CNL-15-214, Updated Pages for As-Constructed Fire Protection Report
| ML15280A508 | |
| Person / Time | |
|---|---|
| Site: | Watts Bar  |
| Issue date: | 10/07/2015 |
| From: | James Shea Tennessee Valley Authority |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| CNL-15-214, TAC ME3091 | |
| Download: ML15280A508 (22) | |
Text
Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 CNL-15-214 October 7, 2015 10 CFR 50.48 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Watts Bar Nuclear Plant, Unit 2 Construction Permit No. CPPR-92 NRC Docket No. 50-391
Subject:
WATTS BAR NUCLEAR PLANT (WBN) UNITS 1 AND 2 - UPDATED PAGES FOR UNIT 1/UNIT 2 AS-CONSTRUCTED FIRE PROTECTION REPORT (TAC No. ME3091)
Reference:
Transmittal of Unit 1/Unit 2 As-Constructed Fire Protection Report (TAC No. ME3091)," dated June 24, 2015
[ADAMS Accession No. ML15175A508]
Updated Pages for Unit 1/Unit 2 As-Constructed Fire Protection Report and License Condition 2.C(9) Addition Request (TAC No. ME3091), dated August 27, 2015 [ADAMS Accession No. ML15239A794]
The purpose of this letter is to provide revised pages for the Watts Bar Nuclear Plant (WBN)
Unit 1/Unit 2 As-Constructed Fire Protection Report (U1/U2 FPR) provided in Reference 1 and updated in Reference 2.
By letter dated June 24, 2015 (Reference 1), Tennessee Valley Authority (TVA) submitted the WBN U1/U2 FPR. During a review of the WBN U1/U2 FPR, a number of revisions and updates were identified. Enclosure 1 provides a clean copy of the affected WBN U1/U2 pages submitted in References 1 and 2. Revision bars are included for the affected pages of the FPR.
U.S. Nuclear Regulatory Commission CNL-15-214 Page 2 October 7, 2015 In addition, based on conversations with NRC staff, it was determined that the description of the WBN U1/U2 FPR records retention requirements needed additional clarification. Per the requirements of 10 CFR 50.48(a)(3), WBN provides document retention for changes in the Fire Protection Program and associated procedures in accordance with the Fire Protection Quality Assurance procedure and applicable parts of the TVA Nuclear Quality Assurance Plan.
Additionally, TVA is proposing a revision to the WBN Unit 2 License Condition 2.C(9) in .
There are no new regulatory commitments contained in this letter. Should you have any questions regarding this submittal, please contact Gordon Arent at (423) 365-2004.
I declare under penalty of perjury that the foregoing is true and correct. Executed on this 7th day of October 2015.
Respectfully, Digitally signed by J. W. Shea J. W. Shea DN: cn=J. W. Shea, o=Tennessee Valley Authority, ou=Nuclear Licensing, email=jwshea@tva.gov, c=US Date: 2015.10.07 19:05:35 -04'00' J. W. Shea Vice President, Nuclear Licensing
Enclosures:
- 2. Revision to Proposed WBN Unit 2 License Condition 2.C(9) cc (w/ Enclosures):
U.S. Nuclear Regulatory Commission, Region II NRC Senior Resident Inspector, Watts Bar Nuclear Plant, Unit 2 NRC Project Manager, Watts Bar Nuclear Plant, Unit 2
Tennessee Valley Authority (TVA)
Enclosure 1 Revised and Updated Pages WBN Unit 1/Unit 2 As-Constructed Fire Protection Report (FPR)
CNL-15-214
PART I - INTRODUCTION TABLE I-1
SUMMARY
COMPLIANCE FIRE PROTECTION Revision XXX CSD Repairs Safe Automatic Automatic Combustible Deviation Evaluation Fire Rated req'd in any III.G Shutdown Detection Y/N, Suppression Load, Fire Number in Number in Room Number and Name Wraps room due to Compliance Equipment or Partial Y/N, Partial Severity Part VII Part VII (Note 6) fire in room for HSD Cables Y/N (Note 6) (Note 6) (Note 6) (Note 6) (Note 6)
(Note 7)
FIRE AREA 1-2:
692.0-A19 - Safety Injection Pump Yes Yes Yes No Insignificant 2A-A FIRE AREA 2-1:
676.0-A10 - RHR Pump Room 1B-B Yes Yes, Partial No No Insignificant FIRE AREA 2-2:
676.0-A13 - RHR Pump Room 2B-B Yes Yes, Partial No No Insignificant FIRE AREA 3-1:
676.0-A11 - RHR Pump Room 1A-A Yes Yes, Partial No No Insignificant FIRE AREA 3-2:
676.0-A12 - RHR Pump Room 2A-A Yes Yes, Partial No No Insignificant FIRE AREA 4:
692.0-A6 - Turbine Driven Auxiliary Yes Yes Yes No Insignificant Feedwater Pump 1A-S FIRE AREA 5:
692.0-A7 - Unit 1 Penetration Rm 3.1.1.a, Yes Yes, Partial Yes, Partial No Insignificant 1-G 7.1.3.1 FIRE AREA 6:
692.0-A10 - Charging Pump Room Yes Yes, Partial Yes, Partial No Low 3.1.1, 7.1.3.1 1-G, 1-O 1B-B FIRE AREA 7:
692.0-A11 - Charging Pump Room Yes Yes, Partial Yes, Partial No Low 1C I-8
PART I - INTRODUCTION TABLE I-1
SUMMARY
COMPLIANCE FIRE PROTECTION Revision XXX CSD Repairs Safe Automatic Automatic Combustible Deviation Evaluation Fire Rated req'd in any III.G Shutdown Detection Y/N, Suppression Load, Fire Number in Number in Room Number and Name Wraps room due to Compliance Equipment or Partial Y/N, Partial Severity Part VII Part VII (Note 6) fire in room for HSD Cables Y/N (Note 6) (Note 6) (Note 6) (Note 6) (Note 6)
(Note 7)
FIRE AREA 68:
692.0-A23 - Charging Pump 2A-A Yes Yes, Partial Yes, Partial No Moderate 3.1.1 FIRE AREA 69:
692.0-A26 - Turbine Driven Aux Yes Yes Yes No Low Feedwater Pump 2A-S Room FIRE AREA 70:
3.1.9.a; 692.0-A25 - Unit 2 Penetration Room Yes Yes, Partial Yes, Partial No Insignificant 2-G, 2-O 8.3.3 FIRE AREA 71:
713.0-A19 - Unit 2 Penetration Rm Yes Yes Yes No Moderate 3.1.10, 3.2 2-O 713.0-A21 - Unit 2 RB Access Room No No No No Insignificant 3.1.10 FIRE AREA 71-1:
