ML040680544
| ML040680544 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 02/20/2004 |
| From: | Entergy Operations |
| To: | NRC Region 4 |
| References | |
| FOIA/PA-2003-0358 | |
| Download: ML040680544 (12) | |
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A R K A N S A S N U C L E A RO E UNITS 1 AND 2 1
1 10 CFR 50 APPENDIX R FIRE PROTECTION REVIEW I
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UNIT 1 MODIFICATIONS DETAILS FIRE ZONE:
2f09 AND 1Mf-10. YARD MAOLES
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_W Co Both of these fire zones contain the redundant cables associated with the ANO-1 diesel generator fuel oil transfer pumps.
These pumps are required to transfer oil from the ANO-1 fuel oil storage tank to each of the diesel generator day tanks.
Modifications will be made involving crossties to the ANO-2 fuel transfer pumps so that the AND-2 pumps can be used if a fire in either of these zones were to cause loss of both ANO-1 diesel fuel transfer. pipsa_.Such-pumps-wl-ll-not be required-tWlwc lon at t
east 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of shutdown operation allowing sufficient time for transfer to ANO-2 pumps.
These modifications are described in more detail in Appendix B to this report.
Since these modifications are in effect providing an alternate shutdown capability for this zone, as well-as other zones, Appendix B also provides the pertinent information in response to the NRC request for certain details related to alternate shutdown means.
With these modifications this zone will comply with Appendix R.
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4 b~H A R K A N S A S N U C L E A R O N E UNITS 1 AND 2 10 CFR 50 APPENDIX R FIRE PROTECTION REVIEW I
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~~UNIT 1
1 EXEMPTION DETAILS FIRE ZONE:
1H104 and 11G06, YARD AREA MANHOLES 4
A.
AREA DESCRIPTION The manholes are poured concrete construction bunkers that-are I
I
'7approximately 5 feet by 5 feet by 5 feet. :The manhbles contains 1
exposed cables as cabling passes from conduit in one duct bank to 1
I the next duct bank.
These manholes are located as shown in Figure 1 '*t;;
I lO.. The..manhole. bunker is elevated approximately 6rinches above
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tthe surrounding grade.
The manholes are not ventilated and are 1
not normally accessed.
During plant operations there is normally 1
no reason to access these areas.
Access to the areas requires 1
lifting the large concrete cover with a crane.
l B.
SAFE SHUTDOWN CAPABILITY I
11*04 and 1M106 contain the power cables for the red and swing service water pumps.
If th2 green service water pump were out of I
service for an extended period as allowed by the Technical I
Specifications, either the red or swing.service water pump would be required to achieve and maintain hdt shutdown as well as cold
.shutdown.
The service water pump power cables are a type using I
neoprene jacketing.
C.
FIRE HAZARD ANALYSIS These zones contain no combustibles other than cable insulation.
j IMN04' has 61,000 btu's of cable insulation (approximately 5 1
pounds); and zone 1MH06 has 937,000 btu's of cable insulation I
(approximately 78 pounds).
These zones contain no ignition 1
sources.
Since the cabling has been flame tested as described in 1
Appendix C, it is therefore difficult to ignite without a large I
exposure source.
Introduction of transient combustibles into this 1
area is extremely remote due to the lack of the need for such I
access during plant operations and the difficulty of access.
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ZagM zo FRAV4 AS POWER AND UGHT COMPANY CANSAS NUCLEAR-ONE UNIT I
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ARtAHSASNUCLEAR O NE:
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'UNITS-1 AND 2
,..;10 CFR 50 APPENDIX RFIRE'PROTECTIONA-REVIEW-
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STATUS OF F I -.*
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- ' ZONE ;.<-.<...APPEN)IX.R4:...NEED I 1':
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- 120E 125E 128E 129F 14EE 1440 I
149E 157B 1598 116Y 1608 1161B 162A 1638 1678;.
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A R K A N S A S N U C L E A R O N E l
10 CFR UNITS 1 ANO 2 Z
010 CFR S APPENDIX R FIRE PROTECTION REVIEW I
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- ZONE I
K BAIS FOR COMLIANCE A',.
