be present to manually shut the system downand take steps to provide alternate suppression capabilities(hose stations).
Based on the review of the evaluation discussionabove, this pipe support configuration is adequatefor this system's installation and is consideredacceptable.
Deviation: Pressure gages have not been installed for thecharcoal filter units and the H2 Tube Storage Rackwater spray systems within the areas reviewed.
Justification: The purpose of these gages are to provide a means bywhich the integrity of the system piping and systemperformance can be verified. A review of the FireProtection System Description (SD-DCC-FP101)indicates that the water spray systems referencedabove are open nozzle type spray systems that areeither activated manually (filter unit systems) orby dry pilot sprinklers (H2 rack system).
Therefore, the requirement for Code Section 412lc forhydraulically controlled systems is no longerapplicable based on the description above. Therequirement for Code Section 4121b, d, & e for airpressure supervision are not applicable based on thejustification discussion in NFPA 72D, 1967 Edition,Code Sections 3441, 3442 & 3443, Justification b.
The requirement (Code Section 4121a) for verifyingthe performance of the systems by providing a gage onthe supply side of the automatic valve however, isapplicable. Calculations performed by AEPSC for thecharcoal filter unit water spray systems and byGrinnell for the H2 Rack water spray systems,verifies the performance of these systems byconfirming that the waterflow and pressures requiredat nozzles are adequate for providing the properwater spray discharge patterns. Therefore, gages donot significantly enhance the fire protectioncapabilities of these systems and are not considerednecessary.
Based on the review of the evaluation discussionsabove, the lack of gages installed on the charcoalfilter unit and H2 Rack water spray system risers, isconsidered acceptable.
-Grinnell Calculation, " The H2 Bulk StorageTanks", Revision 1, 12/18/71
-Spraying Systems Co. "Unijet" spray nozzle Model 3/8TT9540, Catalog No ~ 29A, pages 22 & 23,1973 Edition
CODE2154.DEK
NFPA 72D 1967 Edition Code Section 2154
Deviation: Documentation was not available to confirm that thealarm initiating and signaling circuits and cablesinstalled for the systems reviewed, have met thecriteria required by this code section for limitedenergy cable.
Justification: The review of the Record of Conversation memos dated6/8/88 and 6/9/88 in addition to the drawingsreferenced below, confirms that the alarm initiatingand signaling circuits and cables installed for theChemetron C02, Pyrotronics system 3 and FIU systemsand the Rochester "EF" annunciator panels, meet therequirements of this code section with theexception of the requirement that the cables beapproved for the application of a limited energycable.
A review of the cable description telex dated 3/16/88forwarded to Impell from AEPSC, indicates the type,size and quantity of conductors for selected cables.The description of the type of insulation is alsoprovided. The cables reviewed meet or exceed therequirements of Code Section 2155 which provides therequirements cable characteristics.
Based on the review of this documentation, anequivalency can be made that the cables reviewed,will meet the requirements of Code Section 2155 dueto the attributes of the construction features ofthese cables.
Since the circuit characteristics for the alarm systemmeets the requirements of Code Section 2154 and anequivalency has been made to confirm compliance withthe requirement for an "approved " cable as verifiedunder Code Section 2155, these cables are consideredto be acceptable for use in the alarm system asinstalled.
Reference: -Record of Conversationsa. D.E. Kipley (Impell) and S. Dimetravich
(Chemetron), dated 6/8/88.b. D.E. Kipley (Impell) and D. Deipalmer
1 Qpggf2 'ZS~Vul kene/Asbestos Braid.FPR/CSPE, ar CSPE/CSF'E
5125 15 Conductor fl2 7-Stranded copper, 600Vinsul at i on XLPE/Asbest as &rai d,Vulkene/Asbestos Brai d, XLPQ/Hypal on f orEPA/CSPE
Cable Number 1775$ -I is Item 83120 air eady l i sted abave.
~Nates There are various insulation types listed for certa>ncables. This is because there were various purchases of thecables cade and dependinq on who we ordered the cable fromusually determined the type of insulation. I can not find whatthese insulation descriptions are but I can give you who thepurchasers wercs
XLPQ/HypalortQkoauard/OkooreneVLF'KffAsbestos Or ai dVul keoe/Asbestos Bra
~ ~ .Plastic Mire Co, Col lyer Ca., GeneralCab l e Co., Essex Int.
~ ~ ~ Pai qe Electric,Coll yer Co, Essex IntGeneral Cabl e Go.
~ ~ e Anac onda, Cant inen t a l~ ..Okonite~ ~ . Cyprus. Esse.". Int ~
...Anaconda . t'~nt i ner>t a 1
...American Insulatec Hire~ ~ .American Insulated Hire...Cantinerital Hire
FVC jacket .....,Samuel Jloore,f'rianqleaG. E.
...ETCH.Continental
...Samuel Moore (Eata~),CERRQ... B IW.Anaconda
...Flackbestos,Samuel encore (Eaton)
...Qlfonite
...Continental4da ~ ~ ~ ~ GsKe
Hopeful }y the manuf acturers catalogues/rear eseotati ves can giveyou some further irffarmatian on the materi al s i f you need them.If yau have trouble, give me a call.
~ ~ ~
wacko
for Class 1 Signal Systens except as etheririse pennoned inthis Article, or other Articles, of this Standard Rs~:icords of the described in Article 4N oC the NatonalRlectrical C shalt not be used.
~
")1'156.
Specked CablNN.
fQL Special cable approved foe the beused as detailed in Pai:agraphs N52, C $454>
~ 85QL
%$2. Low Vdtage Scat'~ Cahie for operathoa f'at 150 volts or less, shal constructed as foSoaa:
a. Conductors shall be of solM cojqer, aoC h'ss thaa ';-No. 14 AWG for single- and tvr~dactor cables. not lessthan No, 18 AWG for three- and four~iuctor cabieII,and not less than No. 22 A%'G for cables having arne thanfour conductors.
e
b. The individual conductors shall have approved in-sulation having a nominal thickness of not less than 1/82inch
c. The cable conductors shaH have a soM InetaNcsheath or a moisture-resistant and flane-retardant jacketylWldl~ 6 8 ip tali shet~blfwtto that obta saith nonmetalHc sheathed cable describedin the National EJe&ical Code.
t1$L The specked cables may be instaHed exposed on a'"
ceiHng and on a side mal ifnot less than V feet from thefloor and ifadequately protected against injury. Concealedcab'nd cable passed through a Boor or located on a sMeindi within 7 feet of the Hoor shall be hmrtaBed in conduitor other approved races~, unless solid metallic sheath isprovided. Cable shall be adequately supported and termi-nated in approved fittings.
2154. Lhnited Energy Applications.Approved cable meeting the requirements of Paragraphs
$ 155 and 2166 mav be used in circuits ha~~ energy limit-ing characteristics as follows:
a Circuit voltages not to exceed those shoinl in Column1 of Table 1.
b. Maximum fault currents desi~ed into the circuitnot to exceed those shown in Column 2 of Table 1.
l522
' )
T$9-10 ~iermr eyrrlcnv! aevmso stages
c. Nonlntemha ble overcurreat pWeeQoo pe fe ex-ceed that Ihom ig gnat 8 of Table $ .
d. Ene Hmitatiogs not to exceed those steep Sa Coi-umn 4 of a 1.
le 1
c
VeWego Riage9N450'51 199
61 1503140040
S-'eslasea Coal
J~ ncLfILl5t100 I
yeeieo4$ oo
LOOafAaVa
.S'-. II~ ".I:,key';;,
'.>tc,',')4.~
100 va (See Note)100 va (See Note)
Nore: Where batter's are used a reshtoc'hall be h. the cheart tolimit the fault current to that obtained frcia I $$ m ap-~M transformer of the same voltage output. RceU5ecs mdII II I lII
2155. Conductors of cable for use wRh Dmin emily"ii,'ircuitsshall be:
a. Solid copper, bunched-tinned (bonded) stranthd cop-per, or copper aDoys of equivalent tensile strength
b Not smjaHer than* l. 18 gauge single conductor copper
2. 1S gauge muM~nductor copperc. Covered by approved insuhtion having a 0.012 inch
nominal 0.010 hch minimum thickness for both the outside~
~
~
acket and the conductors. A single conductor caMe shallve a jacket not less than 0.036 inch nominal O.OSO inch
minimum thickness. Dvo or more conductors may be in 'J,~
Hat Bel construction with 0.023 inch nominal integral'nsulationjacket, minimum 0.020 inch and mth 0.081 inch
minimum web.d. The insulating compound shall have a temperature
rating not lcm than 105 C and the jacket compound shallhave a high degree of abrasion resistance.
215L Limited energy cable described in Patagnq)hs2154 and 2156 may be installed as follows:
a. Exposed on surface of ceiling and sidewaHs or"itched" in concealed spaces. Cable shall be adequately sup-
1523
CODE2223.DEK
NFPA 72D 1967 Edition Code Section 2223
Deviation: Documentation reviewed indicated that the powercables connected to the Alison Control panels A924from power panels 1&2-DAB, circuit 5, are under sizedfor the 35 AMP breakers provided.