713.0-A20 - Unit 2 Volume Control 3.1.10a, 3.5 Yes Yes Yes, Partial No Insignificant 2-O Tank Room & 8.4.2 FIRE AREA 72:
737.0-A10 - Air Lock No No No No Insignificant 2.9.6 3.1.11 729.0-A11 - Unit 2 South Main Steam Yes No No No Insignificant 2.9.6 3.1.11 Valve Rm FIRE AREA 73:
729.0-A10 - Unit 2 North Main Steam Yes No No No Insignificant 2.9.5 3.1.12 Valve Rm 729.0-A13 - Unit 2 North Main Steam Yes No No No Insignificant 2.9.8 3.1.12 Valve Instrument Room B Unit 2 Additional Equipment Building (U2-AEB) (Rooms 729.0-A15, 737.0- Yes Yes, Partial No No Low 2.9.9 A14, and 763.5-A2)
I-23
PART II - FIRE PROTECTION PLAN 150% capacity (3750 gpm) at not less than 65% rated pressure (81 psig/187-foot head). The electric pumps are located in the seismic Category I Intake Pumping Station (IPS). A three-hour fire-rated barrier is provided to separate two electric fire pumps from the other two. The diesel fire pump is remotely located in the Yard adjacent to the Unit 1 cooling tower.
The WBN fire protection system has four electric driven pumps and one diesel driven pump. As defined in Section 14.2.a below, fire protection functionality is based on only two of the four electric pumps and the diesel driven pump. The other two electric driven pumps are considered spares for fire protection purposes. The four electric pumps and associated main piping headers are ASME Section III, seismic class I available for supplying auxiliary feedwater during a design basis event (i.e., Flood Mode). During Flood Mode two electric pumps are aligned to each train header. Details of the Flood Mode are documented in several places in the FSAR such as Section 2.4.14.2, Plant Operation During Floods Above Grade. The ASME and seismic requirements are beyond the requirements of the NFPA Code and are not required for fire protection purposes.
The electric pumps are automatically started by activation of the fire detection systems associated with the automatic water-based suppression systems. The electric pumps can be started manually from either the main control room or the respective 480V shutdown board.
The diesel pump is auto-started on low system pressure, manually from the Main Control Room or manually locally.
Each electric fire pump motor is powered from a separate 480V shutdown board. In the event of loss of offsite power, each shutdown board is powered by an emergency diesel generator.
Indications of fire pump motor running and loss of line power on the line side of the switchgear are provided in the Main Control Room (MCR). Required annunciation signals for the diesel fire pump and its controller are automatically transmitted to the MCR.
Inspection of the strainers for the electric pumps is included in the WBN Preventative Maintenance Program. A single, automatic, motor-driven, self-cleaning strainer is provided for each power train to filter the discharge flow of the two electric pumps on that train. Each strainer is capable of straining 100 percent of the rated flow of two pumps. The strainers are located in the IPS. The strainers conform to the requirements of ASME Section III, Seismic Category I components. Mechanical screens are provided in the suction of the diesel fire pump and a strainer on the discharge.
Water supply for the electric fire pumps is taken from the Tennessee River and is considered unlimited for fire protection purposes. The diesel fire pump takes suction from the Unit 1 cooling tower basin, which has sufficient capacity for the diesel fire pump to run at 150% capacity for two hours. A fire protection water distribution system is provided to serve both units. Sectional isolation valves are provided so that maintenance may be performed on portions of the loop while maintaining firefighting capability. The sectional isolation valves in the underground and building loops are locked or sealed in position and surveillance is performed to ensure proper system alignment. The train headers that are routed from the IPS directly to the Auxiliary Building, that also serve as the flood mode supplies, are provided with isolation valves in the seismically constructed IPS and Auxiliary Building, but not in the underground portions of these headers. The fire protection water distribution system is crosstied between units. The HPFP system is normally pressurized by the raw cooling water (RCW) system when the fire pumps are not running. The RCW system is automatically isolated when a fire pump starts.
The high pressure fire protection system is shared with the raw service water (RSW) system.
Automatic isolation valves are provided to isolate selected large raw service water loads from II-32
PART II - FIRE PROTECTION PLAN biocide controls slime, which helps prevent MIC growth. This provides the most effective treatment that a nuclear plant may use to prevent corrosion in raw water systems.
12.2 Standpipes, Hose Stations, and Hydrants Hydrants are located around the yard loop and provide coverage for exterior portions of significant structures. Normally open key operated curb valves or post indicating valves are provided for isolation of each hydrant off the yard loop. Motorized apparatus at WBN is provided with sufficient equipment to effectively fight fires in the yard area.
