IR 05000390/2008005
| ML090840302 | |
| Person / Time | |
|---|---|
| Site: | Watts Bar  |
| Issue date: | 03/24/2009 |
| From: | Skaggs M Tennessee Valley Authority |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| IR-08-004 | |
| Download: ML090840302 (15) | |
Text
March 24, 2009
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. Gentlemen:
In the Matter of ) Docket No. 50-390 Tennessee Valley Authority ) WATTS BAR NUCLEAR PLANT (WBN) UNIT 1 - DENIAL OF NON-CITED VIOLATION (NCV)05000390/2008005-04, CARBON DIOXIDE SYSTEM IN FIRE AREA 48 FAILED TO
MEET DESIGN CRITERION References:
1. NRC's letter, "Watts Bar Nuclear Plant - NRC Integrated Inspection Report 05000390/2008005, 05000391/2008005, and 05000390/2008501 and Exercise of Enforcement Discretion," dated February 12, 200 (ADAMS
Accession No. ML090440261)
2. NUREG-0847, Supplement Number 18, "Safety Evaluation Report related to the operation of Watts Bar Nuclear Plant, Units 1 and 2, Docket Nos. 50390
and 50-391," dated October 1995 3. TVA's letter, "Request for Correction to NUREG-0847, Supplement 18, Related to WBN Carbon Dioxide Fire Suppression System," dated March 13, 2009 4. TVA's letter, "Denial of Non-Cited Violation (NCV)05000390/2008005-04, Carbon Dioxide System in Fire Area 48 Failed to meet Design Criterion,"
dated March 23, 2009 This letter supersedes in its entirety TVA's letter dated March 23, 2009, "Denial of Non-
Cited Violation (NCV)05000390/2008005-04, Carbon Dioxide System in Fire Area 48
Failed to meet Design Criterion" (Reference 4). Updated information is provided in a revised version of Enclosure TVA regrets any inconvenience this may have cause U.S. Nuclear Regulatory Commission Page 2 March 24, 2009 The events leading to the NRC's issuance of NCV 05000390/2008005-04 in Inspection Report 05000390/2008005, dated February 12, 2009 (Reference 1), demonstrated there
was a misstatement in Supplement 18 to the WBN Safety Evaluation Report (SER)
(Reference 2). TVA understands the need to correct this misstatement and has submitted a
request to the NRC, under separate cover, to have the SSER corrected (Reference 3).
A further problem exists, however, in the fact that NRC has relied upon this misstatement in
SSER 18 in forming the basis for the subject violatio For the reasons set forth in
Enclosure 1 to this letter, TVA does not believe that circumstances warrant, or support, the
issuance of a violatio TVA has evaluated the technical adequacy of the 45% percent
concentration in two documents; 1) Functional Evaluation 43182, and 2) Fire Protection
Program Change Regulatory Review (NEI 02-03). These documents are provided in
Enclosures 2 and 3, respectivel In a March 13, 2009 teleconference, TVA and NRC Region II representations discussed
aspects of TVA's concern with the subject NC As part of the teleconference, an
extension of 1 week to the normal 30-day response time was verbally grante This
response is being provided in accordance with that schedul There are no regulatory commitments in this lette If you have any questions concerning
this matter, please call Mike Brandon, WBN Unit 1 Licensing and Industry Affairs Manager
at (423) 365-182
Sincerely,Mike Skaggs Enclosures cc: See Page 3
U.S. Nuclear Regulatory Commission Page 3 March 24, 2009 Enclosures cc (Enclosures): NRC Resident Inspector Watts Bar Nuclear Plant 1260 Nuclear Plant Road Spring City, Tennessee 37381 U.S. Nuclear Regulatory Commission Mr. John G. Lamb, Senior Project Manager Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation MS O-8 H1A Washington, DC 20555-0001 U.S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, Georgia 30303
ENCLOSURE 1 WATTS BAR NUCLEAR PLANT UNITS 1 REPLY TO NON-CITED VIOLATION (NCV)
NCV 05000390/2008005-04 Description of NCV 05000390/2008005-04
"Watts Bar Unit 1 License Condition 2F requires that the licensee implement and maintain in effect all provisions of the approved fire protection program, as approved in Supplements 18
and 19 of the SER (NUREG-0847). These documents incorporate the requirements of 10 CFR
50, Appendix R,Section III. This section of Appendix R requires a fixed fire suppression