Justification: Based on the review of the letter from E.A. Taylor toB.J. Gerwe, indicates that these cables are adequatefor the currents involved and are equivalent to theNo. 10 AWG. wire required. Therefore, these cablesare considered acceptable.
Reference: -Letter discussing the results of the evaluationperformed for NFPA 72D Code Section 2223 fromE.A. Taylor (AEPSC) to B.J. Gerwe (AEPSC), dated4/26/88.
An engineering evaluation was performed comparing a ¹7/18 to a¹10 cable. A ¹7/18 AWG wire is larger than a ¹10 AWG andtherefore the recommendation for upgrade to a ¹10 AWG isillogical.The other item requiring investigation, Code Section 2154 onenergy limitations, is awaiting further clarification fromImpell. I
paE fROr~criI.
This memo is in response to your request for information dated2/25/88. We have reviewed the recommendation on Code Section2223 dealing with the comparison of a ¹7/18 AWG cable vs. a ¹10AWG cable. The recommendation was to replace the ¹7/18 AWG witha ¹10 AWG.
Elizabeth Taylor
EAT/jj/84.53
Approved
~ ~
cc: T. 0. Argenta/S. H. HorowitzL. F. Caso/J. V. RuparelD. N. Turnberg/J. R. AndersonS. Z. Parsons/J. J. Kutys, Jr.FILE: Cables
CODE2251.DEK
NFPA 72D 1967 Edition Code Sections 2251 and 2331
Deviation: Documentation was not available to verify the adequacy ofthe Alison Control Incorporated alarm system powersupplies for control panel models A700-9, A909, A924,6007, and 7035 with the requirements of this codesection.
Justification: Alison Control Incorporated released the power supplydata required to confirm compliance with this codesection as documented by the Record of Conversation memodated March 17, 1988 between B. J. Gerwe (AEPSC) andF. Kimack (ACI).
These control panels, however, are not approved by anindependent testing laboratory for use as an alarmsignaling system which includes the power supplies forthese panels. An equivalency evaluation of these panelswas performed during the Code Compliance review for NFPA72D, 1967 Edition under Code Section 2032 to confirm thatthese control panels comply with the functionalrequirements of a UL listed alarm signaling system.
Based on the review of the memo, the evaluation performedfor the referenced code section, this equipment isconsidered acceptable for their application.
-Record of Conversation Memo between B. J. Gerwe (AEPSC)and F. Kimack (Alison), dated 3/17/88
CODE2341.DEK
NFPA 72D 1967 Edition Code Section 2341
Deviation: Documentation was not available for review to confirmthat the power supply transformers for the Pyrotronics,Alison Control and Rochester Alarm system panels areproperly protected for a rating not greater than thecontinuous duty rating of the transformer.
Justification: The continuous duty rating data required for confirmingcompliance of the alarm system power supplies wasavailable from the manufacturers referenced with theexception of Alison Control panel A909 and Pyrotronicsfor the System 3 and FIU panels as documented in Recordof Conversations dated 3/17/88 and 6/13/88. This was dueto the fact that these units are no longer beingmanufactured and the data is no longer readilyaccessible.
The Pyrotronics units have however, been tested for useas an alarm signaling system in accordance with theUnderwriters Laboratory (U.L.) testing criteria and havebeen listed by U.L. as such. The testing of these panelsincluded verifying the operability of these panels underadverse conditions and were found to be acceptable byU.L. Therefore, an equivalency can be made in lieu ofthe lack of data available for these panels based on theacceptance by U.L. for the use of these panels as alarmsignaling systems.
The power supply data for the Alison Control Panel A909is not available and cannot be retrieved. In addition,these panels have not been approved or listed for use inthese systems. These panels are however, verified inthese surveillance testing for their operability and havebeen operable since approximately 1974. In addition,these panels are connected to a DC volt power source thatis regulated and is, unlikely to produce surges in thepower thus potentially damaging the panel power supplyunit. Based on the discussion above, a justification canbe provided that the A909 panel's power supply isadequately protected as indicated by the length ofservice of these panels.
A review of the Record of Conversations dated 3/17/88 and6/9/88 and the drawings referenced below indicates thatthe remaining Alison Control Panels and Rochester "EF"alarm panels are adequately protected as required by thiscode section.
CODE2341.DEK
Reference: -Record of Conversationsa. B. J. Gerwe (AEPSC) and F. Kimack (Alison),
dated 3/17/88b. D. E. Kipley (Impell) and D. Deipalmer
(Rochester), dated 6/9/88c. D. E. Kipley (Impell) and F. Kanerath
Deviation: Several fire detectors are subject to mechanicaldamage due to the devices being installed less than7'bove the finished floor of the applicable firezone of the Auxiliary Building. The devicelocations are as follows:
Fire Zone Fire Zone Elevation Device
587 The line type heat detector forfilter unit 1-HV-SATFU is mounted onthe top of the unit and is exposed tomechanical damage outside the unitapproximately 8".
33 609'moke detectors 3-18, 3-21 belowplatform 639'-4", and 3-25, 3-28below platform 646'-9". Theinfra-red detector 3-17 at platform631'. These devices are typicallyinstalled less than 7'bove theplatform floor.
34 609'moke detectors 3-16 below platform631', 3-18 through 3-21 belowplatform 639'-4" and 3-25, 3-26 and3-28 below platform 646'-9". Theinfra-red detector 3-17 at platform631'. These devices are typicallyinstalled less than 7'bove theplatform floor.
38 609'moke detectors 7-5 and 7-7 arelocated in the mezzanine area of thiszone. infra-red detectors 16-3 and16-4 are also located in themezzanine. These devices aretypically installed less than
7'bovethe floor of the mezzanine.
39 609'moke detectors 2-5 is located in themezzanine area of this zone. Theinfra-red detectors 20-3 and 20-4 arealso located at the mezzanine.Typically these devices are installedless than 7'bove the floor.
41 6 45 609'moke detectors 13-7 through 13-9(Fire Zone 41) and 8-7 through 8-9(Fire Zone 45) are located in theunderfloor of these zones and areinstalled less than 4'bove the floor.
60 625'he infra-red detector 27-2 islocated on a column installed lessthan 7'bove the floor.
NFPA2-6.DEK
Justification: The location of these devices are such that they areinstalled in portions of a fire zone which arenormally not accessible due to physical orcontrolled limitations. The bases forjustifications are as follows:
Fire Zone Justification
The filter unit is located at thesoutheast corner of the platformwhich is located in the northeastcorner of Fire Zone 5 at elevation596'. This filter unit is locatedsuch that it is not in the normalpath of travel on the platform. Theheat detector is mounted on top ofthe filter unit and may be exposed todamage by tools used for maintenance.The construction of the heatdetector is of a stainless steelouter jacket surrounding a speciallyformulated ceramic core with aninternal conductor. Therefore, thisdetector is made of durableconstruction and is not susceptibleto mechanical damage. In addition,the device has been installed forapproximately nine years and thewalkdown confirmed that the detectordid not show signs of damage.
33 & 34 The smoke and infra-red detectorslisted are typically located inareas where valves, piping or withinpockets of platform structuralmembers will provide protectionfor the detectors located out of thenormal path of travel in theimmediate area.
38 & 39 The infra-red and smoke detectorslisted are typically installed overcable tray routing, out of the normalpath of travel in these areas. Thecable trays will provide barriers toprevent mechanical damage by oper-ators walking in the path ways.
NFPA2-6.DEK
41, 45 660
The smoke and infra-red detectorsare protected by controlled access tothese areas, thus limiting thepotential for damaging the devices.In addition, these devices aretypically not installed in the areaor the normal path of travel in thesezones.
In general, operators typically would not occupythese areas thus limiting the potential formechanical damage even further.
Based on the evaluation discussions above, theprotection of the detectors listed will not berequired and are considered'cceptable as installed.
Reference: -NFPA 72E Code Compliance Walkdown Checklists0120-108-008N through 0120-108-008S and0120-108-008W
-Alison Control Inc. Data Sheet for 9090 SeriesDetector, dated 3/6/75
FIRE DETECTORS RE UIRING GUARDS
Fire Zone Fire Zone Elevation Device
33 609'moke detector 3-26 and 3-27 arelocated under a platform atelevation 646'-9" at 6.5'bovethe platform elevation 639'-4"floor. These devices arelocated in the normal accesspath to this platform and areexposed to damage.
609'moke detector 3-27 is arrangedas discussed for Fire Zone 33.
39 609'moke detector 2-7 located atthe reactor cable tunnelpenetration mezzanine isinstalled 5.75'bove themezzanine floor and located inthe normal path of travel onthis mezzanine.
Deviation: Automatic ionization smoke detectors in the firezones 1isted have not been installed properly for thebeam construction present at the ceiling for thefollowing fire zones:
52 4-26 633 ~ Ose Device locatedwithin 4" of an18" deep beam.
57 18-10&
18-12
625'-10" Devicesinstalledwithin 4" of18" deep beams.