Interior manual hose installations are provided throughout the plant, typically as back up for the area automatic suppression systems, and, in some cases, as the primary suppression system.
The Unit 1 and Unit 2 Reactor Buildings and the Intake Pumping Station use fixed, installed systems (hose stations and some automatic suppression) as the primary suppression systems supplied from one main supply header. Hose stations from an adjoining area serve as the backup suppression system supplied from a separate, independent main supply header.
Specifically for the Units 1 and 2 Reactor Buildings, selected hazards in the Reactor Buildings have automatic suppression systems protecting specific hazards, but they are supplied from the same header as the primary suppression systems (the hose stations). These hazards include closed head water spray systems installed for each reactor coolant pump (RCP) and preaction sprinklers in the annulus that serve as water spray on select cable concentrations and prevent specific cable interactions. The backup suppression system for the Reactor Buildings is from hose stations in the Auxiliary Building supplied from a separate, independent main supply header. For the Intake Pumping Station, one area has an automatic preaction sprinkler system protecting specific hazards of transformers and switchgear, but it is supplied from the same header as the primary suppression systems (the hose stations). The backup suppression system for the Intake Pumping Station is from the yard hydrant nearby the Intake Pumping Station supplied from a separate, independent main supply header. In addition to the above, the fixed, installed primary suppression systems supplied from one main supply header within the Reactor Buildings and the Intake Pumping Station are provided with common header isolation valves that will allow for back-feeding the automatic suppression or the hose station systems.
Selected areas in the Diesel Generator Building (DGB) have automatic CO2 and preaction sprinkler systems as primary protection with the standpipe system serving as the backup system in these areas. In areas of the DGB without automatic suppression, the standpipe system serves as the primary system, with yard hydrants providing the backup system. The primary and backup for the Diesel Generator Building's Conduit Interface Room is from yard hydrants. The design of manual hose stations were hydraulically verified per the guidelines of NFPA 14 (Part II, Reference 4.4.13). The Diesel Generator Building (DGB) has two feeds from the fire protection water distribution system. One line feeds the fire suppression system and the other line feeds the standpipe and hose system.
Hose stations in safety-related areas of the plant are supplied from risers separate from those for the preaction sprinkler systems providing general area protection serving the same area.
One exception is the Reactor Buildings in which both the hose station flow control valves and the automatic suppression system flow control valves are supplied from a single header for the systems in the respective Reactor Building.
Class II and III Hose stations are equipped with nozzles rated for the hazards present and with a sufficient amount of hose to support firefighting needs in that area. Hose station equipment may, alternatively, be staged adjacent to or at the access to areas/locations to facilitate II-34
3.9 FIRE AREA 5 3.9.1 Room 692.0-A7
==
Description:==
Unit 1 Penetration RM Fire Loading: The combustibles located in the room consist of the lube oil and grease associated with the fans, pumps, and valves and the plastics associated with the electrical panels and boxes and lights. The fire severity is classified as insignificant.
Compartmentation: The room is of reinforced concrete construction.
Barriers:
FPR Figure Regulatory Room Direction Adjacent Area/Room Reference Barrier Rating 692.0-A7 NORTH WALL Area 61, Reactor Building II-28A 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> SOUTH WALL AREA 1, ROOM 692.0-A1 II-28A 2 HOURS AREA 1, ROOM 692.0-A9 II-28A 2 HOURS AREA 1, ROOM 692.0-A8* II-28A 2 HOURS AREA 4. ROOM 692.0-A6 II-28A 2 HOURS 692.0-A7 EAST WALL AREA 1, ROOM 692.0-A1 II-28A 2 HOURS (continued) AREA 1, ROOM 692, 0-A8* II-28A 2 HOURS CEILING AREA 1, ROOM 713.0-A28 II-28A, II-29A 2 HOURS AREA 9, ROOM 713.0-A6 II-28A, II-29A 2 HOURS AREA 9-1, ROOM 713.0-A7 II-28A, II-29A 2 HOURS FLOOR (Partial) AREA 1, ROOM 676.0-A16 II-28A 2 HOURS
(*ENTRANCE LABYRINTH WALLS AND CEILING)
Doors:
Door FPR Figure Room Adjacent Area/Room Door Rating Number Reference 692.0-A7 A26 Area 1, Room 692.0-A1 II-28A 1.5 Hours A27 Area 1, Room 692.0-A8 II-28A 1.5 Hours Dampers:
Damper/Mark Drawing Damper Room Adjacent Area/Room Number Reference Rating 692.0-A7 1-ISD-31-3801 AREA 1, ROOM 676.0-A16 47W866-8 3 HOURS 47A381-442F 47W920-2, 18 1-ISD-31-3802 AREA 1, ROOM 692.0-A1 47W866-2 3 HOURS 47A381-393F 47W920-2 1-ISD-31-3925 AREA 9, ROOM 713.0-A6 47W866-8 3 HOURS 47A381-397F 47W920-2, 4 1-ISD-31-3988 AREA 1, ROOM 692.0-A8 47W866-2 3 HOURS 47A381-619F 47W920-2 Detection: Ionization smoke detection is provided in the room except for the RHR Valve Vault.
Suppression: An automatic, preaction suppression system is provided for the room except for the RHR Valve Vault. A standpipe and hose station is provided in the adjacent room (Corridor 692.0-A1).
Deviations: None.
Evaluations: The lack of detection and suppression in the RHR Valve Vault is documented in Part VII, section 3.1.1.a. The Unit 1 evaluation for performing a manual action in the room of fire origin is documented in Part VII, section 7.1.3.1.
