ML011910426
| ML011910426 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 12/17/1999 |
| From: | Commonwealth Edison Co |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| -RFPFR, 93-124 | |
| Download: ML011910426 (166) | |
Text
A.IVI.,IN..IVIJ-,iNI 1-J QA RECORD COMMONWEALTH EDISON COMPANY UNITS 2/3 DRESDEN NUCLEAR STA TION NFPA CODE COMPLIANCE MA TRICES NTSC Report No.93-124 Revision 1 Date: December 17, 1999 Prepared By:
Joseph H. Talbert, PE S/
Principal Engineer Reviewed By/'ýý David G. Mahoney Pnncipal Engineer Approved By:_.
Tho J.
Cormack, PE Principal Engineer Nexus Technical Services Corporation 125 Fairfield Way, Suite 380 Bloomingdale, IL 60108 Phone (630) 893-2277 Fax (630) 893-2401 http://vwww.nexus-tech.corn/
28-1
A-VIINli.viL)
I*i ij, COMMONWEALTH EDISON COMPANY UNITS 2/3 DRESDEN NUCLEAR STA TION NFPA CODE COMPLIANCE MA TRICES NTSC REPORT NO.93-124, REV.1 December 17, 1999 TABLE OF CONTENTS 1.0 PURPOSE 1
2.0 METHODOLOGY 1
3.0 ASSUMPTIONS 4
4.0 REFERENCES
4 5.0 EXPLANATORY NOTES 9
6.0 RESULTS 10 TABLE A - NFPA DEVIATION CLOSE OUT MATRICES TABLE B - NFPA DEVIATION JUSTIFICATION MATRICES TABLE C - NFPA CODES OF RECORD : Technical Justification for Deviation NFPA 72D-06.2 : Dresden Fire Door Items to be Resolved, Appendix G 28-2
UNITS 2/3 DRESDEN NUCLEAR STATION NFPA CODE COMPLIANCE MATRICES NTSC REPORT NO.93-124, REV.1 December 17, 1999 1.0 PURPOSE Dresden Station used National Fire Protection Association (NFPA) codes as guidelines in the design of passive and active fire protection features and in the development of administrative controls of fire hazards. Where deviations from significant provisions of the applicable codes were made, technical justifications were developed and documented in various reports.
These reports also provided recommendations to eliminate certain significant NFPA code deviations. The purpose of this document is to:
- 1.
Compile the NFPA code technical justifications in a single source.
- 2.
Document the available objective evidence that resolves the above-mentioned recommendations.
2.0 MIETHODOLOGY 2.1 Revision 0 (1994)
The status of each code deviation listed in the NFPA Code Matrices was determined by reviewing the Fire Protection Program Documentation Package (FPPDP) (Ref. 4.9) and Station Fire Protection Program Procedures. The information found was recorded under the "Justification" section of each matrix. The information consisted of either the objective evidence that resolved the deviation or an engineering evaluation justifying the station's position for deviating from the code. Where the infornation was taken from the FPPDP, the specific document was referenced by number.
Each reference was then listed and described on the last page of each matrix.
All information taken from the FPPDP was paraphrased.
For actual wording, see the referenced document. If the information was obtained through a procedure review, then the procedure number and revision was listed in the matrix.
When there was no information found to address a deviation, then Nexus Technical Services Corporation (NTSC) either developed an engineering evaluation to justify the deviation or identified that the station had to resolve the deviation. When a justification was written by NTSC, "(NTSC)" was listed after the justification.
Page 1 of 10 28-3
Units 2/3 Dresden Nuclear Station NTSC Report 93-124, Rev. I NFPA Code Compliance Matrices 12/17/99 2.2 Revision 1 (1999)
Dresden Station performed a Fire Protection Program Self-Assessment (FPPSA), the results of which are documented in the Dresden Self-Assessment Report (Ref. 4.1). That report identified NFPA Code Compliance issues that remained open. The following NFPA Code Compliance open items are addressed in this report through drawing reviews, walk downs and technical justifications:
- a.
The circuits associated with the manual pull stations used for activation of fixed suppression systems are unsupervised. This situation was believed to be a code deviation from NFPA 72D. This report developed a Technical Justification for this condition. (Deviation 72D-06.2)
- b.
The installation of a non-approved by-pass line and a timer to delay operation of each Cable Mezzanine pre-action sprinkler system deluge valve. This configuration is a deviation from NFPA 13. This report developed a Technical Justification for this condition. (Deviation 72E-05)
- c.
The 1995 NFPA 80 Code Compliance Report identified a number of outstanding fire door issues which were documented in Appendix G of the Fire Door Analysis (Ref. 4.2). To obtain the current status of each issue, these fire doors were walked down by NTSC and the Dresden Fire Protection Systems Engineer (DFPSE) in accordance with NTSC Procedure 99-4003.001, Rev. 0 (Ref. 4.55). The information obtained from the walkdown was used to update Appendix G of the Fire Door Analysis (Ref, 4.2). (Deviation 80-03)
- d.
The original Grinnell Unit 2 MG Set sprinkler Drawing 13-5165-8 (Ref. 4.3) identified that 3/8 inch orifice sprinklers were installed as required by the original design. The FPPSA identified that the 3/8 inch sprinklers had been replaced by V2 inch orifice sprinklers. The original method to resolve this issue was to analyze the potential effects on safe shutdown capability from larger amounts of water discharging from the larger sprinklers (1/2 inch vs. 3/8 inch).
However, while performing this suppression effects evaluation, it was identified by walkdown that, after the FPPSA, the Station had replaced the V2 inch sprinklers with 3/8 inch sprinklers. As a result, the plant was no longer out of compliance with this item. In addition, the plant has the necessary documentation on Grinnell drawings that show the proper orifice size and temperature rating of the sprinklers, so that the plant is in compliance with NFPA code provision 1.9-2 (m). (Deviation 13-89)
- e.
Based on the Dresden Self-Assessment report, there were three open items related to NFPA 90A. These items were investigated and the status of each were evaluated and documented as described below:
Page 2 of 10 28-4
Units 2/3 Dresden Nuclear Station NTSC Report 93-124, Rev. I NFPA Code Compliance Matrices 12/17/99
- 1.
The FPPSA identified that there was no documentation that fire dampers were installed in the control room ductwork at the time of the writing or the NFPA 90A Code Compliance review. During this project, the Modification Package M12-2/3-87-05E (Ref. 4.4) was reviewed, along with Specification T-3395 (Ref. 4.5) and Drawing M-3653 (Ref. 4.6) demonstrating that there are 3-hour rated fire dampers in the ductwork. (Deviation 90A-01)
- 2.
As of the writing of the NFPA 90A Code Compliance review, smoke detectors in the ductwork were not being routinely tested, cleaned or calibrated in accordance with the manufacturer's recommendations. During this project, Procedure 4183-14, Rev. 2 (Ref. 4.7) was reviewed and it was determined that the smoke detectors in the ducts are being tested annually in accordance with the manufacturer's instructions. However, the procedure does not indicate that the smoke sampling tubes in the ducts are being checked in accordance with the Manufacturer's Operations, Installation and Maintenance manual. (Deviation 90A-03)
- 3.
As of the writing of the NFPA 90A Code Compliance review, the flame spread rating of the ductwork insulation was undocumented. Calculation DREG97-0105, Rev. 3 (Ref. 4.8) was reviewed. This calculation assumed that external ductwork insulation was a combustible material and determined the loading contributed by external ductwork insulation in its computations. The calculations demonstrated that the plant is within safe limits with the existing ductwork insulation. (Deviation 90A-09)
Report 93-124, Rev. 0 was revised to address the issues described above.
In addition, this report revision incorporates:
"* The objective evidence found during the Fire Protection Program Self-Assessment, which closed out certain NFPA Code Compliance Report 93-124, Rev. 0 open issues.
"* The technical evaluation that was issued by the Station to address the lack of a fusible link at the ceiling for Fire Doors 12 and 46 (Clean and Dirty Oil Tank Room)
"* Resolution of the battery room airflow monitoring device surveillance issue (Deviation 50-10) and the fire hose system hydraulic capability issue (Deviation 14-02).
Finally, the report has been revised to divide those Matrices, which served to document more than one NFPA Code into two or more matrices so that each NFPA Code is addressed by a separate a separate matrix. For example, the matrix which reflected NFPA 4 and NFPA 4A has now been divided into two matrices, one for NFPA 4 and one for NFPA 4A.
Page 3 of 10 28-5
Units 2/3 Dresden Nuclear Station NTSC Report 93-124, Rev. 1 NFPA Code Compliance Matrices 12/17/99 3.0 ASSUMPTIONS None.
4.0 REFERENCES
4.1 Dresden Station Fire Protection Program Self-Assessment Report, Report Number 237-251-98-03100, 09/28/98 through 11/20/98 4.2 An Analysis of Fire Doors in Nuclear Safety Related Areas at Dresden Nuclear Power Station, Units 2 and 3 for Commonwealth Edison Company, April 15, 1988, Rev. 1 4.3 Grinnell Drawing 13-5165-8 (No Rev. Number given).
4.4 Memorandum to E. D. Eenigenburg, Station Manager, entitled "
Subject:
Partial Modification Approval Installation of HVAC Work Associated with Control Room Modifications Dresden Station - Units 1, 2 and 3 Modification No. M12 2/3-087-005E Specification Number T-3394 AIR - N/A", dated May 5, 1989 4.5 "Specification T-3395 FIRE DAMPERS Dresden Station - Units I and 2/3 Commonwealth Edison Company Project 7930-00", transmitted via letter from Mr. Jack W. Oneal, Contract Procurement Specialist, Sargent & Lundy Engineers to Mr. R. D. Koenig, BWR Cognizant Engineer, Commonwealth Edison Company, dated February 20, 1989 4.6 Drawing M-3563, Sheet 1, Rev. F, dated 12/14/98 "Control Room Kitchen and Locker Room Ventilation System Plans, Sections and Detail 4.7 "Unit 2/3 Control Room HVAC Smoke Detector Annual Surveillance Procedure, Unit 2/3 DFPS 4183-14, Revision 02", effective March 19, 1999 4.8 Calculation No. DREG97-0105, "Determination of Combustible Loading, Rev. 3, Attachment E, Page No. 13", dated 3/30/99 4.9 "Dresden Nuclear Station Units 2 and 3 Commonwealth Edison Company Fire Protection Program Documentation
- Package, Volume 9,
NFPA Code Conformance" 4.10 An Evaluation of Organization for Fire Services (NFPA #4) at Dresden Nuclear Power Station, Units 2 and 3 for Commonwealth Edison Company, April 24, 1985, Rev. 0.
Page 4 of 10 28-6
Units 2/3 Dresden Nuclear Station NTSC Report 93-124, Rev. I NFPA Code Compliance Matrices 12/17/99 4.11 An Evaluation of Organization of Industrial Fire Loss Prevention (NFPA #6) at Dresden Nuclear Power Station, Units 2 and 3 for Commonwealth Edison Company, April 24, 1985, Rev. 0 4.12 An Evaluation of Management Control of Fire Emergencies (NFPA #7) at Dresden Power Stations, Units 2 and 3 for Commonwealth Edison Company, Rev.0, 4/24/1985 4.13 An Evaluation of Management Responsibility for Effects of Fire on Operations (NFPA #8) at Dresden Nuclear Power Station, Units 2 and 3 for Commonwealth Edison Company, Rev.0, 4/24/85 4.14 An Evaluation of Standard Portable Fire Extinguishers (NFPA #10 and #10A) at Dresden Nuclear Power Station, Units 2 and 3 for Commonwealth Edison Company, April 24, 1985, Rev.0 4.15 S&L letter dated 8/7/87 to R.J. Whalen from J. W. Zeszutec, Fire Protection Closure Report - Draft Subsections I and 5, Project No. 7927-05 4.16 Initial Fire Brigade Training Program, Module FBP-07, "Hose and Fire Streams",
Section F, "Handling Fire Streams", Rev 4, January, 1999.
4.17 Dresden Nuclear Power Station Units 2 & 3 Fire Pre-Plans, Rev. 4, December 13, 1999.
4.18 Fire Suppression Survey in Nuclear Safety Related Areas at Dresden Nuclear Station Units 2 and 3 for Commonwealth Edison Company, Rev.3, 9/30/86 4.19 Low Pressure C02 Fire Extinguishing System Functional Operability and Full Discharge Tests for the Diesel Generator and Day Tank Rooms, Rev.0 (5/31/89)
(FPPDP Vol. 8) 4.20 A Review of Fire Suppression System Surveillance Procedures for Compliance with NFPA 12,12A,13,15,20 and 2 in Nuclear Safety Related Areas at Dresden Nuclear Station, Units 2 and 3 for Commonwealth Edison Company, Rev.0, 4/22/85 4.21 An Evaluation of Standard for the Installation of Standpipe and Hose Systems (NFPA#
- 14) at the Dresden Nuclear Power Station, Units 2 and 3 for Commonwealth Edison Company, 5/30/85, Rev. I Page 5 of 10 28-7
28-8 Units 2/3 Dresden Nuclear Station NTSC Report 93-124, Rev'. 1 NFPA Code Compliance Matrices 12/17/99 4.22 Hydraulic Calculations in the FPPDP Volume 10 and 11.
4.23 S&L letter dated 9/22/87 to R.J. Whalen from J. W. Zeszutec, Fire Protection Closure Report, Project 7927-05 4.24 Modification Addendum Letter # 2, Modification M12-0-93-001, Doc. ID #
0005807258 4.25 Memorandum of Telephone Conversation dated December 15, 1994, Person Called: Mark Ferris and Mike Thoma.
4.26 Aurora Pump, A Unit of General signal, Letter dated March 6, 1995 from Mark Farnis to V. Sehgal 4.27 Outside Protection Survey for Nuclear Safety Related Areas at Dresden Nuclear Station, Units 2 and 3 for Commonwealth Edison Company, Rev.0, 7/3/85 4.28 Fire Suppression System Valve Supervision in Nuclear Safety Related Areas at Dresden Nuclear Power Station, Units 2 and 3 for Commonwealth Edison Company, Rev.0, 4/22/85 4.29 An Evaluation of Organization, Training and Equipment of Private Fire Brigades (NFPA #27) at Dresden Nuclear Power Station, Units 2 and 3 for Commonwealth Edison Company, Rev.0, 4/24/85 4.30 An Evaluation of Flammable, Combustible and Highly Reactive Chemical Storage and Handling (NFPA #30 and #49) at Dresden Nuclear Power Station, Units 2 and 3 for Commonwealth Edison Company, Rev.0, 4/24/85An Analysis 4.31 A Survey of the Fire Hazards of Hydrogen Storage and Handling in Nuclear Safety Related Areas at Dresden Nuclear Power Station, Units 2 and 3 for Commonwealth Edison Company, Rev.0, 4/24/85 4.32 An Evaluation of Fire Hazards of Cutting and Welding Processes in Nuclear Safety Related Areas at Dresden Nuclear Power Station, Units 2 and 3 for Commonwealth Edison Company, Rev.0, 4/24/85 4.33 Applicability of NFPA 70 to Dresden Nuclear Power Station, Units 2 and 3 for Commonwealth Edison Company, 4/22/85, Rev.0 4.34 Fire Detection and Alarm Survey in Safety Related Areas at Unit 2 and 3, Dresden Nuclear Power Station, Commonwealth Edison Company, 1 1/11/84, Rev. 1.
Page 6 of 10
I LJVAZ,&
Units 2/3 Dresden Nuclear Station NTSC Report 93-124, Rev. 1 NFPA Code Compliance Matrices 12/17/99 4.35 NFPA Code Review of Standard for Installation, Maintenance and Use of Proprietary Protective Signaling Systems (NFPA 72D-1974) for Commonwealth Edison Company, Dresden Station, Units 2 and 3, Rev.0, 11/5/86.
4.36 A Review of the Fire Detection and Alarm System Surveillance Procedures for Compliance with NFPA 72D and 72E in Nuclear Safety Related at Dresden Nuclear Power Station, Units 2 and 3, Rev.0, 4/22/85.
4.37 Lightning Protection Survey in Nuclear Safety Related Areas at Dresden Nuclear Power Station, Units 2 and 3 for Commonwealth Edison Company, April 23, 1985, Rev.0 4.38 An Analysis of Fire Doors in Nuclear Safety Related Areas at Dresden Nuclear Power Station, Units 2 and 3 for Commonwealth Edison Company, April 23, 1985, Rev.0 4.39 Fire Protection Survey of HVAC Systems installed in Computer and Nuclear Safety Related Areas at Dresden Nuclear Power Station, Units 2 and 3 for Commonwealth Edison Company, 7/24/85, Rev.O 4.40 Sheet 3 of 6 of RSM D82617-1, Doc. 4 of the M12-2/3-087-005E Modification Documentation Package 4.41 Memorandum from Eric Skowron, Technical Staff Engineer, Dresden Nuclear Power Station to Mssrs. Rob Whalen and Brian Barth entitled "Dresden Station Closure Report Response to PLC's NFPA 90A Code Recommendation 5.10",
dated April 7, 1988, contained in the Dresden Station Units 2 & 3 Commonwealth Edison Company Fire Protection Documentation Package, Volume 9, Page C-I.
4.42 Floor Drain Survey in Nuclear Safety Related Areas at Dresden Nuclear Power Station, Units 2 and 3 for Commonwealth Edison Company, 7/22/85, Rev.0 4.43 Dresden Station Units 2 and 3 Commonwealth Edison Company Fire Protection Reports, Volume 1, Updated Fire Hazards Analysis, Amendment 12 4.44 An Evaluation of Screw Threads and Gaskets for Fire Hose Connections (NFPA #
194) and Standard Fire Hose (NFPA #196) at Dresden Nuclear Power Station Units 2 and 3 for Commonwealth Edison Company, April 24, 1985, Rev.0 Page 7 of 10 I
28-9
Units 2/3 Dresden Nuclear Station NTSC Report 93-124, Rev. I NFPA Code Compliance Matrices 12/17/99 4.45 An Evaluation of a Training Standard on Initial Fire Attack (NFPA #197) at Dresden Nuclear Power Station, Units 2 and 3 for Commonwealth Edison Company, 4/24/85, Rev.0 4.46 An Evaluation of Records Storage at Dresden Nuclear Power Station, Units 2 and 3 for Commonwealth Edison Company, 7/24/85, Rev.0.Application of NFPA 251 and NFPA 255 to Dresden Nuclear Power Station, Units 2 and 3 for Commonwealth Edison Company, Rev.0, 4/22/85 4.47 Application of NFPA 251 and NFPA 255 to Dresden Nuclear Power Station, Units 2 and 3 for Commonwealth Edison Company, Rev. 0, 4/22/85 4.48 An Evaluation of The Security Force Response to Fire Emergencies in Nuclear Safety Related Areas at Dresden Nuclear Power Station, Units 2 and 3 for Commonwealth Edison Company, Rev.0, 4/24/85 4.49 Completed DFPS 4132-03, Rev. 03 dated 02/06/96, Refuel Operating Cycle Verification of Unit 3 Sprinkler Systems Integrity.
4.50 Completed DFPS 4132-02, Rev. 03 dated 08/22/95, Refuel Operating Cycle Verification of Unit 2 Sprinkler Systems Integrity.
4.51 Completed DFPS 4132-01, Rev. 03 dated 08/22/95, Verification of Unit 2/3 &
Unit I Sprinkler Systems Integrity.
4.52 Commonwealth Edison Company Dresden Station Resolution of Engineering Request NFPA Code Deviation Justification Program, NTSC Report No. 97 010.001, Rev. 0, dated 8/12/97 4.53 Commonwealth Edison Company Work Request Number 9900022111, issued to close out NTS number 237-212-98-0660, source Document: PIF D1998-05753 4.54 S & L Drawing F-396, Rev. A, 9/11/85 4.55 NTSC Procedure 99-4003.001, Rev. 0, "Dresden Units 2 & 3 Fire Door Walkdown Methodology and Checklist."
4.56 Airflow Monitor Devices Data for U2/3 Battery Rooms: Drawing M-973, Rev. F, Work Request 970087796 (EPN 3-5786-102), Work Request 970088680 (EPN 3 5786-103),
Work Request 970086175 (EPN 2-5786-100),
Work Request 970086763 (EPN 2-5786-101)
Page 8 of 10 28-10
Units 2/3 Dresden Nuclear Station NFPA Code Compliance Matrices NTSC Report 93-124, Rev. 1 12/17/99 5.0 EXPLANATORY NOTES 5.1 All deviation numbers with an "S" mean that the deviation has to do with a surveillance, maintenance or test requirement.
5.2 In some cases, under the "Code Section" of the matrices, the FHA, SER or an other document is referenced instead of a NFPA paragraph. These documents were listed because the Code Compliance report referenced these documents. In addition, there were cases where the Code Compliance reviews did not specify the code paragraphs. In those cases, the code section was not provided.
Page 9 of 10 28-11
Units 2/3 Dresden Nuclear Station NFPA Code Compliance Matrices NTSC Report 93-124, Rev. 1 12/17/99 6.0 RESULTS The NFPA Code Matrices Report has been updated to address all open issues, including the NFPA Code Compliance issues identified in the Dresden Fire Protection Program Self-Assessment FPPSA (Ref. 4.1) [FPPSA deficiencies DO1, D02, D15, D16, D17, D18 D19 and recommendation R05]. These FPPSA issues have been resolved through the Station's corrective actions program or have been technically justified.
Detailed results are provided in the attached tables.
Table A: NFPA Deviation Closeout Matrices The NFPA Code Closeout Matrix enumerates all deviations from NFPA Codes that have been identified. The Close-out Matrix then lists the objective evidence that resolved the deviation. If a deviation has been resolved by corrective action, the "Recommended Action" column states "Delete Deviation". If a deviation was resolved by a Technical Justification, the Matrix lists the Technical Justification. The "Recommended Action" column states "None". If a deviation has not been resolved, the Closeout Matrix states the suggested action to close the item, such as "Review and Evaluate".
Table B: NFPA Code Justification Matrices Unlike the NFPA Code Close-out Matrix, which enumerates all deviations from NFPA Codes that have been identified, the Justification Matrix lists only those deviations, which have been closed out by a Teclmical Justification. The Technical Justification is shown in Table B for each item for which this is the method of closing out the deviation.
Table C: List of NFPA Codes of Record 28-12 Page 10 of 10
Units 2/3 Dresden Nuclear Station NFPA Code Compliance Matrices NTSC Report 93-124, Rev. 1 12/17/99 TABLE A NFPA DEVIATION CLOSEOUT MATRICES Table A contains the NFPA Deviation Close Out Matrices.
The NFPA Code Close-out Matrix enumerates all deviations from NFPA Codes that have been identified. The Close-out Matrix then lists the objective evidence that resolved the deviation.
If a deviation has been resolved by corrective action, the "Recommended Action" column states "Delete Deviation".
If a deviation was resolved by a Technical Justification, the Matrix lists the Technical Justification and the "Recommended Action" column states "None".
If a deviation has not been resolved, the Close-out Matrix states the suggested action to close the item, such as "Review and Evaluate".
I 28-13
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices NTSC Report No.93-124, Rev. I December 17, 1999 TABLE A DRESDEN NUCLEAR STATION NPFA DEVIATION CLOSEOUT MATRICES TABLE OF CONTENTS CODE NUMBER NFPA 4 NFPA 20 NFPA 72D NFPA 24 NFPA 72E NFPA 4A NFPA 26 NFPA 78 NFPA 6 NFPA 27 NFPA 80 NFPA 7 NFPA 30 NFPA 90A NFPA 8 NFPA 49 NFPA 92M NFPA 10 NFPA 50A NTPA 194 NTPA 12 NFPA 50B NFPA 196 NFPA 12A NFPA 51 NFPA 197 NFPA 13 NFPA 51 B NFPA 232 NFPA 13A NFPA 69 NFPA 251 NFPA 14 NFPA 70 NFPA 255 NFPA 15 NFPA 601 28-14
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE A NFPA 4 Deviation Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation Code Deviation Justification Recommended Action No.
Section 04-01 Not identified.
Combined fire drills with the local fire DAP 03-01, Rev. 4 identifies that thie station fire None.
department are not conducted annually (Rcf.
marshal is responsible for making arrangements
- 4. 0, pg 6. para I).
with the local fire department.
Procedure DFPP 4100-01 Section G. 1,b(2) addresses offering annual training to the local fire department. Discussions with thie Station Fire Marshal indicated that members of the Coal City Fire Protection District have not participated in fire drills at the station in the recent past.
However, training sessions are conducted with the Coal City Fire Protection District. Dresden Station hosts the Shabbona Fire Clinics for all area fire departments. This was completed on 4/4/98 and was scheduled again for 4/10/99.
GSEP Training is given to Coal City Fire Protection District annually and they are invited to participate in Station drills annually. Although an opportunity for improvement exists ifthe Coal City Fire Protection District participates in fire drills or other exercises held at the Station, the Station has no control over the local fire department. The issue was discussed and recognized by Assistant Fire Marshal. Under the circumstances, the relationship between the two parties is ACCEPTABLE (Ref. 4.1, Section 2.7, page 25).
00j 00
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE A NFPA 4A Deviation CIose Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999 ON Deviation Code Deviation Justification Recommended Action No.
Section N e
.4)o None None (Re r. 4. 1 0).
None.
i TABLE A NFPA 6 Dcviation Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation Code Deviation Justification Recomnmended Action No.
Section 06-01 Not identified.
Procedures do not address overall Loss Procedure DAP 03-01, Rev. 4 addresses this Delete Deviation (DD).
Prevention Program (Ref 4.11,. pg 4, para 2).
issue.
06-02 Section 220.
Procedures do not address organi7ational Procedure DAP 03-01, Rev. 4 addrCsscs this DD NFPA 6 functions of Plant Fire Loss Prevention Manager issue.
.___(Ref.,4.11._pg,4._para33).
06-03 Paragraph's 230 Relationship with the local fire dcpartment needs Procedure DAP 03-01, Rev. 4 addresses this DD
- 233,. NFPA 6 improvement (Ref. 4.11. pg 5. para I).
issue.
06-04 Section 240, Plan engineering department deficiencies (Ref.
DAP05-01,Rev.20 checklist 5-1C addresses this DD NFPA 6 4.11. pg 5. para 3).
issue.
06-05 Section 263, "The on-going relationship between Safely and Corporate safety and fire protection policies and DD.
NFPA 6 Fire Protection is not Formalized" (Rcf.4. II, pg 5, implementing procedures are in place to para 7).
adequately accomplish safety and fire protection objectives.(NTSC) 06-06 Section 280, "No central point of control or coordination in Procedure DAP 03-01, Rev. 4 addresses this DD NFPA 6 relationship to the procedures dealing with Loss issue.
Prevention appears to exist" (Ref.4. II, pg 6, para 3).
06-07 Section 290, Poor docunientation on Loss Prevention Procedure DAP 03-01, Rev. 4 addresses this DD NFPA 6 Standards (Ref.4. 11, pg 6, para 4).
issue.
06-08 Section 261 and Lack of loss prevention program documentation Procedure DAP 03-01, Rev. 4 addresses this DD
- 300, (Rc'.4. II, pg 6, para 4 and pg 7).
issue.
NFPA 6
-0 Unit 2/3 Dresden Nuelear Station NIPA Code Matrices
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE A NFPA 7 Deviation Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999 t-Q 00 Deviation Code Deviation Justification Recommended Action No.
Section 07-01 Section (40, There is no Industrial Emergency Association The CECo corporate GSEP is so structured that None.
NFPA 7 which provides for *mutual aid between Dresden support from one CECo plant would be provided and other industrial plants (Ref.4.12, pg 3. para to a other as appropriate (Ref. 4.12, pg 3. para 3).
3).
07-02 Section 220 and Outside firc departments arc not involved in plant These items are addressed in the NFPA #4 and DD.
- 230, ire drills and are not coordinated (Ref. 4.12, pg H4A evaluation (Ref. 4.12, pg 4. para 3).
NFPA 7 4, para 3).
I TABLE A NFPA 8 Deviation Close Out Matrix NTSC Report No.93-124, Rev. I Decemher 17, 1999 Deviation Code Deviation Justification Recommended Action No.8 SectionoII(142 8-01 No deviations (Rcf, 4. 12).
00o Unit 2/3 Dresden Nuclear Stntion NFPA Code Matrices
Unit 213 Dresden Nuclear Station NtPA nCde Matrices TABLE A NFPA 10 Deviation Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation Code Deviation Justification Recommended Action No.SNo more prominent markings would be helpful on extinguishers (Ref. 4.14, pg 3, para 3).
Extinguishers for Class hazards are not distributed per NFPA 10 (Ref. 4.14, pg 3 para 5 and pg 4 para I).
Travel distance for Class B extinguishers is exceeded (Ref. 4.14, pg 4 and 5).
Adequate markings are provided.
DFPS 4114-04, Rev.0 verifies that proper labels are on extinguishers on an annual basis as opposed to monthly.
Annual surveillance is considered adequate based on the following:
- a. Station personnel are periodically trained to operate plant fire extinguishers.
- h. Access to tei plant is controlled through nuclear security procedures.
- c. Instructions for proper operation of the extinguishers are affixed permanently to the extinguisher. (Ref 4.15, pg 1. 1-6, Item 4.1).
The quantity 01 Uass A comnusunles is
......-
..,..:.....I The quantity of Class A combustibles is limited primarily to cable insulation and well distributed hose stations are provided for a trained, on-site fire brigade. (Ref. 4.14, pg 3, Para 5 and pg 4 Para I).
The increased travel distances are justified based on major hazards being protected by automatic and manual suppression and detection systems monitored by a proprietary fire alarm system and ignition sources are controlled. (Ref4.14., pg 4 and pg 5).
None.
n-1.11. I "
10-01 Paragraph 1-4, NFPA 10 t'j 00 O0 10-02 10-03 Section 3-2.
NFPA 10 Section 3-3, NFPA 10 None.
NOIIC-
Unit 2/3 Dresden Nuclear Station TABLE A NTSC Report No.93-124, Rev. I NFPA CodeMatrices NFPA 10 Deviation Close Out Matrix December 17, 1999 Deviationcode Deviation Justification Recommended Action IFNo.
Section I
10-04 Section 3-6, Travel distance for Class C extinguishers is Electrically safe nozzles are provided on all hoses None.
NFPA 10 exceeded (Ref. 4.14, pg 4 and 5).
except the refuel floor (Ref. 4.14, pg 4 and 5; Rcf. 4.15. pg 1. 1-6, 4.2) (See Footnote 1) and on the hard rubber hoses provide to cover the Control Room.
Fire Brigade members are trained in the risks involved in using non-electrically rated fire nozzles in the Initial Fire Brigade Training Program, Module FBP -07, "Hose and Fire Streams", Section F, "Handling Fire Streams".
Fire Brigade members also receive biennial requalification training in this subject ( Ref.
4.16).
The Dresden Nuclear Power Station Units 2 & 3 Fire Pre-Plans document the locations of these nozzles and identify risks involved in using these nozzles on the Fire Pre-Plans (Ref. 4.17).
Footnote I.
This is to minimize the potential of applying water to the new fuel in the new iuel storage pit, straight stream nozzles are used on the refuel floor (NTSC).
Page 2 of 2
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE A NFPA 12 l)evialion Close Out Matrix NTSC Report No.93-124, Rev. I Decemher 17, 1999 Dcviation code Deviation Justification Recommended Action No.
SectionL I_1
_1 12-01 Not provided.
The roll up fire door at the large louvered opening The louvered doors can maintain anl adequate None.
in each room is currently arranged to close only C02 concentration without the fire door closing on operation ofthe fusible link (Rcf. 4.18, Sect.
(Ref. 4.19 and Ref. 4.1, Section 3.2.1.3) 4.2 and 6.3).
12-02 Not provided.
The fire doors at louvered openings into the The louvered doors can maintain an adequate None.
emergency DG rooms do not close :automa:tically C02 concentration without the fire door closing upon actuation o[1the C02 system (Ref. 4.1S, pg (Ref. 4.19 and Rer. 4.1, Section 3.2.1.3).
- 3. sect.2.2) 12S-01 Par. 1716, No fire protection procedure could he located An acceptable weekly check is conducted under a DD.
NFPA 12 which requires a weekly cheek of C02 storage procedure known as Appendix B Center Desk tank level and pre'ssire. as required by NFPA 12-Logbook (Ref.4.20, Sect.3.1).
1973. Paiagraph 1716. DRIP 4114-3 indicates these inspections are carried out monthly (Ref`.
4.20. Sect 3. 1. para I and pg 4 Subpart I).
12S-02 1712 and 1714, Simulated tests of the system components.
Dresden exceeds these requirements by None.