Justification: A walkdown performed the week of 4/4/88 confirmed theconfiguration of the ionization detectors withrespect to the combustibles present in eachindividual fire zone.
4-3etc.DEK
Fire Zone 32
Automatic smoke detection and dry pilot preactionsprinkler systems have been installed throughout FireZone 32. Smoke detector 5-29 however, has beeninstalled at the bottom of a 6'-0" deep beam. Thepreaction sprinkler system's dry pilot sprinklershave been properly installed throughout this firezone, The dry pilot sprinklers act as heat detectiondevices, as defined by NFPA 13, 1983 Edition, CodeSection 5-3.4 and are provided to actuate thepreaction sprinkler system in this fire zone. The drypilot sprinklers will, upon actuation, transmit awaterflow signal (via the preaction valve operating)to the Control Room to alert the operators of thefire condition in this fire zone.
Therefore, an equivalency can be made for the drypilot sprinklers to act as heat detectors and will toprovide detection in the area of smoke detector 5-29in lieu of that device.
Fire Zone 49
The review of drawings 1-1444 & 1-1437 and thewalkdown data collected, indicated that the primarypurpose of these detectors 4-13 & 4-16 were installedto provide specific protection'f cable trays andother combustibles located at a lower elevation inthe area of these detectors.
Detector 4-16 has been installed at elevation 639'-6"due to HVAC duct work congestion. Should a fire occurin the area of this detector, products of combustionfrom the fire will stratify under the HVAC ductingand the bottom of the beam thus provi.ding adequatearea for smoke to collect to activate detector 4-16.
1
Detector 4-13 has been installed on the bottom of a12" deep beam directly over charcoal filter units1-HV-AES-1&2. A review of the Fire Hazards Analysisindicates that the primary insitu combustible in thisfire zone is the charcoal beds of the filter units.Therefore, the primary purpose of detector 4-13 is toprovide specific hazard protection as discussed underCode Section 4-3.1.1 of NFPA 72E, 1982 Edition.
4-3etc.DEK
Fire Zones 52 and 57
The walkdown verified that ionization detectors 4-26(Fire Zone 52) and 18-10 & 18-12 (Fire Zone 57)are installed 6" from the side the respective beam asconfirmed by measurement. Therefore, these detectorinstallations are considered acceptable as NFPA 72Erequires that detectors not be installed less than 4"to a wall.
Fire Zones 32 49 52 and 57
Based on the review of the discussions above, theplacement of these detectors with respect to thecombustibles present, the detector arrangements areconsidered
Deviation: Smoke detectors are not properly spaced for the airmovement present in the Valve Gallery (Fire Zone 37)at elevation 617'f the Auxiliary Building.
Justification: Ionization smoke detectors have been installed inthe demineralizer central hallway portion of thisfire zone. The individual cubicles for thedemineralizer and ion exchangers, however„ are notprovided with detectors. Impell Calculation No.0120-108-009 has verified that the spacing for theair movement through this fire zone will requirefour smoke detectors in lieu of the three smokedetectors installed.
A review of the Fire Hazards Analysis for Fire Zone37 has identified that the combustible loading inthis zone is negligible.
The maximum allowable combustible loading andequivalent fire severity for Fire Zone 37 are 13,000BTU/sq. ft. and 10 minutes (the actual combustibleloading and equivalent fire severity existing atthis time are zero BTU/sq. ft. and zero minutes).
The walls, floors, and ceilings to adjacent fireareas and fire zones are constructed of reinforcedconcrete in excess of a three-hour rating.Although, there are unrated penetrations through thebarriers, a fire occurring in this space would berequired to take a circuitous path in order toimpact redundant safe shutdown components and thebarriers will limit the spread of fire.The smoke detectors are located in the portion ofthe fire zone that is normally accessible. Allother portions have limited accessibility due tothese areas being high radiation areas. The accessto the fire zone is controlled due to ALARAconcerns.
A review of calculation No. 0120-108-009 indicatesthat the requirement for the fourth smoke detectorin the fire zone based on the air movement and thespacing requirements is not that significant. Inaddition, the placement of detectors provided aresuch that they are in the return air path throughthe fire zone.
NFPA4-4.DEK
Based on the negligible combustible loading,construction features and smoke detectors providedin this fire zone, the configuration of these smokedetectors is considered acceptable.
NFPA 72E 1974 and 1978 Edition Code Sections 2-6.5, 2-6.7, and 4-1.2
Deviation: Smoke detectors 3-27 and 3-28 have been installed on thebottom of 12" beams and may not provide proper firedetection in accordance with NFPA 72E for Fire Zone 44Sof the Auxiliary Building at elevation 609'-0".
Justification: A walkdown of the plant was performed the week of 4/4/88to determine what combustible loading and safety relatedcomponents are present for the areas in question. Theionization smoke detectors 3-27 and 3-28 have beeninstalled directly over specific hazards as verifiedduring the walkdown. Detector 3-27 has been installedover Panel No. CMO-410 which is part of the green train.Detector 3-28 is located over the opening to the
Laundry'oom.
These devices have been installed over thesespecific areas to provide a rapid response to a fire
, developing in these immediate areas.
Zn addition, an automatic dry pilot sprinkler system hasalso been provided at the ceiling over the cable traysand conduit which are installed throughout the areaaround detectors 3-27 and 3-28 in Fire Zone 44S. Thepilot sprinklers are provided to "actuate the sprinklersystem and will serve the purpose of a heat detector, asdefined by NFPA 13, 1983 edition, Code Section 5-3.4.Upon actuation, the pilot sprinklers, a waterflow alarmsignal will be transmitted (via the preaction valveoperating) to the Unit 1 Control Room. Therefore, therequizement for additional smoke detection in thisimmediate area is unnecessary.
Based on the review of the combustible loading, automaticsprinkler and smoke detection configurations in theimmediate area of the existing smoke detectionarrangement for this area is considered acceptable.
Deviation: Smoke and flame detection is not properly provided abovethe platform at Elevation 646'-9" in Fire Zone 33 (Unit1) and 34 (Unit 2) of the Auxiliary Building.
Justification: A walkdown of the plant was performed the week of 4/4/88to determine the adequacy of the fire detection systemfor the combustible loading present on this platform.The walkdown identified that the fixed combustiblespresent primarily included a flamable liquids cabinetwhich contains limited quantities of lubricating fluids,electrical motors. In Fire Zone 34, terminal boxes withcable terminations were also present. Transientcombustibles were not present at either unit for theseelevations.
The configuration of the fire detectors in Fire Zones 33and 34 is a combination of smoke and infrared devicesproperly spaced throughout multiple platform elevations.This is consistant for all the platform levels except forthe platform at 646'-9" elevation. Infrared detectorshave been installed at the east wall of each fire zoneapproximately 1'elow the platform elevation. Theplatform extends out from the containment wallapproximately 11.5'ith the leading edge of platformapproximately 8.33'rom the east wall. The roof abovethe 646'-9" platform is located at Elevation 682'-6" andis honeycombed with a series of deep beams. Due to theheight of the ceiling above the 646'-9" platform, theelevated ambient temperatures normally above theplatform, and lack of effectiveness to detect a fire fromplacement of detectors on the beams, infrared detectorswere chosen to provide the required detection coverage.
A review of RFC Packets 01-2679 an'd 02-2694 has confirmedthat the cone of vision of the AFA Minerva infrareddetectors will be partially obstructed by the platformstructure. At the farthest point of the platform fromthe detector, the blind spot is no more than 3'bove theplatform. Fixed combustibles are limited with theprimary concerns being a stop valve motor, lube oil leakor terminal cabinet fire on the platform. All componentconfigurations on the platform are such that a firepropagating from these components will be detected by theinfrared device due to the equipment height and positionon the platform. The flammable liquids cabinet istypically placed in the front half portion of theplatform. However, if placed anywhere on the platform itwould be visible to an infrared detector should a firestart inside the cabinet and propagate out.
NFPA5-4.DEK
Should transient combustibles be stored on the 646'-9"platform. A fire propagating from these combustibleswould be detected by the infrared detectors. This wouldoccur either by an open flame that would develop or byflaming embers falling through the 1" x 4" open gratingof the platform onto the 639'-4" platform below.Ionization smoke detectors are installed on the 639'-4"platform and would also assist. in detecting a fire fromembers dropping on to the Platform from above.
Based on the review of the combustibles present and theirconfiguration, the current arrangement of infrareddetection in these fire zones is adequate and willprovide proper detection inlieu of providing smokedetection at the ceiling.
Edition) Code Sections 4-3.7.2 and 4-3.7.3Edition) Code Section 4-3.5.1.1
Deviation: Smoke detection is not properly installed in Fire Zone 52on Elevation 633'f the Auxiliary Building for deep beamconstruction. Also, detection is not provided to coverall portions of the fire zone within 0.7 times the listedspacing of the device.