3.76 FIRE AREA 70 3.76.1 Room 692.0- A25
==
Description:==
Unit 2 Penetration Room Fire Loading: The combustibles located in the room consist of lube oil and grease associated with fans, pumps and valves and plastics associated with electrical panels, boxes and lights, and rubber hoses. The fire severity classification is insignificant.
Compartmentation: The room is bounded by regulatory fire barriers constructed of reinforced concrete.
Barriers:
Regulatory FPR Figure Room Direction Adjacent Area/Room Barrier Reference Rating 692.0-A25 North Wall Area 77, Unit 2 Reactor Building II-28A 3 Hours South Wall Area 1, Room 692.0-A1 II-28A 2 Hours Area 65, Room 692.0-A24 II-28A 2 Hours Area 69, Room 692.0-A26 II-28A 2 Hours West Wall Area 65, Room 692.0-A24 II-28A 2 Hours Ceiling Area 65, Room 713.0-A29 II-28A, II-29A 2 Hours Area 71, Room 713.0-A19 II-28A, II-29A 2 Hours Area 71-1, Room 713.0-A20 II-28A, II-29A 2 Hours Doors:
Door FPR Figure Door Room Adjacent Area/Room Number Reference Rating 692.0-A25 A44 Area 1, Room 692.0-A1 II-28A 1.5 Hours A45 Area 65, Room 692.0-A24 II-28A 1.5 Hours Dampers:
Damper Mark Drawing Damper Room Adjacent Area/Room Number Reference Rating 692.0-A25 2-ISD-31-3861 Area 65, Room 692.0-A24 2-47W866-11 3 Hours 47A381-396F 47W920-2, 3 2-ISD-31-2930 Area 65, Room 692.0-A24 2-47W866-8 3 Hours 47A381-402F 47W920-2, 3 2-ISD-31-3862 Area 1, Room 692.0-A1 2-47W866-11 3 Hours 47A381-393F 47W920-2 Detection: Ionization smoke detectors are provided in the room except for the RHR Valve Vault.
Suppression: An automatic, preaction suppression system is provided in the room except for the RHR Valve Vault. A standpipe and hose station is available from the adjacent room (692.0-A1).
Deviations: None.
Evaluations: The lack of detection and suppression in the RHR Valve Vault is documented in Part VII, section 3.1.9.a. The feasibility and reliability evaluation for Unit 2 Operator Manual Action in 692.A25 is documented in Part VII, Section 8.3.3.
PART VII - DEVIATIONS AND EVALUATIONS The room and entrance labyrinth is enclosed by reinforced concrete construction that is equivalent to at least 2-hour fire rated barriers. The in situ combustible loading for the room is insignificant. The room is a radiological controlled area and access is administratively controlled. No significant quantities of transient combustibles are anticipated in the rooms during power operation.
In the unlikely event a fire did occur in the labyrinth, it is detected by smoke detectors located in the room. The sprinklers in the room provide containment of the fire until the fire brigade responded to extinguish it.
The combination of fire rated construction, insignificant in situ combustible loads, and installed fire detectors and suppression systems provide a level of fire protection that is adequate.
Additional suppression in the entrance labyrinth of the room is not required for protection of the safe shutdown capability in the area.
Rooms 692.0-A29 and 692.0-A.30: Boric Acid Evap Package Rooms A and B As concluded in Section 2.9.1.4 above, there is an insignificant fire threat to FSSD equipment in this location or adjacent rooms. Therefore it is concluded that no additional suppression or detection is required in this location due the insignificant threat of a fire.
Remaining Rooms of Fire Area 1 Without Full Detection and/or Suppression The remaining rooms in the tabular list of Fire Area 1 rooms without full detection and/or suppression capability do not contain any equipment or cables required for fire safe shutdown.
Each of the rooms has a combustible loading that result in an equivalent fire severity classification of insignificant except 676.0-A5 and 692.0-A31 which are low. Based on the lack of safe shutdown equipment and cables, combined with the low fire loading in each of the rooms, an adequate level of protection is currently provided. The addition of automatic detection and/or suppression in the rooms is not required for protection of the safe shutdown capability in the area.
3.1.1.a Fire Area 5 Room 692.0-A7 (Unit 1 Penetration Room)
The general area of Room 692.0-A7 is provided with automatic suppression and detection.
Within this room is an enclosure for the Unit 1 Containment Spray and RHR Valve Vault, 1-FCV-63-72-A, 1-FCV-63-73-B, 1-FCV-72-44-A, and 1-FCV-72-45-B. One section of the enclosure is provided for the A-train valves and a second section for the B-train valves. The enclosure is of reinforced concrete construction with a heavy steel hatch covering the access opening. The walls, ceiling and floor for this enclosure are greater than 6 inches thick and with a steel liner.
The steel hatch is approximately 54 inches in diameter and designed for a pressure of greater than 21 psi. This enclosure is part of room 692.0-A7, but is not provided with automatic suppression and detection.
The combustible loading in each section of the enclosure consists of the valves lubricant. The electrical circuits to the valves are not considered ignition sources because they are protected by circuit protection (breakers, fuses) that are designed to clear an electrical fault before the cable reaches its auto-ignition temperature. Therefore, since there are no exposed VII-114
PART VII - DEVIATIONS AND EVALUATIONS combustibles and no credible ignition sources, there is no credible fire hazard in the enclosure and the lack of suppression and detection is acceptable. These rooms are accounted for in the fire safe shutdown analysis of room 692.0-A7 (Analysis Volume 18). There are no OMAs associated with the valves in this enclosure.
Thus the lack of detection or suppression in the enclosure does not impact safe shutdown capabilities of the plant.