NFPA 12 including a "Puff test" are to be carried out every performing semi-annual maintenance testing of 18 months according to Dresden Tech Spec Item the C02 systems. The procedure for these tests is 4.12.D.3. NFPA 12 has no periodic actuation test listed in DFPP 4145-I (Ref.4.20, Sect.3.1).
requirement, although periodic (at least annual) inspections are recommended (Paragraph 1714) and discharge tests made when advisable (Paragraph 1712) (Ref. 4.20, Sect 3.1, para I and pg 4 Subpart I).
00 t'j K)
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE A NFPA 12A Deviation Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation Code Deviation Justification Recommended Action No.
Section
_I[II 12AS-01 Par. 1553.
Paragraph 1553 ofNFPA 12A requires a The Station did not commit to NFPA 12A None.
NFPA 12A hydrostatic test of charged cylinders at least every maintenance requirements. As a result, this 12 years. No procedure could be located which activity is not required (Ref. 4.1).
indicates these hydrostatic tests are heing carried out (Rcf.4.20, Sect. 3.2, para I and pg 5 Subpart 2).
12AS-02 Not provided Dresden Tech Spec Item 4.1 2.H. I requires a In actuality, there are no valves in this flow DD.
monthly check of the valves in the flow path from (Ref.4.20, Sect. 3.2).
the Halon cylinders to the nozzles path (Ref.4.20, Sect. 3.2, para I and pg 5 Subpart 2).
12AS-03 1715 and 1716.
DFPP 4114-3 requires the Halon cylinder DFPS 4195-01, Rev.0 DD NFPA 12A pressure to be checked monthly, but does not list addresses this issue.
any minimum acceptance criteria for this pressure. Semi-annual procedure DFPP 4195-1 also requires a pressure check, as well as cylinder weight in accordance with NFPA 12A-1973 (Paragraphs 1715 and 1716) and Dresden Tech Spec 4.12.1-.2. The miniTTnL acceptance criteria for weight and pressure is assumed to be that noted on the tag attached to each cylinder, although this is not clearly indicated by the procedure (Ref.4.20, Sect. 3.2, para I and pg 5 Subpart 3).
12AS-04 Not provided "Dresden Tech. Spec 4.12.1-1.3 requires the DFPS 4195-02. Rev.0 DD system to be verified to actuate manually and addresses this issue.
automatically, and a flow test to be made through headers and nozzles to verify no blockage at least once every 18 months. No permanent procedure could be found which verifies these items are performed (Rcf.4.20, Sect. 3.2, para I and pg 5 Subpart 4).
tN 00 NJ
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE A NIPA 13 Deviation Close Out Matrix NTSC Report No.93-124, Rev. 1 December 17, 1999 Deviation Code
[Deviation I
Justification Recommended Action No.
Section R
13-01 SER (3/87)
Documentation transmitted to the NRC regarding Hydraulic calculations address this issue (Ref.
DD.
Section 4.3.1.2, the adequacy of the new pump with the shortest 4.22).
NFPA 13, piping leg out of service indicates the 750 gpm Section not hose demand cannot be met for the largest system provided.
demands. Also, several systems have been installed since this documentation was prepared and the flow and pressure requirements of some of these systems may also exceed the available supply. Hydraulic calculation data has not yet been located for five safety related systems (See Table One for specific systems) (Rcf. 4.18, pg 7, Sect 5.!1; pg 12, Sect 6.2; pg 3, Sect. 2.1; and pg 3, Sect.2.2).
13-02 Not provided Documentation has not been located to verify that Due to the arrangement of the distribution system None.
the distribution piping has been flushed (or at a and the use of strainers the intent of the code is specific flow rate)prior to connection to the net (Ref.4.18, Sect 6.1, Pgs ItI and 12).
numerous sprinkler and water spray systems (Ref.4.18, pg 11, Sect.6.1).
13-03 SER (3/87)
A sprinkler system has not been installed to Hydraulic calculations address this issue DD Section 3.1.3.
protect the U3 Containment Cooling Service (Ref.4.22).
Water Pumps (Ref.4. IS; pg 8, Sect 5.3 and pg 3, Sect.2. 1).
Not provided Contractor's test certificates are available and have been reviewed for 51 of the water suppression systems. However, no documentation has been located to verify such testing for the remaining 5 systems (Ref. 4.18, pg 15, Sect.0.6).
All systems were installed by Grinnell whose standard practice is to perform hydrostatic testing. The systems have been in operation for fourteen years now with no significant leaks or breaks (Ref. 4.18, Sect 6.6. Pg 15).
13-05 4-2.4.6, U2 Condensate Pump Area: One sprinkler head Mod. M 12-2-84-107 addresses this issue (Ref.
DD NFPA 13 on the north side of the man-lift is 3 inches to one 4.23. pg 1, Item 7.1.1).
side of a beam which obstructs the water distribution pattern (Ref. 4.18, pg IS, Sect.7.1. 1).
t'J 00 13-04 i
I None.
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE A NFPA 13 Deviation Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation Code Deviation Justification Recommended Action No..Section 13-08 4-1.1.1(1) 13-09 4-2.4.6 U2 Condensate Pump Area: Sprinklers are not provided below the large pipe (column lines 37.1 to 38.5) along the south wall of the room. This large pipe appears to be slightly less than 4 feet wide. However, an adjacent pipe approximately 2 feet wide is located slightly above and to the side of the larger pipe resulting in an effective obstruction approximately 6 feet wide (Ref. 4.18, pg 19, Sect.7.1.2).
U2 Condensate Pump Area: Sprinklers below the wide HVAC duct located in the east portion of the room (column line 35.7 to 37. 1). The ventilation duct is 4-5 feet wide (Ref.4.18, pg 19, Sect.7.1.3).
U2 Condensate Pump Area: Sprinklers are not provided to protect the open hatch area in the southeast comer of the area which is currently used for storage of lube oil (Ref. 4.18, pg I9, Sect.7.1.4).
U3 Condensate Pump Area: One sprinkler head located 10 feet north of the man-lift at (coluni 48.7) is currently obstructed by a steel beam (Ref.4.18, pg 19, Sect.7.2.I).
Mod. Ml 2-2-84-107 addresses this issuc (Ref.
Mod. M 12-2-84-107 addresses this issue (R.f2 4.23, pg 1, Item 7.1.2).
Mod. M12-2-84-107 addresses this issue (Ref.
4.23, pg 1, Item 7.1.3).
Mod. M12-2-84-107 addresses this issue (Ref.
4.23, pg I, Item 7.1.4).
The obstruction is minor and due to other sprinklers installed, this is an acceptable configuration (Ref. 4.18, Sect 7.2. 1, Pg 19).
DD DD None.
I 1
11 13-06 13-07 4-1.1.1(3),
NFPA 13 4-4.11 and 4-4.13.
NFPA 13 t'Q 00 I
I I
I r-.n DD
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE A NFPA 13 Deviation Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation Code Deviation Justification Recommended Action No.
Section
_L_
II 13-10 4-1.1.1(3)
U3 Condensate Pump Area: Heads are not Mod. M12-3-84-107 addresses this issue (Ref.
DD provided below the large pipe (column line 49.5 4.23, pg 1, Item 7.2.2).
to 50.3) along the souith wall of the room. This piping is over 4 rt wide (Ref. 4.18. pg 20.
Sect.7.2.2).
13-11 4-4.11 and 4-U3 Condensate Pump Area: Heads are not Mod. M12-3-84-107 addresses this issue (Ref.
DD 4.13 located below the wide HVAC duct in the west 4.23, pg I, Item 7.2.3).
portion of the room (column lines 49.9 to 52.4)
(Ref. 4.18, pg 20, Sect.7.2.3).
13-12 4-1.1.1(1)
U3 Condensate Pump Area: Sprinklers are not Mod. M12-3-84-107 addresses this issue (Ref.
DD provided to cover the pen hatch area in the 4.23, pg 1. Item 7.2.4).
southwest corner of the room which is currently used for storage of lube oil (Ref. 4.18, pg 20, Scct.7.2.4).
13-13 Not provided U2 Cont. Cooling Service Water Pump and CRD Mod. M 12-2-84-107 addresses this issue (Ref.
DD Pump Room: An inspector's test connection for 4.23, pg 1, Item 7.3.1).
the system is not installed (Rer.4.IS, pg 20, Sect.7.3. I).
13-14 SER Section U2 and U3 HPCI Pump Room: A deluge system Preaction systems were installed to reduce the None.
5.1.8.6 is not installed for the U2 and U3 HPCI Pump potential of inadveriant operation. This type of Rooms (Ref. 4.18, pg 21, Sect.7.4.I).
system provides an equivalent level of protection compared to a deluge system (Ref. 4.23, pg 2 1, Item 7.4. 1I).
13-15 Not provided U2 and U3 HPCI Pump Room:
Ai inspector's Mod. M 12-2(3)-84-107 and PLC Letter 2/26/86 DD test connection for both systems are not installed address this issue (Ref.4.23, pg 2, Item 7.4.2).
(Ref. 4.18, pg 21, Sect.7.4.2).
t0
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE A NFPA 13 Deviation Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation Code Deviation Justification Recommended Action ti No.
I7Section U2 and U3 HPCI Pump Room: The south end of the room is not protected (Ref. 4.18, pg 20, Sect.7.4.3).
U2 and U3 HPCI Punmp Room: Heads arc within 6'-0" of each other (Ref. 4.1S, pg 20, Sect.7.4.4).
U2 and U3 HPCI Pump Room: No waterflow alarm is provided for these systems (Ref. 4.18, pg
- 21. Sect.7.4.5).
Mod. M 12-2(3)-84-107 and PLC Letter 2/26/86 address this issue (Ref'. 4.23, pg 2, Item 7.4.3).
Mod. M 12-2(3)-84-107 and PLC Letter 2/26/86 address this issue (Ref. 4.23, pg 2. Item 7.4.4).
Since each systems consists of fewer than 20 sprinkler heads, the waterflow alarm may be waived and is, therefore, acceptable (Ref. 4.18, pg 21, Sect.7.4.5).
This is in compliance with NFPA 13.
DD 4-1.1.1, NFPA 13 13-17 Not provided 13-1S Not provided 13-19 Not provided U2 Trackway: Inadequate hanger supports for Mod M12-2(3)-84-107 and PLC Its dated 2/26/86 DD the sprinkler pipe between heads I and 2 near tile addresses this issue (Ref. 4.23, pg 2, Item 7.5.1).
stairs (Ref. 4.18, pg 22, Sect.7.5.1).
13-20 4-1.1.1(3)
U2 Trackway: The existing sprinkler location is Mod M 12-2(3)-84-107 and PLC Its dated 2/26/86 DD effectively obstructed by stairs and mechanical addresses this issue (Ref. 4.23, pg 2, Item 7.5.2).
piping in thie northeast corner of the area (Ref.
- 4. I1S, pg 22, Sect.7.5.2).
13-21 4-1.1.1(2)
U2 Trackway: The distance between the sidewall Mod M12-2(3)-84-107 and PLC Its dated 2/26/86 DD heads exceeds NFPA 13 requirements (Ref. 4.18.,
addresses this issue (Ref. 4.23, pg 2, Item 7.5.3).
pg 22, Sect.7.5.3).
13-22 4-1.1.1(3)
U2 Trackway: Sprinkler 4 is obstructed by Mod Ml2-2(3)-84-107 and PLC Its dated 2/26/86 5D piping (Refr. 4.18, pg 22, Sect.7.5.4 ).
addresses this issue (Ref. 4.23. pg 2, Item 7.5.4).
13-16 t'Q
.-.o r
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE A NFPA 13 Deviation Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation Code Deviation Justification Recommended Action No.
Section
_I_
_ II__
_I 13-23 SER 3.1.5.2 Sprinklers have not been installed in the U3 Sprinklers have been installed under the hot well DD Turbine Upper Basement, El. 495-0 (Ref. 4.18, and in the CRD pump rooms which are located on pg 3, Sect.2.1).
this area. (Ref. 4.18, pg.3. sect.2.1).
13-24 4-3, NFPA 13 U2 Trackway: All 8 sprinkler heads at the south Mod M 12-2(3)-84-107 and PLC Its dated 2/26/86 DD end of the trackway (column lines G - 11) are not addresses this issue (Ref. 4.23, pg 2. Item 7.5.5).
within 16 inches of the ceiling as required by NFPA 13 (Ref. 4.18, pg 22, Sect.7.5.5).
13-25 4-1.1.1(4)
U2 Trackway: Sprinkler 10 is not parallel with WR DR46359 addresses this issue (Ref. 4.23, pg DD the ceiling (Ref. 4.IS, pg 22. Scct.7.5.6).
- 2. Item 7.5.6).
13-26 Not provided L13 Trackway: Existing heads along ihe cast side Mod M 12-3-84-107 addresses this issue (Ref.
DD of the open bay area (column lines E to G) exceed 4.23, pg 3, Item 7.6.1).
distances between the heads as required by NFPA 13 (Ref. 4.18, pg 23, Sect.7.6. 1).
13-27 4-3, NFPA 13 U3 Trackway: Four sprinklers at the southeast Mod M 12-3-84-107 addresses this issue (Ref.
DD corner of the trackway (branches lines B and C) 4.23, pg 3, Item 7.6.2).
are not within 12 inches of the ceiling (Ref. 4.18, pg 24, Sect.7.6.2).
13-28 Not provided U3 Trackway: Heads are not provided as shown Mod M 12-3-84-107 addresses this issue (Ref.
DD on the sketch as X. These heads are required by 4.23, pg 3, Item 7.6.2).
NFPA 13 since the steel beams in the area exceed 7-1/2 foot spacing (Ref. 4.18, pg 24, Sect.7.6.2).
13-29 4-3 U3 Trackway: Sidewall heads I, 2, 3, 4, 5. and 6 Mod M 12-3-84-107 addresses this issue (Ref.
DD are not within 12 inches of the ceiling in the 4.23, pg 3, Item 7.6.3).
beam pockets to ensure timely actuation of each sprinkler as required by NFPA 13 (Ref. 4.18, pg 24, Sect.7.6.3).
00 00
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE A NFPA 13 Deviation Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation Code Deviation Justification Recommended Action No.
Section 13-30 Not provided U3 EHC Fluid Reservoir: The sprinklers located However, the anticipated type of fire in this area None.
below the cable trays above the Unit 3 EIIC fluid is a rapidly developing oil type fire which will reservoir are not centered directly beneath the result in high temperatures at an early stage.
cable trays (Ref 4.18. pg 25, Sect.7.7 I).
Therefore, there is no need to relocate thce head(s) to directly beneath the cable trays or to provide heat collectors. The sprinklers will actuate in a timely manner as installed and will protect the cable trays for an exposure fire below (Ref. 4.18, pg 25, Sect.7.7.I).
13-31 Not provided U3 EHC Fluid Reservoir: The northernmost head However, the anticipated type of fire in this area None.
on the branch line located along the cable trays is a rapidly developing oil type fire which will above the Unit 2 ElIC fluid reservoir is not result in high temperatures at an early stage.
centered directly beneath the cable tray. This Therefore, there is no need to relocate the head(s) sprinkler is located immediately southeast of to directly beneath the cable trays or to provide column line E44 (Ref. 4.18, pg 25, Sect.7.7.2).
heat collectors. The sprinklers will actuate in a timely manner as installed and will protect the cable trays for an exposure fire below (Ref. 4.18, pg 25, Sect.7.7.2).
13-32 4-1.1.1(1)
U3 EHC Fluid Reservoir: Sprinklers are not Mod M12-2-84-107 and PLC Itr 5/28/86 address DD provided near ceiling level (within 12 inches) to this issue (Ref. 4.23, pg 3, Item 7.7.3).
cover the existing areas described below: a. The northeast section near column line 43E. b. The northwest section near column line 45E (Ref.
4.18, pg 25, Sect.7.7.3).
13-33 Not provided EHC Fluid Reservoir: Sprinklers are not Mod M 12-2-84-107 and PLC Itr 5/28/86 address DD provided to protect the area above each cable tray this issue (Ref. 4.23 pg 3, Item 7.7.4).
parallel to branch lines B and C in the event of a cable initiated fire (Ref. 4.18, pg 25, Sect.7.7.4).
00
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE A NFPA 13 Deviation Close Out Matrix NTSC Report No.93-124, Rev. 1 December 17, 1999 Deviation Code Deviation Justification Recommended Action No.
SectiodenDeviat[onI 13-34 Not provided EHC Fluid Reservoir: Note: This paragraph Mod M 12-2-84-107 and PLC htr 5/28/86 address DD discusses planned additional protection. A this issue (Ref. 4.23, pg 4, Item 7.7.5).
specific deviation is not stated, but it is insinuated that the additional protection is required (Ref.
4.18, pg 26, Scct.7.7.5).
13-35 Not provided U2 Bus Duct Pen (517-6): No waterflow alarm is However, since only 8 water spray nozzles are DD provided for this system (Ref. 4.18, pg 27, provided, the lack of such an alarm is acceptable Sect.7.S. 1).
(Ref. 4.18, pg 27, Sect.7.8. 1).
This is in accordance with NFPA 13.
13-36 Not provided U2 Bus Duct Pen (517-6): 2 water spray nozzles WR D46362 addresses this issue (Ref. 4.23, pg4, DD near column line 32 are directed away from the Item 7.8.2).
bus duct penetrations (Rcf. 4.1S. pg 27, Sect.7.8.2).
13-37 Not provided U2 ACAD Air Comp. (530-6): Heat collector Mod M 12-2-84-107 addresses this issue (Ref.
DD plates are not provided above the two sprinklers 4.23, pg 4, Item 7.9.1).
as indicated on the original sprinkler drawing (Ref. 4.18, pg 27, Sect.7.9.I).
Not provided U2 ACAD Air Comp. (530-6): The heads arc not a minimum of 6 feet apart to prevent cold soldering as required by NFPA 13 (Ref. 4.1 S. pg 27, Sect.7.9.1 ).
Mod M 12-2-84-107 addresses this issue (Re4.
4.23, pg 4, Item 7.9. 1 ).
13-39 4-3 U2 Instr. Air Comp. (517-6): One sprinkler head
...this is acceptable in this case since the specitic None.
located over the air compressor at column line hazard for this head is an oil fire which will result 34D is located approximately 9 feet below the in a rapidly developing fire which will provide ceiling (Ref. 4.18, pg 28, Sect 7.10. 1).
sufficient heat to operate the sprinkler even though not located within 12 inches of the ceiling (Ref. 4.18, pg 28, Sect 7.10.1).
t00 13-38 i
i DD i
m 4*
k1--
n.,,P.7 or, I A*
Unit 2/3 Dresden Nuclear Station NFTPA Code Matrices TABLE A NFPA 13 Deviation Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation Code Deviation Justification Recommended Action No.
Section I
13-40 4-1.1.1(3)
U2 Instr. Air Comp. (517-6): Lower four pendent Mod M 12-2-84-107 and PLC ltr dtd 2/26/86 DD sprinkler heads (SSP) located below the cable address this issue (Rcf. 4.23, pg 4, Item 7.10.2).
trays in the hallway at colunin line 33 for E to F:
All four sprinklers are located approximately I inch above a PIP obstruction located only 3 inches horizontally to the side which significantly impairs the water distribution pattern of the sprinkler heads for this area (Ref. 4.1S, pg 28, Sect 7.10.2).
13-41 4-3 UI Crib House: Several sprinklers within the area For this particular area, the sprinklers need not be None.
are located 14-IS inches below ceiling level relocated since the anticipated hazard in the area instead of the maximum distance below ceiling of is an oil fire which will be a rapidly developing 12 inches allowed by NFPA 13 (Ref. 4. IS, pg 28 type fire with large amounts of beat and smoke.
and 29, Sect 7.11.1).
Relocation of the sprinklers in this area would not protetion for the a ea.T ereforethe eitn resultin signlif
,icant impr vem nti n
ml t
t protection for the area. Therefore, the existing location of the sprinklers is considered acceptable (Ref. 4.18, pg 28 and 29, Sect 7.11.1).
13-42 Not provided U2/3 Crib House: Sway bracing and hangers Mod M 12-2/3-84-66 addresses this issue (Ref.
DD supporting the water spray system piping 4.23, pg 4, Item 7.12.I).
currently existing around the diesel driven fire pump are inadequate (Ref. 4.18, pg 29, Sect 7.12.1).
13-43 Not provided U2 Reactor Feed Pump Room: The use of the Hydraulic calculations address this issue (Ref.
DD pipe schedule method of system design for the 4.22).
Reactor Feed Pump Area is inappropriate due to the excessively long run of dead-end 4 inch supply main (approximately 200 feet) in the Turbine Building east-west corridor, ground floor (Ref. 4.18, pg 30, Sect 7.13, para 2).
13-44 Not provided.
The existing globe type valves in the fire pump This is a NFPA 20 issue which is addressed by DD diesel engine cooling water line are not of the Deviation 20-06.
indicating type.(Ref. 4.18. pg.30, sect.7.12.2).
Patie 8 of 16 t',Q 11q r
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE A NFPA 13 lceviationu Cloe Ow Matrix NTSC Report No.93-124, Rev. I December 17, 1999
_-r Deviation Justification No.
SNone.
13-47 4-1.1.1(1) 13-49 Not provided U2 Reactor Feed Pump Room: One sprinkler head in the northwest corner of the room has been removed near column line 38 (Ref. 4.1 S. pg 3 1.
Sect 7.13.1).
U2 Reactor Feed Pump Room: Sprinkler heads are not provided to protect the north side of the room just north of column line G. The existing sprinklers will not protect the entire distance to the north wall (Ref. 4.18, pg 31, Sect 7.13.2).
U2 Reactor Feed Pump Room: The eastern end of the room is inadequately protected (apparently the sound barrier walls were relocated after installation ofrthe sprinkler system) (Ref. 4.18. pg 3 1, Sect 7.13.3).
U2 Reactor Feed Pump Room: Several problems regarding heads installed to protect beneath wide HVAC ducts in the room (Ref. 4.18, pg 31, Sect 7.13.4).
U2 Reactor Feed Pump Room: The use of the pipe schedule method of system design for the Reactor Feed Pump Area is inappropriate due to the excessively long run of dead-end 4 inch supply main (approximately 200 feet) in the Turbine Building east-west corridor, ground floor (Ref. 4.18, pg 33, Sect 7.13.4).
The original sprinkler design required this head to provide protection beneath the wide ventilation duct in the area. This HVAC duct does not presently exist and therefore, no sprinkler is needed at this time (Ref. 4.18, pg 31, Sect 7.13.1).
Mod M 12-2-84-107 addresses this issue (Red.
4.23, pg 5, Item 7.13.2)
Mod M 12-2-84-107 addresses this issue (Ref.
4.23, pg 5, Item 7.13.3)
Mod M 12-2-84-107 addresses this issue (Ref.
4.23, pg 5, Item 7.13.4)
Hydraulic calculations resolve this issue (Ref.
4.22).
I I
Recommended Action None.
DD DD DD DD Deviation Code 13-45 13-46 4-4.1 I and 4-4.13 4-1.1.1(1) ti 00 L.,J.
13-48 4-4.11 and 4-4.13 I
I I
I I
I I
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE A NFPA 13 Deviation Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation Code Deviation Justification Recommended Action No.
Section[
13-52 4-1.1.1(1) 13-53 Not provided 13-54 4-1.1.1(3)
I I
U3 Reactor Feed Pump Room: The lower level sprinkler head located just southwest ofcoluimn G5 I is not centered beneath thel -IVAC duct (Ref.4.1 S, pg 33. Sect 7.14.1).
"U3 Reactor Feed Pump Room: Two sprinkler heads located below the ventilation ducts at the north end ofcolumni line 53 were intended for installation directly beneath the ducts. Also, the northernmost sprinkler head below the HVAC duct along column line 52 was intended to be no more thaan 12 inches below the duct according to the sprinkler drawings. The First two heads arc not installed beneath the duct and the third sprinkler is located IS inches below the duct" (Ref.4.IS. pg 33, Sect 7.14.2).
U3 Reactor Feed Pump Room: The existing sprinklers will not cover the entire distance to the north wall (Ref. 4.IS. pg 34, Sect 7.14.3).
U3 Reactor Feed Pump Room: The branch line located 5 feet west ofcolumn line 51 is twisted such that two heads are angled at 30 degrees to the vertical (Ref. 4.18, pg 34, Sect 7.14.4).
U3 Reactor Feed Pump Room: The sprinkler head just northeast of column line H52 is obstructed by a pipe support (Ref. 4.18, pg 34. Sect 7.14.5).
Due to the anticipated type of fire, this Due to the anticipated type of fire. this configuration is acceptable (Ref.4.18, pg 33, Sect 7.14.1).
The location ofrall three of these heads are considered acceptable because an oil fire in this room would produce high temperatures very quickly. (Ref. 4.18, pg 33, Sect 7.14.2).
Mod. M 12-2-84-107 resolves this issue (Ref.
4.23, pg 5, Item 7.14.3).
WRD46460 resolves this issue (Ref. 4.23, pg 6, Item 7.14.4).
Mod. M 12-2-84-107 resolves this issue (Ref.
4.23, pg 6, Item 7.14.5).
None.
DD DD DD 13-50 13-51 Not provided 4-4.11 and 4-4.13 00 I kv-I I
I None.
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE A NFPA 13 Deviation Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation Code Deviation Justification Recommended Action No.
Section I
13-55 4-1.1 I and U3 Reactor Feed Pump Room: Several problems Mod. M12-2-84-107 resolves this issue (Rcf.
DD 4-4.13 regarding heads installed to protect beneath wide 4.23, pg 6, Item 7.14.6).
ventilation ducts in the room (Ref. 4.18, pg 34, Sect 7.14.6).
13-56 4-3 Two sprinkler heads located in the northwest However. the expected oil fire for this area will None.
corner of the room are spaced approximately 10 produce high temperatures in a short period of feet above floor level. This does not comply with time, thus providing prompt actuation of the the requirement of NFPA 13 to be located within sprinkler heads even though they are located an 12 inches of the ceiling to achieve prompt excessive distance from the ceiling. Therefore, actuation of the sprinkler heads (Rcf. 4. IS. pg 34, the location of these two sprinkler heads can be Sect 7.14.7).
considered acceptable for this area (Ref. 4.18, pg 34, Sect 7.14.7).
13-57 4-1.1.1(3)
Turb Mezzanine N/S: One sprinkler head located The affected head is located approximately 5 feet None.
in the northeast corner of the area near the south of the stairs and six feet west of the wall.
stairway is obstructed by existing mechanical The obstruction of the stairs at six feet west of the piping (Ref. 4.18, pg 36. Sect 7.15.1).
wall. The obstruction to the distribution pattern of the sprinkler system is minor and protection for the area would not be significantly improved by relocating the head. Therefore, no action is required for this item (Ref. 4.18, pg 36, Sect 7.15.1).
13-58 Not provided Turb Mezzanine N/S: Inspector's test connection Mod. M12-2-84-107 addresses this issue. (Ref.
DD is not installed for the system as required by 4.23, pg 6, Sect 7.15.2).
NFPA 13 (Ref. 4.18. pq 36, Sect 7.15.2).
13-59 4-4.1.1.1(1)
U2 Turb Mezz Cable Conc: Coverage is Mod 12-2-84-107 addresses this issue (Ref. 4.23, DD inadequate in the northeast portion of this area pg 6, Sect 7.16.1).
near the stairs (near column line G33) (Ref. 4.18S, pg 37, Sect 7.16.1).
00
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABI.E A NFPA 13 Deviation Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Code Deviation Justification Recommended Action No.
Section 13-60 Not provided U2 Turb Mczz Cable Cone: A number of nozzles WRD4659 addresses this issue (Ref. 4.23. pg 6, DD are pointing the wrong direction on branch line Sect 7.16.2).
risers located approximately 22 feet west of column line 34 near the south wall (Ref. 4.18, pg 37, Sect 7.16.2).
13-61.1 4-3 U2 Turb Mczz Cable Cone: In the southeast Mod 12-2-84-107 addresses this issue (Ref. 4.23, DD corner of the area a number of nozzles arc located pg 7, Sect 7.16.4).
6 to IS inches above the cable trays, but are 10 to 20 feet below the ceiling (Ref. 4.18, pg 38, Sect 7.16.4).
13-61.2 4-3 U2 Turb Mezz Cable Cone: South wall nozzles Mod 12-2-84-107 addresses this issue (Ref. 4.23, DD are not within 12 inches of the ceiling (Ref. 4.18.
pg 7, Sect 7.16.3).
pg 38, Sect 7.16.3).
13-62 4-3 U2 Turb Mczz Cable Cone: The top row of water Mod 12-2-84-107 addresses this issue (Ref. 4.23, DD spray nozzles are improperly located in relation pg 6, Sect 7.16.4).
to the ceiling (Ref. 4.18, pg 38, Sect 7.16.4).
Not provided
_i i
Not provided U2 Turb Mezz Cable Cone: A waterflow alarm is not provided for each of the two pre-action systems protecting this area (Ref. 4.18, pg 38, Sect 7.16.5).
U2 Turb Mezz Cable Cone: Hangers and survey bracing are inadequate (Ref. 4.18, pg 38, Sect 7.16.6).
Mod 12-2-84-107 addresses this issue (Ref.
4.23, pg 7, Sect 7.16.5).
Mod 12-2-84-107 addresses this issue (Rcf. 4.23, pg 7. Sect 7.16.6).
DD I
I I..
Relocation or addition of nozzles would not None.
4-1.1.1.(3)
U3 Cable Thnnel: Several locations exist where the installation of water spray nozzles does not pgrnrm in, Sec 7.1 7.1)i
- .oo -.
1 relative to the obstruction of the water distribution pattern fromt the nozzles (Ref. 4.18, pg 39, Sect 7.17. 1)
Relocation or addition of nozzles would not significantly improve the performance of the system (Ref. 4.18, pg 39 and 40, Sect 7.17.1)
Deviation 00 13-63 13-64 13-65 DD None.
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABI.E A NFPA 13 Deviation Close Out Matrix NTSC Report No.93-124, Rev. I Decemher 17, 1999 Deviation Code Deviation V
Justification Recommended Action No.
Section_1__
13-66 Not provided U3 Cable Tunnel: Hangers and sway bracing are Mod M12-2-84-107 and WRD46365 address this DD inadequate (Ref. 4.18, pg 40, Sect 7.17.2).
issue (Ref. 4.23, pg 8, Sect 7.17.2).
13-67 4-3 U3 Cable Tunnel: Nozzles protecting the top row Mod M12-2-84-107 and WRD46365 address this DD of cable trays on each side of the cable tunnel issue (Ref. 4.23, pg 8. Sect 7.17.2).
between columns 50 and 44 are located over 12 inches from the ceiling (Ref. 4.18, pg 40, Sect 7.17.2).
13-68 4-1.1.1(3)
Nozzles protecting other areas, excluding no1zles Due to the ceiling configuration and the type of None discussed in paragraph I of Section 7.17.3, are fire anticipated, relocation of heads would not located over 12 inches from the ceiling (Ref.
significantly improve the performance of the 4.18, pg 41, Sect 7.17.3).
system (Ref. 4.18, Sect 7.17.3. pg 41, para 2) 13-69 4-1.1.1(3)
U3 Cable Tunnel: Several locations exist where Mod M 12-2-84-107 addresses this issue (Ref.
DD additional water spray nozzles need to be 4.23, pg 8, Sect 7.17.4).
installed to ensure adequate coverage where significant obstructions to the water distribution pattern exist and/or unusual configurations of cable tray routing require additional protection (Ref.4.18, pg 42, Sect 7.17.4).
4-1.1.1(3)
U3 Cable Tunnel: Many heads require relocation to avoid existing obstructions to the water distribution spray pattern (Ref. 4.18, pg 42, Sect 1.7 117 ).
Completed (No Sod or WR referenced) (Ref.
4.23, pg 9. Sect 7.17.5).
13-71 Not provided U3 Cable Tunnel: T11e top two nozzles in water Completed (No nood or WR referenced) (Ref.
DD spray riser 5N are misdirected one quarter turn 4.23, pg 9, Sect 7.17.6).
(Rer. 4.18, pg 44, Sect 7.17.6).
t0 ON 13-70 I
Justification DD
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE A NFPA 13 Deviation Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Justification Recommended Action Deviation coeDeviation No.
j Section 13-73 Not provided 13-75 Not provided 13-76 Not provided 13-77 Not provided Not provided WRD46365 addresses this issue (Re'. 4.23, pg 9, Sect 7.17.7).
WRD46365 addresses this issue (Rcf. 4.23, pg 9.
Sect 7.17.8).
WRD46365 addresses this issue (Ref. 4.23. pg 9, Sect 7.17.9)
WVRD46365
=addresses this issue (Ref. 4.23, pg 9, Sect 7.17.10 disposition)
The sprinkler head was apparently installed to provide protection beneath a large ventilation duct in the area. However, the sprinkler head is not located beneath the duct. No relocation of the head is required since the HVAC duct is less than 4 feet wide and relocation of the sprinkler would not significantly improve protection of the area (Ref. 4.18, pg 45, Sect 7.18.1).