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- E North Emergency Diesel -.
Contains no.redundant safety.
. I Generator Exhaust Fans (EL-386)-
equipment or cables nor" I
s X ; ; ;*.associated circuit concerns.
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lHH03 Manhole between'Auxiliary Contains no redundant safety I
t Building and'intake structure equipment or cables nor,63 A
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>* associated. circuit concerns';'$I
- A HOS Contains no redundant safety.
Building and intake structure equipment or cables nor J
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-l associated circuit concerns.-
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I 10EE East Decay Heat Removal.
Contains no redundant safety I
I Pump Room (EL 317) equipment or cables nor I
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associated circuit concerns.
I 104S Electrical Equipment Room Redundant safety system in I
(EL 368) zone not required for hot/cold I shutdown.'I 1
105T South Lower Electrical Contains no redundant safety i
I Penetration Room (EL 374'-6")
equipment or cables nor I
I associated circuit concerns.
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.OL South Battery Room (EL 372)
Contains no redundant safety I
equipment or cables nor I
associated circuit concerns.
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115C Lube Oil Tank Room (EL 354)
Contains no redundant safety 1
I equipment or cables nor I
I associated circuit concerns.
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12EE Tendon Gallery Access Area Contains no redundant safety I
I (EL 317) equipment or cables nor I
I associated circuit concerns.
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l20E Boric Acid Addition Tank Contains no redundant safety I
I and Pump Room (EL 386) equipment or cables nor I
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l associated circuit concerns.
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I A R K A H S A-S-H U C L E A R O E -
UNITS 1 AND 2 10 CFR 50 APPENDIX R FIRE PROTECTION REVIEW SECTION 3 ZONES THAT WILL 'SATISFY APPENDIX R.
FOLLUWING OUIFICAILONS.
The evaluation that vas perfoed t odeternine-,the7crpli>^.-I hrkansas Nuclear One,, Units 1-and 2.with the',requirements'of.1DC.FR:SO
"'Appendix R identified:several fire.zones that did not.fully.couly with
-the requirements of.Appendix R. For certain. of these fire zones -
I exemptions'are beingsrequested as deicrlibed..in'Se tionA4.09ofthls~'
.- report.
For the remaining:zones that Ldo not*.presently.'cmply+twith:.^.
.,..;Appendix.R, modifications can be`..tade-yto'bringb"the.zones into"'
compliance.with the requirementsof Appendix Rl-'The following provides a brief descri ption of modifications.that.wil1 esImade toathose fire;.
zones. Where alternate shutdown capability.is' hbeing relied upon to > _
I-brlngthezoneinto compliance viith.1O' tFR 50 ':endix7~
Rihe.
modifications and plant features to provide this alternate shutdown capability are described in Appendices'A-& B.
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A R K A H S A S H U C L E A R O N E UNITS I AND 2 10 CFR 50 APPENDIX R FIRE PROTECTION REVIEW II
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.SE O4 ZO REQUIR1NG EEBTON'.-. 1
- 1S-As a result of the evaluation. perforned-.to ;detemineo.-acpiancewofi" ".v'.,
Arkansas Nuclear One, Units L.aiid 2, with the-requirements of OCFR5*O I.
Appendix'R, several fire'zones-have:been identified,which'do.not fully comply with Appendix R requirements...:For.each'of'these -zoneszan I 'exemption is requested herein,.and a:decription of the specific exemption including justification for..the.'fire..protection'.features':,
Iavailable-is provided.
For some of these:fire'zones significant modifications have been'made to enhance -fire protectlon.features in'"
order to bring'these zones into partial-compliance with Appendix R requirement yet provide a commensurate level of fire protection.
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I-A R K A N S A S N U C L E A R ON E UNITS 1 AND 2 10 CFR 50 APPENDIX R FIRE PROTECTION REVIEW UNIT I EXEMPTION DETAILS FIRE ZONE:
20Y, RADWASTE PROCESSING AREA U?7 0
A.