system for the auxiliary instrumentation room area since it contains safe shutdown equipment and alternative safe shutdown was selected for this are The Watts Bar CO2 gas suppression
system was required to be designed in accordance with NFPA 12, 1973 Edition and the SSER
No.1 NFPA 12, 1973, specified that an acceptable CO2 system deliver and hold a minimum
gas concentration of 50 percent and the SSER stated that this concentration must be held for
15 minute Contrary to the above, since receipt of the operating license on February 7, 1996, until the
present, the CO2 system for the auxiliary instru mentation room was not designed in accordance
with the 1973 Edition of NFPA 12 and SSER No. 18, in that, the CO2 system was unable to
deliver and maintain a minimum gas concentration of 50 percent in the upper portion of the
room for 15 minute Because this finding is of very low safety significance and has been
entered into the licensee's corrective action program as PER 125632, this finding is being
treated as an NCV, consistent with Section VI.A.1 of the NRC's Enforcement Policy: NCV 05000390/2008005-04, Carbon Dioxide System in Fire Area 48 Failed to Meet Design
Criterion."
TVA Response TVA denies the violatio Basis for Denial of the Violation TVA's Fire Protection Plan describes the design basis for the Auxiliary Instrument Rooms
protected by CO The Plan provides as follo ws: "Auxiliary Instrument Rooms - Deep seated fire Must achieve 30% concentration within 2 minutes, 50% concentration within 7 minutes, and maintain at least 45% concentration for at least 15 minutes."
TVA arrived at this level of "soak time," (i.e., at least 45% concentration for at least 15 minutes)
as a result of an exchange of correspondence with NRC in 1995 (References 1 and 2). In
Reference 1, Item 1 of NRC's Request for Additional Information (RAI) asked TVA to justify how
the current CO2 system design met Section 2232 of NFPA 12-1973 NFPA-12, Section 2232 does not require a s pecific soak time of 15 minutes or of any specific duratio This section of the code only states: "...required extinguishing concentration shall be maintained for a sufficient period of time to allow the smoldering to be extinguished and the material to cool...In any event, it is necessary to inspect the hazard immediately thereafter to make certain that the extinguishment is complete and to remove any material involved in the fire." E1-1 ENCLOSURE 1 WATTS BAR NUCLEAR PLANT UNITS 1 REPLY TO NON-CITED VIOLATION (NCV)
NCV 05000390/2008005-04 In Reference 2, TVA's response to Item 1 included the following commitment:
"TVA will revise the system design description for the CO2 system supplying the auxiliary instrument rooms (Units 1 and 2) to include a minimum soak tim The soak time will be to maintain CO2 concentration greater than 45% for at least 15 minute The revision will be completed by June 30, 1995."
NRC's SSER 18 (Reference 3) correctly recited the Fire Protection Plan's design basis that "the
system must achieve a 30-percent concentration within 2 minutes and a 50-percent
concentration within 7 minutes after system discharge." However, the SSER went on to state
that, "In addition, the leakage from the room must be limited to and the system must maintain at
least a 50-percent concentration for 15 minutes." This last statement appears for the first time
in SSER 18 and is inconsistent with TVA's RAI response which commits to maintain a CO2
concentration greater than 45% for at least 15 minute TVA failed to identify this misstatement as it should have when the SER was issued in 199 TVA understands the need to correct this
discrepancy and has submitted a request to the NRC, under separate cover (Reference 4), to
have the SER correcte The fact remains, however, that WBN's CO2 gas suppression system was designed for and can achieve a 50% concentration after discharge in accordance with NFPA 12, 1973 Editio It will
also, as committed, maintain a concentration greater than 45% for at least 15 minute These
statements constitute WBN's current licensing basis for Auxiliary Instrument Rooms Carbon Dioxide Suppression Syste The technical adequacy of this basis was revalidated and is
supported by an Engineering Functional Evaluation (Enclosure 2) and Fire Protection Program
Change Regulatory Review (Enclosure 3).