Mod M 12-3-84-107 addresses this issue (Ref.
4.23, pg 10, Sect 7.18.2).
DD 13-72 U3 Cable Tunnel: The water spray risers 3M and 3K approximately 90 degrees are not properly oriented to ensure water spray pattern (Ref. 4.18.
pg 44, Sect 7.17.7).
U3 Cable Tunnel: In water spray risers 4F and 4G near column line 42, the second nozzle from the top is directed towards the ceiling (Ref. 4.18, pg 44, Sect 7.17.8).
U3 Cable Tunnel: The top nozzle in water spray riser 2D is currently pointing in a downward direction and should be pointing horizontally (Ref. 4.18, pg 44, Sect 7.17.10).
U3 Cable Tunnel: The top nozzle in water spray riser 4K is misdirected 45 degrees (Ref. 4.1 S, pg
- 44. Sect 7.17.1 I).
One sprinkler head located 9-7" west of column 45 and approximately 9 feet south of column line C is now located a considerable distance below the ceiling and is exposed to water flow from ceiling level sprinklers. This is a deviation from the requirements of NFPA 13 (Ref. 4.1S, pg 45, Sect 7.I8.1).
Turb Mezz. E/W: Hangers are not provided for the sprinkler pipe under stairs in the northwest corner of the area (Ref. 4.18, pg 45, Sect 7.18.2).
t'Q o0 Nnt nrovided I
I 1 13-78 1 NOT proviucu I
I No.
Sct- -
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE A NFPA 13 Deviation Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation Code Deviation Justification Recommended Action No.
Section__
4-3 Turb Mcz7. E/W: Inspector's test connection is not provided for the system as required by NFPA 13 (Ref. 4.18, pg 45. Sect 7.18.3).
Turb Mezz. EMW Many of the existing sprinklers are located 16 to 20 inches below the ceiling (Ref. 4.18, pg 45, Sect 7.18.4).
One sprinkler head has a damaged deflector located in the northwest corner of the zone near the stairs. The head is located 15 feet south of the wall near the edge of the stairs (Ref. 4.18. pg 45, Sect 7.18.5).
U2, U3 and U 2/3: Emer D.G. Day Tank RMS:
Sprinklers are obstructed (Ref. 4.18 pg 46, Sect 7.19.1).
U2, U3 and U 2/3: Emer D.G. Day Tank RMS:
Install ait inspector's test connection on all three diesel generator day lank room sprinkler systems (Unit 2, Unit 3. and Unit 2/3) (Ref. 4.18 pg 46, Sect 7.19.2).
U2 H.P. Heater Bay: One 12-inch long branch line (I1 inch dianieter) is badly corroded (Ref'.
4.1 S. pg 47. Sect 7.201.1 }
Aux Heating Bay: Air supcrvision and a watcrflow alarm are not provided as required by NFPA 13 (Ref. 4.18, pg 47, Sect 7.21.1).
13-SO Not provided 13-SI Not provided 13-82 4-1.1.1(3) 13-83 Not provided 1 13-84 1 Not provided Nut pTUVIUt.U I
I I
I I
13-79 90 00 Mod M 12-3-84-107 addresses this issue (Ref.
4.23, pg 10, Sect 7.18.3).
Mod M 12-3-84-107 addresses this issue (Ref.
4.23, pg 10, Sect 7.18.4).
WRD46364 addresses this issue (Re£. 4.23. pg 10, Sect 7.18.5)
Obstructions do not have a significant impact on system performance. (Ref. 4.18 pg 46, Sect 7.19.1)
Mod M 12-2(3)-84-10 7 and PLC Ltr 1/23/86 address this issue (Ref. 4.23, pg 10, Sect 7.19.2).
Mod M12-2-84-107 addresses this issue (Rer.
4.23, pg 10, Sect 7.20.1).
Mod M 12-1-84-107 addresses this issue (Ref'.
4.23, pg 10, Sect 7.2 1.I1).
I I 1 3 -S 5 I N o t p r o w ud C u I
Unit 213 Dresden Nuclear Station NFPA Code Matrices TABLE A NFPA 13 Deviation Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation Justification Recommended Action U2 and U3 MG Set Fluid Drivers: Many of the
...the location of the sprinklers for this area are None.
sprinklers located in this area are It) inches below acceptable due to the anticipated oil fire which the ceiling which exceeds the requirements of will produce high temperatures in a short period NFPA 13 not to exceed 16 inches below ceiling of tinle thus providing prompt actuation for the level for areas with this particular beam depth sprinklers in their existing locations (Ref. 4.18, Radwaste Compactor: The supply valve for the system is currenly closed and the waterflow i...r..
I..,no vet en connected (Ref. 4.18, pg
_Li Lr 4.3 p 12-2/3-82-13 addresses this)issue.Rel.
4.23, pg 10, Sect 7.22. 1).
- 48. Sect 7.22.1I ).
13-SS SER 3.1.5.2 Sprinklers have not been installed in the U-1 see Supplement 2 of the hydraulic calculations DD Control Rod Drive reed Pump Area (I, ef. 4. 19, (Ref. 4.22) pg a3 Sect 2.1w).
discovered that the sprinkler system protecting inch sprinklers by Work Order 990002111 (Ref.
the Unit 2 MG set area on the 561s elrvation of 4.53). The 3/8 inch sprinklers were also field the Turbine Building is not in accordance with verified by NTSC. Information about the the Design Drawings (Grinnell drawing 13-5165-sprinkler orifice size and temperature is contained 8 and S & L drawing F-396). The drawing on Grinnell Drawing 13-5165-8 (Ref. 4.3). The showed 3/8 inch orifice sprinklers as the proper S & L Drawing, F-396 (Ref. 4.54), incorporates orifice size. It was discovered that the 3/8 inch the Grinnclll Drawing by reference, so the plant orifice sprinklers had been replaced by '/. inch is in compliance with Section 1-9.2 (m).
orifice sprinklers under Work Order WR 960016293-01 in May 1907 because of paint overspray on the original 3/8 inch orifice sprinklers (Ref. 4. 1, Section 3.2.1.1) 13-90 Section 4 Several sprinklers were obstructed (Ref. 6).
Obstructions to sprinkler systems are justified in DD Attachment C of Reference 4.52.
v --Ifof Ii Devi ation 13-86 13-S7 I-.
00.
pg 48, Sect 7.23.1. ).
,,,ILIspiacillo (lcr. 4. IS. pg 48, Sect 7..l.
DuL
U TABLE A NFPA 13A Deviation Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation I
Code Deviation Justification Recommended Action No..
Secio 13S-04 Not provided Kr.
U Li As per an NTSC walkdown, seals are no onger DD DD.
DFPP 4114-2 and 4114-3 list several fire main (FM) and sprinkler system (SS) valves dtat are inspected wvithout a specific acceptance criteria (normally open, normally closed) (Ref. 4.20, pg7, Sect 3.3. para 2, subpart 2 and pg 6, Table 3.3-1 ).
DFPP 4114-2 and 4114-3 indicate unsealed valves are to be resealed without test. These proccdures should be corrected to require valves to be physically tested and returned to their proper positions prior to resealing (Ref. 4.20.
pg7, Sect 3.3, para 2, subpart 2 and pg 6, Table 3.3-1).
DFPP 4114-2 and 4114-3 specify the procedure for conducting an alarm test at the sprinkler riser.
However, they do not address those wet pipe systems having an inspector's test location remote from the riser, and it would appear these valves are not being used for waterflow alarm testing (Ref. 4.20, pg 7, Sect 3.3, para 2, subpart 3 and pg 6, Table 3.3-1I).
On Page 15 of DFPP 411 4-3,SS valve number 2-4199-50 1 is listed as "normally open".
However, a note beneath the valve location status: "VERIFY that the valve is CLOSED" (Ref. 4.20, pg 7, para I, subpart 4).
DFS414...e.4 4
402
- e...
,and, DFPS 4114-01, Rev.04a 4114-02, Rev.02 and 4114-03, Rev.3 address this issue.
As per an NTSC walkdown, seals are no longer used. Locks have been installed.
Procedure DFPS 4133, Rev.01 addresses this issue.
Procedure 4114-02 inspects the proper position of Unit 2 fire mains and sprinkler system valves.
It does not include this valve. As shown on Drawing M-23, valve 2-4199-501 is at a dead end and does not control any fire suppression system or water supply.
Its position would have no impact on the performance of the fire water systems and, as a result, there is no need to monitor its position (Ref. 4.1, Section 3.2.1. 1).
Paic I of4 Unit 2/3 Dresden Nuclear Station NFPA Code Matrices Not provided 13S-01 13S-02 13S-03 t00.0 41 Not provided Not provided DDJL DDJ
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE A NFPA 13A Deviation Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation Code Deviation 1
Justification Recommended Action No.
Section i
13S-05 Not provided DFPP's 4132-1,4132-2 and 4132-3 apply only to Non Tech Spec systems are now covered by DD sprinkler and water spray systems required by Ihc DFPS 4132-01. Rev.O; 4132-02. Rev.; and tech. specs. Non-tech spec systems are not 4132-03, Rov.t).
inspected in accordance with these procedures..."
01 -
n...
.nt.,t.,et, scni s thev 13S-06 Not provided
",,.althaOLign lhese :re n1oL t teeniS ec syt ems z
tu,,*....
are generally located in, or expose, safety-rclated areas or are related to the Appendix R analysis.
The Turbine Mezzanine cable concentration is mentioned in the SER (Ref. 4.20, pg 8, Sect 3.3, para 2, subpart 5).
Sketches attached to DFPP's 4132-I, 4132-2 and 4132-3 do not clearly indicate the proper nozzle or sprinkler orientation, nor the hanger locations.
Drcsdeii Tech Spec Item 4.1 2.C. Lb requires sprinkler headers to be inspected; item 4.1 2.C. Ic. requires nozzles to be inspected to very no blockage (NFPA I3A requires piping, as well as supports to he checked). These procedures do not require inspection of sprinkler or nozzle condition, only orientation. Because of these deficiencies, either detailed acceptance criteria (in the fonr of detailed plans) need to be developed, or the qualifications of the personnel performing the procedure need to be expanded to insure a thorough system walk-down is conducted (Ref. 4.20, pg 8, Sect 3.3, para 2, subpart 6 and pg 6 Table 3.3-1).
NFPA 13A requires weekly checks of control valve position, valve seal integrity, and control valve operability (1/4 turn). Dresden procedures indicate these tests are carried out monthly, but only on supervised valves (Ref. 4.20, pg 9, Sect 3.3, para 2, subpart 7 and pg 6 Table 3.3-1).
Procedures DFPS 4132-01. Rev.0; DFPS 4132 02,Rev.0; and DFPS 4132-03, Rev.0 address this issue.
None.
This lotiger period is justified due to This longer period is justified due to administrative controls which keep a record of all valve closures (Ref. 4.20, pg 9, Sect 3.3, para 2, subpart 7).
DD t00 13S-07 Not provided None.
A
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE A NFPA 13A Deviation Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation Code Deviation Justification Recommended Action No.
Section I
.4 -
1*
NFPA I 3A requires weekly checks of riser gage readings, as well as a 2-inch drain test at cach riser. These requirements are not being implemented. However, NFPA 13A requires these tests at sprinklered properties normally served by city water connections. The test verifies that the city supply is in service (Ref.
4.20, pg 9, Sect 3.3, para 2, subpart 8 and pg 6 Table 3.3-1I).
NFPA 13A requires yearly lubrication of control valve stems and indicating mechanisms. No procedure could be located to confirm that this maintenance is being performed (Ref. 4.20, pg 0.
Sect 3.3. para 2. subpart 9 and pg 6 Table 3.3-1).
NFPA 13A does not specifically require, but implies, a periodic inspection to verify air pressure maintenance on those preaction systems where supervisory air is maintained. There is not Dresden procedure to verify air pressure is maintained ott any preaction system (Ref. 4.20, pg 9, Sect 3.3, para 2, subpart 10 and pg 6 Table 3.3-1).
Sprinkler system No. 2-4199-501 is listed as nomially open. A note beneath the valve location states,"Veri fy the valve is closed".(Ref. 4.20, no 101.
since the water supply it Dresden is totally under plant control, these tests are unnecessary (Ref.
4.20. pg 9, Sect 3.3, para 2, subpart 8).
Procedure 4 132-04, Rev.01 addresses this issue.
The XL3 System continuously monitors preaction system air pressure. XL3 System Dresden Annunciator Procedures (DANs) provide operator instructions for when the XL3 System identifies when there is a low air pressure condition. As a result, a procedure is not needed.(NTSC)
Procedure 4114-02 inspects the proper position of Unit 2 fire mains and sprinkler system valves.
It does not include this valve. As shown on Drawing M-23, valve 2-4199-501 is at a dead-end and does not control any fire suppression system or water supply.
Its position would have no impact on the performance of the fire water systems and, as a result, there is no need to monitor its position (Ref. 4.1, Section 3.2.1.1).
Page 3 of 4 13S-08 Not provided 00o 13S-09 13S-I0 13S-II Not provided Not provided Not Provided None.
Unit 2/3 Dresden Nuclear Station NFPA Code Nlatriccs TABLE A NFPA 13A Deviation Close Out Matri'x NTSC Report No.93-124, Rev. 1 December 17, 1999 P;I.y.1 "1I.
.1
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABI.E A NFPA 14 Deviation Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation -
-Code Deviation Justification Recommended Action No.
F7 Section 14-01 Chapter I The addition of hose reel numbers to the F-P&lDs and F-Drawings have been updated (Rcf.
DD drawings would simplify the gathering of needed 4.15, pg I.1-12, Item 4.1).
information (Rcf. 4.21, pg.8, para 2).
14-02 2!9 In the Turbine Building some standpipe sizes are A hydraulic analysis was pcrformed on three hose None.
less than 2 inches (Ref. 4.21. pg 8, para 5).
stations to verify adequacy of 1-1/2" supply pipe.
I i nissruI
'r.-
ei.,,,.ireda rrniont nof 14-03 322 14-04 342 14-05 42 Several plant areas shown in Table 3.1 cannot be reached with 100' of hose and a 30' hose strceam (Ref. 4.21,.pg 9, 10, II).
As identified in Table 3.1 standpipes not provided with 1-1/2" outlets at each floor (Ref.
4.21, pg 1-I, para 3).
More than 100' of approved hose is at some hose stations (Ref. 4.21, pg 11, para 7). Two 150 ft hard rubber hoses are provided to protect the Control Room.
ThIe analysis inIII;.icatcs 1me rc'.*H rHJ U u.........
water can be delivered (Rcf. 4.21, pg 8, para 5).
In specified areas, due to the minimal amount of combustibles and other fire protection features provided, the existing configuration is adequate (Ref. 4.21, pg9(,
10,11).
Recommendation made for additional hose to select hose stations with less than 100 ft hose (Ref. 4.21, pg 17. Item 4.3).
PIF D1099-05386 and NTS 237-251-90-3125 addressed this issue (Ref. 4.1, Section 3.3)
Table 3.c does not reference any srand p Tpes without 1 1/2 inI1ch outles.
The additional hose length is required to provide adequate coverage for the control roorn (NTSC).
Nonc.
DD DD Page ! of 2 00 jý I
I I
I
]I
Unit 213 Dresden Nuclear Station TABLE A NFPA 14 Devintion Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999 11 Page 2 of 2 INF 00 Deviation Code Deviation Justification Recommended Action No.
Section i
14-06 43 Labels indicating use and operating instructions Thc fire hoses are for usc by the firc brigadc only.
None.
are not provided on hose racks (Ref. 4.21, pg 11.
Signs have been provided on each hose station parai S).
identifying that only the fire brigade can use tile hoses. All fire brigade member have been adequately trained to handle hoses. As a result, operating instructions on the hose stations are 4annecessary (NTSC).
14-07 446 OSHA Sub-Pressure reducing devices are not provided for CECo policy is not to use pressure reducing None.
part L standpipes exceeding 100 psi (Ref. 4.21, pg 12, devices...
a(Ref. 4.15, pg 1.11 u2,e inc 4.4) Fire para 3).
hoses are for tie use of the fire brigade only. All brigade members have been adequately trained to handle hoses subject to high pressure. (NTSC) 15
'ns" tiaplrunning valadwnrmoundthat).
14-08 6
The main 2/3 dischiarg valve is not of ail A NTSC walkdlown found that all indicator has DID indicating type is required (Ref. 4.21, pg 15. paral been installed onl the valve.
2).
14-09 67 Water flow switches are not provi ded oil all A primary runction of a nlow switch is to provide None.
standpipes (Ref'. 4.21, pg 15, para 5).
notification of unauthorized use. Since access to a nuclear power plant is controlled, unauthorized operation is not normally a concern. In addition, operation or a hose station should activate the Fire puimp ruinning alarm (NTSCQ.
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE A NFPA 15 Deviation Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation Code
'--IDeviation I
JuStifi C'ationnRecommended Action No.
Section 15-01 SER (3/87)
Hydraulic calculations are not provided for five Hydraulic Calculations address this issue. The None.
Section 4.3.1.2, systems.(Ref. 4.1S, pg 7 and pg 12, Sect 6.2).
calculations contain justifications to minor NFPA I......
15 deviations (Ref. 4.22).
I I
None.
All systems were installed by Urinnell wuose Contractor's test certificates are available and have been reviewed for 51 of the water suppression systems. However, no documentation has been located to veriry such testing for the remaining 5 systems (Ref. 4.18, pg 15, Sect.6.6).
There is no weekly visual check of the deluge systems as required by Paragraph 6003 of NFPA 15-1973; however, Paragraph 6003 also states that the frequency of such inspections may be at "other frequent regularly scheduled plant inspections" (Ref. 4.20, pg 10, Sect 3.4, para 3, subpart I ).
No procedures exit to check outdoor piping annually for proper drainage (Paragraph 6013) or to conduct an annual flushing of the underground lead-in connection (Paragraph 6019) (Ref. 4.20, pg 10, Sect 3.4, para 3, subpart 2).
All systems were installed by Grinnell whlose standard practice is to perform hydrostatic testing. The systems have been in operation for fourteen years now with no significant leaks or breaks (Ref. 4.18, Sect 6.6, Pg 15).
Dueto he ighlevl 0 n~iln~trtiv cuIt u,ýN.
Due to the high level of administrative controls at this plant, such an inspection to identify major deficiencies could be extended to a monthly basis and included in DFPP's 4114-2,.4114-3 and 4114-6, as applicable (Ref. 4.20, pg 10, Sect 3.4, para 3, subpart I).
IN U I IC.
Because strainers are provided and to be cieaneu Because strainers are provided and to be cleaned annually, the requirement for a flushing test of the underground lead-in connection is eliminated (Ref. 4.20, pg 10, Sect 3.4, para 3. subpart 2).
K-
~
r) r No procedures exist to annually inspect and clean strainers on the deluge valves (Paragraph 6012).
as well as strainers on underground lead-in connection to the Turbine and Reactor Buildings, except for those valves controlling water to the hydrogei seal oil unit systems (DFPP 4134-1)
(Ref. 4.20, pg II, Sect 3.4, para 3, subpart 3).
Procedure is not used to perform this task. ITne Station surveillance program (GSRV) requires main strainers to be cleaned and inspected annually and individual system strainers every 5 years.(NTSC)
Page 1 of 2 INFP A 1,5 Section Not Provided (Rep.
I )
t'l) 00 GO Not Provided 6003 6013 and 6019 15-02 15S-01 15S-02 15S-03 Par. 6012 iNone.
NoncII1.*
NoIne.
D D).
I I
I I
I
Unit 2/3 Dresden Nuear Station TABLE A NTSC Report No.93-124, Rev. I NFPA Code Matrices NFPA 15 Deviation Close Out Matrik December 17. 1999 Deviati~on Code Deviation Justification Recommended Action No.
Section 15S-04 6013 Procedures exist to conduct air flow tests of the Procedures DFPS 41t35-05, Rev.0; DFPS 4134-DD hydrogen seal oil unit systems (DFPP 4134-1),
06, Rev.0; DFPS 4134-07, Rev.0 and DFPS U-2/3 fire pump and fuel day tank (DFPP 4134-4134-04, Rev.0 address this issue
- 2) and water flow tests of the outside transronmier systems (DFPP's 4132-2 and 4133-3). No-flow test procedures (air or water) for the following open head spray systems could be located: U-2 &
U-3 Bus duct penetrations at outside transformers. U-2/3 Turbine lube oil reservoirs.
Such tests are necessary to verify no obstructions to water discharge exist at the nozzles (Ref. 4.20, pg 11, Sect 3.4, para 3, subpart 4).
00
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE A NFPA 20 Deviation Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999 SER (3/87)
Sections 5.4.6 and 5.12.6 SER (3/87)
Section 5.4.6 Deviation Justification Recommended Action During thc firc pumps original acceptance test,
...even though the pump may not comply with the Nonc.
the Unit I fire pump was unable to achieve NFPA 20 performance requirements, its sufficient pressure at all points along the performance could be considered acceptable as manufacturer's curve (Rcf. 4.1 S, pg 3, Sect 2.2; long as it exceeds the requirements (flow and pg 7; and pg 13, Sect 6.4.).
pressure) of all installed water suppression systems (Ref. 4.18, pg 7 and pg 13, Sect 6.4.).
Hydraulic calculations address this issue (Ref.
4.22).
The curb has not yet been installed to contain the Mod M 12-2/3-84-7 addresses this issue (Ref.
DD diesel fuel oil for the Unit 2/3 fire pump (Ref.
4.23, pg 1.1-22. Item 4.6).
4.1 S, pg 2, Sect 3 and pg 8, Sect 5.4).
A curb is not provided at the north door to the There are two entrances to this room. A curb has None.
AEER (Ref.4.18, pg 8, Sect 5.5).
been installed at the west door opening onto the Unit 2 Trackway area. A similar curb is provided approximately 10 feet from the north door in the I icnitv of the Unit 2 480V switchgear area.
Therefore, an additional curb at the north door to the room is unnecessary as the curb in the switchgear area should be sufficient to prevent any oil spill in this area from entering the room.
The intent of this commitment is satisfied (Ref.
4.18, pg 8, Sect 5.5).
20-04 Not provided Documentation for the original acceptance testing However, justification for this deviation can be None.
of the Unit 2/3 fire pump is not available for provided based on the satisfactory performance or review (Ref. 4.1 S, pg 13, Sect 6.4).
the annual pump test for the last two years. The problems that existed during the original acceptance test have apparently been satisfactorily addressed (Ref. 4.18, pg 13, Sect 6.4).
20-05 SER (3/87)
... the main discharge valve in the 2/3 pump A NTSC walkdown found that an indicator has DD Section 3.1.3 discharge line is a motor operated type valve been installed.
{MO-2/3-41111). This valve is not o1" the indicating type (Ref. 4.18, pg 7, Sect 5.2).
Page I of 4 20-02 20-03
Unit 2/3 Dresden Nuclear Statiotn NFPA Code Matrices TABLE A NFPA 20 Deviation Close Out Matrix NTSC Report No. 93-1 24, Rev. 1 December 17, 1999 20-06 Deviation Code Deviation 1-Justification Recommended Aetion No.
Section E :_
__=-_
___ru 20-07 20-OS (New 2/3 Fire Pump) 20-09 (New 2/3 Fire Pump)
I.
l*
I Mod M12-2/3-84-66 addresses this issue I vu.
Mod Ml 2-2/3-84-66 addresses this issue (Ret.
Not provided Not provided Section 2-14.2.2 Section 8-2.3 The existing globe type valves in tie fire pump diesel engine cooling wvater line are not indicating type valves (Ref. 4.18. pg 30, Sect 7.12.2).
Tie ttwo strainers in the cooling water bypass line are not provided as required by NFPA 20.
Centrilfugal Fire Pumps (Ref. 4.18, pg 30, Sect 7.12.2).
NFPA 20, Table 2-20 lists 12 1/2-inch hose valves needed to test a fire pump with 3,000 gpm capacity rating. Dresden Station has a fire pump test header with S 1/2-inch hose valves. This constitutes a deviation from NFPA 20, 1993 edition (Ref. 4.24).
Dresden Station has ani unlisted coupling in lieu of a listed drive shaft for Unit 2/3 diesel driven fire pump assembly. This constitutes a deviation from NFPA 20, 1993 edition (Ref. 4.24, 4.25, 4.26).
Mod M12-2/3-84-66 addresses this issue (Ref.4.23, pg 4, Item 7.12.2).
Mod M It2-2/3-84-66 addresses this issue (Re.
4.23, pg 4, Item 7.12.2).
None.
This deviation is acceptable based on the This deviation is acceptable based on tihe station's ability to perform the capacity test using the Unit 1 test header and local fire hydrants.
This method was proven during acceptance testing of the installation. The procedure for the 2/3 diesel fire pump annual capacity check has already been revised to direct performance of the test using an arrangement of the test header and adjacent fire hydrants.
The coupling is identified as a Wood's Sure-Flex Coupling by thle pump and diesel supplier. Based on torsional analysis conducted by the pump and diesel supplier, the Wood's Sure-Flex Coupling with a stiffness of 0.305 Deg/l 00 LB FT will not present a torsional problem andt is a suitablC alternative to the flexible drive shaft originally specified for tile Unit 2/3 Diesel Fire Pump.
I
U U.
DFPS 4123-01. Rev.l and DII'S 4lLi-U, Kev.i 20S-01 8-6.3.1, 8-6.3.2, I I Ind..AQ DFPP 4123-I does not reference battery maintenance items and fuel day tank level checks inite nrnrodure but these items are listed on the 6.4 inspection shcct. Similarly, DFPP 4123-S does not reference a chieck of tile fuel day tank level although this item is listed on the checklist (Ref.
4.19. pg 12. Sect 3.5. para 2, subpart I an(] pg 13 table 3..s-I)
DFPS 4123-0s1, Rev.1s and DFPS 4123-0seev. I address this issue.I None.
Parll,., d III DID DD1..
i I
I I
Nonec.
IL/l).
Unit 2/3 Dresden Nuclear Station NFPA Code NMatrices "rABLr A NFPA 20 Deviation Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation Code Deviation Justification Rcommende Aco No.
Sectionlil I..--,.......
I,
"Thi; q dcvi hitified due to the limited use None.
20S-04 12.3.1 NFPA 20 requires nlamitenarice to be pcrro'rmedu on diesel engines at least annually, whereas DFPP"s 4124-3 and 4124-4 allow this maintenance to be conducted at I s month intervals (Rcf. 4.1), pg 12. Sect 3.5, para 2.
subpart 2 anld pg 13 table 3.5-I).
There is no procedure for verifying the temperature in the fire pump rooms as required by Paragraph 8-6.5 of NFPA 20 (Ref. 4.19. pg
- 12. Sect 3.5, para 2, subpart 3 and pg 13 table 3.5-1).
DFPP 4123-7 requires six or seven flow test points (as well as test at slht-off) for the Un iit I annual Fire pump test. However, no procedure exists for correctin. the pressure and flow data to rated RPM, and using these tests points to construct a graph which can be compared to sonic miinimum acceptance criteria in order to detect any deteriorati on in the purnip. 'This mni iii lum acceptanice criteria is preseniiy not specilII'.
No operational test of the pressure relief valve is conducted (Ref. 4.19, pg 12, Sect 3.5. para 2, subpart 4 aiid pg 13 Table 3.5-I ).I I 111s oevIa"011 J, J 1 i.........
of these engines and,,e, operability tests of the fire pumps which insure the engines arc in proper condition (Rcf. 4.1()pg 12, Sect 3.5, para 2, subpart 2).
Dreden Annunciator Procedure (DAN)
- XL3, Device 51-15, Rev.0 states that there is a low temperature device in the Crib House that is set to alarm at 32 F.
Procedure 51-15, Rev. 3 shows that the alarm was reset to activate at 50 degrees F instead of 32 degrees F (Ref. 4.1, Section 3.2.2).
Procedures DFPS 4123-07, Rev.2 addresses this issue DFPS 4123-06. Rev 0.
DD DD.
Page 3 of 4 20S-02 Not provided 20S-03 S-6.5 00 l!
C)
L I
Unit 2/3 Dresden Ntclcar Station NFPA Code Matrices TABLE A NFPA 20 Deviation Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation code Deviation Justification Recommended Action No.
Section II 20S-05 12.3.1 DFPP 4123-6 (U-2/3 Diesel Fire Pump Annual See 20S-04 DD Capacity Check) has the deficiency noted above, except that insufficient data is collected to construct a valid 3-point test curve (shuit-ofm, 100% capacity and 150% capacity). This procedure utilizes fire hydrants onl the yard loop for flow test outlets, instead of a test header or flowmcter as recommended by NFPA 20.
However, the 1983 edition of NFPA 20 allows test to be made through yard hydrants, providing justification for the existing procedure. This procedure also does not require pressure relief valve to be shut before the test and reopened after the test, nor are any operational tests of the pressure relief valve conducted (Ref. 4.19, pg 13, Sect 3.5, para 2, subpart 5 and pg 13 Table 3.5 20S-06 Not provided Good fire protection practice would require that Dresden satisfies the intent of this issue DD.
every 18 months it should be verified that each (Ref.4.19, pg 1.1-8, Item 4.1.9).
fire suppression pump starts (sequentially) to maintain the fire suppression water system pressure greater than or equal to some minimum required pressure. Dresden has no tech spec item relating to this requirement and no procedure to implement it (Ref. 4.19, pg 15, Sect 3.5, para 2, subpart 6).
Page 4 of 4
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE A NFPA 24 Deviation Close Out Matrix NTSC Report No.93-124, Rev. 1 December 17, 1999 Deviation Code Deviation Justification Recommended Action No.
Section 24-01 2600 No fire department connection provided (Ref.
due to the remote location, lack of nearby None.
4.27, pg 7, para 2).
public water supply, redundancy of fire pumps.
and intake canal supplies through which water may he pumped from draft, omission of such a connection is justified (Ref. 4.27, pg 7, para 2).
24-02 3302 PlV's located closer than 40 feet from buildings Exiting PIV locations are justifiable (Ref. 4.27, None.
with exnosed openings (Ref. 4.27, pg 7. paras pg 7, paras 3A4,5 and 6).
24-04 9301 and 3502 NRC Staff Position SF.7 5 26-77 Dresden
Response
6-22-77 4101, NRC Staff Position PF.5, PF.26 4201, Appendix 3,4,5 and 6).
Lack of barriers around PIV north and U-I HPCI Building (Rcf. 4.27, pg 7, para 7 and pg 8, para I).
Underground piping run below buildings (Ref.
4.27, pg 8, para 2).
Additional PIVs are required (Ref. 4.27, pg S, para 3).
Hydrants not provided with isolation valves (Ref.
4.27, pg S. para 5).
Hydrant spacing exceeds requirements (Ref. 4.27, pg 9 para 2).
24-08 4204 Hydrant closer than 50 feet from buildings (Ref.
4.27, pg 9 para 3, 4, 5 and pg 10 para 1, 2, and 3).
..loss of tiis valve will not affect the water supply to the U-2/3 plan. as a sectional valve exists to cut off supply to this U-1 area (Ref.
4.27, pg 7, para 7 and pg 8, para I ).
These installation are justifiable as a break in either line would not prevent water supplies from reaching the Turbine and Reactor Buildings (Ref.
4.27. p* 8, ara 2).
Not requiring additional PIV's is justifiable as the existing sectional PIV's could be used to remove this section of pipe from service without blocking flow to any water suppression system in the U 2/3 Turbine and Reactor Buildings (Ref.4.27, pg 8, rara 3).
Lack of valves are acceptable (Ref. 4.27, pg 9 para 1).
The existing installation is justified as sufficient hose is available to reach all buildings with no hose line exceeding 500 feet in length as required by Paragraph 4201 ) (Ref. 4.27, pg 9 para 2).
Existing hydrant s are acceptable (Ref. 4.27, pg 9 para 4 and 5; and pg 10 para 1,2, and 3)
None.
None.
None.
None.
None.
None.
I,
1 Page I of" 5 24-03 t-,
00 61 ti 3304.
NRC/CEC's letter 6/12/71) 24-05 24-06 24-07 A
I
ý I
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices "TABI.E A NFPA 24 Devia'tion Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation Code Deviation Justification Recommended Action No.
Section I
24-09 4301 - 4304 Lack of information on installation designs (Ref.
As no serious problems have been encountered None.
4.27. pg 10 para 4).
with the hydrants, the existing installation is considered adequate (Ref. 4.27, pg 10 para 4).
24-10 4305 Barricades protecting hydrants 2-7 not provided As noted previously in this report, these hydrants None.
(Ref. 4.27, pg 10 para 4).
are generally located in U-I areas and would not be needed for a fire in a U-2/3 area (Ref. 4.27. pg 10 para 4).
24-I 1 SER Item 3.1.23 Hydrant wrench obstructions on hydrants 1,.22, Rachet type wrenches available (Ref. 4.27, pg 10 None.