-AREA DESCRIPTION This zone generally is a large area (over 9;000 square feet) at.
elevation 3356 of the Auxiliary Building that contains primarily radwaste processing components and equipment (see attached photographs). Most locations in this zone do not contain safe shutdown components however, there are two areas where safe Icoonents a ei'cate~dizi thijs 1ii'izonne One is in the area of the makeup pump rooms and an adjacent corridor where cables associated with the makeup pumps are located.
Figures 20-1 provide a sketch of the makeup pump room area and adjacent corridor.
This area has a 17 foot ceiling; certain walls are only partial 8 foot high walls while the' remainder-are ful-l height.
The pump cubicles are approximately'10 feet by 20 feet each.
The' walls are reinforced concrete construction, except as noted in Fibure 20-1.
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Il The other area-in this fire zone containing safe shutdown equipment is in the Treated Waste Monitor Tanks Room, which contains the two redundant borated water storage tank dropline valves (See Figure 20-2).
This room is approximately 37 feet by 34 feet with a 17 foot ceiling.
The two areas containing safe shutdown components are generally open and uncongested (See photographs).
B.
SAFE SHUTDOWN-CAPABILITY
- Makeup Pump Area:
... 1 Figure 20-1 illustrates 4the makeup pump location, and routingtadM-0 l separation maKeup pump c1bres. No iable trays are acediWThe makeup pump rooms or in the adjacent corridor areas.- At least one' makeup pump is required in order to achieve and maintain safe PAGE 9 of S2 I
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-.. !....1 A R K A N S A S N U C L E A R O N E II UNITS 1 AND 2 1
10 CFR 50 APPENDIX R FIRE PROTECTION REVIEW I
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l shutdown.
Since one of the three makeup pumps may be out of service for an extended period, separation must be provided so 1
that fire damage is limited to only one makeup pump.
I Treated Waste Monitor Tank Room:
Figure 20-2 illustrates the location of the BWST dropline valves, I
and the routing and separation of cabling for these valves.
All cables in this room are routed -in conduit; no in-situ combustibles l
are located in this room. At least one of these BWST dropline I
valves is required in order to provide a source of water for I
charging and boration with the makeup pumps to achieve and I
maintain hot shutdown with loss of offsite power.'
C.
FIRE HAZARD ANALYSIS I
keup-Pqmp-Area:
.1 The makeup pumps each contain approximately 10 gallons of lube I
oil.
In order to assure that the contents of an oil'spill are contained within a makeup pump cubicle, floor drains are: provided.
I Theres are no combustibles in the east corridor outside the makeup' pump rooms where the makeup pump cables are located in conduit.
I The transient combustible that must be considered for this l
corridor is 10 gallons of lube oil used for servicing the makeup pumps.
'I The makeup pump cables in this corridor are for the A and C makeup I
pump suction valves and are separated by less than one inch.
I Since the cables are well off the floor, damage due to a fire in transient combustibles is unlikely. To assure that a fire does 1
not cause loss of both the A and C makeup pumps, a 1-hour i
fire-barrier will be provided to enclose cables required for the A and C makeup pumps.
The storage cabinet in this corridor used for storage of small 1
amounts of flammable liquids will be moved to a fire zone that '
does not contain redundant safe shutdown components.
' 1 combustibles would'be introduced into the makeup pump cubicles or in -the east corr.idor. to. support. maintenance operations; however, the maximum amount of transient combustible that could reasonably be introduced into this zone is 10 gallons of lube oil.
The I
partial height (8 feet) walls separating the pump cubicles will I
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I UNITS 1 AND 2
I 10 CFR 50 APPENDIX R FIRE PROTECTION REVIEW I
serve as a radiant energy shield for adjacent components, and l
allow heat generated by a fire in a pump cubicle to be dissapated into the larger volume of zone 20Y.
.1 The makeup pump room contamination levels and health physics l
requirements restrict the access to these areas and results in I
minimal personnel entry during operations.
However, the fire brigade would be able to enter these cubicles within 5 minutes of I
a fire alarm in the control room.