3.1.2 Fire Area 8 The following table identifies those rooms in Fire Area 8 that have less than full detection and/or full suppression capability as required by Section III.G.2.b and/or III.G.2.c criteria.
FSSD Rooms Description Detection Suppression Component 713.0-A1(*) Aux Bldg, Boric Acid Area Yes Yes (Partial) Yes 713.0-A1(*) Demin and Fltr Enclosure No Yes (Partial) None 713.0-A1(*) Boric Acid Fltr Enclosures No Yes (Partial) None 713.0-A1(*) Ion Exchgr, Demin & Fltr No Yes (Partial) None 713.0-A1(*) Demineralizer and Fltr No Yes (Partial) None 713.0-A9 Unit 1 Mixed Bed and No No None Cation Valve Gallery 713.0-A10 Seal Water Hx Room 1A No No None 713.0-A11 Hx Room 1B No No Yes 713.0-A12 Hx Room 1A No No Yes 713.0-A15 Hx Room 2A No No Yes 713.0-A16 Hx Room 2B No No Yes 713.0-A17 Seal Water Hx Room 2A No No None 713.0-A18 Unit 2 Mixed Bed and No No None Cation Valve Gallery 713.0-A23 CVCS Valve Gallery No No None 713.0-A24 WGC Valve Gallery No No None 713.0-A25 Waste Gas Compressor B No No None 713.0-A26 Waste Gas Compressor A No No None 713.0-A30 Air Lock No No None 713.0-A31 Waste Gas Analyzer Rm No No None As shown in the above listing, of the rooms within Fire Area 8 that do not have full detection and suppression capability, only five have any equipment or cables that are required for FSSD.
(*Room 713.0-A1 has full detection and suppression except for the boric acid tank area between column lines A11-A13/Q-R, which only has detection, and the filter and demineralizer units inside concrete monolithic enclosures, which are not provided with detection or suppression.)
Evaluations of each of the rooms with FSSD capabilities follow.
Room 713.0-A1: Auxiliary Building Room (Boric Acid Tank Area)
The general floor area on elevation 713.0 is provided with fire detection and automatic suppression except for the portion of the room over the boric acid transfer pumps, tanks, and filters located between column lines A11-A13/Q-R which is not provided with automatic suppression.
VII-115
PART VII - DEVIATIONS AND EVALUATIONS An adequate level of fire protection is provided for redundant FSSD components in the two rooms. Extension of the suppression systems into the small unprotected areas is not required for protection of the safe shutdown capability in the area.
3.1.9 Fire Area 65:
The below listed rooms in Fire Area 65 have less than full detection and/or full suppression capability as required by Section III.G.2.b and/or III.G.2.c criteria.
FSSD Rooms Description Detection Suppression Component 676.0-A17 Unit 2 Pipe Chase Yes No Yes 692.0-A24 Unit 2 Pipe Chase Yes No Yes 713.0-A29 Unit 2 Pipe Chase Yes No Yes Room 676.0-A17, 692.0-A24, and 713.0-A29: Auxiliary Building Unit 2 Pipe Chase The pipe chase extends from elevation 676.0 to elevation 737.0 and is comprised of Rooms 676.0-A17, 692.0-A24, and 713.0-A29. The pipe chase is separated from other fire zones on elevations 676, 692, 713, and 737 by reinforced concrete construction that is equivalent to at least 2-hour fire rated barriers. Smoke detectors are installed in the pipe chase. The in situ combustible loading of the pipe chase is insignificant.
The pipe chase contains one path of FSSD equipment consisting of a Volume Control Tank (VCT) level transmitter and associated cabling, and cables for narrow and wide range level indication for two steam generators. The redundant path instrumentation is located outside the pipe chase. The chase also contains redundant RHR mini-flow valves and Containment Spray pump suction valves. These valves are required for FSSD only if a fire causes spurious pump actuation of an RHR or Containment Spray pump. Cables that could cause such spurious pump actuation are located outside the pipe chase.
Transient combustibles are minimized in the pipe chase. Rooms 676.0-A17 and 692.0-A24 are locked rooms with access controlled by Radiation Protection personnel. Room 713.0-A29 is a combustible control zone. Based on these considerations, fires involving transient combustible materials are not considered to be a credible event.
The addition of automatic fire suppression in the pipe chase would not significantly enhance the fire protection of FSSD capability of the plant. This is based on the insignificant combustible loading, access limitations and administrative controls to limit the introduction of transient combustible materials, adequate compartmentation, and provision of fire detection in the pipe chase.
3.1.9.a Fire Area 70 Room 692.0-A25 (Unit 2 Penetration Room)
The general area of Room 692.0-A25 is provided with automatic suppression and detection.
Within this room is an enclosure for the Unit 2 Containment Spray and RHR Valve Vault, 2-FCV-63-72-A, 2-FCV-63-73-B, 2-FCV-72-44-A, and 2-FCV-72-45-B. One section of the enclosure is VII-119
PART VII - DEVIATIONS AND EVALUATIONS provided for the A-train valves and a second section for the B-train valves. The enclosure is of reinforced concrete construction with a heavy steel hatch covering the access opening. The walls, ceiling and floor for the enclosure are greater than 6 inches thick with a steel liner. The steel hatch is approximately 54 inches in diameter and designed for a pressure of greater than 21 psi. This enclosure is part of room 692.0-A25, but is not provided with automatic suppression and detection.