23,.24 and 25 (Ref. 4.27, pg 10 para 6 and pg I I, para 6 and pg I1, para I).
para I).
24-12 5101,5102, Hose not provided at hydrants 25 and 27 Hydrant 25 hose cabinet temporarily removed and DD 5201, and 5202 (Ref.4.27, pg II para 2).
has been replaced (Ref. 4.19, pg 1.1-14, Item 4.2)
Hydrant No. 27 is essentially redundant to No. 2, therefore providing additional hose for this None.
hydrant would not significantly improve fire protection (Ref. 4.27, pg I1I para 2).
24-13 52-01, Hose houses in poor repair (Ref. 4.27, pg I I para WRD45381 addresses this issue (Ref. 4.19, pg DD SER 3.1.23 3).
1.1-14, Item 4.4) 24-14 5501 Hydrants (or hose houses) not marked; Marking provided (Ref. 4.19, pg 1.1-14, Item DD 21,22,23,25 &27 (Ref. 4.27, pg I I para 4).
4.3)
Page 2 of 5 t'J 00
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE A NFPA 24 Devialtion Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999 COde Deviation Justification Recommended Action No.
Section i
till"__________________________
None 5601, NRC Staff Position NRC Request i 31,41 n 6301, 6401 and 6402 93-3 Hose houses and hose reel cabinets not properly equipped (Ref. 4.27, pg II para 5; pg 12; and pg 13 paras 1,2 and 3).
Nozzle not designed to operate in modes requested (Ref. 4.27, pg 13 para 4).
No procedure for care and maintenance of hose (Ref. 4.27, pg 13 para 5).
No covered pipe trench provided where piping is below railroad tracks (Ref.4.27, pg 14 para I).
24-19 9501 No documentation to verify existing pipe joints (Ref. 4.27, pg 14 para 2 and 3).
I.
Justification provided (Ref. 4.27. pg Justification provided (Ref. 4.27, pg 12, para 3)
- 2.
Suitable hose will be made available if hose cabinets are damaged, suitable hose eqmt will be made available through the use of portable carts, or hoses from other nearby fire hydrants.... (Ref. 4.19, pg 1.I -14. Item 4.4.2).
- 3.
WRs D45381, D45740 and 46739 addresses this issue.
Not replacing nozzles is justified as they are used only by properly trained fire brigade personnel (Ref. 4.27, pg 13 Para 4).
DFPS 4114-05, Rev.0 addresses this issue.
...due to over 5-foot bury depth and infrequent use of these tracks, lack of such trenches is justified (Ref. 4.27, pg 14 para I).
There is no evidence of excessive leakage in the underground piping. As a result, die existing pipe joints arejustified (Rer. 4.27, pg 14, Para 3).
None.
Page 3 of 5 24-15 24-16 24-17 24-18 None.
None.
DD None.
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE A NFPA 24 Deviation Close Out Matrix NTSC Report No.03-124, Rev. I December 17, 1999 Page 4 of 5 00 00 UI Deviation Code Deviation Justification Recommended Action No.
Section 24-20 Section 06 No documentation to verify anchoring of fire Lack of such documentation is justified as the None.
mains (Ref. 4.27. pg 14 para 4).
piping has been in service in excess of 10 years with no serious problems reported (Ref. 4.27, pg
- 14. Para 4).
24.1-01 SER (3/S7)
Distribution pipe is unlined (Ref. 4.18, pg 3. Sect Hydraulic calculations address this issue (Ref.
None.
Section 4.3.1.2 2.2; and pg 14, Sect 6.5).
4.22).
24.1-02 In the original matrix, deviation 24.1-02 was duplicated in this space. As a result, during this tipdate, it was deleted.
24.1-03 Not provided.
Contractor's test certificates are available and All systems were installed by Grinnell whose None.
have been reviewed for 51 of the water standard practice is to perform hydrostatic suppression systems. However, no testing. The systems have been in operation for documentation has been located to verify such fourteen years now with no significant leaks or testing for the remaining 5 systems (Ref. 4.27, pg breaks (Ref. 4.27, Sect 6.6, Pg 15).
15, Sect.6.6).
24.1-04 In the original matrix, deviation 24.1-02 was duplicated in this space. As a result, during this update, it was deleted.
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE A NFPA 24 Deviation Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation No.
24S-01 Deviation Justification Recommended Action Deficiencies regarding verification of valve position are identical to those specified in Section 3.3 of this report. namely 1) lack of specific acceptance criterias. and 2) the possibility or sealing a valve without physically verifying that it is open. This item is addressed in the Fire Suppression System Valve Supervision Survey (NFPA 26) by PLC (Ref. 4.19, pg 15, Sect.3.6, para 2, subpart I; and pg 17 Table 3.6-1).
See NFPA 26 code review.
24S-02 3601 NFPA 24 recommends weekly verification of However, justification exists for monthly None.
valve position, whereas DFPP 4114-6 requires inspections as unauthorized valve closures are monthly inspections (Ref. 4.1 (), pg 15, Sect.3.6, unlikely rot these reasons: 1) Access to areas para 2, subpart 2; and pg 17 Table 3.6-1).
where these valves are located is restricted to CECo personnel. approved contractors, and escorted visitors, and 2) There is consistent attendance of the plant with on-site guard service to reduce the probability of valve tampering (Ref.
4.19, pg 15, Sect.3.6, para 2, subpart 2).
24S-03 None.
No permanent procedure was located to perform DFPS 4132-08, rev.0 addresses this issue.
None.
a water flow test on the yard system in accordance with Dresden Tech. Spec. 4.12.3.1.e (Ref. 4.19, pg 15, Sect.3.6, para 2, subpart 3; and pg_17_Table_3.6-I).
24S-04 4102 Performance of DFPP 4125-I results in the DFPP 4125-1, Fire System Annual Flush, is None.
hydrants being operated yearly. However, NFPA performed in the Fall to flush the hydrants and 24-1973, Paragraph 4102, recommends operation check for proper drainage. During the Spring, the two times per year (Spring and Fall) (Ref. 4.19, Station will rely on leak detection systems to pg 15, Scct.3.6, para 2, subpart 4; and pg 17 detect any underground leakage (Ref. 4.15, pg Table 3.6-1).
1.1-1I, Item 4.9).
Page 5 of 5 I'j 00 None.
Unit 2/3 Dresden Nuclear Station NFPA Code MNitrices TABLE A NFPA 26 Deviation Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation Code Deviation No.
j SectUionI j
26-01 26-02
_ I 26-03 Not identified.
Paragraph 3-I, NFPA 26 Chapter 5.
NFPA 26 Procedures should identify acceptance criteria indicating valve positions not provided (Ref.
4.28, pg 5, para 2).
(I) Inspections not conducted weekly. (2)
Procedures do not identify need to reseal valves (Ref. 4.28, pg 5, para 3).
Failure to conduct 2-inch main drain tests after opening shut valves (Ref. 4.28, pg 6., para I).
Procedures 4114-01, Rev.04; 4114-02, rev.02; 4114-03, rev.02; 4114-06, rev.05 address this issue.
(I) Justification exists for monthly inspections for the following reasons:
I ) Access to valves is restricted.
- 2) 24 hr guard service reduces the probability or valve tampering.
(Rev. 4.28, pg 5, Para I, subpart 2).
(2)The station chooses to lock valves rather than seal them. (Ref. 4.15, pg 1.1-17, Item 4.1.2).
Section 3.0 of the Dresden FPP Self-Assessment (Ref. 4. 1 ) summarized the station's fire protection system maintenance requirements.
Based onl this summary, the station is not required to comply with NFPA 26.
i f
I DO 26-04 Not identified.
Valves noted without seals and valves not on procedure DFPP 4 144-6 (Ref. 4.28, pg 6, para 2).
Procedures 4114-01, Rev.04; 4114-02, rev.02; 4114-03, rev.02: 4114-06, rev.05 list all fire protection valves in plant. As per the fire asst.
fire marshal and based on a NTSC field sampling of valves, all FP control valves are locked.
According to NFPA 26, locks are an acceptable altenaitive to seals.
26-05 Not identified.
Broken lock on valve 3-4199-167 (Ref. 4.28, pg New lock installed (Ref. 4.15, pg 1.1-17,1tein DD 7, dash I ).
4.3).
26-06 Not identified.
Valve supervision inoperable on the U3 WRD42832 addresses this issue (Ref. 4.15, pg DD Hydrogen Seal Oil Unit (Ref. 4.28, pg 7, dash 2).
1.1-17,1tern 4.4).
26-07 Not identified.
Non-indicating valve (MO-2/3-4 101) installed on An indicating rod was installed per Mod. MO-DD U2-3 fire Pumiflp discharge (Ref. 4.28, pg 7, dlash 2/3-4101 (Ref. 4.15. pg 1. 1-18, Itern 4.5).
3).
Page I nf 2 Justification Recommended Action tJ 00 i-l DD None.
None.
Kl-I qprt;nn I
Unit 2/3 Dresden Nuiclear Station r...t,. NA.itriucnc TABLE A NFPA 26 Deviation Close Out Matrix Deviation Code Deviation Justification Recommended Action No.
Section
- .i...,:DD h~ 4efiir-Nont all control valves havc Valve tags installed Tags arc installed on all valves.
26-08 26-09 26-10 Chapter 8, NFPA 26 Tech. Spec.
4.12.3B. I1.a (Ref.4.28, pg 7, dash 4).
No plant procedure for non-tech spec. areas (Ref.
4.28, pg 7. dash 5).
Performing a water flow check in lieu of monthly inspections for inaccessible valves.
DATR Rev. 04 sect 3/4.1.3 ensures that compensatory measures for all systems except for outlying bldgs (Boiler Rm, warehouse etc.)
Justification provided in the following letters:
from D Roberts, T Hausheer, G Tietz to E Eenigenburg dtd 8/7/89 and Itr from D Robcrts, T Hausheer. P Kuhel to E Eenigenburg dtd 3/27/89.
Procedure DFPS 4123-09 perforns monthly flow tests on non accessible valves.
Page 2 of 2 NTSC Report No.93-124, Rev. 1 December 17, 1999 DD None.
INo L)[I(Jl tIILI Iu.
Unit 2/3 Dresden Nuclear Station TABLE A NTSC Report No.93-124, Rev. 1 NFPA CodeMatrices NFPA 27 Deviation Close Out Matrix December 17, 1999 Deviation I
Code i Deviation Justification Recommended Action No.
Section
_I__
r 27-01 No deviations (Rer. 4.29).
I
- I ( f t-0 00 1ý 1.0
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE A NFPA 30 Deviation Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Paragraph 5122, NFPA 30 Paragraph 43 13, NFPA 30 Not identified.
Deviation Justification Recommended Action Storage Warehouse: In this warehouse building flammable and combustible liquids are kept in a separate cut-off room which meets most of the requirements of NFPA 30 (Ref. 4.30, pg 5, para 2 and 3).
There is no station receiving and storage restriction for combustible liquids (Ref. 4.30, pg 8, para 3).
Chemical lists needs to be updated to provide more accurate information (Ref. 4.30. pg 8, para teeit does not expose any safety related areasd therefore, no recommendations have been made concerning this building (Ref. 4.30, pg 5, para 2 and 3).
DAP 16-I, Rev.06 and DAP 3-3, Rcv.03 address these issues.
DAP 16-1, Rev.06 and DAP 3-3, Rev.03 address these issues.
No knowledgeable personnel review chienlicall DDAAP 16-1, Rev.06 and DAP 3-3, Rev.03 address prior to plant entfry(Ref. 4.30, pg 9, para 1 ).th s i su.
No procedure exists to monitor storage and uise in Based on a review, a cabinet wvill not be provided plant areass. Plant stirvey revealed storage in open (Ref. 4.15, pg 1. 1-22, Item 4.8) plant areas on the Turbine Operating Floor (Ref.
4.30, g9.ara I and 2).
xitin installation can be justified as Class Clean and Dirty Lubc Oil Tank R0011: LX1allt..,,,u, and air intakes not located within 12 inches of floor (Ref. 4.30. pkz 12. Para 2).
Fire barrier deficiencies for the HPCI Pump Rooms aiid Clean and Dirty Lube Oil Tank Room (Ref.. 4.30. pg 10. para 4; pg I I. para 4; and pg 12, para 2).
40 liquids do not require special ventilation (Ref.
U2 HPCI door has been replaced (Rer. 4.15, pg 1.1-31, Item 4.1.2.)
U2 DG Day Tank Rm Door (150) and U3 DG Day Tank Rm Door (H0132) are acceptable based on justifications for unlisted fire door frame and signs attached to the door (Ref.4.2.
Appedix D).
None.
"None.
30-OS Section 52, Fire resistive requirements tnclear for several Based on active and passive protection provided, None NFPA 30 areas (Ref. 4.30. pg 13. para 2; pg 13. para 5; pg as well as the high flash point of the liquid, the 17, para 2 and 5; and pg 18, para 3).
existing configuration is acceptable (Ref. 4.30, pg 13, para 2; pg 13, para 5; pg 17, para 2 and 5; and pg 18, para 3).
Deviati on 00
,oN oo 30-01 30-02 30-03 3 0-04 30-05 30-06 30-07 None.
4).
I P,,e I of 3
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE A NFPA 30 Deviation Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation Code Deviation Justification Recommended Action No.
Section I1II__
30-09 Procedure 5650-Proccdurce 5650-3 references the use of space Procedure DOP 5650-3 has been revised to DD 3
heaters and temporary enclosures to preheat the address this issue (Ref. 4.15, pg 1. 1-22. Item EHC fluid (Ref. 4.30, pg 13, para I).
4.7).
30-10 Not identified.
U2 Oil Drum Storage Room: Nonstandard fire
...because ofrthe fixed suppression system, None.
door (Ref. 4.30, pg 15, dash 1).
ramped access and limited exposure to important equipment, door replacement is not justified (Rer.
4.30. pg 15. dash 1).
30-11 Not identified.
U2 Oil Drum Storage Room: Electrical Based on the fact that the quantity of Class I None.
equipment is not approved for Class I, Division 2 liquid is small and the quantity of flammable oper ations (Rcf. 4.30, pg 15, dash I; andj pg 16, liquids stored is close to that specified by NFPA para I).
30 for unprotected areas, this is acceptable (Ref.
4.30, pg 16, para I).
30-12 Not identified.
U2 Oil Drum Storage Room: No ventilation
... this is justified as no dispensing operations take None.
system provided (Ref. 4.30, pg 15, dash 3).
place within this room (Ref. 4.30, pg 15, dash 3).
30-13 Not identified.
U2 Oil Drum Storage Room: No bonding or
...this is justifiable as these liquids are not None.
grounding wires provided (Ref. 4.30, pg 15. dash dispensed in this room (Ref. 4.30, pg 15, dash 4).
4).
30-14 Paragraph 4311, U2 Oil Drum Storage Room: Room size exceeds The excessive size ofrthis room can be justified None.
NFPA 30 500 fQ2 limit (Ref. 4.30, pg 15, dash 5; and pg 16 based on the room being of fire resistive para 3).
construction, sprinkler protection installed and that most of the liquid in the room is Class Ill liquid (Ref. 4.30, pg 16 para 3) 30-15 DAP 3-11 Procedure DAP 3-11 not enforced (Ref. 4.30, pg DAP 3-11 is now enforced.
DD 16 para 2).______________________
30-16 Not identified.
Curbs and adequate drainage not provided for Mod M12-2/3-85-68 addresses this issue. (Ref.
DD Hydrogen Seal Oil Units (Ref. 4.30, pg 17 para 4.15, 1.1-21, Item 4.4).
4).
90 ON
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE A NFPA 30 Deviation Close Out Mntrix NTSC Report No.93-124, Rev. 1 December 17, 1999 Code Deviation No.
Seone.
Paragraph 2343, NFPA 30 Heat-actuated shut-off valve not provided for the DG Cell Day Tank Rooms (Ref. 4.30. pg 18 para 5).
+ -
1
Appendix A, Section F-10 Not identi fled.
Paragraphs 5130 and 5291, NFPA 30 Not identified.
30-22 Not identifled.
Paragraph 2343, NFPA 30 30-24 Paragraphs 5130 and 5241, NFPA 1
3 * - - - - - -
I,
Unprotected steel in the U2 day tank room (Ref.
4.30, pg 19, dash 2).
Deficiencies in Day Tank Room %
wall peiet ratiol (Rcf.4.30 pg 19, dash I and 3)..
No drainage from diked area in this U I Cribhouse (Ref. 4.30, pg 20, para 3).
U I and U2/3 Cribhouse: No fire resistive enclosure (Ref. 4.30, pg 20, para 3; and pg 21).
UlI and U2/3 Cribhouse: Tank venting arrangement is not standard as the ventilate should terminate outside (Ref. 4.30, pg 20, para 4; and pg 21 para 3).
No automatic closing heat actuated valve provided (Ref. 4.30, pg 20, para 5: and pg 21 para 4).
U2/3 Cribhouse: No curbing or drainage provided (Ref. 4.30, pg 21, para 2).
[
Justification I Recommended Action 30-17 Pnao
- nf II Deviation However, this position is overridden by concern for the possible spurious operation of such a valve, as fuel for the DG unit could be cut off by such operation. It is desired that the DG units be able to operate even ifa fire occurs due to the overriding concern for safe shutdown (Ref. 4.30.
pg 18 para 5).
The unprotected beam is in a room with sprinkler protection.... (Ref. 4.15, pgl. 1-2 1, Item 4.5).
Each of the day tank rooms commnicates only with its associated DG cell. As these DG cells are cut off fronm remaining plant areas by 3-hour barriers, justification exists for not requiring the deficiencies in wall penetration to be corrected (Ref. 4.30, pg 19, dash I and 3).
...this can be justified as the diked area will contain three times the tank capacity (Ref. 4.30, pa 20, para 3).
Not requiring an enclosure of suitable Fire resistance can be justified due to the fixed fire suppression system provided (Ref. 4.30, pg 20, para 3; and pg-21I).
Thei present arrangement can be justified due to fire-resistive construction and the installed sprinkler protection (Ref. 4.30, pg 20, para 4; and pg 21 para 3).
... this emission is justified due to the relatively small tank size, fixed suppression provided, and redundancy of fire pumps (Ref. 4.30, pg 20, para 5: and pg 21 para 4).
Mod M 12-2/3-84-7 addresses this issue(Ref.
4.25, pg1. 1-22, Item 4.6).
30-IS 30- It) 30-20 30-21 0,0 None.
None.
None.
None.
None.
None.
DD I --
0.1 I
l-f;-
i I -I,,'-", -
I None.
Unit 2/3 Dresden Nnclenr Station NFPA Code Matrices TABLE A NFPA 49 Deviation Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation Code Devi1tion Justification Recommended Action No.
Section No deviations (Ref. 4.30).
I I
_I__
.1 None 00o oo'
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABlF A NFPA 50A Deviation Close Out Matrix NTSC Report No.93-124, Rev. 1 December 17, 1999 Deviation Code Deviation Justification Recommended Action No.
Section I
1__
50-02 Paragraph 413 Bulk Hydrogen Storage Systems: Hydrogen signs Signs provided (Ref. 4.15, pg 1.1-23, Item 4. 1)
DD and 451, NFPA not visiblc (Ref. 4.31. pg S, para 3).
50A 50-03 Paragraph 512, Bulk Hydrogen Storage Systems: Hydrogen The current hydrogen storage system at the site is DD.
NFPA 50A, systems not above ground (Ref. 4.3 1, pg 8, para a liquified hydrogen storage system. The older "Gaseous 5).
gaseous hydrogen equipment is still on-site, but is Hydrogen not in service at this time.
Systems" NFPA 50A does not apply. NFPA 50B, which governs Liquificd Hydrogen Systems. has no such requirement. In addition, since hydrogen supply piping is routed above ground before it enters the building, any leaks would not be carried into the building, and tile below ground piping installation could be justified, even for a gaseous hydrogen system (Ref. 4.31, pg 8, para 5).
50-04 Paragraph 513, Bulk Hydrogen Storage Systems: Hydrogen As per NTSC walkdown, this system has been DD NFPA 50A systems below power lines (Ref. 4.31, pg S, para removed. A portable system is now installed 6).
away from power lines.
50-05 Not identified.
Bulk Hydrogen Storage Systems: Electrical However, the existing installation can be justified None.
equipment not listed for Class I, Group B as Class I, Group C equipment is installed, the operation (Ref. 4.31, pg 9. para 2).
outdoor installation should dissipate flammable mixtures quickly, and the tanks do not expose any areas necessary for safe shutdown (Ref. 4.31, pg 9, para 2).
50-06 Paragraph 446, No procedure requiring electrical bonding (Ref.
The Air Products Co. procedure already provides DD NFPA 50A 4.3 1, pg (, para 3).
for grounding of the trailer prior to unloading (Ref. 4.15, pg 1.1-23, Item 4.4).
plop I ArI 00 Oo
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABI.E A NFPA 50B Deviation Close Out Matrix NTSC Report No.93-124, Rev. 1 December 17, 1999 Deviation Code Deviation Justification Recommended Action No.
SectionI-1_1_---_
I__
50-01 Paragraph 463, Bulk Hydrogen Storage Systems: Vehicular Barriers provided (Ref. 4.15, pg 1.1-23, Item DD NFPA 50B barriers will be needed (Rcf. 4.31. pg 8, para 2).
4.2).
50-02 Paragraph 515, Bulk Hydrogen Storage Systems: Hydrogen signs Signs provided (Ref. 4.15, pg 1.1-23, Item 4.1)
DD NFPA 50B not visible (Ref. 4.31, pg 8, para 3).
50-06 Paragraph 74, No procedure requiring electrical bonding (Ref.
The Air Products Co. procedure already provides DD NFPA 50B 4.3 1, pg 9, para 3).
for grounding orfthe trailer prior to unloading (Ref. 4.15, pg 1.1-23, Item 4.4).
50-07 NFPA 50B Bulk Hydrogen Storage System: Hydrogen Since the fuel oil tank on the west side is diked, None.
facility is not above ground level (Ref. 4.31, pg 9, this should not present a problem (Ref. 4.31, pg para 4).
9, para 4). In addition, this equipment is not in service at this time.
t-j 00 ON 61
(-A
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE A NFPA 51 Deviation Close Out Matrix NTSC Report No.93-124, Rev. 1 December 17, 1999 ON ON
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE A NFPA51IB Deviation Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation Code Deviation Justification Recommended Action t00 00 v).*.-,
T Nr i*
No.
Section 51-01 Not identified.
Persons issuing hot work permits arc not NGET and DAP 3-2 address this issue (Ref.4.15, DD receiving training (Ref. 4.32, pg 5. dash 1).
pg 1.1-25,Item 4.2) 51-02 Not identified.
Procedure DMP 4100-1: "Item B, Refcrences, DAP 3-2, Rev.03 replaced DMP 4100-!. It DD does not include NFPA 51B" (Ref. 4.32, pg 5, references NFPA 51B.
dash 2).
51-03 Not identified.
Procedure DMP 4100-1: Precautions, does not DAP 3-2, Rev.03 addresses this issue.
DD include ducts or removal of combustibles (Ref.
4.32, pg 5. dash 3).
51-04 Not identified.
Procedure DMP 4100-1: Required minimum DAP 3-2, Rev.03 addresses this issue.
DD distance to comhustibles is not specified (Ref.
4.32, pg 5, dash 4).
51-05 Not identified.
Procedure DMP 4100-1: Requirements not However, this omission can bejustified as all None.
specified for combustibles behind walls in safety related areas are of masonry noncombustible walls (Ref. 4.32, pg 5, dash 4).
construction (Ref. 4.32, pg 5, dash 4).
51-06 Paragraph 412, Procedure DMP 4100-1: No requirement to check DAP 3-2, Rev.03 addresses this issue.
DD NFPA 51B that sprinkler systems are operable (Ref. 4.32, pg 6, dash 1).
51-07 Paragraph 434, Procedure DMP 4100-1: Lack ofcontinuous fire DAP 3-2, Rev.03 addresses this issue.
DD NFPA 51B watch for 30 minutes (Ref. 4.32, pg 6. dash 2).
51-08 Not identified.
Procedure DMP 4100-1: No permit expiration DAP 3-2, Rev.03 addresses this issue.
DD date specified (Ref. 4.32, pg 6. dash 3).
51-09 Not identified.
Form S6-5186: Forms are ambiguous (Ref. 4.32, DAP 3-2, Rev.03 addresses this issue.
DD pg 6, last para).
Justifliction
Unit 2/3 Dresden Nucleiar Station NFPA Code Matrices TABLE A NFPA 69) Deviation Close Out Matrix NTSC Report No.93-124. Rev. I December 17, 1999 Deviation I
ICodc Deviation Justification Recommended Action No.
Section Paragraph 3722, NFPA 69 NRC Staff Position No. 14, March 10, 1977 50-10 Paragraph 3742 Battery Room: No procedure for loss of ventilation (Rer. 4.31, pg 9. para 5).
Exhaust ducts not0 routed outside (Rcf.4.31. pg
- 10. para I).
Battery Room: No procedure for periodic maintenance and recalibration of airflow meters (Ref. 4.31. pg 9. para 7).
Dresden Annunciator Procedures (DANs) XL3 Dresden Annunciator Procedures (DANs) XL3 52-29, 52-30. 62-29, 62-30(all Rev.0) address this issue.
However, due to continuous air now monitoring and the existence of calculations showing the time necessary to reach the lower explosive limit in the event of ventilation system failure, periodic air sampling is not necessary (Ref, 4.31. pg 9.
para 6).
The following U2/3 air flow switches are shown on drawing M-973 (Ref. 4.56):
3-57S6-102 (U3 Battery Rm, el 538')
3-5786-103 (U3 Battery Rm, el 551')
2-5786-100 (U2 125V Battery Rm) 2-5786-101 (U2 250V Battery Rm)
The two year Station Preventive Maintenance Surveillance for these devices call for calibration checks per vendor manuals. Recent work requests (Ref. 4.56) validate that this activity is being performed.
50-I I NRC Staff Exhaust ducts not routed outside (Rcf4.3 I, pg t0.
Adequate dilution is provided where the exhaust None.
Position No. 14, para 1).
discharges into the TB (Ref. 4.15, pg 1. 1-24, Item March 10, 1977 4.6).
l'age I of I 50-08 50-09 i
- - t 00 O0 00 ID T-I I
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE A NFPA 70 Deviation Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation Code Deviation Justification Recommended Action No.
Section
_II_--_1__
70-01 No deviations (Ref. 4.33).
00 I*.1,,,. I,*t" T
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE A NFPA 72D Deviation Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation Code Deviation Justification Recommended Action No.
Section
[III 72D-01 1321 Paragraphs 1112 and 1131 do not apply in this Dresden has not committed to or required by the None.
case. The Mux security panels are connected in a NRC to provide Class A supervision. Style C loop circuit to the CPU. Thie loop will still be circuits (Class B) are installed. Initiation of local operational under a single ground or open circuit, alarm signals is not supervised; however, these However, the Signaling Line Circuits (SLC) from circuits are not essential to the receipt of signals the Mux panel to the Fire Control Unit appears to at the central station (Ref. 4.35, Sect 2 -7.1 and not have this capability based ont the information Table 3-9.1).
provided to date. The NRC has also imposed these conditions on circuits installed to actuate fire suppression systems. Thie actuating device circuits at Dresden (deluge valve solenoids) are supervised (Class B), but are not operable during a single ground or open circuit condition (Class A). Browns Perry was required by the NRC to upgrade these circuits for Class A operation (Ref.
4.34, pg 12 and pg 46).
The water flow switch circuit arrangement shown on ASCO DRWG PE-497-2 is not capable of operating during a single ground fault or open circuit on the initiating device circuit. Paragraph 1323 is not applicable (Ref. 4.34. pg 12).
This circuit configuration is a Class B arrangement and is acceptable. A Class A circuit configuration would allow the circuit to continue to function under an open circuit or ground condition; however, Dresden has made no commitment to install Class A circuits. If a open or ground occurs, a trouble signal will be received at the XL3 panel (NTSC).
None.
The NRC is the authority havingjurisdiction.
All new equipment (XL3 System) is UL listed for None.
They require that equipment be listed or labeled their intended service; however, a few devices by a nationally recognized testing laboratory for (e.g., door switches) wired to the addressable the services for which it is used. The fire alarm interface modules are not listed for fire service system and fire control units are not listed for but are designed to produce a trouble signal upon NFPA 72D service. The existing system is a failure. In addition, there are still some unlisted customized assembly (Ref. 4.34, pg 13).
local control panels remaining. The functional importance of these panels is minimal. Ltr 2/13/86 (Ref. 4.35, Sect 2-2.2).
)i
., r 7
00 1322 72D-02 72D-03
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE A NFPA 72D Deviation Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation Code Deviation Justification Recommended Action No.
Section 72D-04 2035 The Dresden fire alarm system is combined with The security panel is no longer used For U2/3 fire DD the security signaling system. The security alarm signal monitoring. As per field signaling system could be considered a system for verification, U2/3 fire alarm signals are being protection of life and property (the majority of monitored by a UL listed fire alarm panel (XL3 existing nuclear stations today have independcnt System).(NTSC) dedicated fire alarm systems) (Ref. 4.34, pg 13).
72D-05 2224 This requirement is under the category for power The CSS is no longer used for U2/3. Power to DD.
supplies, Central Supervision Station (CSS). The the XL3 system is described in Section 2-6 of the main power supply at Dresden provides operation NFPA 72D Review. Deviations arc discussed in of trouble signals in the CSS based on available this section(Ref. 4.35. Sect 2-6).
information (Ref. 4.34, pg 14).
72D-06. I 2230 and 2231 The CSS and Mux panels are supplied by the The CSS is no longer used for U2/3. Power to DD.
dedicated security diesel with 125VDC battery the XL3 system is described in Section 2-6 of the back-up as a secondary supply. This is according NFPA 72D Review. Deviations are discussed in to FHA and conversations with CECo and the this section(Ref. 4.35, Sect 2-6).
local fire control units do not have a secondary or trouble power supply. This is the reason the Security computer receives an overload of fire alarm trouble signals on any loss of main power to the local panel (Ref. 4.34, pg 14).
72D-06.2 2431 Manual pull stations used for actuiat ion of fixed The manual pull stations utilized to actuate DD.
suppression systems are arranged such that an deluge sprinkler, open-head water spray, pre open circuit or,round fault would go undetected action, carbon dioxide and Halon 1301 fire (Unsupervised circuits). (eg. See ASCO suppression systems are not fire alarm "initiating DRWGS PE-497-I and PE-497-17). Items (a),
devices" or "signaling circuits". Thie manual pull (b), and (c) are not applicable (Ref. 4.34, pg 15).
stations used for actuation of fire suppression systems are arranged in accordance with NFPA 12, 12A. 13 or 15 which do not require supervision of these circuits. There is no code violation. See the Technical Justification in Attachment I of this report.
n.
0-0
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE A NFPA 72D Deviation Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation Code Deviation
[
Justifiication f Recommended Action No.
Section I
I 72D-07 2441 Local fire alarm bells are not supervised. A NFPA 72 D does not require local alarms; None.
single ground fault or open circuit would,go however, Dresden committed to providing local undetected (cg. ASCO DRWG PE-497-4) (Rcf.
alarnms in their response to the BTP 9.5-1, 4.34, pg 15).
Appendix A, Sect E.l(b). (Appendix A recommended the use of local alarms). As a result, the requirements of NFPA 72A must be met. NFPA 72A requires indicating circuits to be supervised. The alarm system provides unsupervised local audibles via existing local control panels except in the areas protected by C02 and Halon. These areas have supervised indicating circuits. Unsupervised circuits decrease the reliability of the providing a local alarm. However, since a P.A. system is available and procedurally (XL3 DANS) set up to provide evacuation notification when a fire alarm is received in the control room, the existing level of alarm circuit reliability is adequate (Ref. 4.35, pg 19, Para 4-2.3).
72D-08 2521 Local alarm bells and trouble horns are listed by See Justifications for 72D-03.
None.
U.L. However. it is uncertain that audible signals in the CSS and Control Room are listed since the security systems is not listed. Insufficient information has been provided for this conclusion (Ref. 4.34, pg 16).
72D-09 2541 The fire alarm system is not intended for total Fire alarms are received in the control room. The None.
evacuation of the plant, only of the immediate fire alarms indicate the location of concern to the area. A justification starting the plant's position control room operators. The operators notify should be documented (Ref. 4.341, pg 16).
station personnel of the condition via the P.A.
system and address the alarm condition accordingly with the assistance of written emergency response procedures - XL3 DANS (NTSC).
P:!,e I of 7 N) 00 tQ
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE A NFPA 72D D)eviation Close Out Maitrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation Code Deviation I
Justificationt Recommended Action No.