Justification:
I
A walkdown of this fire zone performed the week of4/4/88 verified the arrangement of fire protectionfeatures with respect to combustible loading present inthe zone. The primary combustibles present are theauxiliary subpanels, other miscellaneous electricalcabinets and cable trays at column lines WL-3.9 in Unit 1and WL-8.1 in Unit 2. Cable trays and MCC panels arealso provided from column lines WL-3.9 through WL-8.1 atWL-L.5 in both Units 1 and 2. A dry pilot sprinklersystem is also provided throughout the fire zone toprovide fire detection and suppression capabilities.Although the smoke detectors are not placed throughoutthe fire zone to provide smoke detection for all portionsof the zone, the smoke detectors are placed over theportions of the zone which contain the primarycombustibles (subpanels, cable trays, etc.). Theplacement of the smoke detectors meets the intent of NFPA72E, 1984 edition, Code Section 4.3.1.1 which states thatsmoke detection can be installed closer to a spec4.fichazard to readily intercept smoke. Combustible loadingin other portions of the fire zone is not as significantdue primarily to (4) large supply and (4) large exhaustHVAC units which cover a ma]ority of the floor area atcolumn lines WL-K through WL-M and WL-3.5 and WL-8.5.
In addition, dry pilot sprinklers are installedthroughout the fire zone. An equivalency can be made forthe pi.lot sprinklers as heat detectors as defined in NFPA13 Code Section 5.3.4, 1983 Edition. The dry pilotsprinklers, upon the fusing of an element, will transmita waterflow alarm signal (via the preaction valveoperating) to the Control Room to alert operatingpersonnel to the fire condition. Since pilot sprinklersare provided throughout the fire zone, the relocation oraddition of smoke detection is not necessary.
Based on the review of the combustible loading and fireprotection features present, this condition isacceptable.
Deviation: Smoke detectors are not provided in a deep beam bayarea at the east end of the new fuel room, Fire Zone48) as required.
Justification: The review of the Fire Hazards Analysis for D. C.Cook Nuclear Plant indicates that the combustibleloading in the room is negligible and that there areno fixed transient combustibles (trash cans, etc.)located in the room. The detectors installed in theroom are properly provided over the new fuel area.The portion of the room where the deep bay occurreddoes not contain any fixed or transient combustiblesin the area. In addition, the security access level forentering the room, severely restricts all normalaccess to this space.
Deviation: Ionization smoke detectors are not properly providedfor the high ceilings and deep beam constructionpresent in the Unit 1 (Fire Zone 7) and Unit 2 (FireZone 27) Quadrant 1 Cable Tunnels, located atelevation 596'-4" of the Auxiliary Building.
Justification: A walkdown of the plant was performed the week of4/4/88 to confirm the configuration of the ionizationsmoke detectors with respect to the combustiblespresent in the applicable fire zones. Automaticionization and infrared flame detectors are providedthroughout Fire Zones 7 & 27. A review of the FireHazards Analysis for these fire zones, indicates thatthe primary insitu combustibles located in these firezones are system cables. Therefore, the firedetectors should be installed to provide protectionof the system cables in these fire zones.
Fire Zone 7
The system cables are installed in cable trays whichare located along the containment wall (north wall)and the east wall at a maximum elevation of 603'-9"above the floor of the space. Cable trays are alsolocated along the south wall at a maximum elevationof 628'-9" above the floor of the space. The smokedetectors have been evaluated to confirm that thedetectors have been properly provided in thefollowing discussions:
a \ A smoke detector has not been provided for thedeep beam bay area at column lines WL-4.5 ANDWL-R. The combustibles in this immediate areaconsist of system cables. A review of HVACDrawing 1-5688 indicates that fan unit 1-HV-ET-1discharges air out into this area from Fire Zone8 toward the south wall of Fire Zone 7. Shoulda fire occur in a cable tray along theContainment wall (north wall), the smoke willprimarily be forced toward the south wall ofthis fire zone due the air movement produced bythe fan unit and into the deep bay containingdetector 6-3. In addition to the ionizationdetectors provided, infrared detectors, oncerelocated, will provide adequate protection ofthe cable trays in this immediate area.Therefore, an additional detector for this deepbay area is not required.
b. The area of Fire Zone 7 between column linesWL-R to WL-P and Z.-4.5 to WL-4.8 has a highceiling of approximately 35'bove the floor ofthis fire zone. Ionization detectors 6-3 & 6-4are installed at the ceiling within theimmediate area of the fire zone. A review ofNFPA 72E, 1984 Edition, Appendix C, SectionC-4-2.1.1 indicates the criteria for spacingsmoke detectors in high ceiling areas. Assumingthat a postulated fire in this area is one thatdevelops slowly, then the maximum spacing forthese detectors can be determined by reviewingFigure C-4-2.1.1C. Based on the ceiling heightbeing 35', the smoke detectors will respond tofire that develops at a rate of 5)0 BTU/sec. andcan be spaced a maximum of 784 ft /device(spaced 28ft. on center). A review of ImpellCalculation No. 0120-108-009 has indicated thatthe spycing of detectors in this fire zone is240 ft /device. Therefore, the spacing of smokedetectors in this fire zone is well within themaximum spacing allowed and will provideadequate protection for the high ceiling area.
Fire Zone 27
The fire zone physical configuration and detectorplacement are essentially the same for Fire Zone 27as they were for Fire Zone 7 as discussed above. FireZone 27 however has been rotated 180 degrees from thesoutheastern quadrant of the Unit 1 ContainmentBuilding to the northeastern quadrant of the Unit 2Containment Building. The evaluation discussions forFire Zone 7 also apply to Fire Zone 27 with theexception that the smoke detector numbers for thisfire zone are, 1-1 through 1-4.
Fire Zone 7&27
Based on the review of the evaluation discussionsabove, the configuration of the ionization smokedetectors provided with respect to the combustiblesand the structural features present, are consideredacceptable.
Deviation: Smoke detection has not been installed in deep bayequipment hatch areas to provide proper fire detectionin accordance with NFPA 72E for the following fire zonesof the Auxiliary Building.
FireZone No. Evaluation573'ocation
WL-K and WL-6.3
5587'4N609'-P and WL-6.3
WL-N and WL-6.3
Justification: A walkdown of the plant was performed the week of4/4/88 to determine what combustible loading and safetyrelated components are present for the areas inquestion. Based on a review of the data collected, theSafe Shutdown System Analysis (SSSA) and the FireHazards Analysis, it was determined that the fixed ortransient combustible loading located in the immediatearea of cable trays with Essential Safety System (ESS)cables installed adjacent to the equipment hatch isminimal. Further review also determined that shouldthese cables be exposed to a fire condition, that theirfailure would not prevent safe shutdown of the plant.
Fire Zone 1
The fixed combustibles in Fire Zone 1 on Elevation573'n
the area of this equipment was limited. A radiationmonitor was installed directly under two essentialsafety system cable trays at the entrance to Fire Zones1E and 1F. Temporary transient combustible storage inthe immediate area of the hatch are typically notsignificant in quantity and would be located in theimmediate area of a smoke detector. Based on thetransient combustibles present during the walkdown, theywould not present a significant fire exposure to thecable trays in the area.
Should a fire occur in the cable trays or fromcombustibles located below, a delay in the response tothe fire by the smoke detector located on the north sideof the hatch will occur due to the existence of thehatch, the smoke will eventually activate one or both ofthe two smoke detectors in the immediate area of thehatch and will alert the Control Room operators to thefire condition. As discussed earlier, the loss of thesecables to fire would not impact the safe shutdown of theplant.
Fire Zone 5
An automatic sprinkler system has been installedprimarily under the cable trays and around most of theequipment hatch areas in Fire Zone 5 on Elevation 587'.The sprinklers are installed approximately 15'bove thefinished floor (AFF) which are located beneath the cabletray conduit and piping obstructions. The sprinklerswere installed to provide protection for the cable traysfrom exposure fires below the trays. The dry pilotsprinklers act as heat detection devices, as defined byNFPA 13, 1983 edition, Code Section 5-3.4, and areprovided to actuate the sprinkler system. The dry pilotsprinklers will also transmit water flow alarm signalsto the Unit 1 Control Room to alert operating personnelof the fire condition once they are fused.
Therefore, an equivalency can be made for the dry pilotsprinklers to act as heat detectors which are providedin lieu of smoke detectors.
Where temporary transient combustible equipment storagemay be located under the equipment hatches, thosetransients are typically not significant in quantity.The location of these transient combustibles wouldtypically be in the immediate area of smoke detectionand sprinklers. Therefore, the combustibles would notpresent any significant fire exposure to the cable trayspresent.
Fire Zone 44N
An automatic dry pilot sprinkler system has also beenprovided at the ceiling over the cable trays and conduitwhich are installed adjacent to the equipment hatch inFire Zone 44N on Elevation 609'. The dry pilotsprinklers are installed throughout area of the
equipment hatch. The pilot sprinklers are provided toactuate the sprinkler system and will serve the purposeof a heat detector, as defined by NFPA 13, 1983 edition,Code Section 5-3.4. Upon actuation, the pilotsprinklers will transmit a water flow alarm signal tothe Unit 1 Control Room, therefore, making therequirement for additional smoke detection in thisimmediate area unnecessary. The configuration oftransient combustibles is similar for this area as itwas for Fire Zone 5 above and will not presentsignificant fire exposure to the cable trays present.