The combustible loading in each section of the enclosure consists of the valves lubricant. The electrical circuits to the valves are not considered ignition sources because they are protected by circuit protection (breakers, fuses) that are designed to clear an electrical fault before the cable reaches its auto-ignition temperature. Therefore, since there are no exposed combustibles and no credible ignition sources, there is no credible fire hazard in the rooms and the lack of suppression and detection is acceptable. This enclosure is accounted for in the fire safe shutdown analysis of room 692.0-A25 (Analysis Volume 106). There are no OMAs associated with the valves in this enclosure.
Thus the lack of detection or suppression in the enclosure themselves does not impact safe shutdown capabilities of the plant.
3.1.10 Fire Area 71 Fire Area 71 consists of Rooms 713.0-A19 and -A21. Room 713.0-A19 is provided with full detection and suppression system capability. Room 713.0-A21, the RB Access Room, is not provided with automatic detection or suppression systems. This room contains no equipment or cables that are required for fire safe shutdown. It has a combustible loading that results in a fire severity classification of insignificant.
Based on the lack of safe shutdown equipment and cables, combined with the insignificant fire loading in the room, an adequate level of protection is currently provided. The addition of automatic detection and suppression in the rooms is not required for protection of the safe shutdown capability in the area.
3.1.10a Fire Area 71-1 Fire Area 71-1 (713.0-A20) contains the VCT room itself and the entrance labyrinth into the room. The VCT room is provided with full automatic suppression, but the entrance labyrinth is not. Lack of suppression in the entrance labyrinth is acceptable because there are insufficient in situ combustibles and no credible ignition sources. The combustibles in the labyrinth consists of a small amount of lube oil associated with two valves, insulation on cables in small junction/control boxes, and a small amount of plastics associated with light covers and an emergency lighting unit. Even considering the total quantity of hydrogen that could be in the VCT, the combustible loading for the entire area results in an equivalent fire severity classification of insignificant. Room 713.0-A20 is identified as a combustible control zone (CCZ), which prohibits storage of transient combustible material unless compensatory measures are established. The Control of Transient Combustibles Program (Part II, Reference 4.2.68) and the Control of Ignition Sources (Hot Work) Program (Part II, Reference 4.2.69) provide assurance that no credible fire could occur in the labyrinth. The lack of suppression in the entrance labyrinth does not adversely impact the fire safe shutdown capabilities of the plant.
VII-120
PART VII - DEVIATIONS AND EVALUATIONS access into the rooms in the identified time frames and the ability to perform the requisite manual actions are described in more detail below.
7.2.1 Combustible Materials, Combustible Loads, and Fire Severities Room 692.0-A7, the U1 Penetration Room, has a combustible load that results in a fire classification of insignificant. The majority of the combustible loading is the lube oil and grease associated with the fans, pumps and valves in the room. Room 692.0-A7 is identified as a CCZ in order to control potential storage of transient combustible materials in the room. The valves are located just inside the room near the door to room 692.0-A1A and are next to the wall with easy access.
Room 692.0-A10, the 1 B-B Centrifugal Charging Pump room, has a combustible load that results in an equivalent fire classification of low. Over 95% of the combustible load is due to lube oil in the pump. Access to 692.0-A10 is from Room 692.0-A1 (Auxiliary Building Corridor) which has a combustible load that results in an equivalent fire classification of moderate. Over 90% of the combustible load is due to insulation on cables in cable trays.
Room 713.0-A7 is the Unit 1 Volume Control Tank room. The combustible material in the VCT portion of the room is associated with the maximum quantity of hydrogen which can be in the VCT, assuming that the tank is completely filled with hydrogen and pressurized to 75 psig. In the event of a leak in the hydrogen piping or the VCT itself in excess of 50 scfm, flow of hydrogen is automatically isolated by an excess flow device. Leaks less than 50 scfm are dispersed by the Auxiliary Building Ventilation system, precluding the danger of an explosion.
The labyrinth contains the balance of combustible materials in the room (small amount of lube oil associated with the two valves, insulation on cables in a small junction box and three control boxes, and small amount of plastics associated with seven light covers and one emergency lighting unit). Even considering the total quantity of hydrogen that can be in the VCT, the combustible loading results in an equivalent fire classification of insignificant. In addition, Room 713.0-A7 is identified as a combustible control zone (CCZ), which prohibits storage of transient combustible material unless compensatory measures are established.
The fire severity in the rooms where manual actions may be necessary, especially considering the nature and location of combustible materials in each room, would not preclude the ability to enter the rooms within the identified times. Room 713.0-A7 is a normally locked room, thereby further limiting the potential for introduction of transient combustible materials in the room. The residual heat of a postulated fire in this room should not impact operator actions in the room.
The possibility exists, however, that residual smoke from the postulated fire may require the Operator to wear a self contained breathing apparatus (SCBA); therefore, SCBAs are available for use if needed.
7.2.2 Automatic Detection and Suppression Capabilities Each room is provided with an automatic detection system ensuring prompt notification of the fire brigade to initiate manual firefighting activities if necessary. Each of the rooms is also provided with an automatic suppression system. The only portion of Room 692.0-A7 that is not protected by automatic suppression and detection is the Containment Spray and RHR Valve Vault. There are no OMAs in the valve vault and a fire in the valve vault will not affect the OMAs in the general area of the room. The only portion of Room 713.0-A7 that is not protected by automatic suppression is the entrance labyrinth.
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PART VII - DEVIATIONS AND EVALUATIONS
- g. Portable Equipment No portable equipment is needed for these OMAs.
- h. Personnel Protection Equipment This action is to be performed in a room near the fire location; therefore, the NAUO may be required to use the SCBA, which was obtained when originally mobilized.
- i. Procedures and Training The Appendix R operator manual actions procedures (0-AOI-30.2 series) are clear, complete and current. These procedures are part of the ongoing Operator training.