Section I
-____I 72D-10 2551(b) and (c)
(b) Status or this item is uncertain at this time (b) Addressed (Ref.2, Sect.4-3.1 and 4-4.1(b) and (b) DD because of lack of available design data. (c) This 4-4. 1 (c)).
mcans precedence over all signals on the fire alarm signaling system (cg. security). The Fire (c) Security system is no longer used to monitor (c) DD alarm system is connected to and operated by the the fire alarm system. An XL3 system has been security department. Alarm signals are installed to monitor Fire protection alarms.
transmitted to the control room where they are monitored. Conversations with CECo personnel indicates software changes to the security CPU which may jeopardize fire alarm precedence (Ref.
4.34, pg 17).
72D-11 2630 and 1244 Insufficient inrormation is available to draw any Addressed (Ref. 4.35, Sect.4-5.3)
DD conclusions regarding the interface of the local fire control units and the Mux system (Ref. 4.34, p_ 17).
There is no manual fire alarm service as intended in this Section at Dresden Station.
Documentation reviewed shows only manual pull stations associated with the actuation of Fire suppression systems. These pull stations are similar in design to manual fire alarm boxes and could be easily confused. All pull stations are not located adjacent to the suppression system and are not clearly identified as to their function unmarked. This could lead to the inadvertent operation of thee suppression system (Ref. 4.34, pg 18).
A number of water suppression systems were found without water flow devices. See PLC Fire Suppression Survey (Ref. 4.34, pg 19).
Although the station does not comply with this item, however. PLC agrees that the extensive plant communication system provides an equivalent service since through administrative procedures, personnel are trained to use this system in case of Fire (Ref. 4.34, pg 18).
Remotely located manual pull stations are labeled (Ref. 4. 1, Section 3. 1 ).
Sprinkler system water flow switches are provided and monitored (Ref. 4.35, Sect.3-6.3).
DD DD L
00 3113 72D-12 72D-13 None.
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices Deviation,0-II72D-14 r72D-IS TABLE A NTSC Report No.93-124, Rev. I NFPA 72D Deviation Close Out Matrix December 17, 1999 D evi tion JustificationR ecom m ended A ction See Sections 4 and 5 and Appendix A report for See NFPA 72E Matrix.
None.
details on deviations from NFPA 72E (Ref. 4.34, A few devices wired to the Pyrotronics These devices are designed to produce a trouble None.
addressable module interfaces (e.g., time delay signal upon failure. The functional importance of relays for door switches on areas having gaseous existing unlisted equipment (most control panels) suppression) are unlisted (Ref. 4.35, pg 6).
was minimized or eliminated. See letter dated "1111196 (Re.
4.35.A nP 6),
moduesindcatng crcuts romSXthle receipt of signals at thle central station (Ref.
72D-16 2-7.1 Detection loops, actuation circuits from SPX The local alarm signal circuits are not essential to None.
moduesindcatng circuits from SPXthreepofsgasa ecnrlsain(R.
modulesoildicating circuits to the Control R ooni 4.15, pg I 0).
and the dry contact connections to the addressable interface (TRX-l) modules are supervised for opens and grounds. 'Initiation of local alarm signals is iiot supervised (Ref. 4.35.
Pg 10).
72D-17 3-.1)
Door switches and air flow mionitors are They are monitored via TRX modules so they None.
combined systems (Ref. 4.35, pg 16 and 18).
cannot interfere (Ref. 4.35, pg 16 and 18).
72D-18 3-9.1 A single detection loop may have more thin one Since each panel is monitored by a single None.
existing panel monitored via TRX modules (Ref.
addressable TRX module, this is acceptable (Ref 4.35, pg l6 and IS).
4.35, pg 16 and IS).
72D-19 4-2.3 The i ndicatio oiOf location shall utilize indicating The dispatching of roaming operators with hand-NN one.
appliances acceptable to the AHJ. NRC requires held radios and Fire brigade members to all local audible signals. System provides alarms supplements and thus reduces the need for unsupervised local audible via existing panels and local audible alarms. Additionally, the P.A.
provide evacuation notification. Therefore.
bells (Ref. 4.35, pg 19).
system is available and procedurally set up to unsupervised local audible alarms without secondary power is acceptable. "It is desired to have local audible in Halon and C02 protected areas for personnel safety reasons. These meet the NFPA 72A (Ref. 4.35, pg 19).
tQ 00 4:i I 2113/ZSC) (KC1.
1)ý; U),
F
TABLE A NTSC Report No.93-124, Rev. I NFPA Code Matrices NFPA 72D Deviation Close Out Matrix December 17, 1999 N
F A
C d e v ia t ri c e s Deviation Code Deviation Justification Recommended Action No.
Section I
72DS-01 Not provided.
DFPP 4185-2 does not include a co1mcnt section DFPP 4185-2. "Smoke Detector Semi-Annual DD.
for the inspector to note any unuisual problems Maintenance Test" has been deleted. DFPS encountered durine the inspection (Ref. 4.36, pg 4183-03, Rev.0I: DFPS 4183-04, Rev.01; and W)-..
re nrP 4185-..
DFPP 4185-2 does not include surveillance of DFPS 4 183-05, I.R.v.u02 repla.ce l.'* ',4,181-L.
These procedures do not have comment sections; however, these procedures require that the Shift Engineer and the Fire Marshal address of any potential problems.
UL).
As per the station flre marshal, all non-restorable As per tie station fire marshal, all non-restorable beat detectors have been replaced with restorable detectors ill tile following areas. U Turbine Lube Oil Reservoirs water spray systems hbeat detectors. Furthur evidence that they were U-2 & U-3 112 Seal Oil Units water spray replaced with restorable detectors is in test systems U-2 & U-3 Turbine Bearing Lift Pump procedures DFPS 4183-1. Rev.0; DFPS 4183-2, water spray systems All outside transformer Rev.0, and DFPS 4183-08, Rev.0.
water spray systems (Ref. 4.36. pg 3. para 1, subpart 2; and pg 4, Table 3.0-1I, Item 9).
72DS-03 232.b Test of transmitters every two months as required Tile XL3 system addressable interface None.
by Paragraph 1232.b of NFPA 72D-1975 modules(e.g. TRXs and TRIs) transmit the (Ref.4.36, pg 3, para I, subpart 3; and pg 4, signals to the head end panel. These transmitters Table 3.0-1, Item I).
are tested semi annually. not every two months.
The station did not commit to maintaining the fire alarm in accordance with NFPA 72D, therefore, semi-annual testing is acceptable (Ref. 4. 1.
Section 3.1).
72DS-04 1232.c A semi-annual test of miscellaneous sprinkler Procedure DFPS 4133-01. Rev.0I addresses this DD supervisor devices, such as air supervision to issue.
preaction sprinkler systems, as required by Paragraph 1232.c of NFPA 72D-1975 (Ref. 4.36.
pg 3, para 1, subpart 3; and pg 4, Table 3.0-1.
Item 3).
72DS-02 00
-1 3,para 1 upr
)
I r-)
I I
D-D/.
I
Unit 2/3 Dresden Nuclear Station NFPA Code NIntrices TABLE A NFPA"72D DevNiation Close Out Matrix NTSC Report No.93-124, Rev. 1 December 17, 1999 00 OO Page 7 of 7
TABLE A NTSC Report No.93-124, Rev. I Unit 2C3 Dresden Nuclear Station NFPA 72F Deviation Close Out Matrix December 17, 1999 NFPA Code Matrices Dcvi1tion Code Deviation Justification Recommended Action No.
Section i=
i 72E-01 Not provided.
The existing detectors in the diesel generator Mod M 12-3-84-109 addresses this issue (Ref.
DD.
room are listed by U.L. (Fire Protection 4.23, Item 4.1.1).
Equipment Directory Page 171) for 25 ft spacing on a smooth ceiling and 12.5 ft maximumn spacing to a wall or partition. The existing detectors in the diesel room are installed too far rroni each wall and cover too much area for the type of service for which they are listed (Ref. 4.34, pg 21, Sect 4.1.2).
72E-02 Not provided.
The U2 and U3 MCC (EL 517'-6") ionization Mod M 12-2-84-10 9 and M 12-3-84-1 0 9 addresses DD.
detectors under a sheet tuetal canopy located this issue (Ref. 4.23. Item 4.1.3).
above an MCC, does not meet the requirements of NFPA 72E-1974 which call for smoke detectors
-,...to be located at ceiling level (Rcf*. 4.34.pg 23, Sect 4.1.3).
72E-03 Not provided.
No Detection in the New Fuel Area (Ref. 4.34, pg Techinical justification provided via tw~ole~tters d
to None.
26, Sect 4.1.7).
the NRR dated 2/25/80 and 12/5/85. See FPPDP (Ref. 4.23, pg 2, Item 4.1.7).
72E-04 Not provided.
The AEER Room fire detection system is not in Mod. M 12-2 109 addresses this issue (Ref.
DD.
compliance with NFPA 72E-1974 for a beam 4.23, pg 2, Item 4.2.1).
construction ceiling (Ref. 4.34, pg 28, Sect 4.2.1).
TABLE A NFPA 72E Deviation Close Out Matrix NTSC Report No.93-124, Rev. t December 17, 1999 Deviation Code Deviation Justification Recommended Action No.
Section1I1I1I 72E-05 Not provided.
The Cable Cone. Area Based on a review of drawing 12E-6580B, DD.
(Mezzanine EI.538') preaction Rev. L, dated 10/6/98, the system is system is actuated by the smoke equipped with a solenoid that allows water detectors transmitting a signal to to flow through the by-pass. This solenoid the preaction valve. The circuitry is controlled from a local panel.
for this arrangement is detailed on ASCO DRWG PE-497-1 7. This The actuation of the deluge valves are drawing indicates that a timer completely independent of the bypass circuit is installed in the logic
- solenoid, acluate thle preaction system. The timing sequence of this timer is When any one ofthe detectors 2-4135 401 uncertain. It is assumed through through 415 detect fire or TRX-142-4135 tile ASCO drawing that the timer 426 is actuated, after 10 seconds SPX-1-04 is used to delay water into thle Output #3 energizes the deluge valve at system. This arrangement is Valve 2-4199-142B to arm the pre-action nonstandard and unwarranted system protecting the East Side Mezzanine (Ref. 4.34, pg 3 1, Sect 4.2.4).
Floor Cable Tray Panel 2202-56A.
When any one of the detectors 2-4132-701 through 716 detect fire or TRY-I #2-4132 730 is actuated, after 10 seconds, SPX-l 04 Output N2 energizes the deluge valve at valve 2-4199-142A to arm the pre-action system protecting the West Side Mezzanine Floor Cable Tray Panel 2202 56B.
Failure of the by-pass solenoid will not prevent the actuation of the deluge valve.
In addition, a 10-second delay will not have a significant effect on the system's ability to control a fire (Ref. 4.1, Section 3.1).
Page 2 of 5
'.j
?o 00 Unit 2/3 Dresden Nuclear Station NFPA Code Matrices
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE A NFPA 72E Deviation Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation Code Deviation Justification Recommended Action No.
Section JIII 72E-06 Not provided.
The Cable Cone. Area (Mezzanine El. 538')
The fire detection system has been accepted by None.
detection system arrangement is not as specified the NRC in this configuration to activate the in NFPA 72E-1974 and the detection should be preaction water spray system in the cable trays extended over MCC 28-2. (Ref. 4.34, pg 3 1, Sect (Ref. 4.34, pg 31, Sect 4.2.4).
4.2.4).
Mod. M 12-2-84-109 addresses extension of detectors (Ref. 4.23, pg 2, Item 4.2.4).
There is no fire detection in consoles and cabinets The existing configuration is acceptable based all None.
in the operator's area in the Control Room (Ref.
but two of the consoles and cabinets are open or 4.34. pg 32 and 33, Sect 4.2.5).
vented thus allowing smoke to de detected by the ceiling system. Plant operators arc in attendance continuously and a fire in the enclosed cabinets would be quickly identified (Rcf.4.34, pg 32 and 33, Sect 4.2.5).
72E-OS Not provided.
The Station Battery Room (U2 El. 549') detection Mod. M 12-2-84-109 addresses extension of DD system installation does not comply with NFPA detectors (Ref. 4.23, pg 2, Item 4.2.6).
72E-1 974 for beam construction ceilings or detectors located in sidewalls (Ref.4.34, pg 34, Sect 4.2.6).
72E-09 Not provided.
The fire detection placement in the cable tunnel Mod. M 12-2-84-109 addresses extension of DD complies with NFPA 72E-1974 location and detectors (Ref. 4.23, pg 2, Item 4.3.1).
spacing requirements except for detector 8941 222 near column line (Col. 45) located 5 ft. from the ceiling (Ref. 4.34, pg 35, Sect 4.3.1).
00 Page 3 of 5
I TABLE A NFPA 72E Deviation Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation Code Deviation Justification Recommended Action No.
Section
_I1II 72E-10 Not provided.
I) The installation of the fire detectors in the Unit The existing detector installation will achieve its None.
2 DG Room does not comply with NFPA 72E-objective based on the environmental variables 1974. The three detectors are not mounted on the (Ref. 4.34, pg 37 and 38).
ceiling. They are mounted on the lower flanges of beams in the room.
- 2) The existing detectors are 225.F dteectors listed by U.L. for 25 foot spacing on a smooth ceiling and 12.5 ft maximum spacing to a wall or partition. The existing detectors are installed too far From each wall for which they are listed (Ref.
4.34, pg 36, Sect 4.3.2).
72E-1I Not provided.
Detector No. 894 1-18 (U2 480V Swtgr and MCC Mod. M 12-2-84-109 addresses extension of DD El. 517-6") is located just above MCC 29-2 detectors (Ref. 4.23, pg 2, Item 4.3.3).
several feet from the ceiling (Ref. 4.34, pg 39, Sect 4.3.3).
72E-12 Not provided.
One beam pocket between Col. 55-56 in U3-4KV Mod. M12-2-84-109 addresses extension of DD switchgear & MCC area, El. 538', lacks detectors (Ref. 4.23, pg 2, Item 4.3.6).
detectors. Detectors are spaced too far (approximately 18 ft) from column line 53 (Ref.
4.34, pg 4 1, Sect 4.3.6).
72E-13 Not provided.
The U3 MCC 38-2 El. 538'. fire detection system Mod. M 12-2-84-109 addresses extension of DD is not installed to provide modification of a fire detectors (Ref. 4.23, pg 2, Item 4.3.7).
exposure to the MCC's (Ref. 4.34, pg 42, Sect 4.3.7).
Page 4 of 5 00 C)
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE A NFPA 72E Deviation Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999 7-4.1 Deviation 1
Justification Recommended Action The fire detector located immediately adjacent to Mod. M 12-2-84-10 9 addresses extension of DD t...
.. i tiat,,e on the north wall near I detectors (Ref. 4.23, pg 2, Item 4.3.3).
thel air suply
.l*venti~late ot,,mu.....
Col. 32 (U2 480V Swtgr & MCC El. 517'-6")
will not be effective due to the strong air flow patterns in the area (Ref. 4.34, pg 39, Sect 4.3.3).
A periodic check of smoke detectors to clean, inspect, and adjust the sensitivity of the device as required by Paragraph 7-4.1 of NFPA 72E-1974.
Most detector manufacturers require the sensitivity check to be conducted annually (Ref.
4.36 n 5. n ara 1, subpart 3: and pg 8, Table I -
DD Procedure DFPS 41 85-03, Rev.0 addresses this Procedure DFPS 4185-03, Rev.0 addresses this issue.
3.01, Item8).
72E S-02 7-3..
I Paragraph 7-3.1.1 of NFPA 72E-1974 requires As per the station fire marshal, all non-testable, DD non-restorable detectors to be sample tested.
non-restorable heat detectors have been replaced After the fifteenth year in service, and at 5-year with restorable heat detectors. Furthure evidence intervals thereafter, at least 2% /
of all ion-that they were replaced with resorable dectectors is restorable detectors should be removed and in test procedures DFPS 4183-I, Rev.O: DFPS submitted to a testing laboratory (such as UL, 4183-2, Rev.O, and DFPS 4183-08, RevO.O Inc.) for testing. Removed detectors shall be replaced with new detectors. Test failure may result in the submittal of additional detectors for testing (Ref. 4.36I pg 5. para I, subpart 4; and pg
- 8. Table 3.01w. Item 9)
Page 5 of 5 Deviation No.
ýr
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE A NFPA 78 Deviation Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999 p.
I of I 00 O0 I
lI
TABLE A NFPA 80 Deviation Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation Code Deviation Justification Recommended Action No.
Section IIII 80-01 1.6.1 and 10.2.3 No U.L. label for the bullet proofControl Room See Justification I of-Appendix A of NFPA 80 None.
doors (numbers 28.-30, U 1-36 and U1.-39) (Ref.
Report, Rev.2 (Rcf. 4.2).
4.38, pg6, Sect 3.1.1).
80-02 1.6.1 and 10.2.3 No U.L. label for the Diesel Generator 2/3 Room Scc Justification 2 ofAppendix A oCNFPA 80 None.
Entrance Door (Number 137) (Ref. 4.3S, pg 6, Report, Rcv.2 (Ref. 4.2).
Scct 3.1.2).
80-03 Various Various deviations to be resolved by See Appendix G, Updated November 30, 1999, Resolve eight maintenance (Ref. 4.2, Appendix G).
contained in Attachment 2 of this report.
remaining open issues listed in Appendix G.
80-04 2-5.1 Of the single and double swinging doors See Justification 3 of Appendix A of NFPA 80 None.
observed at Dresden. seven have listed door Report, Rev.2 (Ref. 4.2).
frames (Door number 8, 39,, SO, 81,82, 83 and 168) withl lahels attached. The remaining ftames appear to have been fabricated at the site (Ref.
4,38. pg 7, Sect 3.3).
80-05 2-5.4 Of the swinging doors observed, ten doors See Justifications 4 and 5 of Appendix A of None.
(Numbers 14, 50. 70, 76,82, 117, 129, 132, 140 NFPA 80 Report, Rev.2 (Ref. 4.2).
and 168) were found to meet the required maximum limits of Paragraph 2-5.4. The remaining swinging doors deviate from NFPA 80 (Ref. 4.3S, pg 7, Sect 3.4).
80-06 2-8.2, 2-8.7 Specific doors do not meet lock and latch See Justification 6 of Appendix A oFNFPA 80 None.
10.1.2 requirements.
Report, Rev.2 (Ref. 4.2).
Doors 70 and 73 are not provided with strike plates. Since the door frame is a channel frame this condition is acceptable (NFPA 80-1983, paragraph 2-8.2.8, Exception).
t,,)
00 w0 Unit 2/3 Dresden Nuclear Station NFPA Code Matrices
Unit 2/3 Dresden Nuclear Station N IP r,
ilpNinOice TABLE A NFPA 80 Deviation Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation Code Deviation Recstiication Rcommended Action No.
Secti o 80-07 2-S and '.M Alteration or fire doors exist at Dresden. Thesc See Justification 7 of Appendix A of NFPA 80 None.
altcrations fall into the following principal Report, Rev.2 (Rcf. 4.2).
categories: I ) Damage 2) Repairs 3) Additional of extra hardware, signs, etc. 4) Deletion of extra hardware, etc., leaving small holes or voids in the door surface (Ref. 4.38, pg 9, Sect 3.9).
SO-OS Chapter 4 80-09 Chapter 6 80-10 Section 2-8.2, NrPA SO 80 - II Not identified Comparing the requirements of Chapter 4 with See Justifications 8 through 14 of Appendix A of the actual door installations, the doors were NFPA 80 Report, Rev.2 (Ref. 4.2).
found to meet the code except for the conditions discussed. These conditions are also acceptable (Rcf. 4.38, pgg9, Sect 3.10).
Dresden has installed four roll-up steel Fire doors See Justifications 15 and 16 of Appendix A of (Numbers 17A, 57, 5A and 1005). In general, NFPA 80 Report, Rev.2 (Ref. 4.2).
the doors appear to be in good condition; however, they were not operating during the survey. These doors were installed in accordance with NFPA 80, except for lack of fusible links for rolling doors (Ref. 4.38, pg 9, Sect 3.11).
Coordinating devices are not provided on doors The lack of this device is acceptable since the 20, 28, 30,U 1-36 and U 1-39 (Ref. 4.38, pg 8, inactive leaf of each door are normally closed Sect 3.7).
and bolted (Ref. 4.38, pg 8, Sect 3.7).
There is no fusible link at the ceiling to activate See Technical Justification dated February 9, the door closing mechanism for Doors 12 and 46 1999 contained on Page 17.4-1 of the FPPDP to the Clean and Dirty Oil Room.
(Ref. 4.9).
None.
None.
None.
None 1
11 t00 00 I
I I
Unit 2/3 Dresden Nuclear Station Porv
~ou r.,iý mtrr OO L,-A TABLE A NFPA 80 Deviation Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999
[*
Diation Code Deviation Justification Recommended Action No.
Section S0-12 6-6.2 There are no fusible links at the ceiling on the Fusible links are installed near the ceiling on the None Turbine Building side of the fire wall to activate inside of the Diesel Generator Rooms to provide the door closing mcchanisnm for Fire Doors I 7A automatic closing of tile fire doors in accordance and 9)SA oil the Unit 2 and Unit 3 Diesel with NFPA 80, Section 6-5.1 in the event of a Generator Rooms.
fire inside the Diesel Generator Rooms. The heat generated by an oil fire in one of the Diesel Generator Rooms would be significant and would melt the fusible link near the ceiling rapidly, achieving prompt closure.
In the event of a fire outside tile Diesel Generator Rooms, the Diesel Generator is not needed to achieve Safe Shutdown for a fire in the Turbine Building in the vicinity of the Diesel Generator Room (i. e., the Unit X Diesel Generator is not needed to safely shut down the plant in the event of a Fire in the Unit X Turbine Building near the Unit X Diesel Generator Room). If fire spread to the Diesel Generator, it would not jeopardize safe shutdown of the plant, therefore the lack of a fusible link near the ceiling on the Turbine Building side of the Diesel Generator Room wall is acceptable (NTSC).
TABIE A NFPA 90A Deviatiori Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation Code Deviation Justification Recommended Action No.
Section
_II 90A-0I Not provided.
There are currently no fire dampers installed in As a part of Modification Number M12-2/3 DD.
Control Room HVAC ducts (Ref. 4.39, pg 6, para 05E, 3-hour rated fire dampers were installed in
- 2.
the Control Room HVAC dampers (Ref. 4.4. Pgs.
I & 2). These dampers were procured in accordance with Specification T-3395, "Fire Dampers" issued by Sargent & Lundy for use on February 23. 1989. This specification calls for the procurement and installation of four Type C, 3-hour rated, UL listed dampers, Equipment Numbers 213-9472-163, 2/3-9472-164, 2/3-9472 165 and 3/2-9472-166 (Ref. 4.5, Section 302. 1, page 3-1).
Sheet 3 of 6 of RSM D82617-1. Doc. 4 of the M 12-2/3-87-05E modification package (Ref. 4.4) indicates that the QA inspection verifies that these fire dampers were installed by a Receipt Inspection on 12/23/91, 12/24/91 and 1/21/92 by
"'RJS" who signed as "Foreman". "VRP" verified their receipt as a representative of the QC /QA department on 6/8/92.
Drawing M-3563 (Ref. 4.6) indicates that these dampers are installed in the ductwork that passes through the control room walls. Note 10 of that drawing indicates that these dampers were furnished under specification T-3395.
90A-02 Not provided.
The Dresden Station currently does not have a DFPS 4175-9, Rev. 0 addresses this issue except None.
procedure for the routine maintenance, inspect, for operability testing. Operability checks are and/or testing of installed fire dampers (Ref. 4.39, performed at the time of installation per the pg 11. para 3).
manufacturers' instructions (Ref. 4,15. pg 1.1-48, IItem 5 1) 00 00 Unit 2/3 Dresden Nuclear Station NFPA Code Matrices
0 TABLE. A NFPA 90A Deviation Close Out Matrix NTSC Report No.93-124, Rev. 1 December 17. 1999 Deviation Code Deviation Justification Recommended Action No.
Section 1
90A-03 Not provided.
Smoke detectors which are installed in the The smoke detectors installed in the ductwork arc Institute a procedure to ductwork arc not being routinely tested to ensure now being tested annually in accordance with the clean and maintain the their operability or periodically cleaned and manufacturer's recommendations to ensure their sampling tubes in the properly calibrated in accordance with the operability via Procedure 4183-14, Rev. 02, ductwork in accordance recommendations of the manufacturer (Ref. 4.39, effective march 19. 1999 (Ref. 4.7). These tests with the manufacturer's pg 11, para 4).
include testing the smoke detector via the instructions. Action sampling tube using the test port provided, Request Number 19427, however, the procedure does not address the Task 05 has been issued cleaning and maintenance of the sampling tubes.
to address this condition.
90A-04 Not provided.
Fire damper 2/3-9472-009 consists of two 1-1/2 Mod M 12-2(3)-84-1 10 addresses this issue (Ref.
DD hour fire dampers in series and is located in tile 4.15, pg 1.1-49, Item 5.4).
supply air duct for the Auxiliary Electric Equipment Room. The bottom fire damper is installed upside down so that the damper release latches are not accessible from the bottom. If the damper is actuated, it cannot be reset (Ref. 4.31),
pg II, para 4).
90A-05 Not provided.
Fire damper 2/3-9482-142 consists of two 1-1/2 Mod M12-2(3)-84-1 10 addresses this issue (Ref.
DD hours Fire dampers in parallel and is located in the 4.15, pg 1. 1-49, Item 5.5).
supply air duct for the Prime Computer Room.
Both dampers are installed in the vertical position with the head section of the damper at the bottom.
Release latches are installed such that the damper can only be reset from inside the Computer Room under the floor. Both dampers have labels on the frame stating "For Horizontal Installation Only" (Ref. 4.39, pg 11, para 5).
90A-06 Not provided.
Fire damper 2/3-9482-141 is located in return air Mod M 12-2(3)-84-110 addresses this issue (Ref.
None.
duct and mounted in the Prime Computer Room 4.15, pg 1. 1-49, Item 5.6).
wall. The damper is installed such that the release latches will not be accessible to reset the damper should the damper be actuated, There is currently no access door to the opposite side of the damper (Ref. 4.39, pg 12, para I).
00 00 Unit 2/3 Dresden Nnclear Station NFPA Code Matrices
I TABLE A NFPA 90A Deviation Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999
.,i 00 00 00 Deviation Code Deviation Justification Recommended Action No.
Section
_IIII 90A-07 Not provided.
Dampers 3-9472-023 and 3-9472-024 are Walkdowns and WRD63467 address this issue DD mounted in a wire mesh and pyrocrete wall which (Ref. 4.15, pg 1.1-49, Items 5.7 and 5.8).
separates the Unit 3 HPCI Room from the East LPCJ Corner Room. The ductwork has been removed from damper 3-9472-023 and an air line run through the damper into the HPCI Room.
Adjacent to the dampers were large holes through the pyrocrete wall. The wall does not appear to adequately support the damper assemblies (Ref.
4.39. pg 12, para 2).
90A-08 Not provided.
Fire damper 2/3-9482-138 located between the Training provided (Ref.4.15, pg 1. 1-49, Items DD Battery Room and the UPS Room in thle Control 5.9).
Building has an electrical cord passing through the opening. This cord was removed during the inspection (Ref. 4.39, pg 12, para 2).
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices
TABLE A NFPA 90A Deviation Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation Code Deviation Justification Recommended Action No.
Section
_I_
II 90A-09 Not provided.
Documentation concerning the flame spread In a memo from E. Skowron and T. Hausheer to DD rating of duct insulation, originally installed in R. Whalen and Brian Barth, dated April 7, 1988, the plant, was not available for review. No entitled "Response to PLC's NFPA 90A code conclusions can be reached regarding this Rec. 5. 10", Commonwealth Edison states that insulation without verifiable information (Ref.
Specification K-2230, dated 615/67 was reviewed 4.39, pg 12. para 3).
to determine the combustiblilty of the external duct insulation that was specified for construction in the plant. This memo is contained in the FPPDP, Volume 9, Tab 27 (Ref. 4.41). The memo states that the review was inconclusive as to whether or not the ductwork insulation satisfies the requirements ofNFPA 90A - 1976.
Commonwealth Edison then states that the contribution of external ductwork insulation to the total fire loadings was deemed to be "insignificant".
The Dresden Combustible Loading calculation (Ref. 4.8) includes fire loadings for external duct insulation based on 2,500 BTU/lb. These calculations demonstrate that the fire loading is within acceptable limits including the combustible loading of the external ductwork.
90A-10 Not provided.
Access doors of adequate size for visual Mod M12-2(3)-84-110 addresses this issue (Ref.
DD inspection and resetting of the following fire 4.15, pg 1.1-48, Item 5.3).
dampers arc not provided: 2-9472-012 Unit 2/3 Clean/Dirty Oil Room 2-9472-013 Unit 2/3 Clean Dirty Oil Room 2-9472-014 Unit 2 125V Battery Room 2-9472-053 Unit 2/3 Clean/Dirty Oil Room 2-9472-054 Unit 2/3 Clean/Dirty Oil Room OVW46Y Radwaste Building Stock Control Room (Ref. 4.39, pg 13, Sect.5.3).
00 600 110o Unit 2/3 Dresden Nuclear Station NFPA Code Matrices
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE A NFPA 92NM Deviation Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation Code Deviation Justification Recommended Action No.
Section 92-01 Not identified.
Floor drains for the Hotwell are plugged According to the plumbing plans, these drains are None.
according to the plans (Ref. 4.42, pg 7, note 2).
plugged. In this way, if a large accumulation of radioactive water were to occur, it would be held in the pit until disposal arrangements could be made. Containment of radioactive materials takes priority over fire protection water drainage (Ref. 4.42, pg 7).
92-02 Not identified.
Drains in the cable tunnel are not effective (Ref.
There appears to be no economically justifiable None.
4.42, pg 8, para 2).
method ofcorrecting this condition (Ref. 4.42, pg 8, para 2).
92-03 Not identified.
Floor drains at U-2 Trackway and U-3 Turbine The floor drains in the south end of the U2 None.
Oil reservoir are clogged (Ref. 4.42, pg 8, para 4 Trackway are required to be plugged as they and 5).
drain to the station storm sewers. WRD56408 opens the U3 Turb Oil Res drain. It was completed on 8/7/86 (Ref. 4.42, pg 1.1-51, Item 4.1.1).
92-04 Appendix A, Sprinkler protection not provided in a resin This lack of protection can be justified as no None.
Section G.2 storage area (Ref. 4.42, pg 9, para 2).
safety-related systems are directly exposed (Ref.
4.42, pg 9, para 2).
92-05 Appendix A.
Dresden's response to Appendix A contains one This error was corrected in Amendment 2 (2/86)
DD Section D.I.i error. Dresden states MG set areas have no of Appx A Comparison in the drains. Curbs and drains are provided (Ref. 4.42, UFHA.
pg 1, para 3).
92-06 Not identified.
No curbs have been installed in the U-2/3 DG cell Lack ofsuch curbing can be justified as the plant None.
to prevent water or oil fromn flowing into1 the can initiate safe shutdown vwith both the I IPCI HPCI stairwell ladder enclosure (Ref. 4.42, pg 9, pumps and the U-2/3 diesel generator out of the para 6).
service (Ref. 4.42, pg 9, para 6).
92-07 Not identified.
Inadcquate drainage is provided for the diesel fuel Mod M 12-2/3-84-7 addresses this issue (Ref.
None.
tank ini the Unit 2/3 Cribhousc (Ref. 4.42. pg 10, 4.15, pg 1.1-51. Item 4.3).
pa:ra 2).
00
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE A NFPA 92M Deviation Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999 D-vieDeviation Justification Recommended Action No.
Section 92-10 Not identified.
It could not be determined ifdrains in the HCPI rooms go to thc room sump or to Radwaste (Ref.
4.42, pg 8, para 6).
Mod M12-2/3-84-81 addresses this issue (Ref.
4.15, pg 1. 1-5 1, item 4.2).
I I..INOIW.
This room is located in the Unit 2 Turbine In the CRD area there is an enclosed watertight room containing a CCSW pump required for safe shutdown in the event of a flood. No drains are provided from these rooms (Ref. 4.42, pg 7, note 3).
Drains for the Turbine Building Turbine Bearing Lift pumps could not be located due to equipment storage on the floor in the SE area, and due to a dress-out area established in the NW area, with Thjis room is located in thle Unit 2 Turbine Building at the 495' elevation. It is in Fire Zone 8.2.2.A. It is protected by a -et pipe automatic sprinkler system. The Fire Suppression Effects Analysis documented on Page 4.8-6 of Reference 4.43 gives justification for the drainage in this area.