NRC's violation states that "Watts Bar Unit 1 License Condition 2F requires that the licensee implement and maintain in effect all provision of the approved fire protection program, as
approved in Supplements 18 and 19 of the SER (NUREG-0847)" and that "the SSER stated that
this concentration [50%] must be held for 15 minutes." TVA has demonstrated that this is a
misstatement in the SSER and is outside of WBN's current licensing basi TVA does not
believe it is proper to engage in enforcement on the basis of a misstatement in the SSE Nor
does TVA believe that citing to a violation of a license condition cures the problem when the
sole basis for the violation is a misstatement in the SSER which the license condition mentions
as approving TVA's Fire Protection Repor The fact remains that the SSER misstates TVA's
licensing basis, and the SSER cannot alone establish such a basi Moreover, TVA is in
compliance with the terms of the license condition as well, since WBN's Auxiliary Instrument
Rooms CO2 Suppression System fully conforms to the terms of the Fire Protection Repor TVA's Views Regarding Current Licensing Basis are Consistent with NRC's Views TVA believes that its views regarding what constitutes a valid current licensing basis are in
accordance with NRC's own view We acknowledge that, in addition to NRC requirements
applicable to a certain plant, a plant's current licensing basis includes licensee's written E1-2 ENCLOSURE 1 WATTS BAR NUCLEAR PLANT UNITS 1 REPLY TO NON-CITED VIOLATION (NCV)
NCV 05000390/2008005-04 commitments for ensuring compliance with and operation within applicable NRC requirements and the plant-specific design basi The licensee's commitments remaining in effect are those
made in docketed licensing correspondence, which include licensee commitments documented in NRC safety evaluations or licensee event reports (based on the Introduction of Revision 1 of
Nuclear Reactor Regulation (NRR) Office Instruction LIC-100, "Control of Licensing Basis for
Operating Reactors"). As such, it is clear that commitments such as the one made in TVA's
May 26, 1995, letter (Reference 2) may be properly restated in an SSER and be considered part
of WBN's current licensing basi However, it is also the case that SERs cannot alone establish a current licensing basi NRC
recognizes that SERs are valuable in that they provide the bases for the staff's decision However, "The staff should not attempt to establish licensing bases information in SEs or SER The staff can stress the importance of certain licensing bases information and can cite
regulations, regulatory commitments, or other established licensing bases information in its
safety evaluation It is important that the lic ensees provide the licensing bases information so that there is no confusion following the licensing action and to avoid a perception of staff-
imposed backfits (see 10 CFR 50.109)." (Excerpted from Section 6 of Revision 1 of NRR Office
Instruction LIC-100, "Control of Licensing Basis for Operating Reactors")
Conclusion TVA's May 26, 1995, letter (Reference 2) and TVA's approved Fire Protection Plan properly
describe WBN's current licensing basis for WBN'
s CO2 system for the Auxiliary Instrument Room and compliance with the NFPA 12-1973 (including soak time). This portion of the CO2
system has been maintained at all times in a configuration that provides the committed
concentrations and soak time and it has been fully qualified during the period Unit 1 has been
operationa TVA does not believe it is proper to cite, as the sole basis for a violation, a
misstatement contained only in SSER 18 regarding soak time for the Auxiliary Instrument
Roo Accordingly, TVA denies the subject violatio References 1. NRC's letter dated May 10, 1995 - Watts Bar Unit 1 - Request for Additional Information (RAI) Regarding Carbon Dioxide Automatic Fire Suppression
Systems (TAC NO. M63648)
2. TVA's letter, "Watts Bar Nuclear Plant (WBN) - Reply to Request for Additional Information Regarding Carbon Dioxide Automatic Fire Suppression Systems,"
dated May 26, 1995 (ADAMS Accession No. ML073230886)
3. NUREG-0847, Supplement Number 18, "Safety Evaluation Report related to the operation of Watts Bar Nuclear Plant, Units 1 and 2, Docket Nos. 50390 and 50-
391," dated October 1995 4. TVA's letter, "Request for Correction to NUREG-0847, Supplement 18, Related to WBN Carbon Dioxide Fire Suppression System," dated March 13, 2009 E1-3 ENCLOSURE 2 WATTS BAR NUCLEAR PLANT UNITS 1 FUNCTIONAL EVALUATION FOR CO2 FOR UNIT 1 AUXILIARY INSTRUMENT ROOM 1.0 Description Problem Evaluation Report (PER) 125632 was written based upon NRC's NUREG-0847, Supplemental Safety Evaluation Report (SSER) 18 specifies a Carbon Dioxide (CO 2) concentration in the Auxiliary Instrument Room Unit 1 at 15 minutes of 50% vs. the Fire
Protection Report (FPR) concentration of 45%. The NRC inspectors believe that although the
CO 2 system appears to be capable of performing its function in the Auxiliary Instrument Room, the actual analysis to demonstrate the 45% concentration could be enhanced to address what
fires could possibly be generated in this are The 50% value in the SSER appears to be an
editorial error since all docketed correspondence just prior to the issuance of the SSER stated
the system is designed to 45% concentratio The NRC considers this item to be a violation of
WBN License Condition 2.F, "Approved Fire Protection Program."