Based on the review of the combustible loading,automatic sprinkler and smoke detection configurationsin the immediate area of each equipment hatch, theexisting smoke detection arrangement for the areasdiscussed is considered acceptable.
Edition) Code Section 4-4.6Edition) Code Section 4-3.7.2 and 4-3.7.3
Deviation: Ionization smoke detectors installed at the ceiling ofthe Unit 1 (Fire Zone 49) and Unit 2 (Fire Zone 50) HVACVestibule areas at elevation 633'-0" of the AuxiliaryBuilding, are not properly provided for the deep beamconstruction present in these fire zones.
Justification: A walkdown of the plant was performed the week of 4/4/88to confirm the configuration of the smoke detectors withrespect to the combustibles present in these fire zones.A review of the Fire Hazards Analysis has identified theprimary insitu combustible in these fire zones to be thecharcoal located inside the filter units within thesefire zones. The filter units however, are provided withindividual heat detection systems installed within eachfilter unit and will provide alarm signaling to therespective Control Room to alert operators of a firecondition in one of these units. These units are alsoprovided with a manually actuated fixed water spraysuppression system to control a fire which may occur inthese filter units. Therefore, the primary insitucombustible located in these fire zones can be said to bethe system cables installed in trays. Smoke detectionshould therefore be primarily provided to protected thesesystem cables.
4
Fire Zone 49
Automatic ionizati.on smoke detection has been installedthroughout this fire zone. The construction of theceiling in this fire zone is primarily 8" to 12" deepbeam type construction with the exception of 18" and 36"deep beams located at the east end of this fire zone.Based on the review of drawing 1-1444 and 1-1446 and thewalkdown data collected it was verified that smokedetectors were installed in each deep bay area formed bydeep beams as required by the Code Section 4-3.7.3.
The verification for the requirement for reduced spacingof smoke detectors (Code Sections 4-3.7.2 and 4-4.6) forareas with beam construction of 8" to 18" was confirmedto be in compliance with the code based on the review ofdrawing 1-1444 and 1-1446, the walkdown data collectedand Impell Calculation No ~ 0120-108-009. The review ofthis data confirmed that smoke detectors have beenprovided over the primary insitu combustibles of concern(cables), at reduced spacings within these bays asrequired by the code sections referenced above.
CODE4-4.DEK
Fire Zone 50
Automatic ionization smoke detectors are providedthroughout this fire zone. As discussed earlier,charcoal filter units area also provided in this firezone and are provided with heat detection and firesuppression systems. In addition, Fire Zone 107 islocated within it's own enclosure at the northeast cornerof this fire zone. Fire Zone 107 is provided with a heatdetector which will provide alarm signaling to theControl Room to alert operators of a fire condition inthis area.
The ceiling mounted smoke detectors have been installedto provide protection of insitu combustibles with respectto the beam construction present in this fire zone, asrequired by Code Sections 4-3.7.2, 4-3.7.3, and 4-4.6with the exception of the following:
a ~ An 18" deep bay area at the northeast corner of thisfire zone has not been provided with a smokedetector. The review of drawing 2-1444 and thewalkdown data collected verified that this corner ofthe fire zone is primarily occupied by the enclosurefor Fire Zone 107 which is provided with a firedetector. The floor area not occupied by Fire Zone107 in the area of this deep bay, is limited.Therefore, transient combustibles are unlikely to bestored there. The insitu combustibles located inthis immediate area are made up of local powerpanels. These panels contain negligiblecombustibles and will not present a fire exposure tocomponents in this immediate area. System cablesare installed in conduit in this area and are notconsidered to be an exposure problem.
Smoke detection has also not been installed at thecenter west portion of this fire zone between two18" deep beams which form a bay. The presence oftransient combustibles observed during the walkdownin this immediate area was negligible and the insitucombustibles were limited to the system cableslocated in cable trays 2AU-C18 and 2-AU-C19. Thesecable trays do traverse the area between the two 18"deep beams located in this immediate area.
CODE4-4.DEK
The cables that have been installed in these cabletrays have been subjected to fire resistive testingin accordance with IPCEA S-19-81, paragraph 6.19.6,and have successfully passed. In addition, thesecables are also constructed of the same materialsused in the Unit 2 containment system cables whichalso underwent fire resistive testing in accordancewith IEEE Standard 383 and successfully passed thattesting. Therefore, an equivalency can be made forthe cables installed outside the Unit 2 containmentare afforded the same fire resistive characteristicsas the cables that passed the IEEE testing.
Based on this data, the potential for an exposurefire from the cable trays to components located inthis immediate area is limited. Therefore, theprimary fire concern would be a floor based exposurefire. Since insitu combustibles at the floor levelare negligible in this immediate area, it must beassumed that this fire must originate from transientcombustibles stored in this area. Should anexposure fire occur in these transient combustibles,products of combustion will accumulate in this bayarea and travel toward the back of the fire zone(east) toward detectors 4-30 and 4-31.
This is due to the return air movement for this firezone which is brought through the 3000 CFM returnair diffuser located near column line WL-N and thenorth wall of the fire zone. Smoke detectors 4-30and 4-31 are located directly in line with thereturn air diffuser and a fire that is postulated tohave started at the west end of this fire zone.Smoke detectors 4-30 or 4-31 will eventually respondto the fire condition, thus signaling an alarmcondition to the Control Room and alerting theoperators to the fire condition in this area.
Fire Zones 49 and 50
Based on the review of the evaluation discussions above,the configuration of the smoke detectors with respect toceiling beam construction and combustibles present, areconsidered to be acceptable.
Deviation: Smoke detectors in Fire Zone 3 on Elevation 587'f theAuxiliary Building are installed at the bottom of 3'eepbeams which are 7.5'nd 10'n center.
Justification: A walkdown of the area was performed on 4/4/88 todetermine if the arrangement of the smoke detectorsinstalled was based on the location of the combustiblespresent in the room. The walkdown verified that thesmoke detection devices were placed over the area of thegreatest activity within the room where exposedcombustibles are present.
Fire Zone 3 is used for the preparation of contaminatedwaste, The zone is divided into two areas. These areasinclude a drum storage area having very high radiationlevels and a work area containing baling equipment withlower radiation levels. Access into Fire Zone 3 iscontrolled due the very high radiation levels presentwithin general portions of the zone. Smoke detectorswere installed over the baling equipment at column WL-Tand WL-6.4 and over the bagging area at WL-5.2 and WL-6.In addition to the smoke detectors, an automatic drypilot sprinkler system is also provided throughout thearea where operating personnel would normally beperforming any required duties. Should the dry pilotsprinkler system actuate, a waterflow alarm signal wouldbe transmitted (via the preaction valve operating) to theUnit 1 Control Room to alert oeprating personnel of thefire condition in that zone. NFPA 13, 1983 Edition, CodeSection 5-3.4 defines the use of the dry pilot sprinklersin this application as heat detectors. Therefore, anequivalency can be made for the dry pilot sprinklers toact as heat detectors and have been provided in lieu ofsmoke detectors.-
NFPA 72E, 1984 edition, Code Section 4-3.1.1 alsoindicates that where smoke detectors are installed toreadily intercept the smoke of a specific hazard, thatthe detectors may be installed closer to the hazard. Theintent of these smoke detectors are to provide detectionover the areas where operating personnel and exposedcombustibles would be present and the dry pilotsprinklers provide detection for the remaining portion ofthe accessible portions of the fire zone.
Based on the revie~ of the fire protection featuresinstalled, the normally high radiation levels in the roomand the limited access to the area, the detectionarrangement in Fire Zone 3 is considered acceptable.
Deviation: Smoke detection is not properly provided for 12" deepbeam construction at column lines WL-S and WL-6.3 in FireZone 5 on Elevation 587'of the Auxiliary Building.
Justification: A walkdown was performed the week of 4/4/88 to determinethe adequacy of the fire protection features with respectto the combustibles present. The present fire detectionsyst: em includes the installation of an ionization smokedetector at column lines WL-S and WL-S.5 above the1-HV-SATFU charcoal filter unit. A dry pilot sprinklersystem is also installed under the conduit congestionthroughout the area at column line WL-S in Fire Zone 5.
Transient combustibles potentially may be stored undersafe shutdown cable trays. The cable trays, however, areprotected with an automatic dry pilot sprinkler systemwhich will alleviate the exposure potential of a firefrom these transient combustibles.
The dry pilot sprinklers provided to actuate thesprinkler system, also provide an equivalency for heatdetectors as defined by NFPA 13, 1983 Edition, Section5-3.4. Upon the activation of a pilot sprinkler element,a waterflow alarm signal will be transmitted to the Unit1 Control Room to alert operating personnel of a firecondition.
Based on the provision of the dry pilot automaticsprinklers and smoke detectors installed in the immediatearea, additional detection will not be required and theexisting detection configuration is consideredacceptable.