I Treated Waste Monitor Tank Room:
There are no in-situ combustibles located in this tank room.
The only combustible that could be considered for a fire in this room is a small amount of transient material used for maintenance.
The BWST valves are actually located below an opining into zone 67U.
--Zone-671U-does--not contain any tedgiianciesdreq ri for safe shutdown.
The only exposure fire would be from transient combustibles.. Due to the proximity of the BWST valve cable conduit to each other, a 1-hour fire barrier-will be installed to protect one of the conduits. Due to the height off the floor and the separation between these valves, it is not judged that these valves would be damaged by an exposure fire below them. However, sprinkler protection will be provided for these valves.
D.
FIRE PROTECTION - EXISTING OR COMMITTED Makeup Pump Rooms:
The makeup pump rooms each contain 6 ionization type smoke detectors.
Portable extinguishers and hose stations are located outside of the pump rooms providing ready access for -fire fighting. As noted above, the walls separating the pump rooms will act as a radiant heat shield.
The corridor east of the pump rooms contains a hose station and several extinguishers.
In addition ionization type smoke detectors are located in this corridor.
As noted above, a 1-hour fire barrier will be provided to enclose cables required for operation of one of the two makeup pumps that have cables located in this-corr4dor.... -
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A R K A N SAS A
U C L E A R O N E UNITS 1 AND 2 10 CFR 50 APPENDIX R FIRE PROTECTION REVIEW Treated Waste Monitor Tank Room:
This room contains 4 ionization type smoke detectors, and has portable extinguishers and hose stations nearby outside of the room as well as in zone 67U, for use in promptly suppressing any fires that may occur in transient combustibles.
E.
SUMMARY
OF AND BASIS FOR EXEMPTIONS For this fire zone, three types of exemptions are requested:
- 1.
Omission of a 1-hour fire barrier and automatic suppression system for the makeup pump rooms; these rooms contain redundant components separated by less than 20 feet;
- 2.
Omission of a sprinkler system'for the corridor east of the makeup pump-twofurs, th iscorridor cdfitahinis-edu-iid'idt components separated by less than 20 feet but with a 1-hour barrier to be installed enclosing cables for two makeup I
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- 3. Omission of a 1-hour fire barrier for the BWST valves in the Treated Waste Monitor Tank Room; cables and valves are separated by less than 20 feet but with a 1-hour barrier to be installed enclosing the conduit for one of the valves.
Sprinkler protection will be provided to protect these valves.
.With the existing floor drains, the walls separating makeup pump cubicles that serve as radiant heat shields, the large size of zone 20Y, the ability for heat from a makeup pump fire to be dissipated into the general open area of zone 20Y, and the capability to promptly detect and suppress fires in the pump rooms, 1-hour fire barriers and an automatic suppression system are not deemed to be required to preserve at least one makeup pump for a fire in one makeup pump cubicle.
Due to the lack of in-situ combustibles in the corridor east of the makeup pump rooms, the height of the makeup pump conduit off of the floor, the ceiling height above the conduit, the ventilation flow through the corridor, the addition of an 1-hour fire barrier to the two channels of makeup pump conduit in the I
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I ARKANSAS NUCLEAR ONE UNITS 1 AND 2 10 CFR 50 APPENDIX R FIRE PROTECTION REVIEW l
corridor and the capabilility to promptly detect and suppress I
fires that could occur, the addition of a sprinkler system to this corridor is not judged to be required to preserve at least one makeup pump.
. I Based on the separation of the BWST valves, their height off the floor, the lack of in-situ combustibles, the minimal need for-the introduction of transients into the area, and the low potential for damage to a valve or opreatbr for such small fires, the addition of a 1-hour fire barrier to spearate the redundant BWST valves is not required to preserve the function of one of.these valves.
However, sprinkler protection will be provided to protect these valves.
With the changes and modifications proposed for this zone and the present configuration and protection, at least one.train..ofsafe.
---shutdown equipment will be available to achieve and maintain safe shutdown.
Modifications to fully comply with Appendix R will not enhance fire protection safety for this zone.
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