2.0 Required Function The primary function of the automatic CO 2 fire suppression systems is to extinguish a fire or control and minimize the effects of a fire until the fire brigade can respond and extinguish i The automatic total flooding CO 2 suppression systems have been provided for the Auxiliary Instrument Rooms and Computer Room in the Control Building; and the Lube Oil Storage Room, each Diesel Engine Room (4), Fuel Oil Transfer Room, and each 480-V Board Rooms
(4) in the Diesel Generator Buildin A signal from either the fire detection system or a push button station activates the area alarms, CO 2 discharge timer which actuates the master control valve and the area selector valve permitting the CO 2 to be discharged into the selected are In addition, the system can be manually operated via the electro-manual pilot valve for each hazard protecte Personnel safety is considered by providing the predischarge alarm to notify anyone in the area
that CO 2 is going to be discharged and by the addition of an odorizer to the CO 2 to warn personnel that CO 2 has been discharge Actuation of the CO 2 system causes selective closure of dampers and doors to the area protected, and shuts down HVAC fans to the protected are This prevents spread of the fire
and ensures that the minimum concentration of CO 2 is maintaine Full discharge tests for representative rooms in conjunction with door fan pressurization tests have been conducted to
validate CO 2 concentration and soak time The duration of the discharge is determined by the area requirements and is controlled by the discharge timer. This system is quality relate .0 Evaluation The following documents were reviewed:
E2-1 ENCLOSURE 2 WATTS BAR NUCLEAR PLANT UNITS 1 FUNCTIONAL EVALUATION FOR CO2 FOR UNIT 1 AUXILIARY INSTRUMENT ROOM Date Document Description October 1986 Sandia National Laboratory NUREG/CR-3656, "Evaluation of Suppression Methods for Electrical Cable Fires" April 8, 1992 NRC Information Notice 92-28 April 6, 1995 NRC Inspection Report No. 50-390/95-16, 50-391/95-16 May 1, 1995 NRC Inspection Report No. 50-390/95-26, 50-391/95-26 May 10, 1995 NRC Request for Additional Information (RAI) Regarding Carbon Dioxide Automatic Fire Suppression Systems (TAC No. M63648)
May 26, 1995 TVA Reply to Request for Additional Information (RAI) Regarding Carbon Dioxide Automatic Fire Suppression Systems (TAC No. M63648)
NRC RAI (TAC No. M63648) states that in order to further evaluate thes e inspection findings and assess the design of these C02 suppression systems due to changing minimum required C02 concentration 50
% to 45% for 15 minutes, the staff has reviewed NFPA-12-1973 and NFPA-12, 1989 edition that considers the results of fire s uppression experiments performed by Sandia National Laboratories (NUREG/CR-3656, "Evaluation of Suppression Methods for Electrical Cable Fires," October 1986), and the recommendations of NFPA-
12, 1989 edition Section 2232. TVA concluded in response to this RAI that the C02 suppression system for the Au xiliary lnstrument Rooms is adequately designed for a deep seated fi r The soak time will maintain C02 concentration > 45
% for at least 15 minute There are significant differences between Sandia Test Number 83 and the WBN Unit 1 Auxiliary Instrument Room configuration that provides a ssurance that WBN's Unit 1 Auxiliary Instrument Room CO 2 suppression is more robust than the test cas The Sandia Test total time that the CO 2 concentration was above 50% was approximately 4 minute The total time there was CO 2 in the room before ventilation was restored was 8 minute WBN Unit 1 Auxiliary Instrument Room has CO 2 concentration of 30% within 2 minutes, 50% within 7 minutes, maintains greater than
50% for 10 minutes, and greater than 45% for 15 minute The Sandia Test cables did not reignite until ventilation was restored to the roo Note that this essentially terminated the tes WBN actuation of the CO 2 system in Unit 1 Auxiliary Instrument Room causes closur e of fire dampers and sliding fire doors to prevent air flow into the area of CO 2 discharg Upon visual confirmation of a fire in this area, the fans are manually shutdown to stop airflow to adjacent areas, and causes