Deficienc The field of vision for the infrared flame detectorslisted are obstructed by cable trays and MCC panelsinstalled in the respective fire zones. The detectorsand fire zones evaluated are located within the AuxiliaryBuilding and include the following:
Fire Zone Device No.Fire ZoneElevation
Fire Zone
41 21-3, 21-4& 21-5
609'-0" Unit 1 EngineeredSafety System, MCC
Room and Underfloor
45 25-3, 25-4& 25-4
609'-0" Unit 2 EngineeredSafety System, MCC
Room and Underfloor
42A 22-1 609'-0" Unit 1 E.P.S.Transformer Room
Justification: A walkdown of the plant performed the week of 4/4/88confirmed the configuration of the infrared flamedetectors with respect to the combustibles presentin the applicable fire zone. A review of the FireHazards Analysis has identified the primarycombustibles located within the fire zonesreferenced, as being system cables. The primaryequipment installed in Fire zones 41 and 45 includeessential motor control center (MCC) and trans-formers; and Fire Zone 42A contains switchgearpanels and transformers. Therefore, the infrareddetectors should provide protection for the cablesand components within their respective fire zone.
Fire Zone 41
Automatic ionization and infrared flame detectorsare provided throughout this fire zone. Infrareddetectors 21-1 & 21-2 are located at the ceiling ofthe northeast and northwest portion of the firezone. These devices are pointing down with theirsensing element at an elevation of 623'-4" (13.83')above the main floor (at elev. 609'-0") of the spacebeing protected. In addition, infrared detector21-2 also provides protection for a portion of theMCC floor area which is located at elevation613'-0". The maximum height of the cable traysabove the floor in these areas is 622'-3". A reviewof the Pyrotronics Application Bulletin B-188,indicates that these detectors have a capability ofproviding an area coverage of three times the heightof the device
from the floor of the protected space. Therefore;detectors 21-1 will prgvide an area coverage for themain floor of 1353 ft. . Detector 21-2 will providean area coverage of 378 ft. for the MCC floor areaand 677 ft. for the main floor space. Therefore,these detectors will provide adequate protection ofthe equipment and system cables located at thenortheast and northwest portions of the fire zone.
Detector 21-3 is located on the south wall near thesoutheast corner of this fire zone. This detectoris located at an elevation of 623'-6" (10.5') abovethe MCC floor area and is pointing out, lookingacross the MCC floor area. As discussed inPyrotronics Bulletin B-188, this detector willprovide an optimum field of vision of 43'ith 170degree angle cone. This detector will be capable ofdetecting a fire propagating from the top of thetrays or the MCC panels located in this area.
Detectors 21-4 and 21-5 area located in theunderfloor space of the MCC floor area. Detector21-4 is located on the south wall near the southwestcorner at an elevation of 612'-0" (3') above thefloor and detector 21-5 is located on the east wallnear the northeast corner, also at an elevation of612'-0". The maximum height of the cable traysinstalled in the underfloor area are at an elevationof 610'-9" (1.75'). As discussed earlier, detectorsarranged in the horizontal position, have an optimumfield of vision of 43'. Therefore, these detectorswill be capable of. providing adequate for the systemcables present in this portion of the fire zone.
Fire Zone 45
The infrared detection, cable tray and MCC equipmentconfigurations are essentially typical of that forFire Zone 41 discussed above. The primarydifference between Fire Zones 41 and 45 is thepositioning of detector 25-2 (detector 21-2 for FireZone 41). Detector 25-2 is located on the eastwall, 14'orth of the south wall at an elevation of620'-2" (11.16') above the floor area of theprotected space. This detector is pointing outtoward the west wall of this fire zone. The minimalamount cable trays located in this immediate areaare located at a maximum elevation of 620'-5"(11.47'). Based on the discussion for Fire Zone 41,the detectors installed in Fire Zone 45 will provideadequate protection for this fire zone.
72E4-4.DEK
Fire Zone 42A
Automatic ionization and infrared flame detectorsare provided throughout the fire zone. Infrareddetector 22-1 is located on the east wall near the/northeast corner, at, an elevation of 623'-3"(13.75') above the floor area protected. Detector22-2 is located on the south wall near the southwestcorner, at an elevation of 612'-0" (11.5') above thefloor of the protected space. Both of thesedetectors are directed out toward the middle of thefire zone to provide protection of the entire space.The maximum height of the cable trays located in thearea of detector 22-1 is at an elevation of 622'-8"(13.17') above the floor.
The maximum height of the cable trays in the area ofdetector 22-2 is at an elevation of 618'-2" (8.66')above the floor. A review of the PyrotronicsApplication Bulletin B-188, the detectors installedin their horizontal position will provide an optimumfield of vision of 43'ith a a 170 degree anglecone. Therefore, these detectors will provideadequate protection of the system cables and thetransformer equipment present in this fire zone.
Fire Zones 41, 42A, and 45
Based on the review of the evaluation discussionsabove, the configuration of the infrared detectorswith respect to the combustibles present in thesefire zones, are considered acceptable.
Deviation: The field of vision for infrared Detector No. 17-3located in the Unit 2 Quadrant 3S Cable Tunnel (Fire Zone23) at elevation 596'-0" of the Auxiliary Building, isobstructed by cable trays installed at the east end ofthe fire zone.
Justification: A walkdown performed the week of 4/4/88 verified thearrangement of the automatic fire detectors with respectto the combustibles present in the zone. A review of theFire Hazards Analysis identified the primary combustiblesin this fire zone to be system cables located in multiplecable trays and motor control center (MCC 2-CT-B5 and2-CT-C5). The cable trays are located at elevations from5'o 11'bove the finished floor (AFF) and primarilyrun along the north, south, and east walls of the firezone. The MCC unit is located approximately 17'-0" westof the east wall of the fire zone.
Automatic ionization and infrared fire detection deviceshave been installed throughout this fire zone. Infrareddetectors 17-1 and 17-2 are installed at the ceilingpointing down. A review of the Pyrotronics ApplicationBulletin B-188, indicates that these detectors have acapability of providing an area coverage of three timesthe height of the device from the floor of the protectedspace. The detector sensing element height for detectorsNo ~ 17-1 and 17-2 are located approximately 13'FF.Therefore, )hese detectors can provide an area coverageof 1195 ft.. . These detectors will provide adequateprotection for the center and west end of this fire zone.
Infrared Detector No. 17-3 is located on the east wallapproximately 13'FF, pointing toward the west wall ofthe fire zone. The Pyrotronics Bulletin indicates thatthis detector is capable of providing an optimum field ofvision of 43'ith a 170 degree angle cone due to thehorizontal positioning of the device. The purpose ofthis detector is to provide protection of the MCC unitand the cable trays that run parallel with the east wallof this zone. Although the east face of the MCC unit isnot entirely visible to detector 17-3 due to theobstruction of the field of vision for this detector bythe cable trays which run in front. This device will becapable of detecting a fire propagating from the uppertwo thirds of the MCC unit or from any of the cable trayslocated in front of this device. This is due to theheight of the detector above the cable trays and thedistance of the detector from the MCC unit.
Based on the review of this evaluation and the infrareddetector configuration with respect the cable tray andMCC equipment in this fire zone, this arrangement isconsidered acceptable.
Deviation: The field of vision for infrared flame detector19-3 located in the Unit 2 Quadrant 3S CableTunnel (Fire Zone 24), at elevation 596'f theAuxiliary Building, is obstructed by expandedmetal type cable trays in this zone.
Justification: A walkdown of the plant performed the week of4/4/88 confirmed the configuration of the infrareddetectors with respect to the combustibles presentin the applicable area. The review of the FireHazards Analysis has confirmed that the primarycombustible present in this fire zone are thesystem cables. Therefore, the detectors should bearranged to provide protection of the system cablesin this fire zone.
Automatic ionization and infrared flame detectors areinstalled throughout the fire zone. The infraredflame detectors installed in this fire zone arelocated at the ceiling above the maximum height ofthe cable trays which is 606'-3" (10') above thefloor and are pointing down. The elevation above thefinished floor (AFF) to the infrared detector'ssensing element is 609'-4" (13'). A review of thePyrotronics Application Bulletin B-188 indicates thatthese detectors can provide an area coverage of threetimes the height of the device from the floor of theprotected space. Detectors 19-1, 19-2, ayd 19-3 willeach provide an area coverage of 1195 ft.Therefore, a clear view of the primary combustibles(system cables) in this fire zone are provided bythese detectors. In addition, these detectors willalso provide limited floor area protection due to theconfiguration of the detectors and the cable trays.This however, is not the primary concern due to thelack of insitu or transient combustibles under thecable trays in this fire zone.
Based on the evaluation discussion above, theconfiguration of the flame detectors in this firezone are considered acceptable.
Deviation: The field of vision for infrared flame detector 18-13located in the Unit 1 Quadrant 4 Cable Tunnel (Fire Zone8), detectors 14-1 and 14-2 located in the Unit 1Quadrant 3M Cable Tunnel (Fire Zone 10) and detector 22-4located in the Unit 2 Quadrant 4 Cable Tunnel (Fire Zone26), at elevation 596'f the Auxiliary Building, areobstructed by cable trays installed in these zones.