This area is located on the Unit 2 Turbine Building, Fire Zone 8.2.8.A. The Turbine Bearing Lift Pumps are protected by an automatic sprinkler system.
paper taped to the noor. In these areas, unprotected floor penetrations exist and water The Fire Suppression Effects Analysis could easily travel to the floor below (Ref. 4.42, documented on Page 4.11-6 of Reference 4.43 pg 7, note 4).
gives justification for the drainage of fire protection water runoff in this area. In addition, there is a large floor hatch covered by grated metal floor nearby this area. This would further assist in drainage of fire protection water runoff.
None.
Page 2 of 2 92-OS 92-09 Not identified.
Not identified.
00 None.
I NI-P I
None.I*'
28-92 I
tlVIVILýINj-jivlj-ANI I-)
Y E u
ci
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices 00 TABLE A NFPA 196 Deviation Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices 00 TABLE A NFPA 197 Deviation Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999
Unit 2/3 Dresden Nuclear Station I I, A LOLI I.,i.
m rip TABLE A NFPA 232 Deviation Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999 NOTE:
- see Deviation 232-14 Itj 00 oo0 U.,ll 4FP IA CodeMtriesIlllIL.
Deviation Code Deviation Justification Recommended Action No.
Section 232-01 Section 5-3 and Central File Room: Use of enclosed cabinets for This room is no longer used for records storage.
DD.
Paragraph 3-1.5, vital records instead of rated record protection NFPA 232 equi ment (RefA.46, p,4, ara I).*
232-02 Paragraph Central File Room: The file room HCB walls do This room is no longer used for records storage.
DD.
3-4.3, not extend above the noncombustible roof (Ref.
NFPA 232 4.46, t
a 4, ara 2).*
232-03 Section 3-8, Central File Room: Thie file room walls do not This room is no longer used for records storage.
DD Paragraph have approved file room doors and are pierced for 3-6.3.2, ventilation ducts (Ref. 4.46, pg 4, para 3).*
3-6.3.3, and 3 11.2, NFPA 232 232-04 Paragraph Central File Room: The roof of the file room is This room is no longer used for records storage.
DD.
3-7.1, not independent of the remaining roof area of the NFPA 232 old Administration Building (Ref. 4.46, pg 4, para 4).*
232-05 Paragraph Central File Room: The rile room electric lighting This room is no longer used for records storage.
DD.
3-10.3, units arc not vapor-proof or explosion resistant NFPA 2332 (Rer. 4.46, 4, ara 5).*
232-06 Paragraph Central File Room: The 2ile room contains This room is no longer used for records storage.
DD.
3-12.4, limited work stations arid access is not closely NFPA 232 controlled (Ref. 4.46, p, 4, para 6).*
232-07 Paragraph Central File Room: Smoking is not prohibited T'his room is no longer used for records storage.
DID 3-12.4, (Ref. 44.446, pg 4, para 7).*
_NFPA 232 ta c
Sm 232-08 Paragraph Records Vault: The walls of the vault are pierced This room is no longer used for records storage.
DID 2-7.5.5, for ventilation equipment (Ref. 4.46, pg 6. para NFPA 232 2)...
232-09 Paragraph Thie vault is not provided with listed vault doors This room is no longer used for records storage.
[DID 2-7.5.2 and 2-(Ref.I1 4.46, pg 6, para 3).
10.1, NFPA 232
Unit 2/3 Dresden Nuclear Station r.,.ICodeMitrirce TABLE A NFPA 232 Deviation Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999 r
NOTE:
- see Deviation 232-14 tk) 00
-'Devito Deviation Justifiention Recommended Action No.
i Section 232-10 Paragraph Records Vault: Vapor-proof or explosion-proof This room is no longer used for records storage.
DD.
2-11.3, lighting is not installed (Ref. 4.46. pg 6. para 4).
232-1I Paragraph Records Vault: Records are not fully enclosed in This room is no longer used for records storage.
DD.
2-12.1, noncombustible containers (Ref. 4.46, pg 6, para NFPA 232 5).
232-12 Paragraph Records Vault: The vault volume exceeds 5000 This room is no longer used for records storage.
DD.
2-4, fU3 (Ref. 4.46, pg 6, para 6).
NFPA 232 232-13 Paragraph Records Vault: The vault floor is surfaced with This room is no longer used for records storage.
DD.
2-6.1.
linoleum (Ref. 4.46. pg 6, para 7).
NFPA 232 232-14 N/A Decficiencies for the Camera Room and Storage This room is no longer used for records storage.
DD.
Room are referenced in the code compliance report as being similar to those listed for the Central File Room. These deficiencies are marked with an asterisks (*) above (Ref. 4.46, pg 7, ara 5).
232-15 Paragraph Walls in central file room, camera room, and This room is no longer used for records storage.
DD 3-4.3, records storage room are not fire rated (Ref. 4.46, 3-6.3.2.
pg 8, para 4 and 5).
3-6.3.3.
3-7.1, 3-11.2, and Section 3-8, NFPA 232 232-16 Paragraph Camera Roomn and Storage Room: Records in the This room is no longer used for records storage.
DD 3-12.1, Storage Room are not in noncombustible NFPA 232 containers (Ref. 4.46, pg 4, para I and pg 7 para 4).
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices K)o 00 TABLE A NFPA 251 Deviation Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999
TABLE A NFPA 255 Deviation Close Out Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation Code Deviation Justification Recommended Action No.
Section jI1I1I No deviations (Ref. 4.47).
00 003 Unit 2/3 Dresden Nuclear Station NFPA Code Matrices
Unit 2/3 Dresden Nucleiar Station NFPA Code Matrices 0-0 TABLE A NFPA 601 Deviation Close Out Matrix NTSC Report No.93-124, Rev. 1 December 17, 1999
Units 2/3 Dresden Nuclear Station NFPA Code Compliance Matrices NTSC Report 93-124, Rev. 1 12/17/99 28-100 TABLE B NFPA DEVIATION JUSTIFICATION MATRICES Table B contains the NFPA Code Justification Matrices.
Unlike the NFPA Code Close-out Matrix, which enumerates all deviations from NFPA Codes that have been identified, the Justification Matrix lists only those deviations, which have been closed out by a Technical Justification. The Technical Justification is shown in Table B for each item for which this is the method of closing out the deviation.
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices NTSC Report No.93-124, Rev. I December 17, 1999 TABLE B DRESDEN NUCLEAR STATION NPFA JUSTIFICATION MATRICES TABLE OF CONTENTS CODE NUMBER NFPA 4 NFPA 20 NFPA 72D NFPA 6 - (Deleted)*
NFPA 24 NFPA 72E NFPA 7 NFPA 26 NFPA 78 - (Deleted)*
NFPA 8 - (Deleted)*
NFPA 27 - (Deleted)*
NFPA 80 NFPA 10 NFPA 30 NFPA 90A NFPA 12 NFPA 50 - (Deleted)*
NFPA 92M NFPA 12A NFPA 50A NFPA 194- (Deleted)*
NrTPA 13 NFPA 50B NFPA 196- (Deleted)*
NFPA 13A NFPA 5IB NFPA 197 - (Deleted)*
NFPA 14 NFPA 69 NFPA 232 - (Deleted)*
NFPA 251 - (Deleted)*
NFPA 255 - (Deleted)*
TABLE B NFPA 4 Justification Matrix NTSC Report No.93-124, Rev. I December 17, 1999 pq,,* I of I Ii I',o)
Deviation Code Deviation Justification No.
Section 1
1 04-01 Not identified.
Combined fire drills with the local fire DAP 03-01, Rev. 4 identifies that the station fire marshal is responsible for department are not conducted annually (Ref.
making arrangements with the local fire department.
- 4. 10, pg 6, para I).
Procedure DFPP 4100-01 Section G. l.b(2) addresses offering annual training to the local fire department. Discussions with the Station Fire Marshal indicated that members of the Coal City Fire Protection District have not participated in fire drills at the station in the recent past. However. training sessions are conducted with the Coal City Fire Protection District. Dresden Station hosts the Shabbona Fire Clinics for all area fire departments. This was completed on 4/4/98 and was scheduled again for 4/10/99. GSEP Training is given to Coal City Fire Protection District annually and they are invited to participate in Station drills annually. Although an opportunity for improvement exists if the Coal City Fire Protection District participates in fire drills or other exercises held at the Station, the Station has no control over the local fire department. The issue was discussed and recognized by Assistant Fire Marshal. Under the circumstances, the relationship between the two parties is ACCEPTABLE (Ref. 4.1, Section 2.7, page 25).
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE B NFPA 7 JustificaItion Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Page I of I 00 uO
TABLE B NFPA 10 Justification Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation Code Deviation Justification No.
Section I
I I
10-01 Paragraph 1-4,
...more prominent markings would be helpful on Adequate markings are provided.
NFPA 10 extinguishers (Rcf. 4.10, pg 3, para 3).
DFPS 4114-04, Rev.0 verifies that proper labels are on extinguishers on an annual basis as opposed to monthly.
Annual surveillance is considered adequate based on the following:
- a. Station personnel are periodically trained to operate plant fire extinguishers.
- b. Access to the plant is controlled through nuclear security procedures.
- c. Instructions for proper operation of the extinguishers are affixed permanently to the extinguisher. (Ref. 4.15, pg 1. 1-6. Item 4.1).
10-03 Section 3-3, Travel distance for Class B extinguishers is The increased travel distances are justified based on major hazards being NFPA 10 exceeded (Ref. 4.10, pg 4 and 5).
protected by automatic and manual suppression and detection systems monitored by a proprietary fire alarm system and ignition sources arc controlled. (Ref4. I0., pg 4 and pg 5).
10-02 Section 3-2, Extinguishers for Class hazards are not The quantity of Class A combustibles is limited primarily to cable insulation NFPA t0 distributed per NFPA I U(Ref. 4.1(0, pg 3 para 5 and well distributed hose stations arc provided for a trained, on-site fire and pg 4 para I).
brigade, (Ref. 4. 10, pg 3, Para 5 and pg 4 Para I).
10-04 Section 3-6, Travel distance for Class C extinguishers is Electrically safe nozzles are provided on all hoses except the refuel floor (Ref.
NFPA 10 exceeded (Ref. 4.10, pg 4 and 5).
4.10, pg 4 and 5: Ref.2, pg 1. 1-6, 4.2) (See footnote I ) and oii the hard rubber hoses provided to cover the Control Room.
Fire Brigade members are trained in the risks involved in using non-electrically rated fire nozzles in the Initial Fire Brigade Training Program, Module FBP 07, "Hose and Fire Streams", Section F. "Handling Fire Streams" (Ref. 4.16).
Fire Brigade members also receive biennial requalification training in this subject.
The Dresden Nuclear Power Station Units 2 & 3 Fire Pre-Plans document the locations of these nozzles and identify risks involved in using these nozzles on the Fire Pre-Plans (Ref. 4.17).
o n To minimize the potential of applying water to the new fuel in the new fuel storage pit, straight stream nozzles are used on the refiicl floor (NTSC).
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices Footnote:
. -11
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE B NFPA 12 Justification Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation Code Deviation J ustification No.
Section I
12-01 Not provided.
The roll up fire door at the large louvered opening The louvered doors can maintain an adequate C02 concentration without the in each room is currently arranged to close only fire door closing (Rcf. 4.19 and Ref. 4, Section 3.2.1.3) on operation of the fusible link (Ref. 4. 1S, Sect.
4.2 and 6.3).
12-02 Not provided.
The fire doors at louvered openings into the The louvered doors can maintain an adequate C02 concentration without the emcrgency DG rooms do not close automauially fire door closing (Ref. 4.15 and Rer. 4.1. Section 3.2.1.3).
upon actuation of the C02 system (Rcf. 4.1 S,pg 3, sect.2.2) 12S-02 1712 and 1714, Simulated tests of the system components.
Dresden exceeds these requirements by performing semi-annual maintenance NFPA 12 including a "Puff test" are to be carried out every testing of the C02 systems. The procedure for these tests is listed in DFPP 18 months according to Dresden Tech Spec Item 4145-I (Ref. 4.20, Sect.3.l).
4.1 2.D.3. NFPA 12 has no periodic actuation test requirement, altlhough periodic (at least annual) inspections arc recommended (Paragraph 1714) and discharge tests made when advisable (Paragraph 1712) (Ref. 3, Sect 3.1, para I and pg 4 Subpart 1).
0-o 0o
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE B NFPA 12A Justification Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation I
Code Deviation Justification No.j Section 12AS-01 Par. 1553, Paragraph 1553 of NFPA 12A requires a The Station did not commit to NFPA 12A maintenance requirements. As a NFPA 12A hydrostatic test of charged cylinders at least every result, this activity is not required (Ref'. 4. 1).
12 years. No procedure could be located which indicates these hydrostatic tests are being carricd out (Ref. 4.18, Sect. 3.2, para I and pg 5 Subpart 2).
tI
?o
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE B NFPA 13 Justification Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation Justification No.
Section 13-02 Not provided Documentation has not been located to verify that Due to the arrangement of the distribution system and tile use of strainers tile the distribution piping has been flushed (or at a intent of the code is met (Ref. 4.18, Sect 6. 1. Pgs I I and 12).
specific flow ratc)prior to connection to the numerous sprinkler and water spray systems (Ref.
4.1S, pg 11, Sect.6.1).
13-04 Not provided Contractor's test certificates are available and All systems were installed by Grinnell whose standard practice is to perform have been reviewed for 51 of the water hydrostatic testing. The systems have been in operation for fourteen years now suppression systems. However, no with no significant leaks or breaks (Ref. 4.18, Sect 6.6, Pg 15).
documentation has been located to verify such testing for the remaining 5 systems (Ref. 4.18, pg 15, Sect.6.6).
U3 Condensate Putmp Area: One sprinkler head located 10 feet north of the man-lift at (colunin 48.7) is currently obstructed by a steel beam (Ref.4. IS, pg 19, Sect.7.2.1 ).
+
1
U2 and U3 H-IPCI Pump Room: A deluge system is not installed for the U2 and U3 HPCI Pump Rooms (Ref. 4.18, pg 2 1, Sect.7.4.1 ).
U3 EHC Fluid Reservoir: The sprinklers located below the cable trays above the Unit 3 EHC fluid reservoir are not centered directly beneath the cable trays (Ref. 4.1 S, pg 25, Sect.7.7.1 ).
Tce obstruction is minor and due to other sprinklers installed, this is an acceptable configuration (Re['. 4. 18, Sect 7.2. 1, Pg 19).
Preaction systems were installed to reduce the potential of inadvertant operation. This type of system provides an equivalent level of protection compared to a deluge system (Ref. 4.23, pg 21, Item 7.4.1 ).
However, the anticipated type of fire in this area is a rapidly developing oil type fire which will result in high temperatures at an early stage. Therefore, there is no need to relocate the head(s) to directly beneath the cable trays or to provide heat collectors. The sprinklers will actuate in a timely manner as installed and will protect the cable trays for an exposure fire below (Ref. 4.18, pg 25, Sect.7.7.1 ).
13-39 4-3 U2 Instr. Air Comp. (517-6): One sprinkler head
...this is acceptable in this case since the specific hazard for this head is an oil located over the air compressor at column line fire which will result in a rapidly developing fire which will provide sufficient 34D is located approximately 9 feet below the heat to operate the sprinkler even though not located within 12 inches of the ceiling (Ref. 4.18, pg 28, Sect 7. 10.1).
ceiling (Ref. 4.18, pg 28, Sect 7.10. 1).
Deviation Code 00 4-2.4.6 13-09 13-14 13-30 SER Section 5.1.S.6 Not provided I
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE B NFPA 13 Justification Matrix NTSC Report No.93-124, Rev. 1 December 17, 1999 Deviation Code Deviation J
tustification No.
Section 13-31 Not provided U3 EHC Fluid Reservoir: Tie northernmost head However, the anticipated type of fire in this area is a rapidly developing oil on the branch line located along tie cable trays type fire which will result in high temperatures at an early stage. Therefore, above the Unit 2 EHC fluid reservoir is not there is no need to relocate the head(s) to directly beneath the cable trays or to centered directly beneath the cable tray. This provide heat collectors. The sprinklers will actuate in a timely manner as sprinkler is located immediately southeast of installed and will protect the cable trays for an exposure fire below (Ref. 4.18, column line E44 (Ref. 4.18. pg 25, Sect.7.7.2).
pg 25, Sect.7.7.2).
13-41 4-3 13-45 4-4.11 and 4-4.13 13-50 Not provided U I Crib House: Several sprinklers within the area For this particular area, the sprinklers need not be relocated since the are located 14-1S inches below ceiling level anticipated hazard in the area is an oil fire which will be a rapidly developing instead of the maximum distance below ceiling of type fire with large amounts of heat and smoke. Relocation of the sprinklers in 12 inches allowcd by NFPA 13 (Ref. 4.18, pg 28 this area would not result in significant improvement in the protection for the and 20, Sect 7.1 I I 1).
area. Therefore, the existing location of the sprinklers is considered acceptable (Ref. 4.18, 28 and 29, Sect 7.11.1 ).
U2 Reactor Feed Pump Room: One sprinkler The original sprinkler design required this head to provide protection beneath head in the northwest corner of the room has been the wide ventilation duct in the area. This HVAC duct does not presently exist removed near column line 38 (Ref. 4.18, pg 3 1, and therefore, no sprinkler is needed at this time (Ref. 4.18, pg 31, Sect Sect 7.13.1).
7.13.1).
U3 Reactor Feed Pump Room: The lower level Due to the anticipated type of fire, this configuration is acceptable (Ref. 4.18, sprinkler head located just southwest of column pg 33, Sect 7.14.1).
G51 is not centered beneath the HVAC duct (Ref.
4.18, pg 33, Sect 7.14.1).
2T 17 Page 2 of 4 00 00
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE B NFPA 13 Justification Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation Code Deviation Justification No.
Section 13-57 4-1.1.1(3)
"U3 Reactor Feed Pump Room: Two sprinkler heads located below tile ventilation ducts at the north end ofcoluhmn line 53 were intended for installation directly beneath the ducts. Also, the northernmost sprinkler head below the HVAC duct along column line 52 was intended to be no more than 12 inches below the duct according to the sprinkler drawings. The first two heads are not installed beneath the duct and the third sprinkler is located IS inches below the duct" (Ref. 4.1 S. pg 33. Sect 7.14.2).
Two sprinkler heads located in the northwest corner of the room are spaced approximately 10 feet above floor level. This does not comply with the requirement of NFPA 13 to be located within 12 inches of the ceiling to achieve prompt actuation of the sprinkler heads (Ref. 4.1S. pg 34, Sect 7.14.7).
Turb Mezzanine N/S: One sprinkler head located in the northeast corner of the area near the stairway is obstructed by existing mechanical piping (Ref. 4.18, pg 36, Sect 7.15.1).
The location of all three of these heads are considered acceptable because an The location of all three of these heads are considered acceptable because an oil fire in this room would produce high temperatures very quickly. (Ref. 4.18, pg 33, Sect 7.14.2).
However, the expected oil fire for this area will produce high temperatures in a short period of time, thus providing prompt actuation of the sprinkler heads even though they are located an excessive distance from the ceiling. Therefore, the location of these two sprinkler heads can be considered acceptable for this area (Ref. 4.18, pg 34, Sect 7.14.7).
The affected head is located approximately 5 feet south of the stairs and six feet west of the wall. The obstruction of the stairs at six feet west of the wall.
The obstruction to the distribution pattern of the sprinkler system is minor and protection for the area would not be significantly improved by relocating the head. Therefore, no action is required for this item (Ref. 4.18, pg 36, Sect 7.15.1).
Page 3 of 4 I3-51 13-56 4-4.11 and 4-4.13 4-3 00 I
I I
I
- I I
I
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE B NFPA 13 Justification Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation iCode Deviation Justification No.
Section 13-65 4-1.1.1.(3)
U3 Cable Tunnel: Several locations exist where Relocation or addition of nozzles would not significantly improve the the installation of water spray nozzles does not performance of the system (Ref. 4.18, pg 39 and 40, Sect 7.17. 1) conform to specific provisions of NFPA 13 relative to the obstruction of the water distribution pattern from the nozzles (Rcf. 4.18, pg 39, Sect 7.17.1 )
13-6S 4-1.1.1(3)
Nozzles protecting other areas, excluding nozzles Due to the ceiling configuration and the type of fire anticipated, relocation of discussed in paragraph I of Section 7.17.3. are heads would not significantly improve the performance of tlle system (Ref.
located over 12 inches from the ceiling (Ref.
4.18, Sect 7.17.3, pg 41, para 2) 4.18, pg 41, Sect 7.17.3).
13-77 Not provided One sprinkler head located 9'-7" west of column The sprinkler head was apparently installed to provide protection beneath a 45 and approximately 9 feet south of column line large ventilation duct in the area. However. the sprinkler head is not located C is now located a considerable distance below beneath the duct. No relocation of the head is required since the HVAC duct is the ceiling and is exposed to water flow from less than 4 feet wide and relocation of the sprinkler would not significantly ceiling level sprinklers. This is a deviation from improve protection of the area (Ref. 4.18, pg 45, Sect 7.18.1).
the requirements of NFPA 13 (Ref. 4.18, pg 45, Sect 7.IS.l).
13-82 4-1.1.1(3)
U2, U3 and U 2/3: Emcr D.G. Day Tank RMS:
Obstructions do not have a significant impact on system performance. (Ref.
Sprinklers are obstructed (Rcf. 4.IS, pg 46, Sect 4.18, pg 46, Sect 7.19.1) 7.19.1).
4-3, NFPA 13 U2 and U3 MG Set Fluid Drivers: Many of the sprinklers located in this area are 19 inches below the ceiling which exceeds the requirements of NFPA 13 not to exceed 16 inches below ceiling level for areas withl this particular beam depth and spacing (Ref. 4.18, pg 48, Sect 7.23.1 ).
...the location of the sprinklers for this area are acceptable due to the anticipated oil fire which will produce high temperatures in a short period of time thus providing prompt actuation for the sprinklers in their existing locations (Ref. 4.18, pg 48, Sect 7.23. 1).
Page 4 of 4 00 Oo 13-86 I
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE B NFPA 13A Justification Matrix NTSC Report No.93-124, Rev. 1 December 17, 1999 Deviaition Code Deviation Justification No.
I Section_________________________
NFPA 13A requires weekly checks of control valve position, valve seal integrity, and control valve operability (1/4 turn). Dresden procedures indicate these tests are carried out monthly, but only on supervised valves (Ref. 4.20, pg 9, Sect 3.3, para 2, subpart 7 and pg 6 Table 3.3-1).
+
r N FPA 13A requires weekly checks of riser gage readings, as well as a 2-inch drain test at each riser. These requirements are not being implemented. However, NEPA 13JA requtres thcse tests at sprinklered properties norma~l ly served by city wvater connections. The test verifies that tilc City Supply is in service (Ref.
4.20. pg 9. Sect 3.3, para 2, subhpart 8 and pg 6 Table 3.3-I1).
This longer period is justi led due to administrative controls which keep a record of all valve closures (Ref. 4.20, pg 9, Sect 3.3, para 2, subpart 7).
Since the water supply at Dresden is totally under plant control, these tests are unnecessary (Ref. 4.20, pg 9, Sect 3.3, para 2, subpart 8).
Page I of I Not provided 13S-07 13S-08 00 Not provided
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE B NFPA 14 Justification Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation Code Deviation Justification No.
Section 14-02 219 In tile Turbine Building some standpipe sizes are A hydraulic analysis was performed on three hose stations to verify adequacy less than 2 inches (Rcf. 4.21, pg S, para 5).
of 1-1/2" supply pipe. The analysis indicates the required amount of water can bc delivered (Ref. 4.21, pg 8, para 5).
14-06 43 44; OSHA Sub part L 14-09 67 I
I Several plant areas shown in Table 3.1 cannot be reached with 100' of hose and 30' hose stream (Ref. 4.21, Pg. 9. 10, 11).
More than 100' of approved hose is at some hose stations (Ref. 4.21, pg II, para 7). Two 150 ft hard rubber hoses aie provided to protect the Contiol Room.
Labels indicating use and operati ng instructions are not provided oil hose racks (Ref 4.21, pg. II, page S).
Pressure reducing devices are iot provided for standpipes exceeding 100 psi (Ref. 4.21, pg 12, para 3).
Water flow switches are not provided on all standpipes (Rcf. 4.21. pg IS, para 5).
In specified areas, due to tile minimal amount of combustibles and other fire protection features provided, thle existing configuration is adequate (Ref. 4.21, pg., 10, 11).
Recommendation made For additional hose to select hose stations with less than 1.10 ft hose (Ref. 4.21, pg 17, Item 4.3). PIF DI998-05386 and NTS 237-251 90-3 125 addressed this issue (Ref. 4. 1, Section 3.3)
The additional hose length is required to provide adequate coverage for the control room (NTSC).
The fire hoses are for use by the fire brigade only. Signs have been provided ott each hose station identifying that only the fire brigade call use the hoses. All fire brigade member have been adequately trained to handle hoses. As a result.
operating instructions on the hose stations are unnecessary (NTSC).
CECo policy is not to use pressure reducing devices...(Ref. 4.15, pg 1.1-12, Item 4.4) Fire hoses are for the use of the fire brigade only. All brigade members have been adequately trained to handle hoses subject to high pressure.
(NTSC)
A primary function of a flow switch is to provide notification of unauthorized use. Since access to a nuclear power plant is controlled, unauthorized operation is not normally a concern. In addition, operation of a hose station should activate the fire pump running alarm (NTSC).
P.i.,, I nr I 322 14-03 14-05 00 k.)
42 14-07
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE B NFPA 15 Justification Matrix NTSC Report No.93-124, Rev. 1 December 17, 1999 Deviation Code Deviation Justifeltion No.
Section Hydraulic calculations are not provided for five systems.(Ref. 4.1 S. pg 7 and pg 12, Sect 6.2).
Contractor's test certificates are available and have been reviewed for 51 of the water suppression systems. However, no documentation has been located to verify such testing for the remaining 5 systems (Ref. 4.1 S. pg 15, Sect.6.6).
There is no weekly visual check of the deluge systems as required by Paragraph 6003 of NFPA 15-1973; however, Paragraph 6003 also states that the frequency of such inspections may be at "oother frequent regularly scheduled plant inspections" (Ref. 4.20, pg 10, Sect 3.4, para 3, subpart 1).
No procedures exit to check outdoor piping annually for proper drainage (Paragraph 6013) or to conduct an annual flushing of the underground lead-in connection (Paragraph 6019) (Ret. 4.2U, pg 10, Sect 3.4, para 3, subpart 2).
Hydraulic Calculations address this issue. TNe calculationss contain justifications to minor NFPA 15 deviations (Re['. 4.22).
All systems were installed by Grinnell whose standard practice is to perform hydrostatic testing. The systems have been in operation for fourteen years now with no significant leaks or breaks (Ref. 4.18, Sect 6.6, Pg 15).
Due to the high level of administrative controls at this plan, such an inspection to identify major deficiencies could be extended to a monthly basis and included in DFPP's 4114-2, 4114-3 and 4114-6, as applicable (Ref. 4.20, pg 10, Sect 3.4, para 3, subpart I).
Because strainers are provided and to ne cieancu annuilily, iw Becaulse strainers are provided and to be cleaneoa annually, tile: reqt remen*.-,
a flushing test of the underground lead-in connection is eliminated (Ref. 4.20, pg 10, Sect 3.4, para 3, subpart 2).
15-01 15-02 15S-01 15S-02 00 SER (3/87)
Section 4.3.1.2, NFPA 15 Section Not Provided (Rep.
I)
Not Provided 6003 6013 and 6019 I
I I
I I
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE B NFPA 20 Justification Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation Code Deviation Justification No.
Section 20-01 SER (3/S7)
During the fire pumps original acceptance test.
... even though the pump may not comply with the NFPA 20 performance Section 4.3.1.2 the Unit I fire pump Was unable to achieve requirements, its performance could be considered acceptable as long as it sufficient pressure at all points along the exceeds the requirements (flow and pressure) of all installed water suppression manufacturer's curve (Ref. 4.18, pg 3, Sect 2.2; systems (Ref. 4.18, pg 7 and pg 13, Sect 6.4.).
pg 7; and pg 13, Sect 6.4.).
Hydraulic calculations address this issue (Rcf. 4.22).
20-03 SER (3/87)
A curb is not provided at the north door to the There are two entrances to this room. A curb has been installed at the west Section 5.4.6 AEER (Ref. 4. 8, pg S, Sect 5.5).
door opening onto the Unit 2 Trackway area. A similar curb is provided approximately 10 feet from the north door in the vicinity of the Unit 2 480V switchgear area. Therefore, an additional curb at the north door to the room is unnecessary as the curb in the switchgear area should be sufficient to prevent any oil spill in this area from entering the room. The intent of this commitment is satisfied (Ref.4.18, pg 8, Sect 5.5).
20-04 Not provided Documentation for the original acceptance testing However, justification for this deviation can be provided based on the of the Unit 2/3 fire pump is not available for satisfactory performance of the annual pump test for the last two years. The review (Ref. 4.18. pg 13, Sect 6.4).
problems that existed during the original acceptance test have apparently been satisfactorily addressed (Ref. 4.18, pg 13, Sect 6.4).
20-08 (New 2/3 Fire Section 2-14.2.2 NFPA 20, Table 2-20 lists 12 1/2-inch hose This deviation is acceptable based on the station's ability to perform the Pump) valves needed to test a fire pump with 3,000 gprn capacity test using the Unit I test header and local fire hydrants. This method capacity rating. Dresden Station has a fire pump was proven during acceptance testing of the installation. The procedure for the test header with 8 1/2-inch hose valves. This 2/3 diesel fire pump annual capacity check has already been revised to direct constitutes a deviation from NFPA 20, 1993 performance of the test ttsing an arrangement of the test header and adjacent edition (Ref. 4.24).
fire hydrants.
Page I of 2
?0 4::-
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE B NFPA 20 Justification Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Page 2 of 2 t00 00 Deviation Code Deviation Justification No.
Section 1
1 20-09 (New 2/3 Fire Section S-2.3 Dresden Station has an unlisted coupling in licu of The coupling is identified as a Wood's Sure-Flex Coupling by the pump and Pump) a listed drive shaft for Unit 2/3 diesel driven fire diesel supplier. Based on torsional analysis conducted by the pump and diesel pump assembly. This constitutes a deviation from supplier, the Wood's Sure-Flex Coupling with a stiffness of 0.305 Dcg/l 00 LB NFPA 20. 1993 edition (Ref. 4.24, 4.25, 4.26).
FT will not present a torsional problem and is a suitable alternative to the flexible drive shaft originally specified for the Unit 2/3 Diesel Fire Pump.
20S-02 Not provided NFPA 20 requires maintenance to be performed This deviation is justified due to the limited use of these engines and on diesel engines at least annually, whereas operability tests of the fire pumps which ensure the engines are in proper DFPP"s 4124-3 and 4124-4 allow this condition (Ref. 4.20, pg 12, Sect 3.5, para 2. subpart 2).
maintenance to be conducted at IS month intervals (Ref. 4.20, pg 12, Sect 3.5, para 2, subpart 2 and pg 13 table 3.5-1).
V*
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE B NFPA 24 Justification Matrix NTSC Report No.93-124, Rev, I December 17, 1999 Deviation Code Deviation Justification No.
Section 1
24-01 2600 No fire department connection provided (Ref.
... due to the remote location, lack of nearby public water supply, redundancy of 4.27, pg 7, para 2).
fire pumps, and intake canal supplies through which water may be pumped from draft, omission of such a connection is justified (Ref. 4.27, pg 7, para 2).
24-02 3302 PIV's located closer than 40 feet from buildings Exiting PIV locations are justifiable (Ref. 4.27, pg 7, paras 3,4,5 and 6).
with exposed openings (Ref. 4.27, pg 7, paras 3,4,5 and 6).
24-03
...loss of this valve will not affect the water supply to the U-2/3 plan. as a NRC/CEC's Building (Ref. 4.27, pg 7, para 7 and pg 8, para sectional valve exists to cut off supply to this U-I area (Ref. 4.27, pg 7, para 7 letter 6/12/79 I ).
and pg 8, para I).
24-04 9301 and 3502 Underground piping run below buildings (Ref.
These installation are justifiable as a break in either line would not prevent 4.27. pg S., para 2).
water supplies from reaching the Turbine and Reactor Buildings (Ref. 4.27, pg 8, para 2).
24-05 NRC Staff Additional PIVs are required (Ref. 4.27, pg 8, Not requiring additional PIV's is justifiable as the existing sectional PlV's Position 8F.7 5-para 3).
could be used to remove this section of pipe from service without blocking 26-77 Dresden flow to any water suppression system in the U-2/3 Turbine and Reactor
Response
Buildings (Ref. 4.27, pg 8, para 3).
6-22-77 24-06 4101, NRC Staff Hydrants not provided with isolation valves (Ref.
Lack of valves are acceptable (Ref. 4.27, pg 9 para I).