additional closure of selected fire damper These fans are not restarted until the fire
has been extinguishe It can be seen from the rapid decay of CO 2 shown in Sandia Figures 36 that the test room was not a tight roo In contrast, t he WBN Unit 1 Auxiliary Instrument Room is very tight and are able to maintain the CO 2 for a substantial period of tim E2-2 ENCLOSURE 2 WATTS BAR NUCLEAR PLANT UNITS 1 FUNCTIONAL EVALUATION FOR CO2 FOR UNIT 1 AUXILIARY INSTRUMENT ROOM Another important consideration is the method of achieving and the length of time required to achieve a deep seated fire for Sandia Test Number 8 The Sandia test used Bunsen burners located directly below the cable trays for 18 minutes to establish
fully involved cable tray The burners were turned off and the trays were allowed to
free burn for another minute, and then the ventilation was secured and dampers close TVA calculation EPM-DOM-012990, "Combustible Loading Data (CLD)" establishes the
Fire Severity Index for the following areas in the Control Building:
Floor Elevation (Ft)
Combustible Load (Btu/ft 2) Fire Severity Index Equivalent Fire Severity (minutes)
692.0 20,963 Insignificant
< 5 708.0 105,902 Moderate < 120 729.0 529,584 Severe > 180 755.0 29,817 Low < 60 Elevations 708.0 and 729.0 have the highest Fire Severity Index based on combustible loading
in the Control Buildin These areas contain the Unit 1 Auxiliary Instrument Room (708.0-C1),
Corridor (708.0-C2), Computer Room (708.0-C3), Unit 2 Auxiliary Instrument Room (708.0-C4),
and the Cable Spreading Room (729.0-C1). These areas were evaluated for fire risk as a part
of the Electric Power Research Institute (EPRI) Fire Induced Vulnerability Evaluatio TVA
calculation WBN-IPE-004, "Zone of Influence" determined that the only ignition source is two air
handling units in the Corridor on Elevation 70 TVA calculation WBN-IPE-005, "Quantitative
Screening - Phase 2 (Detailed Screening)" Corridor (708.0-C2) was screened out since the
room did not have any safety related component impact Cable Spreading Room (729.0-C1)
was screened out due to a lack of significant fire ignition sources and the presence of automatic
detection and suppression capabilit Based upon this evaluation, all these areas were
screened out from a detail review, and were screened out due to a lack of significant fire ignition
sources and/or the presence of automatic detection and suppression capabilit Based on a review of these calculations, a fire in Unit 1 Auxiliary Instrument Room would be detected in its early stages, would be controlled by the s uppression system, and the development of an extensive fire is not expected to occu Therefore, this review determines that TVA 1978 designed automatic CO 2 suppression system provided for the Unit 1 Auxiliary Instrument Room at Watts Bar is adequately designed for a deep seated fir TVA detection and suppression systems would detect and suppress any fire
with the potential of the severity needed to induce a deep seated fir The defense in depth fire
protection at Watts Bar ensures that the fire protection provided for the Unit 1 Auxiliary
Instrument Room is in compliance with the applicable sections of NFPA 12-1973 and therefore
meet the regulatory requirements found in Branch Technical Position (BTP) 9-5.1, Appendix A, paragraph F.6 and 10CFR50, Appendix R, paragraph III. This is considered to be a non-conforming condition since there is a conflict between the FPR
and the SE This is not an adverse effect on the design function of the system, and is not a
margin management issu Other degraded or non-conforming conditions and margin
management issue were reviewed for adverse aggregate effect, none were identifie E2-3 ENCLOSURE 2 WATTS BAR NUCLEAR PLANT UNITS 1 FUNCTIONAL EVALUATION FOR CO2 FOR UNIT 1 AUXILIARY INSTRUMENT ROOM Limitations No compensatory actions (manual or automatic actions, configuration changes), and no operational mode restrictions are required as a condition of operabilit No interim measures