Justification: A walkdown of the plant performed the week of 4/4/88confirmed the configuration of the infrared detectorswith respect to the combustibles present in theapplicable area. The review of the Fire Hazards Analysishas confirmed that the primary combustible present 'inthese fire zones are the system cables. Therefore, thedetectors should be arranged to provide protection of thesystem cables in these fire zones.
Automatic ionization and infrared flame detectors areinstalled throughout each fire zone. The infrared flamedetectors installed in these fires zone are located atthe ceiling above the maximum height of the cable trayswhich is 607'-6" (11.25") and are pointing down. Theelevation above the finished floor (AFF) to each infrareddetector's sensing element is 609'-4" (13'). A review ofthe Pyrotronics Application Bulletin B-188, indicatesthat these detectors can provide an area coverage ofthree times the height of the device from the floor ofthe protected space. Detectors 18-1 (Fire Zone 8), 14-1and 14-2 (Fire Zone 10) and 22-4 (Fige Zone"26) will eachprovide an area coverage of 1195 ft. . Therefore, aclear view of the primary combustibles (system cables) inthese fire zones are provided by these detectors. Inaddition, these detectors will also provide limited floorarea protection due to the configuration of the detectorswith respect to the cable trays. This however, is notprimary concern due to the lack of insitu or transientcombustibles under the cable trays in these fire zones.
Based on the evaluation discussion above, theconfiguration of the flame detectors in these fire zonesare considered acceptable.
Deviation: The field of vision for infrared detector No. 13-3located in the Unit 1 Quadrant 3S Cable Tunnel (Fire Zone11) at elevation 596'-0" of the Auxiliary Building, isobstructed by cable trays installed at the east end ofthe fire zone.
Justification: A walkdown performed the week of 4/4/88 verified thearrangement of the automatic fire detectors with respectto the combustibles present in the zone. A review of theFire Hazards Analysis identified the primary combustiblesin this fire zone to be system cables located in multiplecable trays and a motor control center (MCC 1-CT-D5 and1-CT-C5). The cable trays are located at elevations from5'o 11'bove the finished floor (AFF) and primarilyrun along the north, south, and east walls of the firezone. The MCC unit is located approximately 17'-0" westof the east wall of the fire zone.
Automatic ionization and infrared fire detection deviceshave been installed throughout this fire zone. Infrareddetectors 17-1 and 17-2 are installed at the ceilingpointing down. A review of the Pyrotronics ApplicationBulletin B-188, indicates that these detectors have acapability of providing an area coverage of three timesthe height of the device from the floor of the protectedspace. The lense height for detectors No. 17-1 and 17-2are located approximately 13'FF. Therefore, the~edetectors can provide an area coverage of 1195 ft.These detectors will provide adequate protection for thecenter and west end of this fire zone.
Infrared detector No. 13-3 is located on the east wallapproximately 13'FF, pointing toward the west wall ofthe fire zone. The Pyrotronics Applications Bulletinindicates that this detector is capable of providing anoptimum field of vision of 43,'ith a 170 degree "anglecone due to the positioning of the device. Although theeast face of the MCC unit is not entirely visible toDetector No. 13-3 due to the obstruction of the field ofvision for this detector by th cable trays which run infront'. This device will be capable of detecting a firepropagating from the upper two thirds of the MCC unit orfrom any of the cable trays located in front of thisdevice. This is due to the height of the detector abovethe cable trays and the distance of the detector from theMCC unit.
Based on the review of this evaluation and the infrareddetector configuration with respect the cable tray andMCC equipment in this fire zone, this arrangement isconsidered acceptable.
Deficienc The field of vision for infrared detectors 16-3 and 16-4(Fire Zone 38) and 20-3 and 20-4 (Fire Zone 39) arelocated in the Unit 1 (Fire Zone 38) and Unit 2 (FireZone 39) Quadrant 2 Penetration Cable Tunnel Mezzanine atelevation 625'f the Auxiliary Building are obstructedby cable trays installed in this area.
Justification: A walkdown of the plant was performed the week of 4/4/88to confirm the configuration of the infrared detectorplacement with respect to the combustibles present in theapplicable area. A review of the Fire Hazards Analysishas confirmed that the primary combustible present inthese fire zones are system cables. Therefore, theinfrared detectors should provide protection for thesystem cables.
Automatic ionization and infrared flame detectors areprovided throughout the respective fire zone. Theinfrared detectors in this portion of the fire zones arelocated at the ceiling over the top of the cable trayswith the detector sensing element at an elevation of630'-6" (5 '') above the finished floor (AFF). Themaximum height of the cable trays are an elevation of629'-9" (4.75') AFF. Infrared detectors 16-3 (Fire Zone38) and 20-3 (Fire Zone 39) are installed pointing downover the cable trays at the west end of the respectivefire zones. A review of the Pyrotronics ApplicationBulletin B-188 indicates that these detectors have acapability of providing an area coverage of three timesthe height of the device above the floor of the protectedspace. therefore, )hese detectors will provide an areacoverage of 214 ft. . These detectors will provideadequate protection of the west end of their respectivefire zones.
Detectors 16-4 (Fire Zone 38) and 20-4 (Fire Zone 39) arelocated on the east wall of their respective fire zone,approximately 5.5'FF pointing west into the mezzanineportion of each respective fire zone. These detectorswill be capable of providing protection for the remainingportions of the mezzanine area not protected by detectors16-3 and 20-3. This is due to detectors 16-4 and 20-4being installed in the horizontal position with anoptimum field of vision being 43'ith a 170 degree anglecone.
5-3ETC.DEK
In addition, the exposure of the cable trays from firefrom insitu and transient combustibles located under thetrays are unlikely due to the cable trays typically beinginstalled approximately 1'-0" AFF.
Based on the review of this evaluation and theconfiguration of the infrared flame detectors installedin these fire zones with respect to the configuration ofthe primary combustibles present, the arrangement s areconsidered acceptable.
Reference: -Fire Hazards Analysis, Revision 2, 1/29/88-AEPSC Drawings; Fire Zone 38: 1-1437-79, 4/8/88
Deviation: The field of vision of infrared flame detector 18-3 islocated at the east end of Quadrant 3M Cable Tunnel (FireZone 24), elevation 596'f the Auxiliary Building, isobstructed by cable trays installed at multiple levelsabove the floor directly in front of this detector inthis zone.
,Justification: A walkdown of the plant was performed the week of 4/4/88to confirm the configuration of the infrared detectorpositioning with respect to components obstructing thefield of vision of this device. The results of thiswalkdown were documented and applied to an engineeringevaluation performed to confirm compliance'heevaluation identified the actual location of thisdetector on the applicable conduit and cable tray plandrawings which verified the actual field of visionobstruction.
Based on the review of the Pyrotronics ApplicationsBulletin for this detector and the position of thedetector with respect to the cable tray obstructionspresent, detector 18-3 will provide adequate protectionof the system cable trays and the front face of MCC panelby a fire propagating over the top of the trays or MCCpanel thus exposing the infrared light source to thedetector. Therefore, the present positioning. of infrareddetector 18-3 is acceptable.
Deviation: The surveillance procedures required for verifying theoperability of the flame detectors installed in theplant, do not confirm if obstructions have occured toprevent the proper operation of the detector since thelast surveillance was performed.
Justification: The review of procedure PMI-5040 has confirmed thatupon completion of the installation of components,conduit or structural members required by an RFCdesign package, the plant Fire Protection Coordinatoris required to review the installation of theequipment or structure to determine the impact on thefire protection features within the plant. Upon thereview of the installation, the Fire ProtectionCoordinator will confirm that the installation isacceptable or indicate where corrective action isrequired to upgrade the fire protection features tocompensate for adverse conditions.
Based on the review of the evaluation discussionabove, the upgrading of surveillance procedures willnot be required and are therefore considered to beacceptable.
Please find attached a copy of the Matrix developed to identifythe procedures requ'ed to be revised to provide compliancewith the applicable NFPA Code.
This Matrix indicates the procedure to be revised, the surveillancerequirement to be incorporated, and the NFPA Code and sectionwhich requires this revision. These recommended proceduralchanges were previously discussed by Mr. D. Kipley of Impell withplant personnel during his April trip to the plant.
Should you have any questions, please do not hesitate to contactme.
BJG/ems
Attachment
cc: P. G. SchoepfW. G. Smith, Jr. — BridgmanJ. R. Sampson — BridgmanJ. A. Kobyra/J. D. Grier/B. J. GerweFile: NFPA Code Compliance C-6945
Procedures which'require revision to incorporate surveillance testingissues which have been 'identified as being required by NFPA CodeSections are detailed below.
NFPACode
Code ProcedureEdition Section To Be Revised Re uirement
10 1984 4-3.2 12-QHP 2270Fire.001
The procedures shouldbe enhanced toreference the firefacilities drawingsfor locatingequipment.