8.3.2.4 Staffing Requirements for a Fire in Room 692.0-A22 For a fire in 692.0-A22, five Unit 2 actions are performed by three NAUOs and three Unit 1 actions are performed by two NAUOs for a total of five NAUOs. The staffing of eight NAUOs is more than sufficient to accomplish all of the needed Unit 1 and Unit 2 manual actions, should there be a fire in room 692.0-A22.
8.3.3 Room 692.0-A25 (Unit 2 Penetration Room) 8.3.3.1 Fire Prevention The Unit 2 Penetration Room, 692.0-A25 is bounded by 2-hour regulatory fire barriers constructed of reinforced concrete. The openings through these barriers are protected with doors, dampers and penetration seals that have a rating identified in Part VI, Section 3. Room 692.0-A25 has a floor area of 2,003 ft2 and a nominal ceiling height of 19-feet. The combustibles in 692.0-A25 consist of lube oil and grease associated with fans, pumps and valves and plastics associated with electrical panels, boxes and lights. The combustible loading in the room results in a fire severity classification of insignificant.
The potential ignition sources consist of four small recirculating chilled water pumps and two large valves. The chilled water pumps contain less than 1/2-gallon of lubricants each and the valves contain approximately 5-1/2 gallons of lubricant each. None of these are considered credible ignition sources and are not in the immediate vicinity of a significant quantity of combustibles. NPG-SPP-18.4.7, Control of Transient Combustibles and NPG-SPP-18.4.8, Control of Ignition Sources (Hot Work) defines the fire preventive measures to preclude introduction of significant quantities of combustible material or ignition sources into the rooms and the compensatory measures necessary when transient combustibles or ignition sources are in a room.
8.3.3.2 Detection, Control and Extinguishment The Unit 2 Penetration Room is provided with ionization smoke detectors that alarm in the Main Control Room (MCR). Any fire that starts is quickly detected and personnel are dispatched from the MCR to investigate the detector alarm. Portable extinguishers are available for extinguishing any small credible fire. If a larger fire occurs, the installed automatic preaction sprinkler system provided for the room activates. A standpipe and hose station system is also available from the adjacent room (692.0-A1) for fire brigade use. See Section VII-3.1.9.a for an VII-158
PART VII - DEVIATIONS AND EVALUATIONS additional discussion regarding detection and suppression not extending to the enclosure containing the RHR and Containment Spray sump valves within Room 692.0-A25.
8.3.3.3 OMA 1065 - Establish RWST Suction The fire safe shutdown requirement for a fire in 692.0-A25 is to manually open 2-LCV-62-136-B (RWST to Charging Pumps Valve) to establish RWST suction. A fire that is contained within room 692.0-A25 could potentially damage cables (2V2777B, 2M166, 2M162, 2V2767A, 2V2100B, 2V2101B, 2V2102B, 2V1202B, 2V1203A, 2V2070A, 2V2071A, and 2V2072A) requiring implementation of this OMA. The operator must open breaker 2-BKR-62-136-B on 2-MCC-213-B1-B to allow operation of a handwheel. This OMA is completed within 75 minutes and performed in room 772.0-A15.
OMA 1065 is both feasible and reliable based on NUREG-1852 criteria, as follows:
- a. Adequate Time Available to Perform Actions The operator has 75-minutes before the OMA must be completed. The analyzed time estimated to travel and complete the action is 5 minutes. Verification and validation (Part II, Reference 4.2.27) for common 0-AOI-30.2 C series procedures (Part II, Reference 4.2.60) were performed for dual unit operation and documented per the requirements of a common WBN Technical Instruction. Specifically, Technical Instruction, 0-TI-2018, Appendix R Walkdown of Manually Operated Components Required Following a Fire, (Part II, Reference 4.2.61). The demonstrated transit time and time to perform the action was 2 minutes 56 seconds; therefore, there is adequate time to perform the action. A fire in 692.0-A25 would not affect the performance of this OMA.
- b. Adequate Time Available to Ensure Reliability The analyzed time estimated to travel and perform the action (5 minutes) provides 70 minutes
(>500%) margin and the demonstrated validation (2 minutes 56 seconds) provides 72 minutes 4 seconds (>500%) margin which is adequate time to ensure reliability.
- c. Environmental Factors Normal and Standby lighting is provided for the access routes and at the location of this OMA.
If they were unavailable, 8-hour emergency battery pack lighting is provided; therefore, there is adequate lighting to access the local panel and perform the needed OMA. Because the operator does not have to traverse or enter the fire zone, there are no impediments associated with fire suppression or firefighting activities. There are no other adverse environmental factors, such as radiation or temperature, associated with this OMA.
- d. Equipment Functionality and Accessibility By comparison to similar Unit 1 actions (OMA 450), equipment necessary for the manual action is functional and accessible. The fire that results in the fire-induced damage requiring implementation of this OMA is contained in room 692.0-A25.
- e. Available Indications Available local indications for verifying the breaker is open are adequate.
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PART VIII - CONFORMANCE TO APPENDIX A TO BTP 9.5-1 GUIDELINES Revision XXX Appendix A Guidelines Plant Conformance Alternatives Remarks E.3 Water Sprinklers and Hose Standpipe Systems
- a. Each automatic sprinkler system Each automatic sprinkler system and hose The Unit 1 and Unit 2 Reactor Buildings Generally, where installed, fixed and manual hose station standpipe station standpipe is connected to the yard main and the Intake Pumping Station use fixed, automatic suppression systems should have an independent or to headers within the buildings, except for installed systems (hose stations and some are considered the primary connection to the plant each Reactor Building and the Intake Pumping automatic suppression) as the primary system, typically supplied from underground water main. Station (IPS). suppression systems supplied from one one main supply header. Manual main supply header. Hose stations from an suppression systems (standpipe adjoining area serve as the backup and hose stations) are suppression system supplied from a considered backup systems, separate, independent main supply header. typically supplied from a separate, independent main supply header. Where no fixed suppression is installed and/or a building is supplied by only one main supply header for all forms of suppression (Reactor Buildings and Intake Pumping Station), the standpipe and hose station or adjacent fire hydrants are considered the primary system supplied from one main supply header. Other independent standpipe and hose stations or yard hydrants serve as the backup suppression system supplied from a separate, independent main supply header.
For the case of the Reactor Buildings and the Intake Pumping Station, the backup suppression systems are from hose stations in the Auxiliary Building and a nearby yard hydrant respectively, supplied from a separate, independent main supply header.
VIII-43
PART X - NFPA CODE EVALUATION Revision XXX NFPA 72D-1975, "Installation, Maintenance and Use of Proprietary Signaling Systems" TVA System 13 Compliance Summary Matrix Code Section Summary Topic/Remarks 100 N/A Definitions 1110 N/A Application - Title 1111 Comply "Class A" system 1112 through 1113 N/A Emergency operation of Class A systems for manual fire alarm stations and guard tour signals 1120 N/A Title, Central Supervising Structure 1121 Deviation Location of the central supervising station in the Main Control Room, but is not in a room that is separated from the rest of the Main Control Room.
1210 N/A Title, System Operation 1211 Comply System arranged to receive and record all signals, and direct supervised circuit to local fire department not deemed necessary 1212 Comply Recording requirements 1213 Alternative The Fire Alarm Console in the Main Control Room is designed and assembled by the TVA Computer Engineering Group (CEG). The equipment has been evaluated to meet applicable UL listing requirements. For additional information refer to Unit 1 License Condition 2.C(10) and Unit 2 License Condition 2.C(9).
1220 N/A Title, Operating Personnel X-53
PART X - NFPA CODE EVALUATION Revision XXX NFPA 72D-1975, "Installation, Maintenance and Use of Proprietary Signaling Systems" TVA System 13 Compliance Summary Matrix Code Section Summary Topic/Remarks 1242 Comply Signal designation 1243 N/A Sprinkler supervisory signals, See 3423 and 3442.
1244 N/A Transmission over common signaling circuit for fire alarm boxes and supervisory signals.
1250 N/A Title, Disposition of Signals 1251 Deviation Actions upon receipt of selected low threshold fire alarm signal - fire brigade not immediately activated, basis for alarm investigated first.
1252 N/A No guard tours.
1253 Comply Actions upon receipt of supervisory signal.
1254 Comply Actions upon receipt of trouble signal.
1310 through 1322 Comply Circuit arrangement 2010 through 2013 N/A Title, Scope, and general information 2020 through 2021 N/A Title, Approval, and general information 2022 Alternative System components are UL listed except as noted in 1213.
2023 Alternative Except for the Main Control Room Console. For additional information refer to Unit 1 License Condition 2.C(10) and Unit 2 License Condition 2.C(9).
2024 N/A Maintenance agreement 2030 and 2031 N/A Title, Installation and Design, and general information 2032 and 2033 Comply Vibration and grounding requirements 2034 N/A Multiple alarm feature 2035 Comply System restricted for fire protection use only.
X-55
Tennessee Valley Authority (TVA)
Enclosure 2 Revision to Proposed WBN Unit 2 License Condition 2.C(9)
Background
During a review of the Watts Bar Nuclear Plant (WBN) U1/U2 Fire Protection Report (FPR), a question was raised concerning the edition of the National Fire Protection Association (NFPA) code chosen for a design change and the Underwriters Laboratory (UL) standards utilized to test the functionality, safety, and reliability of system improvements made. This design change replaced obsolete equipment used in the WBN Unit 1 and Unit 2 fire detection monitoring panel.
To resolve this question, TVA initiated a condition report (CR) as part of TVA's corrective action program (CAP), to identify the appropriate NFPA code for the design change that installed the fire detection monitoring panel and to document a detailed review of the alignment of the fire detection monitoring panel with the standards of a nationally recognized testing laboratory.
TVA has performed a functional evaluation to assess the current systems functionality, reliability, and maintainability in the context of the existing Fire Protection Report, Supplemental Safety Evaluation Report, and applicable codes and standards. The evaluations preliminary conclusion was that the current system is functional, reliable, and maintainable.
Additionally, TVA proposed License Conditions for WBN Units 1 and 2 to ensure that a listing organization acceptable to the NRC (as the Authority Having Jurisdiction) determines that the fire detection monitoring panel in the main control room either meets the appropriate designated standards or has been tested and found suitable for the specified purpose. To support this, TVA has initiated contractual arrangements with Underwriters Laboratories (UL) to evaluate the components and conduct integrated system testing of the fire detection monitoring panel with the intention to Field-List the panel. TVA will pursue resolution of the above license condition within the corrective action program and design engineering processes to support the license condition proposed date of May 31, 2018.
Subsequent to the letter dated August 27, 2015 (Reference 2 of the cover letter), TVA determined that a revision to proposed WBN Unit 2 Operating License Condition 2.C(9) was required to clarify the action that must be taken by TVA.
Revised Operating License Condition 2.C(9)
(9) By May 31, 2018, TVA shall report that a listing organization acceptable to the NRC (as the Authority Having Jurisdiction) has determined that the fire detection monitoring panel in the main control room either meets the appropriate designated standards or has been tested and found suitable for the specified purpose.
CNL-15-214