are neede .0 Conclusion The automatic CO 2 suppression system provided for the Un it 1 Auxiliary Instrument Room is adequately designed for a deep seated fir The detection and suppression system would
detect and suppress any fire with the potential of the severity needed to induce a deep seated
fir Although the design function of this suppression system is maintained, a discrepancy
between the FPR and the SER does represent a non-conforming condition, and this condition will be resolved and docketed with the NR Therefore, the automatic CO 2 suppression system remains functiona .0 References:
6.1 WBN Fire Protection Report, Revision 37 6.2 N3-39-4002 R9, "CO 2 Storage, Fire Protection, and Purging" 6.3 WBN Technical Specifications (TS) and Applicable Bases (None Found Applicable) 6.4 WBN Technical Requirements Manual (TRM) and Applicable Bases (None Found Applicable) 6.5 Sandia National Laboratory NUREG/CR-3656, "Evaluation of Suppression Methods for Electrical Cable Fires", October 1986 6.6 NRC Information Notice 92-28, April 8, 1992 6.7 NRC Inspection Report No. 50-390/95-16, 50-391/95-16, April 6, 1995 6.8 NRC Inspection Report No. 50-390/95-26, 50-391/95-26, May 1, 1995 6.9 NRC Request for Additional Information (RAI) Regarding Carbon Dioxide Automatic Fire Suppression Systems (TAC No. M63648), May 10, 1995 6.10 TVA Reply to Request for Additional Information (RAI) Regarding Carbon Dioxide Automatic Fire Suppression Systems (TAC No. M63648), May 26, 1995 7.0 Signatures:
FE 43182 Revision 0 E2-4 Enclosure 3 PER # 125632 .
R0 NEI 02-03 (Revision 1)
June 2004 Page 1 of 17 ATTACHMENT 1 Fire Protection Program Change Regulatory Review (FPPCRR)
E3-1 1. Station(s) / Unit(s):
Watts Bar / 1 Activity Document No:
PER 125632 2. Description:
Provide a brief description of, including the reason for, the proposed change (or refer to change package that provides description):
At Watts Bar, a CO2 suppression syst em has been installed in the Auxiliary Instrument Room to meet the requirements of Appendix R, Sect ion III. NRC Supplemental Safety Evaluation Report (SSER) No. 18 (NUREG 0847), states that the CO2 syst em must achieve a concentration of at least 50 percent within seven minutes of initiation and hold that concentration for 15 minute This statement may be construed as meaning the concentration values must be achieved at any point in the room wher e combustibles capable of deep seated fires are locate The basis for these values in the SSER is testing performed by Sandia National Laboratory on deep seated fires and CO2 systems as described in NRC Information Notice 92-28, Inadequate Fire Suppression System Testi ng, issued April 8, 199 The Watts Bar Fire Protection Report (FPR) states that the system is capable of achieving 50 percent concentration within seven minutes and maintaining at least a 45 percent concentration for at least 15 minute NFPA No.12 - 1973 (the code of record) specifies 50 percent concentration for deep-seated fires, but does not specify a definite hold tim Although there is an identified difference between the SSER and the FPR with regard to the concentration at 15 minutes, based on a technical review of the Sandia Test Report, it has been determined that the 45% concentration obtained during the TVA tests is consistent with the Sandia tests and the WBN CO2 system design basi A review of the docketed correspondence between TVA and the NRC prior to Licensing show that the 45% concentration was NRC reviewed and is our licensing basi This evaluation will further document the acceptability of the CO2 system as described in the FP . Screening:
Answer the following questions; include a reference to the applicable regulatory, licensing basis, or NFPA document(s), and a brief description of why the proposed change does or does not satisfy the referenced document(s).