Revise the proceduresto verify the reset ofsignals received bythe control room forhose system manualstations, sprinklersystem waterflow andsupervisory signalsand fire pump alarmand supervisorysignals.
72D 1967 2411 6 Ref. Section2422 20473431
Based on the procedureenhancements requiredunder sections 2034.4052, and 2047, a
The procedures shouldbe revised to verifythe operability of "heline type heatdetectors as required.
i!
~
Miscellaneous Support Data
forABB Impell NFPA Code Compliance Report
No. 09-0120-0123
Date: 3/17/88
Time:
TELEPHONE CONVERSATION RECORD
Subject:
From:
To:
Power Supply Data for Alison Control Alarm Systemsinstalled at D. C. Cook Nuclear Power Plant
),/B. J. Gerwe (AEPSC)
r'redKimack (Alison)(201) 575-7100
Summary of Conversation:
Power supply data was requested for the following systems:
A700-9A9247035
A9096007
A conservative estimate of the maximum power load was given foreach power supply by Mr. Kimack as follows:
Panel No. Power Load Description
A909 Because of its age, Alison didn'want to guess
7035 Standby 4.25 VacAlarm 58.25 Vac
6007 Standby 500 VacAlarm 720 Vac
A700-9 Standby 300 VacAlarm 864 Vac
A924 Standby 150 Watts dcAlarm 350 Watts dc
DEK/ems
cc: D. E. Kipley
4
'L
SENT BY: IMPELL/LIncolnshlre, IL 3-16-88:11:16AM
~PEiLg~~
3129402021~614 223 1623
Memorandum
": ~ Qoro~sa(~)
File:
Copy:
From: Q%w 4~ ~)Date:
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4C ~m~(c ~ ~~~~&5~ DQ ~ Q~( ~~ ]~ ~ g~
I
'gS~W~~r ~~~~~
1
e ~
Date: May 24, 1988
Time: ll'25 AM EST
TELEPHONE CONVERSATION RECORD
Subject:
From:
Methodology for Determining the Quantity ofC02 Agent in the Selector Valve Vent Piping
David E Kipa.ly (Zmpall)
To: Karen Holtzich (Chemetron)(312) 534-1000
Summary of Conversation:
I requested the method for calculating C02 agent in the selectorvalve vent piping.
Ms. Holtzich indicated the following:
Assuming the agent characteristics are 2 F at 300 psi, thespecific density of the agent is 0.28.
To determine the quantity of C02 agent in the pipe, thefollowing formula can be used;
Volume of Pipe g specificDensity
of'02
Agent
cc: B. J. Gerwe
lbs. of C02
C%X~~~ ~V~ i~~> Wo ga >a~~~Cdy&RKCW~
HE4LD>Row e, u,<pu=y ('wham~)'Yo ~.q. ~~~ ('~).
l-okmuL.p, ~W~ &6cVv.Bleb ~h3 ~RE<-C~~ .
Date: May 24, 1988
Time: 11:25 AM EST
TELEPHONE CONVERSATION RECORD
Sub ject:
From:
Methodology for Determining the Quantity ofC02 Agent in the Selector Valve Vent Piping
David E. Kipely (Impell)
To: Karen Holtzich (Chemetron)(312) 534-1000
Summary of Conversation:
I requested the method for calculating CO agent in the selectorvalve vent piping.
Ms. Holtzich indicated the following:
Assuming the agent characteristics are 2 F at 300 psi, the0
specific density of the agent is 0.28.
To determine the quantity of CO agent in the pipe, thefollowing formula can be used;
Volume or Pipe specific lbs. of C02 per WBICDensity of - Foot of PipeC02 Agent
cc: B. J. Gerwe
V
Date: 6/7/88
Time: 2:05 PH EST
TELEPHONE CONVERSATION RECORD
Subject:
From:
Audible signals for predischarge signaling of halondischarge in the Unit 1 and 2 Control Room Cable Vaults
David E. Kipley (Impell) W~To: Earl Schimmel (ZGM)
Cook NuclearExtension 1574
Summary of Conversation:
1 requested information on whether predischarge signaling has beenprovided for the halon systems within the subject locations.
Earl indicated that the audible signaling for the CO and halon 1301systems for these areas, is activated by the operation of commonmanifold pressure switches located near the hazard. These pressureswitches include the following:
Unit 1: ZPS — 600ZPA - 602
Unit 2: ZPS — 606ZPA — 604
Earl also indicated that the drawings which will verify this willinclude:
12-5153L and 12-5154A
See Attachment "A" for drawing and device references.
Subject: Power Supply Data for Rochester Power Supply Model AN-159
From: David E. Kipley (Impell)
To: Dino Deipalmer (Rochester)(716) 238-4917
Summary of Conversation:
I requested data information on the power supply data for powersupply Model AN-159. Mr. Deipalmer indicated the following:
The AN-159 power supply outputs are:
Volts DC Min. Current Max. Current
-28+12.12+125
1 amp50 MA
50 MA
5.6 amp500 MA
500 MA
200 MA
In addition, I requested power data for the "EF" panel detectioncards (Model AN-080). Mr. Deipalmer indicated that the detectioncircuits operate on 125 VDC at 1 MA~
DEK/ems
cc: B. J. Gerwe
C
IJ
:-'P iA3~'
'1
Date: 6/13/88
Time: 3:30 PM EST
TELEPHONE CONVERSATION RECORD
From:
Subject: Continuous duty data for Pyrotronics System 3 andFIU unit's power supply transformers
David E. Kipley (Impell) WLC
To: Frank Kanerath (Pyrotronics)(201) 267-1300
Summary of Conversation:
I requested information on the continuous duty data for the trans-formers of the System 3 (PS-30) and FIU unit's power supplies.
Mr. Kanerath indicated that since these units are no longer beingmanufacturered, this data is not available.
DEK/ems
cc: B. J. Gerwe
C'
'
P U
I 'h ' — ~ 'I IV"
J% .
P
'I
4*
l'g
Date; 6/8/88
Time: 3:00 PM EST
Page 1 of 2
TELEPHONE CONVERSATION RECORD
Subject:
From:
Data required to confirm compliance with NFPA 12for EMPC cabinet manual actuator, selector valves,and typical circuit. current output from CO systemrelay cabinets.
David E. Kipley (Impell)~To: Steve Dimetravich (Chemetron)
(312) 534-1000
Summary of Conversation:
X requested data on the following equipment:
a. Maximum circuit current output from the CO system relaycabinets
b. The hydrostatic pressures and equivalent lengths for theCO selector valves
c. Maximum pull pressure and travel distance of EMPC cabinetmanual actuator
Mr. Dimetravich indicated the following:
a. The largest power consuming component connected to the relaycabinets are the EMPC solenoids. These devices are all 10 wattsolenoids.
Note: The current consumption is the following: Amp = WattsVolts
.040 = 10/250 VDCAmps
b. Selector valve data
l. All valves are hydrostatically tested at 1800 psi
2. Equivalent lengths of selector valves are the following:Valve Pipe(inches) Size
Equivalent
1 1/22346
72679961
185
I jJ)C
r,
Telephone Conversation Record — S. Dimetravich (Chemetron)Page 2
June 15, 1988
c. Data is not available for this request for the manual actuatorsof the EMPC cabinets.
DEK/ems
cc: B. J. Gerwe
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7223(9 83)FoRM GE 8(c) ENGINEERING DEPT.
AMERICANELECTRIC POWER SERVICE CORP1 RIVERSIDE PLAZACOLUMBUS, OHIO
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Surveillance ActivitiesInprocess Work ActivitiesSafetyMaterial ControlDocument Review
1313
90
TOTAL 35
One Condition Report was generated during thesesurveillance activities.
NDE Grou
Radiography of CCW piping is complete for the Annulus andBlowdown Flash Tank area.
I
The inaccessible snubber inspection was completed. Allsnubbers are acceptable.
Ultrasonic examination was performed on the Unit. 1 East/WestMSR for verification of thickness measurements.
Visual and nondestructive examinations are being performed asrequired to support various Maintenance and Constructionactivities.Reviewed Job Orders 017823, 017822, and 700135 travelers forASME repair/replacement NDE requirements. These reviews arebeing performed to establish NDE requirements prior to thestart of work.
FIRE PROTECTION COORDINATOR
Mr. Al Barker, AEPSC Site QA, exited with the Fire ProtectionCoordinator on Friday, June 10, 1988, pertaining to QASurveillance QA-88-18. Only one deviation was identifiedduring this surveillance. This item was corrected during thesurveillance and no follow-up response is required.
Fire Protection personnel placed signs on the TrainingSimulator Room doors to,match those of the Unit 2 ControlRoom. Halon fire extinguishers will be purchased and placed inthe Simulator Room.
Fire Protection personnel worked on installation of sprinklerhead guards on low hanging sprinkler heads throughout theAuxiliary Building. This activity will be completed uponreceipt of additional sprinkler head guards.
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AMERICANELECTRIC POWER SERVICE CORPORATION
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