Position PF.5, 4.27, pg 8, para 5).
PF.26 24-07 4201, Appendix Hydrant spacing exceeds requirements (Ref. 4.27, The existing installation is justified as sufficient hose is available to reach all A
pg 0 para 2).
buildings with no hose line exceeding 500 feet in length as required by Paragraph 4201) (Ref. 4.27, pg 9 para 2).
24-08 4204 Hydrant closer than 50 feet from buildings (Ref.
Existing hydrant s are acceptable (Ref. 4.27, pg 9 para 4 and 5; and pg 10 para 4.27, pg 9 para 3, 4, 5 and pg 10 para I, 2, and I, 2, and 3) 3).
4301 -4304 Lack of information on installation designs (Rcf.
4.27, pg 10 para 4).
As no serious problems have been encountered with the hydrants, the existing installation is considered adequate (Ref. 4.27, pg. 10, para 4).
.1 J _____________________________
00 24-09
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE B NFPA 24 Justification Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation Code Deviation Justification No.
Section 1
4305 Barricades protecting hydrants 2-7 not provided As noted previously in this report, these hydrants are generally located in U-I 24-10 (Ref. 4.27, pg 10 para 4).
areas and would not be needed for a fire in a U-2/3 area (Ref. 4.27, pg 10 para 4).
24-1I SER Item 3.1.23 Hydrant wrench obstructions on hydrants 1, 22, Rachet type wrenches available (Ref. 4.27, pg 10 para 6 and pg 11, para I).
23, 24 and 25 (Ref. 4.27, pg 10 para 6 and pg 11, para 1).
24-12 5101,5102, Hose not provided at hydrant 27 (Ref. 4.27, pg I I Hydrant No. 27 is essentially redundant to No. 2, therefore providing additional 5201, and 5202 para 2).
hose for this hydrant would not significantly improve fire protection (Ref. 4.27.
pg 1 I para 2).
24-15 5601. NRC Staff Hose houses and hose reel cabinets not properly
- 1.
Justification provided (Ref. 4.27, pg 12, para 3)
Position equipped (Ref. 4.27, pg 11 para 5; pg 12; and pg 13 paras 1,2 and 3).
- 2.
Stable hose will be made available if hose cabinets are damaged, suitable hose eqmt will be made available through the use of portable carts, or hoses from other nearby fire hydrants.... (Ref.4.19, pg 1.1 -14. Item 4.4.2).
- 3.
WRs D4538 1, D45740 and 46739 addresses this issue.
24-16 NRC Request Nozzle not designed to operate in modes Not replacing nozzles is justified as they are used only by properly trained fire requested (Ref. 4.27, pg 13 para 4).
brigade personnel (Ref. 4.27, pg 13 para 4).
24-I8 93-3 No covered pipe trench provided where piping is
...due to over 5-foot bury depth and infrequent use of these tracks, lack of such helowv railroad tracks (Ref. 4.27, pg 14 para I).
trenches is justified (Ref. 4.27, pg 14 para I).
24-19 9501 No documentation to verify existing pipe joints There is no evidence of excessive leakage in the underground piping. As a (Ref. 4.27, pg. 14, para 2 and 3).
result, the existing pipe joints are justified (Ref. 4.27, Pg. 14, Para 3).
Page 2 of"4 t00
?0
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE B NFPA 24 Justification Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation codeiation Justification No.
Section 1
24-20 Section 96 No documentation to verify anchoring of fire Lack of such documentation is justified as the piping has been in service in mains (Ref. 4.27, pg 14 para 4).
excess of 10 years with no serious problems reported (Ref. 4.27, pg 14, Para 4).
24.1-01 SER (3/87)
Distribution pipe is unlined (Ref. 4. 18, pg 3, Sect I lydraulic calculations address this issue (Ref. 4.22).
Section 4.3.1.2 2.2: and pg 14, Sect 6.5).
24.1-03 Not provided.
Contractor's test certificates are available and All systems were installed by Grinnell whose standard practice is to perform have been reviewed for 51 of the water hydrostatic testing. The systems have been in operation for fourteen years now suppression systems. However, no with no significant leaks or breaks (Ref. 4.27, Sect 6.6, Pg 15).
documentation has been located to verify such testing for the remaining 5 systems (Ref. 4.27, pg 15, Sect.6.6).
24S-01 3601 Deficiencies regarding verification of valve See NFPA 26 code review.
position are identical to those specified in Section 3.3 of this report, namely I) lack of specific acceptance criterias, and 2) the possibility of sealing a valve without physically verifying that it is open. This item is addressed in the Fire Suppression System Valve Supervision Survey (NFPA 26) by PLC (Ref.4. I(), pg 15, Sect.3.6, para 2, subpart 1; and pg 17 Table 3.6-1 ).
Page 3 of 4 00 00o
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE B NFPA 24 Justification Matrix NTSC Report No.93-124, Rev. 1 December 17, 1999 Page 4 of 4 0,0 0o Deviation Code Deviation Justification No.
Scction 24S-02 3601 NFPA 24 recommends weekly verification of However, justification exists for monthly inspections as unauthorized valve valve position, whereas DFPP 4114-6 requires closures are unlikely for these reasons: I) Access to areas where these valves monthly inspections (Ref. 4.19, pg 15, Sect.3.6, are located is restricted to CECo personnel, approved contractors, and escorted para 2. subpai t 2: and pg 17 Table 3.6-I ).
visitors, and 2) There is consistent attendance of the plant with on-site guard service to reduce the probability of valve tampering (Ref. 4.19, pg 15, Sect.3.6, para 2, subpart 2).
24S-03 None.
No permanent procedure was located to perform DFPS 4132-08, rev.0 addresses this issue.
a water flow test on the yard system in accordance with Dresden Tech. Spec. 4.12.B.l.e (Ref. 4.19, pg 15, Sect.3.6, para 2, subpart 3; and pg 17 Table 3.6-I ).
24S-04 4102 Performance of DFPP 4125-1 results in the DFPP 4125-I, Fire System Annual Flush, is performed in the Fall to flush the hydrants being operated yearly. However. NFPA hydrants and check for proper drainage. During the Spring, the Station will 24-1973, Paragraph 4102. recommends operation rely on leak detection systems to detect any underground leakage (Ref. 4.15, pg two times per year (Spring and Fall) (Ref. 4.19,
.1 -I1, Item 4.9).
pg 15, Sect.3.6, para 2, subpart 4; and pg 17 Table 3.6-I).
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE B NFPA 26 Justification Matrix NTSC Report No.93-124, Rev. I November 30, 1999 Deviation Code Deviation Justification No.
Section 26-02 Paragraph (1) Inspections not conducted weekly. (2)
(I) Justification exists for monthly inspections for the following reasons:
3-1, NFPA 26 Procedures do not identify need to reseal valves I) Access to valves is restricted.
(Ref. 4.19, pg 5, para 3).
- 2) 24 hr guard service reduces the probability of valve tampering.
(Ref. 4.19, pg 5, Para I, subpart 2).
(2)The station chooses to lock valves rather than seal them...(Ref.4.15, pg 1. 1 17, Item 4.1.2).
26-10 Tech. Spec.
Performing a water flow check in lieu of monthly Justification provided in the following letters: from D Roberts, T Hausheer. G 4.12.B.].a inspections for inaccessible valves.
Tietz to E Eenigenburg dtd 8/7/89 and Itr from D Roberts, T Hausheer, P Kuhel to E Eenigenburg dtd 3/27/89.
Procedure DFPS 4123-09 performs monthly flow tests on non accessible valves.
00
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE B NFPA 30 Justification Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation
[
Code Deviation Justification No.[
Section 30-01 Not identified.
Storage Warehouse: In this warehouse building
...it does not expose any safety related areas; therefore, no recommendations flammable and combustible liquids are kept in a have been made concerning this building (Ref. 4.30, pg 5. para 2 and 3).
separate cut-off room which meets most of the requirements of NFPA 30 (Ref. 4.30, pg 5, para 2 and 3).
30-05 Paragraph 5122, No procedure exists to monitor storage and use in Based on a review, a cabinet will not be provided (Ref. 4.15, pg 1. 1-22, Item NFPA 30 plant areas. Plant survey revealed storage in open 4.8) plant areas on the Turbine Operating Floor (Ref.
4.30, pg 9. para I and 2).
30-06 Paragraph 4313, Clean and Dirty Lube Oil Tank Room: Exhaust
...tthe existing installation can be justified as Class III liquids do not require NFPA 30 and air intakes not located within 12 inches of special ventilation (Ref. 4.30, pg 12, para 2).
floor (Ref. 4.30, pg 12, para 2).
30-0 7 Not identified.
Fire barrier deficiencies for the HPCI Puimp U2 HPCI door has been replaced (Ref. 4.15, pg 1.1-31, Item 4.1.2.)
Rooms and Clean and Dirty Lube Oil Tank Room (Ref. 4.30, pg 10, para 4; pg 11, para 4; and pg U2 DG Day Tank Rm Door (H50) and U3 DG Day Tank Rm Door (H132) are 12, para 2).
acceptable based on justifications for unlisted fire door frame and signs attached to the door (Ref. 4.2, Appendix D).
Section 52, NFPA 30 Fire resistive requirements unclear for several areas (Ref. 4.30, pg 13, para 2; pg 13, para 5; pg Based on active a of the liquid, the
- I117, para 2 and 5; and pg 18, para 3).
}
pg 13, para 5; pg nd passive protection provided, as well as tihe high flash point existing configuration is acceptable (Ref. 4.30, pg 13, para 2; 17, para 2 and 5; and pg 18, para 3).
00 30-OS
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE B NFPA 30 Justification Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation 1
Code Deviation Justification No.[
Section 30-10 Not idcntified.
U2 Oil Drum Storage Room: Nonstandard fire
...because of the fixed suppression system, ramped access and limited exposure door (Ref. 4.30, pg 15, dash I).
to important equipment, door replacement is not justified (Rer. 4.30, pg 15, dash I).
30-I I Not identified.
U2 Oil Drum Storage Room: Electrical Based on the fact that the quantity of Class I liquid is small and the quantity of equipment is not approved for Class I, Division 2 flammable liquids stored is close to that specified by NFPA 30 for unprotected operations (Ref. 4.30. pg 15, dash I: and pg 16, areas, this is acceptable (Ref. 4.30, pg 16, para 1).
para I).
30-12 Not identified.
U2 Oil Drum Storage Room: No ventilation
...this is justified as no dispensing operations take place within this room (Ref.
system provided (Ref. 4.30, pg 15, dash 3).
4.30, pg 15, dash 3).
30-13 Not identified.
U2 Oil Drum Storage Room: No bonding or
...this is justifiable as these liquids are not dispensed in this room (Ref. 4.30, grounding wires provided (Ref. 4.30, pg 15, dash pg 15, dash 4).
4).
30-14 Paragraph 4311, U2 Oil Drum Storage Room: Room size exceeds The excessive size ofthis room can be justified based on the room being of fire NFPA 30 500 ft2 limit (Ref. 4.30, pg 15, dash 5: and pg 16 resistive construction, sprinkler protection installed and that most of the liquid para 3).
in the room is Class III liquid (Ref. 4.30, pg 16 para 3) 30-17 Paragraph 2343, Heat-actuated shut-off valve not provided for the However, this position is overridden by concern for the possible spurious NrPA 30 DG Cell Day Tank Rooms (Ref. 4.30, pg 18 para operation of such a valve, as fuel for the DG unit could be cut off by such 5).
operation. It is desired that the DG units be able to operate even ifa fire occurs due to the overriding concern for safe shutdown (Ref. 4.30, pg 18 para 5).
30-18 Appendix A, Unprotected steel in the U2 day tank room (Ref.
The unprotected beam is in a room with sprinkler protection.... (Ref. 4.15, Section F-10 4.30, pg 19, dash 2).
pgl.1-2 1, Item 4.5).
00
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE B NFPA 30 Justification Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation Code Deviation Justification No.
Section 30-19 Not identiried.
Deficiencies in Day Tank Room wall penetration Each of the day tank rooms communicates only with its associated DG cell. As (Ref. 4.30, pg 19, dash I and 3).
these DG cells are cut off from remaining plant areas by 3-hour barriers, justification exists for not requiring the deficiencies in wall penetration to be corrected (Ref. 4.30, pg 19, dash I and 3).
30-20 Paragraphs 5130 No drainage from diked area in this UI
...this can be justified as the diked area will contain three times the tank and 5291, NFPA Cribhouse (Ref. 4.30, pg 20, para 3).
capacity (Ref. 4.30, pg 20, para 3).
30 30-21 Not identified.
U I and U2/3 Cribhouse: No fire resistive Not requiring an enclosure of suitable fire resistance can be justified due to the enclosure (Ref. 4.30, pg 20, para 3; and pg 21).
fixed fire suppression system provided (Ref. 4.30, pg 20, para 3; and pg 21 ).
30-22 Not identified.
U I and U2/3 Cribhliouse: Tank venting The present arrangement can be justified due to fire-resistive construction and arrangement is not standard as the ventilate the installed sprinkler protection (Ref. 4.30, pg 20, para 4; and pg 21 para 3).
should terminate outside (Ref. 4.30, pg 20, para 4; and pg 21 para 3).
30-23 Paragraph 2343, No automatic closing heat actuatcd valve
...this omission is justified due to the relatively small tank size, fixed NFPA 30 provided (Ref. 4.30, pg 20, para 5; and pg 21 suppression provided, and redundancy of fire pumps (Ref. 4.30, pg 20, para 5; para 4).
and pg 21 para 4).
?0 N.
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE B NFPA 50A Justification Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation Code Deviation Justification No.
Section 1
1 50-03 Paragraph 512.
Bulk Hydrogen Storage Systems: Hydrogen The current hydrogen storage system at tile site is a liquified hydrogen storage NFPA 50A systems not above ground (Ref. 4.31, pg 8. para system.
Tile older gaseous hydrogcn equipment is still on-site, but is not in 5).
service at this time.
NFPA 50A does not apply. NFPA 50B, which governs Liquified Hydrogen Systems, has no such requirement. In addition, since hydrogen supply piping is routed above ground before it enters the building, any leaks would not be carried into tile building, and the below ground piping installation could be justified, even for a gaseous hydrogen system (Ref. 4.31, pg 8, para 5).
50-05 Not identified.
Bulk Hydrogen Storage Systems: Electrical However, the existing installation can bcjustified as Class I, Group C equipment not listed Iro Class I, Group B equipment is installed, the outdoor installation should dissipate flammable operation (Ref. 4.3 1, pg 9, para 2).
mixtures quickly, and the tanks do not expose any areas necessary for safe shutdown (Ref. 4.31. pg 9, para 2).
00 tk)
-P
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE B NFPA SOB Justification Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation Code 7
Deviation Justification No.
Section T
50-07 NFPA 50B Bulk Hydrogen Storage System: Hydrogen Since the fuel oil tank on the west side is diked, this should not present a facility is not above ground level (Ref. 4.31, pg 9, problem (Ref. 4.31, pg 9, para 4).
para 4).
00
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE B NFPA51B Justification Matrix NTSC Report No.93-124, Rev. 1 December 17, 1999 Deviation Code Deviation Justification No.
Section 51-05 Not identified.
Procedure DMP 4100-1: Rcquirements not However, this omission can be justified as all walls in safety related areas arc specified for combustibles behind of masonry construction (Ref. 4.32, pg 5, dash 4).
noncomb bustible walls (Res. 4.32, pg 5, dash 4).
00 ON
Unit 2/3 Dresden Nuclear Station NFPA Code M.-atrices TABLE B NFPA69 Justification Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation eCode Dviation Justification No.
Section 50-09 Not identified.
Battery Room: No procedure for periodic air However, due to continuous air flow monitoring and the existence of sampling (Rcr. 4.31, pg 9, para 6).
calculations showing the time necessary to reach the lower explosive limit in the event of ventilation system failure, periodic air sampling is not necessary (Ref. 4.3 1. pg 9. para 6).
50-I 1 NRC Staff Exhaust ducts not routed outside (Ref. 4.3 1. pg Adequate dilution is provided where the exhaust discharges into the TB (Ref.
Position No. 14, 10, para I).
4.15, pg 1.1-24, Item 4.6).
March 10, 1977 00
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLFE B NFPA 72D Justification Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation Justification No.
S ection I1 I
Paragraphs 1112 and 1131 do not apply in this case. The Mux security panels are connected in a loop circuit to the CPU. The loop will still be operational under a single ground or open circuit.
However, the Signaling Line Circuits (SLC) from the Mux panel to the Fire Control Unit appears to not have this capability based on the information provided to date. The NRC has also imposed these conditions on circuits installed to actuate fire suppression systems. The actuating device circuits at Dresden (deluge valve solenoids) are supervised (Class B), but are not operable during a single ground or open circuit condition (Class A). Browns Ferry was required by the NRC to upgrade these circuits for Class A operation (Ref.
4.34, pg 12 and pg 46).
4 T
The water flow switch circuit arrangement shown on ASCO DRWG PE-497-2 is not capable of operating during a single ground fault or open circuit on the initiating device circuit. Paragraph 1323 is not applicable (Ref. 4.34. pg 12).
.1.
I All new equipment (XL3 System) is UL listed for their intended service; The NRC is the authority having jurisdiction.
They require that equipment be listed or labeled by a nationally recognized testing laboratory for the services for which it is used. The fire alarm system and fire control units are not listed for NFPA 72D service. The existing system is a customized assembly (Ref. 4.34, pg 13).
Dresden has not committed to or required by the NRC to provide Class A supervision. Style C circuits (Class B) are installed. Initiation of local alarm signals is not supervised; however, these circuits are not essential to the receipt of signals at the central station (Ref. 4.35, Sect 2 -7.1 and Table 3-9.1).
This circuit configuration is a Class B arrangement and is acceptable. A Class A circuit configuration would allow the circuit to continue to function under an open circuit or ground condition; however, Dresden has made no commitment to install Class A circuits. Ira open or ground occurs, a trouble signal will be received at the XL3 panel (NTSC).
All new equipment (XL3 System) is UL listed for their intended service; however, a few devices (e.g., door switches) wired to the addressable interface modules are not listed for fire service but are designed to produce a trouble signal upon failure. In addition, there are still sonic unlisted local control panels remaining. The functional importance of these panels is minimal. Ltr 2/13/86 (Ref. 4.35, Sect 2-2.2).
Deviation Code 1321 72D-01 72D-02 I'.
00 00 1322 72D-03 2022 I
1
-- 7
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE B NFPA 72D Justification Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation Code Deviation Justification No.
Section 72D-07 2441 Local fire alarm bells arc not supervised. A NFPA 72 D does not require local alarms; however, Dresden committed to single ground fault or open circuit would go providing local alanns in their response to the BTP 9.5-I, Appendix A, Sect undetected (eg. ASCO DRWG PE-497-4) (Ref.
E.l(b). (Appendix A recommended the use of local alarms). As a result, the 4.34, pg 15).
requirements ofNFPA 72A must be met. NFPA 72A requires indicating circuits to be supervised. The alarm system provides unsupervised local audibles via existing local control panels except in the areas protected by C02 and Halon. These areas have supervised indicating circuits. Unsupervised circuits decrease the reliability of the providing a local alarm. However, since a P.A. system is available and procedurally (XL3 DANS) set up to provide evacuation notification when a fire alarm is received in the control room, the existing level of alarm circuit reliability is adequate (Ref. 4.35, pg 19, Para 4 2.3).
72D-08 2521 Local alarm bells and trouble horns are listed by See Justifications for 72D-03.
U.L. However, it is uncertain that audible signals in the CSS and Control Room arc listed since the security systems is not listed. Insufficient information has been provided for this conclusion (Ref. 4.34, pg 16).
72D-09 2541 The fire alarm system is not intended for total Fire alarms arc received in the control room. The alarms indicate the location evacuation ofthe plant, only of the immediate fire of concern to the control room operators. The operators notify station area. A justification starting the plant's position personnel of the condition via the P.A. system and address the alarm condition should be documented (Ref. 4.34, pg 16).
accordingly with the assistance of written emergency response procedures XL3 DANS (NTSC).
3113 There is no manual fire alarm service as intended in this Section at Dresden Station.
Although the station does not comply with this item, however, PLC agrees that the extensive plant communication system provides an equivalent service since through administrative procedures, personnel are trained to use this system in case of fire (Ref. 4.34, pg 18).
See NFPA 72E Matrix.
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE B NFPA 72D Justification Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviatio n Code Deviation Justification
- t
- nrle.
NO.
I 72D-15 2-2.2 72D-16 2-7.1 72D-17 3-9.1 72D-18 3-9.1 72D-19 4-2.3 A few devices wired to the Pyrotronics addressable module interfaces (e.g., time delay relays for door switches on areas having gaseous suppression) are unlisted (Ref. 4.35, pg 6).
Detection loops, actuation circuits from SPX modules, indicating circuits from SPX modulesindicating circuits to the Control Room and the dry contact connections to the addressable interface (TRX-I) modules are supervised for opens and grounds. "Initiation of local alarm signals is not supervised (Ref. 4.35, pg 10).
Door switches and air flow monitors are combined systems (Ref. 4.35, pg 16 and IS).
A single detection loop may have more than one existing panel monitored via TRX modules (Ref.
4.35, pg 16 and IS).
The indication of location shall utilize indicating appliances acceptable to the AHJ. NRC requires local audible signals. System provides unsupervised local audible via existinig panels and bells (Ref. 4.35, pg 19).
These devices are designed to produce a trouble signal upon failure. The functional importance of existing unlisted equipment (most control panels) was minimized or eliminated. See letter dated 2/13/86 (Ref. 4.35, pg 6).
The local alarm signal circuits are not essential to the receipt of signals at the central station (Ref. 4.35, pg 10).
They are monitored via TRX modules so they cannot interfere (Ref. 4.35, pg 16 and 18).
Since each panel is monitored by a single addressable TRX module, this is acceptable (Ref. 4.35, pg 16 and IS).
The dispatching of roaming operators with hand-held radios and Fire brigade members to all alarms supplements and thus reduces the need for local audible alarms. Additionally, the P.A. system is available and procedurally set up to provide evacuation notification. Therefore, unsupervised local audible alarms without secondary power is acceptable. "It is desired to have local audible in Halon and C02 protected areas for personnel safety reasons. These meet the NFPA 72A (Ref. 4.35, pg 19).
00 0
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE B NFPA 72E Justification Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation eCode Dviation Justification No.
Section 72E-03 Not provided.
No Detection in the New Fuel Area (Ref. 4.34, pg Technical justification provided via two letters to the NRR dated 2/25/80 and 26, Sect 4.1.7).
12/5/85. See FPPDP (Ref. 4.9, pg 2, Item 4.1.7).
72E-06 Not provided.
The Cable Cone. Area (Mezzanine El. 538')
The fire detection system has been accepted by the NRC in this configuration detection system arrangement is not as specified to activate the preaction water spray system in the cable trays (Ref. 4.34, pg in NFPA 72E-1974. (Ref. 4.34, pg 31. Sect
- 31. Sect 4.2.4).
4.2.4).
72E-07 Not provided.
There is no fire detection in consoles and cabinets The existing configuration is acceptable based all but two of the consoles and in the operator's area in the Control Room (Ref.
cabinets are open or vented thus allowing smoke to de detected by the ceiling 4.34, pg 32 and 33, Sect 4.2.5).
system. Plant operators ar in attendance continuously and a fire in the enclosed cabinets would be quickly identified (Ref. 4.34, pg 32 and 33, Sect 4.2.5).
72E-10 Not provided.
I) The installation of the fire detectors in the Unit The existing detector installation will achieve its objective based oil the 2 DG Room does not comply with NFPA 72E-environmental variables (Ref. 4.34, pg 37 and 38).
1974. The three detectors are not mounted on the ceiling. They are mounted on the lower flanges of beams in the room. 2) The existing detectors are 225.F detectors listed by U.L. for 25 foot spacing on a smooth ceiling and 12.5 ft maximum spacing to a wall or partition. The existing detectors are installed too far from each wall for which they are listed (Ref. 4.34, pg 36, Sect 4.3.2).
00 m-.
-, - r t
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLF B NFPA 80 Justification Matrix NTSC Report No.93-124, Rev. 1 December 17, 1999 Code Deviation Justification 1.6.1 and 10.2.3 1
1-1.6.1 and 10.2.3
+
1 2-5.1 SO-05 2-5.4 2-8.2, 2-8.7 10.1.2 No U.L. label for the bullet proof Control Room doors (numbers 2S, 30, UI-36 and U t-39) (Ref.
4.2, pg 6. Sect 3.1.1).
No U.L. label for the Diesel Generator 2/3 Room Entrance Door (Number 137) (Ref. 4.2. pg 6, Sect 3.1.2).
Of the single and double swinging doors observed at Dresden, seven have listed door frames (Door number 8, 39, 80. S, 82, 83 and 168) with labels attached. The remaining frames appear to have been fabricated at the site (Ref.
4.2, pg 7, Sect 3.3).
Of the swinging doors observed, ten doors (Numbers 14, 50, 70, 76,82, 117, 129, 132, 140 and 168) were found to meet tile required maximum limits of Paragraph 2-5.4. The remaining swinging doors deviate from NFPA 80 (Ref. 4.2, pg 7, Sect 3.4).
Specific doors do not meet lock and latch requirements.
80-07 2.- 8 and '9. I
- o.
o alterations fall into the following principal categories: I) Damage 2) Repairs 3) Additional of extra hardware, signs, etc. 4) Deletion of extra hardware, etc., leaving small holes or voids in the door surface (Rcf. 4.2, pg 9, Sect 3.9).
Deviation 80-01 80-02 80-04 t'J 80-06 See Justification I of Appendix A of NFPA 80 Report, Rev.2 (Ref. 4.9).
See Justification 2 of Appendix A of NFPA 80 Report, Rev.2 (Ref. 4.9).
See Justification 3 of Appendix A of NFPA 80 Report, Rev.2 (Ref. 4.9).
See Justifications 4 and 5 of Appendix A of NFPA 80 Report, Rev.2 (Ref.
4.9).
See Justification 6 of Appendix A of NFPA 80 Report, Rev.2 (Ref. 4.9).
Doors 70 and 73 are not provided with strike plates. Since the door frame is a channel frame this condition is acceptable (NFPA 80-1983, paragraph 2-8.2.8, Exception).
See Justification 7 of Appendix A of NFPA 80 Report, Rev.2 (Ref. 4.9).
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE B NFPA 80 Justification Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation Code Deviation Justification No.
Section I
80-OS Chapter 4 Comparing tile requirements of Chapter 4 with See Justifications 8 through 14 of Appendix A of NFPA 80 Report, Rev.2 the actual door installations, the doors were (Ref. 4.9).
found to meet tile code except for the conditions discussed. These conditions arc also acceptable (Ref. 4.2, pg 9. Sect 3.10).
80-09 Chapter 6 Dresden has installed four roll-up steel fire doors See Justifications 15 and 16 of Appendix A of NFPA 80 Report, Rev.2 (Ref.
(Numbers 17A, 57, 95A and 1005). In general.
4.9).
the doors appear to be in good condition:
however, they were not operating during tile survey. These doors were installed in accordance with NFPA 80, except for lack of fusible links for rolling doors (Ref. 4.2, pg 9, Sect 3.1 I).
80-10 Section Coordinating devices are not provided on doors The lack of this device is acceptable since the inactive leafof each door are 2-8.2, 20, 28, 30,U1-36 and U1-39 (Ref. 4.2, pg 8, normally closed and bolted (Ref. 4.2, pg 8, Sect 3.7).
NFPA 80 Sect 3.7).
80-I1 Not identified "Dresden Nuclear Station Units 2 and 3 See Technical Justification dated February 9, 1999 contained on Page 17.4-1 Commonwealth Edison Company Fire Protection of the FPPDP (Ref. 4.9).
Program Documentation Package, Volume 9, NFPA Code Conformance" 00o
Unit 2/3 Dresden Nuclear Station NT*PA Conde Mitrices TABLE B NFPA 80 Justification Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Devi7tion Code Deviation Justification No.
I Section There are no fusible links at the ceiling on the Turbine Building side of the fire wall to activate the door closing mechanism for Fire Doors 17A and 95A on the Unit 2 and Unit 3 Diesel Generator Rooms.
Fusible links ire installed near tile ceiling oil tile inside of tile Diesel Generator Rooms to provide automatic closing of the fire doors in accordance with NFPA 80, Section 6-5.1 in the event of a fire inside the Diesel Generator Rooms. The heat generated by an oil fire in one of the Diesel Generator Rooms would be significant and would melt the fusible link near the ceiling rapidly, achieving prompt closure.
In the event of a fire outside the Diesel Generator Rooms, the Diesel Generator is not needed to achieve Safe Shutdown for a fire in the Turbine Building in the vicinity of the Diesel Generator Room (i. e., the Unit X Diesel Generator is not needed to safely shut down the plant in the event of a fire in the Unit X Turbine Building near the Unit X Diesel Generator Room). If fire spread to the Diesel Generator, it would not jeopardize safe shutdown of the plant, therefore the lack of a fusible link near the ceiling on the Turbine Building side of the Diesel Generator Room wall is acceptable (NTSC).
SO-12 6-6.2 00 I
I I
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE B NFPA 90A Justification Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Pauc I of I Deviation SeCode Deviation
]
Justification No.
Section d
90A-02 Not provided.
The Dresden Station currently does not have a DFPS 4175-9, Rev. 0 addresses this issue except for operability testing.
procedure for the routine maintenance, inspect, Operability checks are performed at the time of installation per the and/or testing of installed fire dampers (Rer.
manufacturers' instructions (Ref. 4.15. pg 1. 1-48, Item 5. 1) 4.31). pg 1I, para 3).
9OA-06 Not provided.
Fire damper 2/3-9482-141 is located in return air Mod M 12-2(3)-84-110 addresses this issue (Ref. 4.15, pg t. 1 -49, Item 5.6).
duct and mounted in the Prime Computer Room wall. The damper is installed such that the release latches will not be accessible to reset the damper should the damper be actuated. There is currently no access door to the opposite side of the damper (Ref. 4.39, pg 12, para I).
00
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE B NFPA 92lVI Justification Matrix NTSC Report No.93-124, Rev. I December 17. 1999 Deviation Code Deviation J Justific ation No.
Section I
I ____
92-01 Not identified.
Floor drains for the Hotwell are plugged According to the plumbing plans, these drains are plugged. In this way, ir a according to the plans (Ref. 4.42, pg 7, note 2).
large accumulation of radioactive water were to occur, it would be held in the pit until disposal arrangements could be made. Containment of radioactive materials takes priority over fire protection water drainage (Ref. 4.42, pg 7).
92-02 Not identified.
Drains in the cable tunnel are not effective (Ref.
There appears to be no economically justifiable tiethod of correcting this 4.42, pg 8. para 2).
condition (Ref. 4.42. pg 8, para 2).
92-03 Not identified.
Floor drains at U-2 Trackway and U-3 Turbine The floor drains in the south end of the U2 Trackway are required to be Oil reservoir are clogged (Ref. 4.42, pg 8, para 4 plugged as they drain to the station storm sewers. WRD56408 opens the U3 and 5).
Turb Oil Res drain. It was completed on 8/7/86 (Ref. 4.42, pg 1.1-51. Item 4.1.1).
92-04 Appendix A.
Sprinkler protection not provided in a resin This lack of protection can bejustified as no safety-related systems arc directly Section G.2 storage area (Ref,. 4.42, pg 9, para 2).
exposed (Ref. 4.42, pg 9, para 2).
92-06 Not identified.
No curbs have been installed in the U-2/3 DG cell Lack ofsuch curbing can be justified as the plant can initiate safe shutdown to prevent water or oil from flowing into the with both the HPCI pumps and the U-2/3 diesel generator out of the service HPCI stairwell ladder enclosutre (Ref. 4.42, pg 9, (Ref. 4.42, pg 9. para 6).
para 6).
92-07 Not identified.
Inadequate drainage is provided for the diesel fuel Mod M12-2/3-84-7 addresses this issue (Ref. 4.15, pg 1.1-51, Item 4.3).
tank in the Unit 2/3 Cribhouse (Ref. 4.42, pg 10, para 2).
92-08 Not identified.
It could not he determined ifdrains in the HCPI Mod M 12-2/3-84-81 addresses this issue (Ref. 4.15, pg 1.1-51, Item 4.2).
rooms go to the room sump or to Radwaste (Ref.
4.42. pg 8, para 6).
92-09 Not identified In the CRD area there is an enclosed watertight This room is located in the Unit 2 Turbine Building at the 495' elevation. It is room containing a CCSW pump required for safe in Fire Zone 8.2.2.A. It is protected by a wet pipe automatic sprinkler system.
shutdown in the event of a flood. No drains are The Fire Suppression Effects Analysis documented on Page 4.8-6 of Reference provided from these rooms (Ref. 4.42, pg 7, note 4.43 gives justification for the drainage in this area.
3).
P;1o I of ?
00 ON
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE B NFPA 92NI Justification Matrix NTSC Report No.93-124, Rev. I December 17, 1999 1'0 00 Page 2 of 2 Deviation 1
Code Dviation Justification
_I_
__ I.
I Iito No.
Section I
92-10 Not identified Drains for the Turbine Building Turbine Bearing This area is located on the Unit 2 Turbine Building, Fire Zone 8.2.8.A. The Lift pumps could not be located due to equipment Turbine Bearing Lift Pumps are protected by an automatic sprinkler system.
storage on the floor in the SE area, and due to a dress-out area established in theNW area, with The Fire Suppression Effects Analysis documented on Page 4.11-6 of paper taped to the floor. In these areas.
Reference 4.43 gives justification for the drainage of fire protection water unprotected floor penetrations exist and water runoff in this area. In addition, there is a large floor hatch covered by grated could easily travel to the floor below (Ref. 4.42, metal floor nearby this area. This would further assist in drainage.
pg 7, note 4).
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices TABLE B NFPA 601 Justification Matrix NTSC Report No.93-124, Rev. I December 17, 1999 Deviation Codc Deviation Justification No.
Section 601-01 Not identified.
Guards do not perform all duties specified by Where the activities listed in NFPA 601 are performed by others, no deficiency NFPA 601 (Ref. 4.48, pg 3, para 1).
in protection is found to exist (Ref. 4.48. pg 3, para I).
601-02 Not identificd.
Supervised tours of the premises ire not However, due to the large size of the guard force (with guards stationed in conducted (Ref. 4.48, pg 3, para 4).
various areas), electronic and television monitoring of the property parameter, card key entry systems, and 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> operation of the plant, there appears to be little need for supervised tours (Ref. 4.48, pg 3, para 4).
601-03 Section 58, The guard training procedure does not address The security force is not intended as the primary response force....(Ref. 4.15, NFPA 601 fire hazards in the various plant areas (Ref. 4.48, pg 1. 1-57, Item 4.1) pg 4, para I).
00 00
Units 2/3 Dresden Nuclear Station NFPA Code Compliance Matrices NTSC Report 93-124, Rev. 1 12/17/99 TABLE C NFPA CODES OF RECORD Table C lists the NFPA Codes of Record that have been adopted for use at Dresden Units 2 and 3.28-139
Unit 2/3 Dresden Nuclear Station NFPA Code Matrices NTSC Report No.93-124, Rev. 1 December 17, 1999 TABLE C DRESDEN NUCLEAR STATION NPFA CODES OF RECORD (See Note 1)
NFPA 4-1971 NFPA 4A-1969 NFPA 6-1974 NFPA 7-1974 NFPA 8-1974 NFPA 10-1975 NFPA 12-1973 NFPA 12A-1973 NFPA 13-1976 NFPA 13A-1976 NFPA 14-1974 NFPA 15-1973 NFPA 20-1976 NFPA 24-1973 NFPA 26-1976 NFPA 27-1975 NFPA 30-1973 NFPA 49-1975 NFPA 50A-1973 NFPA 51-1974 NFPA 51B-1971 NFPA 69-1973 NFPA 70-1975 NFPA 70-1975 NTPA 72D-1975 NFPA 72E-1974 NFPA 78-1975 NFPA 80-1975/1983 NFPA 90A-1976 NFPA 92M-1972 NFPA 194-1974 NFPA 196-1974 NFPA 197-1966 NFPA 232-1980 NFPA 251-1973 NFPA 255-1973 NFPA 601-1975 Note 1: The code edition year was obtained from the Dresden Station Fire Protection Program Documentation Package, Set 6, Microfiche.28-140
NTSC Report 93-124, Rev. 1 12/17/99 Units 2/3 Dresden Nuclear Station NFPA Code Compliance Matrices ATTACHMENT 1 Technical Justification for Deviation NFPA 72D-06.2 28-141
Technical Justification For Deviation NFPA 72D-06.2 Dresden Nuclear Power Station NTSC Analysis Number 99-4003.001 Revision No. 0 Date: December 17, 1999 Prepared by:
-P o sepwH. Talbert, PE Reviewed by:
David G. Mahoney I
Thomas J. Mc ormack, PE Nexus Technical Services Corporation 125 Fairfield Way, Suite 380 Bloomingdale, IL 60018 Phone: (630) 893-2277 Fax:
(630) 893-2401 Email: ntseng Onexus-tech.com 28-142 f
Approved by:
n"-
- tlnn 79Dl-06 2 NTSC Report 99-4003.001, Rev. 0 December 17, 1999 Table of Contents 1.0 Purpose 1
2.0 Scope 1
3.0 Licensing and Design Basis Commitments 1
4.0 References 5.0 Definitions 2
6.0 Evaluation Methodology and Results 2
6.1 Description 2
6.2 Assumptions 2
6.3 Safe Shutdown Equipment 2
6.4 Fire Protection Equipment 2
6.5 Analysis 2
6.6 Conclusions 6
6.7 Attachments 6
28-143 vo--
NTSC Report 99-4003.001, Rev. 0 Deviation 72D-06.2 December 17, 1999 1.0 PURPOSE Dresden Fire Detection and Alarm Survey (Ref. 4.6) raised the issue that the manual pull stations used to actuate fire suppression systems are not electrically supervised.
According to this report, the lack of electrical supervision is not in compliance with Section 2431 of NFPA 72D, 1975 edition.
This Technical Justification is performed to justify that it is not necessary to electrically supervise or to periodically test the electrical circuits serving manual pull stations that actuate fire suppression systems including deluge sprinkler systems, pre-action sprinkler systems, open head water spray systems, carbon dioxide extinguishing systems and Halon 1301 systems.
2.0 SCOPE This Technical Justification was been developed for the purpose of resolving NFPA Code Compliance Open Issue/Recommendation documented on page 15 of the Dresden Fire Detection and Alarm Survey (Ref. 4.6).
3.0 LICENSING AND DESIGN BASIS COMMITMENTS The following document(s) list commitments made related to this evaluation:
3.1 Dresden 2 & 3 Updated Fire Hazard Analysis Report, Amendment 12
4.0 REFERENCES
4.1 NFPA 72D, Proprietary Protective Signaling Systems, 1975 edition 4.2 NFPA 12, Carbon Dioxide Extinguishing Systems, 1975 edition 4.3 NFPA 12A, Halogenated Fire Extinguishing Agent System, 1975 edition 4.4 NFPA 13, Standard for the Installation of Sprinkler Systems, 1976 edition 4.5 NFPA 15, Water Spray Fixed Systems for Fire Protection, 1973 edition 4.6 Fire Detection and Alarm survey in Nuclear Safety Related Areas at Units 2 & 3 Dresden Nuclear Power Station, Commonwealth Edison Company, Rev. 1, dated November 11, 1984 Page 1 of 6 28-144
NTSC Report 99-4003.001, Rev. 0 Deviation 72D-06.2 December 17, 1999 5.0 DEFINITIONS None 6.0 EVALUATION METHODOLOGY AND RESULTS 6.1 Description This Technical Justification demonstrates that applicable NFPA codes and standards do not require manual pull stations which are used for the purposes of actuating fire suppression systems to be electrically supervised or periodically tested. Consequently, the manual pull stations used for the purpose of actuating fire suppression systems at Dresden Units 2 & 3 are currently in compliance with the appropriate NFPA Codes of Record and Standards.
6.2 Assumptions None 6.3 Safe Shutdown Equipment The safe shutdown equipment protected by systems that utilize manual actuation of fire suppression systems is documented in the Fire Hazards Analysis, Amendment 12.
6.4 Fire Protection Equipment The locations of the systems that utilize manual actuation of fire suppression systems are documented in the Fire Hazards Analysis, Amendment 12. This analysis deals with a generic, plant-wide issue.
6.5 Analysis The Dresden 2 & 3 Updated Fire Hazards Analysis (UFHA), Amendment 12, Section 2.1.3 indicates that National Fire Protection (NFPA) Codes were used as guidelines in the design of fire protection features. It also states that technical justifications for deviations from significant provisions of the applicable codes have been developed and are available in the NFPA Code Review (see FPPDP, Volume 9). Section 2.4.2 further clarifies the station's intent by stating "The fire alarm and detection systems, where provided, are designed and installed tinder the general guidance of NFPA 72D. However, certain specific problem areas encountered in nuclear power plants were not always addressed in Page 2 of 6 28-145
NTSC Report 99-4003.001, Rev. 0 Deviation 72D-06.2 December 17, 1999 NFPA codes. Where such situations occurred, deviations from code provisions were necessary. In all cases, the intent of the NFPA codes were followed (modified, as required, by sound engineering judgment) with major deviations justified and documented in the NFPA Code Review (see FPPDP)" and "All alarm circuits are either electrically supervised or are tested to assure operability."
UFHA Sections 2.4.3.1, 2.4.3.2, and 2.4.3.3 indicate that the appropriate NFPA Codes and Standards are also used as guidelines in the design and installation of water suppression systems, Halon suppression systems and carbon dioxide suppression systems, respectively. These sections also state that where code deviations are required or desirable, they are made under the intent of the code using sound engineering principles.
UFHA Sections 5.4.D.1 (h), 5.4.D.2 (a), 5.4.D.4 (d), 5.5.E.3 (c), 5.5.E.4, 5.5.E.5, 5.6.F.3 (a) (1), 5.6.F.3 (b), 5.6.F.9, and 5.6.F.9 (b) contain commitments to utilize fixed fire suppression systems, some of which are equipped with manual pull stations used to actuate the fire suppression system. UFHA Section 5.5.E.1 (a) states that fire detection systems should as a minimum comply with NFPA 72D and that deviations from the requirements of NFPA 72D should be identified and justified. In its response, Dresden Nuclear Power Station indicated that "Fire detection systems have been reviewed against the criteria of NFPA 72D."
Dresden Fire Detection and Alarm (Ref. 4.6) Section 2431 states that the manual pull stations that actuate certain fixed fire suppression systems are not in compliance with Code Section 2431 of NFPA 72D (Ref. 4.1).
The analyses below evaluate the requirements of each of the NFPA Codes of Record that apply to this situation.
- a.
NFPA 72D, Proprietay Protective Signaling Systems, 1975 edition Section 2431 is a part of Article 240, Electrical Supervision. Section 2431 states, in part, "The electrical supervision shall also include all circuits for signals initiated by the operation of fire alarm boxes, fire detectors, automatically operated transmitters, or other appliances or devices which initiate or transmit signals..."(underlining added by NTSC). As per Article 100, these types of signals are "alarm signals" whose purpose is to provide an indication that there is an emergency requiring immediate action. This is consistent with the Fire Hazards Analysis, Amendment 12, Section 2.4.2 which states that all "alarm circuits" are either electrically supervised or tested to assure operability.
The manual pull stations in question do not transmit "alarm signals". They are not Page 3 of 6 28-146
NTSC Report 99-4003.001, Rev. 0 Deviation 72D-06.2 December 17, 1999 intended to act as a fire alarm box per NFPA 72D, Article 310; nor as a supplementary means for manually operating an automatic fire alarm system as per NFPA 72D, Article 330. The only function of the manual pull stations is to manually actuate the release of a fire suppression agent (water, carbon dioxide gas, or Halon 1301 gas). Each system that uses a manual pull station for this function, fire detectors are provided to initiate an "alarm signal". The alarm initiating circuits are electrically supervised. In addition, the transmitters (local control panels) which send a signal to the Pyrotronics XL3 alarm receiving panel are electrically supervised and the Signaling Line Circuit between the local control panels and the XL3 alarm-receiving panel are electrically supervised. This meets both the intent and the letter of the code.
Although the manual pull stations are not required to be electrically supervised according to NFPA 72D, the issue of whether or not these devices are required to be electrically supervised by other codes was investigated. These codes have been investigated and it has been determined that they do not require that these manual pull stations be electrically supervised. The codes that apply are summarized below.
- b.
NFPA 12, Carbon Dioxide Extinguishing Systems, 1975 edition NFPA 12 states, in Section 144:
"Supervision. Where supervision of any or all of the following - automatic detection system, the electrical actuation circuit, the electrical power supply - is provided, it shall be arranged to give immediate indication of failure". Section 144 does not require the pull stations to be supervised. The current arrangement of pull stations used to manually actuate carbon dioxide systems meets both the intent and the letter of the code.
- c.
NFPA 12A, Halogenated Fire Extinguishing Agent System, 1975 edition Section 1435 requires that all automatically operated valves controlling agent release and distribution be provided with approved independent means for emergency operation. The manual pull stations of concern have been provided for this purpose. Section 1440 states that supervision of automatic systems is advisable. It makes no mention of manual systems. The current arrangement of pull stations used to manually actuate Halon 1301 systems meets both the letter and the intent of NFPA 12A.
- d.
NFPA 13, Standard for the Installation of Sprinkler Systems, 1976 edition NFPA 13 states, in Section 5-3.2 Description, "Pre-action and deluge systems are normally without water in the system piping and the water supply is controlled by an automatic valve operated by means of fire detection devices and provided with manual means for operation which are independent of the sprinklers..
Page 4 of 6 28-147
NTSC Report 99-4003.00 1, Rev. 0 Deviation 72D-06.2 December 17, 1999 For pre-action systems, Section 5-3.5.2 Supervision, states "Sprinkler piping and fire detection devices shall be automatically supervised when there are more than 20 sprinklers on the system."
For deluge systems, Section 5-3.6 states "The fire detection devices or systems shall be automatically supervised when there are more that 20 sprinklers on the system."
The manual pull stations are not used to detect fire. They are used to manually actuate the system. Manual means of operation are not required to be electrically supervised by NFPA 13. The current arrangement meets both the intent and the letter of the code.
- e.
NFPA 15 Water Spray Fixed Systems for Fire Protection, 1973 edition NFPA 15 states, in Section 1020 Definitions, "A water spray system is a special fixed pipe system connected to a reliable source of fire protection water supply, and equipped with water spray nozzles for specific water discharge and distribution over the surface or area to be protected. The piping system is connected to the water supply through an automatically or manually actuated valve which initiates the flow of water..."
Section 2011, states, in part, "Systems shall be operable by automatic means with supplementary manual tripping means."
Section 2082 states "Manual devices may actuate the automatic control valves by mechanical, pneumatic, electrical, or other approved means... "
Section 4062 (b) under "Automatically Controlled Valves", states "Remote manual tripping devices, where required, shall be conspicuously located where readily accessible during the emergency and adequately identified as to the system controlled."
Chapter 8, Automatic Detection Equipment governs the arrangements of automatic detection equipment, including fire detectors. Section 8040 governs Arrangement &
Supervision of Systems. Section 8041. Supervision, states "Central station, remote station or proprietary supervision of detection equipment is recommended." The manual pull stations used for actuation of fire suppression systems are not included in this category because they are not "automatic detection equipment". Their purpose is to trip/actuate the control valve, not to detect a fire or send a fire alarm.
The current arrangement of manual pull stations used to actuate fixed water spray systems meets both the intent and the letter of the code.
Page 5 of 6 28-148 k ý.-
I-
ý I -
I -
NTSC Report 99-4003.001, Rev. 0 Deviation 72D-06.2 December 17, 1999 6.6 Conclusion Based on a review of NFPA 72D, NFPA 12, NFPA 12A, NFPA 13 and NFPA 15, the current arrangement of manual pull stations to actuate fire suppression systems at the Dresden Nuclear Power Station Units 2 and 3 meets all Codes of Record that apply to this situation. This is not a code deviation.
6.7 Attachments None Page 6 of 6 28-149
Units 2/3 Dresden Nuclear Station NFPA Code Compliance Matrices NTSC Report 93-124, Rev. 1 12/17/99 ATTACHMENT 2 Dresden Fire Door Items to be Resolved, Appendix G 28-150
NEXUS TECHNICAL SERVICES CORPORATION 125 Fairfield Way, Suite 380 Bloomingdale, IL 60108 December 17, 1999 Mr. Michael Dillon Fire Protection Systems Engineer Dresden Nuclear Power Station 6500 North Dresden Road Morris, IL 60450
Subject:
Dresden Fire Door Items to be Resolved NTSC Project 99-4003
Dear Mike:
On October 11, 12 and 27, 1999, Nexus Technical Services Corporation (NTSC) visited the site again to follow-up on the open items listed in Appendix G of the Dresden Fire Door Analysis. The results of our walkdown are summarized in the attached updated Appendix G. Many items were found to be resolved. The updated Appendix G lists the Action Request numbers that have been issued by Dresden Nuclear Power Station to correct the remaining open items. Upon completion of the Action Requests and the Action Tracking numbers that are contained in this update, all previously identified fire door issues pertaining to Units 2 and 3 will be completed.
The outstanding items are given in table form. Items labeled as "Priority" (P) must be completed in order for revision 2 of the Dresden Fire Door Analysis to be valid. Items labeled "Maintenance" (M) should also be resolved, but are not necessary to validate revision 2 of the Dresden Fire door Analysis.
The previous "Appendix G" should be removed from the Fire Protection Program Documentation Package, pages 17.1-112 through 17.1-125 and replaced with the attached "Appendix G Updated December 17, 1999" and labeled pages 17.1-112 through 17.1 127.
Please feel free to call me at (630) 893-2277, ext. 22 if you have any questions or if we can be of any assistance.
Sincerely, Nexus Technical Services Corporation Joseph H. Talbert, PE Principal Engineer Telephone: (630) 893-2277 - Fax: (61g *.f-2401 - e-mail: ntsceng@nexus-tech.com
Cc:
Thomas J. McCormack, NTSC Don Mershon, NTSC Mr. Al Casillo, Corn Ed Mr. Russell Peak, Corn Ed Mr. Pete Griffin, SWEC
Attachment:
Appendix G, Updated December 17, 1999 Telephone: (630) 893-2277 - Fax: (a.)1cZ3-2401 - e-mail." ntsceng@nexus-tech.com
I Appendix G Fire Door Items to be Resolved April 12, 1988 Updated December 17, 1999 Item Door Number/Location Priority Action Status Number (P or M) 1
- 8/U2 Oil Storage Room to DR 2 P a) Fill holes in door Door removed.
Transformer 12/Clean & Dirty Oil Storage Room North Door where kick plate was withi metal screws, rivets or bolts a) Install UL listed rear binders (latch plate assemblies) and front binder. See Drwg.
No. 1 at end of letter.
Completed.
Completed b) Provide new pin in Completed.
closing mechanism per manufacturer's instructions.
c) Install fusible link inside Clean & Dirty Oil Storage Room at ceiling.
d) Install weight box around fire door closing mechanism weight.
a) Attach front binder to horizontal surface.
b) Tighten stay roll.
a) Paint Door Red.
b) Provide a door number This issue was resolved by Technical Justification issued by Dresden on February 9, 1999. See FPPDP Page 17.4-1.
Completed.
Completed.
Completed.
Completed.
Completed.
00
2 Appendix G Fire Door Items to be Resolved April 12, 1988 Updated December 17, 1999 Item Door Number/Location Priority Action Status Number (P or M)
- 4) 17A/U2 Diesel Generator Room P
a) Rework caulking on Completed.
Louvered Door right hand side guide so expansion gap between the floor and guide is clear.
- 4)
P b) Interlock with Fusible links are installed near the detection system to close ceiling on the inside of the Diesel upon detection actuation.
Generator Room to provide automatic closing of the fire door in accordance with NFPA 80, Section 6-5.1 in the event of a fire inside the Diesel Generator Room. The purpose of an interlock with the detection system was to ensure prompt closure of the fire door. However, the heat generated by an oil fire in the Diesel Generator room would be significant and would melt the fusible link near the ceiling rapidly, achieving this prompt closure.
In the event of a fire outside the Diesel Generator Room, this Diesel Generator is not needed to achieve Safe Shutdown for a fire in the Turbine Building in the vicinity of the Diesel Generator Room.
If fire spread to the Diesel Generator, it would not jeopardize safe shutdown of the plant, therefore the lack of a fusible link near the ceiling on the Turbine Building side of the wall is acceptable.
00 A'
3 Appendix G Fire Door Items to be Resolved Item Number Door Number/Location April 12, 1988 Updated December 17, 1999 Status Priority Priority (P or M)
I 20/AEER to U2 Switchgear Area North Door IP P
a) Right hand guide is missing 3/8" threaded rod. Replace it.
a) Reduce gap at latch to 1/8" or less.
b) Provide PLC with the door closer model number or P.O. number it was purchased under to verify if it is UL listed for fire door use. (If not UL listed, closer will need to be replaced).
M I a) Provide door closer This door closer does not require a Completed.
Completed.
The door closer is UL listed according to Mr. Joe Gadbois of Yale Security (see letter from Joseph H. Talbert to Mr. Michael Dillon dated October 29, 1999). However, the door closer arms are not UL listed for use with fire doors. Action Request Number 990056420 has been issued to correct this item.
with cover.
- 6) 24/AEER to U2 Trackway P
I a) Reduce gap at latch to 28/Control Room North Wall NW Door.
30/Control Room West Wall to Trackway.
M P
P 1/8" or less.
a) Provide closer with cover.
a) Reduce gap at latch to 1/8" or less.
a) Door will not latch unless fully extended.
Repair so that it will close when only partially opened.
b) Reduce gap at latch to 1/8" or less.
- 5) 5)
4) 5)
cover. The cover is an integral part of the unit. Completed.
Completed.
Completed.
Completed.
Completed.
Completed.
?0 C,'
- 6)
- 7) 8)
8) 4)
M
A Appendix G April 12, 1988 Fire Door Items to be Resolved Updated December 17, 1999 Item Door Number/Location Priority Action Status Number (P or M)
- 9)
Unit I - 36/Control Room P
a) Reduce gap at latch to Door removed. Opening Sealed.
Southwall to Shift Engineer 1/8" or less.
Completed.
Office
- 10) 46/Clean & Dirty Oil Storage P
a) Install UL listed rear Completed.
Room West Door.
binders (latch plate assemblies) and front binder. See Drwg. No. 1 at the end of letter.
- 10)
P b) Provide new pin in Completed.
closing mechanism per manufacturer's instructions.
- 10)
P c) Install fusible link This issue was resolved by Technical inside Clean & Dirty Oil Justification issued by Dresden on Storage Room at ceiling.
February 9, 1999. See FPPDP Page 17.4-1.
- 10)
P d) Install weight box Completed.
around fire door closing rnfT T,)mechanism weight.
- 11) 50/U.2 Diesel Generator Day P
a) Provide PLC with the The door closer is a Corbin Model 166.1 Tank Room door closer model It Is U. L. listed for fire door use.
number or P.O.
Completed.
number it was purchased under to verify if it is UL listed for fire door use. (If not UL listed, closer will need to be replaced).
Appendix G 5April 12, 1988 Fire Door Items to be Resolved Updated December 17, 1999 Item Door Number/Location Priority Action Status Number (P or M)
- 11) 50/J2 Diesel Generator Day M
Tank Room M
- 12) 53/U2 shutdown Cooling Room 57/Between U2 and U2 Rx (517').
P P
a) Install larger screws Completed.
in doorstop.
b) Remove paint from U.
Not completed.
L. door label.
Action Request Number 990056426 has been issued to correct this item.
a) Interlock door with Completed.
ceiling smoke detection system to close door in the event of a fire.
a) Verify the installed The manufacturer of the door (Wayne chain set up for the Dalton Co.) was contacted and fusible links is in indicated that the chain arrangement is accordance with not in accordance with the manufacturer's manufacturer's instructions.
instructions.
Not completed.
Action Request Number 990064617 has been issued to correct this item.
b) Complete WR Completed.
D54125 to install electro thermal link at ceiling.
11) 00 13) 13)
6 Appendix G Fire Door Items to be Resolved Item Door Number/Location Priority Action Status N,,.,,,,,-i
~(P or M)
April 12, 1988 Updated December 17, 1999 64/Iso Cond. Vlv Room 3 (545')
70/Between U2 and U3 Rx (570')
P P
P a) Provide PLC with the The door closer is a Corbin Model 166.
door closer model It is U. L. listed for fire door use.
number or P.O.
Completed.
number it was purchased under to verify if it is UL listed for fire door use. (If not UL listed, closer will need to be replaced).
a) Replace latch with latch that has a ¥/"
throw.
b) Verify brass plug lock is acceptable. If not, replace it with metal similar to installed hardware.
Completed.
According to Underwriters Laboratories, the use of a brass plug is not-acceptable for a fire door.
Not completed.
Replace the brass plug with metal similar to the construction of the door or cover the brass plug with a steel plate of the same gauge as the fire door.
Action Request Number 990056444 has been issued to correct this item.
14)'
- 15) 15) 00
7 Appendix G Fire Door Items to be Resolved April 12, 1988 Updated December 17, 1999 Item Door Number/Location Priority Action Status Number (P or M)
- 15) 70/Between U2 and U3 Rx M
(570')
15)
M
- 16) 73/Between U2 & U3 Rx 589' M
- 17) 76/U2 Iso Cond. VLV Room 2 P
18) 80/U2 250 V Batt. Room North Door
- 19) 81/1U2 125 V Battery Room South Door
- 20) 84/U2 Diesel Generator Room Entrance P
P M
Completed.I (570')
00a a) Tighten screws on bottom hinge.
b) Remove paint off UL label.
a) Provide a cover on door closer.
a) Provide PLC with the door closer model number or P.O. number it was purchased under to verify if it is UL listed for fire door use. (If not UL listed, closer will need to be replaced).
a) Install a sill so that the gap between the door is less than 3/"
or less.
a) Replace latch with latch that has a 3/4" throw.
a) Paint door red.
M Completed.
Completed.
Completed.
The door closer is UL listed according to Mr. Joe Gadbois of Yale Security (see letter from Joseph H. Talbert to Mr. Michael Dillon dated October 29, 1999). However, the door closer arms on Door 20 are not UL listed for use with fire doors. This door closer is similar to the door closer on Door 20, but the arms could not be verified because it is in a high radiation area the door closer arms are not visible from outside the area. Action Tracking Number ATI 19427, Task 01 has been issued to verify whether or not the door closer arms are UL listed at the next outage when the door is open.
The door has a gap of I inch at the floor. Action Tracking Number ATI 19427, Task 04 has been issued for this item.
Completed.
Completed.
8 Appendix G Fire Door Items to be Resolved April 12, 1988 Updated December 17, 1999 Item Door Number/Location Priority Action Status Number (P or M)
- 21) 92/U3 TB to Aux. Transf.
P a) Install two missing Door Removed.
(517')
bolts from security strike Opening Sealed.
coverplate.
Completed.
- 21)
P b) Fill hole in doorjamb Door Removed.
with metal screw, rivet or Opening Sealed.
bolt.
Completed.
- 22) 95A/U3 Diesel Generator Room P
a) Baffle hinge is missing Completed.
Louvered Door two left-hand side screws. Replace them.
- 22)
P b) Guide angles are Completed.
provided with bolts every other hole.
Verify this is adequate per manufacturer's instruction. If not.
Correct it.
00
9 Appendix G Fire Door Items to be Resolved Item Door Number/Location Priority Action Number (P or M)
- 22) 95A/U3 Diesel Generator Room P
c) Interlock door with Louvered Door detection system to close upon detection actuation.
April 12, 1988 Updated December 17, 1999 Status Fusible links are installed near the ceiling on the inside of the Diesel Generator Room to provide automatic closing of the fire door in accordance with NFPA 80, Section 6-5.1 in the event of a fire inside the Diesel Generator Room. The purpose of an interlock with the detection system was to ensure prompt closure of the fire door. However, the heat generated by an oil fire in the Diesel Generator room would be significant and would melt the fusible link near the ceiling rapidly, achieving this prompt closure.
In the event of a fire outside the Diesel Generator Room, this Diesel Generator is not needed to achieve Safe Shutdown for a fire in the Turbine Building in the vicinity of the Diesel Generator Room.
If fire spread to the Diesel Generator, it would not jeopardize safe shutdown of the plant, therefore the lack of a fusible link near the ceiling on the Turbine Building side of the wall is accepal Not completed.
Action Request Number 990064619 has been issued to correct this item.
00 ONa 22) a) Left-hand guide angle is missing a washer.
Replace it.
U Appendix G Fire Door Items to be Resolved April 12, 1988 Updated December 17, 1999 Door Number/Location 11 7/U3 Shutdown Cooling Pump Room
___________________L 124/U3 Iso Cond. VLV room 2 (570')
P P
P a) Replace aluminum door stop and rubber gasketing with bolted, or welded (for weld per detail BI on drwg, B-334) steel stop and UL listed gasket.
F 23) k.AJU1pILU.
The door closer is a Corbin Model 166.
It is U. L. listed for fire door use.
Completed.
Completed.
10 Item Number b) Interlock door with fire detection system at the ceiling to shut the door in event of a Fire.
a) Provide PLC with the door closer model number or P.O.
number it was purchased under to verify if it is UL listed for fire door use. (If not UL listed, closer will need to be replaced).
b) Shim sill so gap between door and sill is 3/4" or less.
Priority (P or M)
Action Status 0O clO t!
24)
Action k-ornptete.
a) z.,j)
Appendix G Fire Door Items to be Resolved April 12, 1988 Updated December 17, 1999 Item Door Number/Location Priority Action Status Number (P or Al) 132/U3 Diesel Generator Day Tank Room P
4 C
P I-t P M
a) Replace lock cylinder. I Completed.
b) There is no UL label on the door. Provide documentation to verify this is a UL listed door (Bill of Material or Purchase Order).
c) Provide PLC with the door closer model number or P.O.
number it was purchased under to verify if it is UL listed for fire door use. (If not UL listed, closer will need to be replaced).
a) Paint door red.
- 26) 140/Diesel Generator Room P
a) Provide PLC with the doo clse moa door closer model number or P.O.
number it was purchased under to verify if it is UL listed for fire door use. (If not UL listed, closer will need to be replaced).
Not completed.
Action Tracking Number ATI 19427, Task 02 has been issued to correct this item.
The door closer is a Corbin Model 166.
It is U. L. listed for fire door use.
Completed.
Completed.
The door closer is a Corbin Model 166.
It is U. L. listed for fire door use.
Completed.
25) 25) 00
- 25) 25)
II P
12 Appendix G Fire Door Items to be Resolved Item Door Number/Location Priority Action Status XT.
,h, (P or M)UII I
April 12, 1988 Updated December 17, 1999
- 27) 153/U3 TB to Rad Waste (517')
P 164/U2 TB Mezz to a) Fill holes in door andr frame with metal screws, rivets and bolts.
b) Reduce gap at latch to 1/8" or less.
a) Paint door red.
b) Replace bolts on handle, latch cover plate and hinges with larger holes to completely fill holes.
c) Remove paint from UL door label.
Completed.
Completed.
Completed.
Completed.
Not completed. Action Request Number 990056439 has been issued to correct this item.
d) Provide door closer Completed.
with cover.
a) Verify brass plug lock is acceptable. If not, replace it with metal similar to installed hardware.
a) Remove paint from UL door label.
a) Paint door red.
Completed.
Completed.
Completed.
Item orNm e/oainPirt cinSau
U Appendix G Fire Door Items to be Resolved April 12, 1988 Updated December 17, 1999 Action i.atu s
- 29)
M b) Provide door with a Not completed.
number tag.
Action Tracking Number ATI 19427, Task 03 has been issued to correct this item.
- 29)
M c) Provide door closer Completed.
with cover.
182/U3 Tip Drive Room 1005/U2RX and 2/3 Diesel Generator Interlock (517')
a) Provide PLC with thle door closer model number or P.O. number it was purchased under to verify if it is UL listed for fire door use. (If not UL listed, closer will need to be replaced).
a) Verify the use of the right hand side lever arm with the manufacturer instructions..
I he door closer is a 1.,oroin Mvodet uu It is U. L. listed for fire door use.
Completed.
Wayne Dalton Co., the manufacturer of this fire door was contacted and indicated that the use of only the right hand side lever to actuate the door is not in accordance with the manufacturer's instructions. The fusible link arrangement does not meet the manufacturer's instructions.
Not completed.
Action Request Number 990064631 has been issued to correct this item.
13 Item Number Door Number/Location Priority (P or M) 30) 00 ON P
31)
I
+
I*
P StatuIs Action
14 Appendix G Pire. T-nor Items to be Resolved April 12, 1988 Updated December 17, 1999 i
manufacturer's instructions. The fusible link arrangement does not meet the manufacturer's instructions.
Not completed.
Action Request Number 990064631 has been issued to correct this item.
M a) Clean debris out from Completed.
under the guides' ex er Iansion gap.
ON Item Door Number/Location Priority Action Status Number (P or M)
- 31) i005/U2RX and 2/3 Diesel P
b) Verify fusible link Wayne Dalton Co., the manufacturer of Generator Interlock (517')
arrangement with this fire door was contacted and manufacturer's indicated that the use of only the right instructions, hand side lever to actuate the door is