Note: If acceptance of the feature being changed was based on a commitment to
"exceed" an applicable requirement or guidance document, then further evaluation may be necessar A. Does the proposed change satisfy applicable fire protection regulatory requirements (i.e., GDC, 10CFR 50.48 and Appendix R), guidance documents (i.e., NUREG 0800, NRC Generic Letters, NFPA Codes, or NRC-approved NEI guidance documents), and/or the fire protection licensing basis (i.e., previously approved alternate compliance strategy, exemption, deviation, SER, docketed correspondence, or NFPA Codes of Record, etc.)?
Yes No Enclosure 3 PER # 125632 .
R0 NEI 02-03 (Revision 1)
June 2004 Page 2 of 5 ATTACHMENT 1 Fire Protection Program Change Regulatory Review (FPPCRR)
E3-2 Basis for Determination:
Based upon the discussion in Question 2 above, there is a discrepancy between the WBN FPR and the SSE If yes, then the proposed change does not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire and NRC approval is not required, check Steps 3.B and 3.C N/A, and proceed to Step 4 B (see Appe ndix A for additional guidance).
If no, then complete Step B. Was the plant licensed prior to January 1, 1979 Yes No N/A If yes, then complete to Step If no, then check Step 3.C N/A and proceed to Step 4 (see Appendix A for additional guidance).
C. Does the proposed change satisfy the detection, suppression and/or separation requirements within the fire area or zone affected by the change specified in Appendix R Sections III.G.2 and/or III.G.3?
Yes No N/A If yes, then proceed to Step 4 (see Appe ndix A for additional guidance).
If no, then NRC approval is required prior to implementi ng the proposed chang Proceed to Step . Evaluation:
Does the proposed change adversely affect the ability to achieve and mainta in safe shutdown in the event of a fire (provide justification below or attach Generic Letter 86-10 type or equivalent evaluation)?
Yes No N/A [This block not included in original NEI form
]
Enclosure 3 PER # 125632 .
R0 NEI 02-03 (Revision 1)
June 2004 Page 3 of 5 ATTACHMENT 1 Fire Protection Program Change Regulatory Review (FPPCRR)
E3-3 Basis for Determination
- The Fire Hazards and Suppression System in the Unit 1 Auxiliary Instrument Room have been evaluated as noted below:
The following documents were reviewed:
Date Document Description October 1986 Sandia National Laboratory NUREG/CR-3656, "Evaluation of Suppression Methods for Electrical Cable Fires" April 8, 1992 NRC Information Notice 92-28 April 6, 1995 NRC Inspection Report No. 50-390/95-16, 50-391/95-16 May 1, 1995 NRC Inspection Report No. 50-390/95-26, 50-391/95-26 May 10, 1995 NRC Request for Additional Information (RAI) Regard ing Carbon Dioxide Automatic Fire Suppression Systems (TAC No. M63648)
May 26, 1995 TVA Reply to Request for Additional Information (R AI) Regarding Carbon Dioxide Automatic Fire Suppression Systems (TAC No. M63648)
The Sandia Test versus TVA CO2 Test Sandia Test Number 83 - the total time that the CO2 concentration was above 50% was approximately 4 minute The total time there was CO2 in the room before ventilation was restored was 8 minute TVA Unit 1 Auxiliary Instrument Room has CO2 concentration of 30 % within 2 minutes, 50 %
within 7 minutes, maintains greater than 50 % for 10 minutes, and greater than 45 % for 15 minute Based on this comparison of key CO2 concentration parameters, it is concluded that the design of the Auxiliary Instrument Room pr ovides an equivalent level of fire suppression capabilit Sandia Test Number 83 - the cables did not reignite until ventilation was restored to the roo Note that this essentially terminated the tes TVA actuation of the CO2 system in Unit 1 Auxiliary Instrument Room causes closure of fire dampers and sliding fire doors to prevent air flow into the area of CO2 discharg Upon visual confirmation of a fire in this area, the fans are manually shutdown to stop airflow to adjacent areas, and causes additional closure of selected fire damper These fans are not restarted until the fire has b een extinguished, visual inspections have been performed by the Onsite Fire Department, and the plant has entered into a fire recovery effor At this time, in the unlikely event the fire reignited, the fire would be immediately suppressed by the fire fighting personnel at the scene Sandia Test Number 83 - it can be seen from the ra pid decay of CO2 shown in Sandia Figures 36 that the test room was not a tight roo In contrast, the TVA Unit 1 Auxiliary Instrument Room is very tight and is able to maintain the CO2 for a substantial period of tim Another important consideration is the method of achieving and the length of time required to achieve a deep seated fire for Sandia Test Number 8 The Sandia test used Bunsen burners located directly below the cable trays for 18 minutes to establish fully involved cable tray The burners were turned Enclosure 3 PER # 125632 .
R0 NEI 02-03 (Revision 1)
June 2004 Page 4 of 5 ATTACHMENT 1 Fire Protection Program Change Regulatory Review (FPPCRR)
E3-4 off and the trays were allowed to free burn for another minute, and then the ventilation was secured and dampers close No ignition sources located in the Unit 1 Auxiliary Instrument Room would introduce thermal insult approximating the initial conditions utilized in the tes TVA calculation EPM-DOM-012990, "Combustible Loading Data (CLD)" establishes the Fire Severity Index for the WB Elevation 708.0 has a Fire Severity Index of Moderate base on combustible loading calculatio This area contains several rooms, including the Unit 1 Auxiliary Instrument Room (708.0-C1), Corridor (708.0-C2), Computer Room (708.0-C3), and Unit 2 Auxiliary Instrument Room (708.0-C4). The Unit 1 Auxiliary Instrument Room is designed/configured such that it is highly unlikely that a fire could progress past the incipient stages without detection and subsequent suppression by either the automatic CO2 system or the plant fire departmen This is based on the following: (1) lack of ignition source(s) with sufficient energy to introduce thermal insult to more than a local area of exposed cable trays; (2) existence of a detection system which ensures prompt detection of a fire in its incipient stages; (3) a room configuration such that rapid development of a cable tray type fire is not likely, specifically, the trays are located several feet below the ceiling thus requiring a large fire to establish a hot gas layer that would impact the trays; and (4) the bounding nature of the CO2 system design relative to the Sandia Tests as discussed in the previous paragraph As a final consideration, a review of the IPE was performed to ensure this area did not introduce risk considerations that would warrant more stringent defense-in-depth controls/feature This review of the IPE and its supporting documentation determined that a fire in the Unit 1 Auxiliary Instrument Room would be detected in its early stages, would be controlled by the suppression system, and the development of an extensive fire is not expected to occu Based on these considerations, it was determined that this area had a low risk relative ranking for WBN and would not warrant any additional defense-in-depth, above that currently provided by the existing Fire Protection Progra This review performed and discussed above, determined that the designed automatic CO2 suppression system provided for the Unit 1 Auxiliary Instrument Room at Watts Bar is adequately designed for the hazard it is protecting While a deep seated fire has been postulated and designed for in this area, the configuration of the room is such that it is not likely to occu These considerations when coupled with the detection and suppression systems, would serve to reduce the severity of any fire in this area, including a postulated deep seated fir Therefore, the fire protection plan for the Auxiliary Instrument Room at Watts Bar ensures that the level of fire protection provided for the Unit 1 Auxiliary Instrument Room is in compliance with the applicable sections of NFPA 12-1973 and therefore meet the defense-in-depth design philosophy as found in Branch Technical Position (BTP) 9-5.1 and NUREG 060 Based on this conclusion, it is determined that the condition discussed in section 1, above, does not introduce any adverse affects relative to the Fire Protection Program for the Auxiliary Instrument Rooms at WB Enclosure 3 PER # 125632 .
R0 NEI 02-03 (Revision 1)
June 2004 Page 5 of 5 ATTACHMENT 1 Fire Protection Program Change Regulatory Review (FPPCRR)
E3-5 If yes, then the proposed change may not be implemented without prior NRC approva If no, then the proposed change does not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire, and NRC approval is not require . Conclusion:
Proposed change may be implemented without prior NRC approva NRC approval is required prior to implementing the proposed chang . I have determined that the documentation is adequate to support the above conclusio Preparer:
Reviewer:
Reviewer: