ML17213B012
| ML17213B012 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 01/14/1983 |
| From: | Clark R Office of Nuclear Reactor Regulation |
| To: | Robert E. Uhrig FLORIDA POWER & LIGHT CO. |
| References | |
| NUDOCS 8301250642 | |
| Download: ML17213B012 (43) | |
Text
DISTRIBUTION:
~acket File Gray File SAÃ 3.d
>g83 NRC POR L
PDR NSIC No. 50-335 ORBg3 Rdg OEisenhut JHeltemes Or. Robert E. Uhrig OELD Vice President ELJordan Advanced Systems 5 Technology JMTaylor Florida Power G.Light Company ACRS-10 P. 0. Box 529100 PMKreutzer-3 IIiami, Florida 33152 RAClark OS el 1 s
Dear Dr. Uhrig:
RFerguson TWambach
SUBJECT:
DRAFT SAFETY EVALUATION (SE)
ON APPENDIX R EXEMPTION REQUEST The staff has completed.its review of your Appendix R exemption request and has enc)osed its draft SE.
It is requested that yourreview this draft SE for accuracy of technical content and inform us within three weeks of'ny.corrections you consider necessary.
With respect to followup action regarding.exemption denials, there are three options:
(1) appeal denials to NRR management; (2) propose another alternative that requires an exemption; or (3} make modifications to meet the specific requirements of Appendix R.. Please inform us within three weeks regarding which action you plan to take.
Docket If.an appeal meeting is requested, it should be limited to the technical review of the information on the record and should be held within six weeks.
E If, for denied exemptions, you choose to propose an alternative i~hich also requires an exemption,.it should be filed under the'rovisions of Section 50.12 of 10 CFR Part 50. If you choose to propose such an alternative, we request that you do so within 60 days.
If, for denied exemptions, you propose to make modifications that.meet the specific requirements of Section III.G of Appendix R, no additional submittal is necessary unless the modifications are to provide alternative shutdown capability.
In these
- cases, you will be given G months to.provide the description of the modification for alternative shutdown capability.
If you have any questions regarding this. letter or the draft SE, please contact the Project IIanager, D. Sells (301) 492-9735.
830i250642 830ii4 PDR ADOCK 05000335 P
PDR Ak' Sincerely, Original signed by Robert A. Clark Robert A. Clark, Chief Operating Reactors Branch 83 Division of Licensing Enclosur
Draft-SC
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SURNAME$
ORB85:OL TWambach
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NRC FORM 318 (10-80) NRCM 0240 OFFICIAL RECORD COPY USGPO: 1981 339-969 r
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4 Florida Power 8 Light Company CC:
Harold 'F. Reis, Esquire Lowenstein,
- Newman, Reis 8 Alexrad 1025 Connecticut Avenue, N.W.
Washington, D. C.
20036 Norman A. Coll, Esquire McCarthy, Steel, Hector E Davis 14th Floor, First National Bank Building Miami Florida 33131 Mr. Jack Schreve Office of the Public Counsel Room 4, Holland Building Tallahassee, Florida
- 32304 Resident Inspector c/o U.S.N.R.C.
7900 S. AIA Jensen Beach, Florida 33457 Administrator Department of Environmental Regulation Power Plant Siting Section State of Florida 2600 Blair Stone Road Tallahassee, Florida 32301 Mr. Weldon B. Lewis County Administrator St. Lucie County
.2300 Virginia Avenue, Room 104
, Fort Pierce, Florida 33450 U.S.
Environmental Protection Agency Region IV Office ATTN:
Regional Radiation Representative 345 Courtland Street, N.E.
Atlanta, Georgia 30308 Mr. Charles B. Brinkman.
Manag'er - Washington Nuclear Operations C-E Power Systems Combustion Engineering, Inc.
4853 Cordell Avenue, Suite A-1
- Bethesda, Maryland 20014 State Planning and Develpment Clearinghouse Office of Planning and Budgeting Executive Office of'he Governor The Capi tol Bui lying Tallahassee, Florida" 32301 Regional Administrator Nuclear Regulatory Corrmission, Region II Office of Executive Director for Operations
. 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303
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Enclosure
'raft Safety Evaluation'y the Office of Nuclear Reactor,,Regulation Exemption Request St. Lucie, Unit 1 Oocket No. 50-335 1.0 Introduction In our letter of November 24, 1980, we identified the following eight open items that remained from the SER:
3.14 Upgrade existing fire pumps 3.6 Fire door evaluation 3.7 Ventilation duct penetrations 3.9 Cable Spreading Room - fire barrier 3.12.7 Smoke detectors 3.13.3.
Reactor Coolant Pump Oil Collection System 4.1 Safe Shutdown Systems 6.0 Fire Bridage Size and Training By letter dated March 19, 1982, the Licensee committed to reroute the
~redundant fire pump cables.
By letter dated February 11, 1981, the licensee provided a comparison of their fire pump controller to the requirements of NFPA Std.
20.
We have evaluated the Licensee's fire pumps and controllers and find them equivalent to an approved system which meets HFPA Std.
20.
The fire pumps and controllers are therefore acceptable.
We consider that item 3. 1.4 is now closed.
By "L-81-122, Requests Exemption from 10CFR50.48 & App R to 10CFR50 Schedule Dates for Compliance W/Fire Protection Requirements Per 10CFR50.12(a) & [[CFR" contains a listed "[" character as part of the property label and has therefore been classified as invalid.)|letter dated March 19, 1981]], the Licensee committed to install 26 approved fire door assemblies throughout the plant, and requested an exemption for six watertight doors which are not approved fire doors.
We have evaluated thi s request and concl ude that the s ix wa.crt ight doors are acceptabl e in the locations described due to the light combustible loading in the area.
We consider that item 3.6 is now closed.
By letters dated March 19, 1981 and July 10, 1981, the Licensee requested an exemption for and provided additional information regarding the requirement for fire dampers in ductwork in safety-related areas.
It is our concern that a
damper is needed in rated fire barriers to prevent flame spread and consequent damage to redundant trains of safe shutdown equipment in adjacent areas.
The information provided is not adequate to perform our review.
We will need a fire hazards analysis for each affected area to, complete our evaluation on a fire-area by fire area basis.
We therefore consider this item as remaining open.
Items 3.9, cable spreading room fire barrier, and 4.1 safe shutdown systems are addressed in this I
report.
By letter dated Harch 19,
- 1981, the Licensee committed to comply with our requirements for items 3. 12.7 smoke detectors,
- 3. 13.3 RCP oil collection systems, and 6.0 fire bridge size and training.
We 0 therefore consider these items closed.
By letters dated June 10, 1982 and October 12, 1982, the Licensee requested 32 exemptions from Section III.G and III.J of Appendix R to 10 CFR 50.
Section III.G.2 requires that one train of cables and equipment necessary to achieve and maintain safe shutdown be maintained free of
'ire damage by one of the following means:
3 a.
Separation of cables and equipment and associated non-safety circuits of redundant trains by a fire barrier having a three hour rating.
Structural steel forming a part of or supporting.yuch fire barriers shall be protected to provided fire resistance equiva'ient to that required of the barrier; b.
Separation of cables and equipment and associated non-safety I
circuits of redundant trains by a horizontal distance of more than C.
20 feet with no intervening combustibles or fire hazards.
In addition, fire detectors and an automatic fire suppression system shall be installed in the fire area; or Enclosure of cables and eouipment and associated non-safety circuits of one redundant train in a fire barrier having a one hour rating.
In addition, fire detectors and an automatic fire I
suppression'ystem shall be installed in the ire area.
If these conditions are not met,Section III.G.3 requires alternative shutdown capability independent of the fire area of concern.
It also requires a fixed suppression system in the fire area of concern if it-contains a large concentration of cables or other combustibles.'hese alternative requirements are not deemed to be equivalent;
- however, they provide equivalent protection for those configurations in which they are accepted.
Because it is not possible to predict the specific conditions under which jre may.occur and.propagate,.the.
desi.gn.basis" protective
features'are specified in the rule rather than the design basis fire.
Plant specific features may require protection different than the measures specified in Section III.G.
In such a case, the Licensee must demonstrate, by means of a detailed fi.re hazards analysis that-existing protection or existing protection in conjunction with proposed modifications will provide a,level of safety equivalent to the technical requirements of Section III.G of Appendix R.
In summary,Section III.G is related to fire protection features for ensuring that systems and associated circuits used to achieve and main-tain safe shutdown are free of fire damage.
Fire protection configura-tions must either meet the specific requirements of Section III.G or an alternative fire protection configuration must be justi."ied by a fire hazards analysis.
Our general criteria for accepting an alternative fire protection configuration are the following:
, The, alternative assures that one train of equipment necessary to achieve hot shutdown from either the control room or emergency control stations is free of fire damage.
The alternative assures that fire damage to at least one train of equipment necessary to achieve cold shutdown is limited such that 4
it can be repaired within a reasonable time (minor repairs with
-.components-stored on=site)=.
t1odifications required to me'et Secti-on-III.G would not enhance fire-protection safety above that provided by either existing or proposed alternatives.
Modifications required to meet Section III.G would be detrimental to overall facility safety.
2.0 Anal tical Method J
The Licensee employed an analytical method to demonstrate. the inherent protection afforded to existing safe shutdown systems.
The intent of this method was to provided common parameters by which individual fire areas could be judged, and to demonstrate that verbatim compliance with Section III.G of Appendix R would not enhance the fire protection for safe shutdown.
The method can be summarized as follows:
The redundant cables and components of concern are identified.
Their geometry and configuration within the fire area are described.
The type of cable insulation and failure criteria are specified.
The minimum quantity of flammable liquid needed to produce sufficient heat flux and heat energy to damage the cables is calculated, considering several heat transfer modes,.i.e.
radiation, plume impingment, and stratification.
The analysis determines the heat flux into the room needed to cause.
electrical failure of redundant cables.
This. heat flux is I
converted to a quantity of flammable liquid, usually acetone, of approximately five to ten gallons, in a circular pool configuration.
We and our'ontractor, Brookhaven Kational Laboratory, have reviewed the analytical method.
We have determined that the results of the methodology as applied do not demonstrate the equivalence of the
'protection. provided for safe shutdown to the specific alternatives set forth in Section III.G of Appendix R.
For example:
The method does not consider the heat released to the room by secondary fires involving in-situ combustibles.
The method uses an electrical failure criteria with the thermal energy release to the
=- room by a single exposure fire.
When the cables of concern are at.
the conditions of electrical failure, other cables within the enclosure are burning and also releasing energy to the room.
The method does not consider the increased heat, release rate of a given fire when it occurs against a wall or in a corner; the method only considers the heat release of a fire as it occurs in an open area.
The method does not consider the effects of excess pyrolyzate resulting from the degradation of plastics burning in the'tratified layer.
The method ddes not consider all of the alternatives set forth in Section III.G, i.e., three hour barrier, one hour fire barrier with suppression
- system, twenty-feet separation free of combustibles with automatic suppression and.alternate or dedicated shutdown capability independent of the area.
The method only considers separation without automatic suppression and uses a stratification model which does not include the effects of separation.
The Licensee has not used the results of this analysis to compare the protection provided with that specified in Section III.G.
The Licensee has only stated that the accumulation of the necessary quantity of flammable liquids in the required configuration is an unrealistic condition, and will be prevented by administrative controls.
We do not deem this to be a valid argument because there is no positive means of preventing the accumulation of transient materials in individual plant areas.
As documented in Inspection and Enforcement Branch Reports, recent inspections at plants such as Davis Besse (50-346/82-03, April 1, 1982),
Duane Arnold (50-331/81-25, January 11, 1982),
D.
C.
Cook (50-315/82-11, December 31, 1982),
and Nine Nile Point (50-220/82-09),
have demonstrated that substantial quantities of hazardous substances such as 55 gallon. drums of waste oil are located in even highly restricted and controlled entry areas.
al We have not relied upon the results of the Licensee's analysis in our evaluation.
We have evaluated each exemption request using our standard method of review, i.e.,
we have:
a)
Reviewed the information submitted and related information existing in the docket file to determine the configuration of the redundant components, and in-situ combustibles in the fire areas of concern.
b)
Evaluated the existing fire protection, proposed modifications, 0
compensating desi.gn features and mitigating factors to determine the overall level of fire protection in the areas of concern, and
c)'etermined if the overall level of safety meets the criteria given previously and therefore is equivalent to that provided by Section I.II.G of Appendix R.
3.0 Fire Zones Anal zed to the Failure Criteria of Five Gallons of
- Acetone, Five Gallons of He tane and Ten Gallons of Lubricatin Oils r
, 3.1 Oiscussion In selected
- areas, the Licensee has analyzed the level of existing fire protection utilizing a modified version of the analytical model described in Section 2..0.
The analytical method normally starts with the failure criteria for the selected cable type and location and calculates the smallest quantity of liquid which must be spilled in the II
- defined pool geometry and location in order to achieve the failure r
criteria.
The method of analysis used in the selected areas inversely applies the methodology i.e. the maximum credible quantity of liquid is arbitrarily selected (in this case five gallons of acetone, five gallons of heptane, and ten gallons of lubricating oil), and its capability of achieving the failure criteria on existing cables and components is predicted.
t",odifications are only proposed if the existing configuration cannot withstand the failure criteria.
As stated in Section l;0, it is not possible to predict the specific conditions under which fires may occur and propagate.
The design basis
protective features are therefore specified in the rule rather than the design basis fire. If plant specific features require protection different that the measures specified in Section III.G, the Licensee needs to demonstrate, by means of a detailed fire hazards analysis, that existing protection or existing protection in conjunction with proposed modifications will provide a level of safety equivalent to the technical requirements of Section III.G of Appendix R.
The Licensee has not made a comparison between the level of protection afforded by the existing configuration and the level of protection required by Appendix R.
The Licensee has instead--compared the level of safety of the existing configuration to the level of fire protection necessary to withstand a fire involving five gallons of,acetone, five gallons of heptane, and ten gallons of lubricating oil.
The Licensee has not compared the level of protection required by the techni.cal r'equirements of Section III.G to these failure criteria.
The Licensee also has not provided a technical basis for the selection of these failure criteria.
We do not deem this to be an adequate justification for the exemptions requested.
The Section III.G fire protection features are intended to protect one train of safe shutdown equipment from a realm of possible fire exposures.
The Licensee's basis addresses only one type exposure, considering limited fuel sources.
We therefore do not have sufficient justification to grant the exemption requested by...relying solely. on. the,--- "-
0 Licensee's analytical model.
We have evaluated the additional informa-tion submitted with each exemption to identify those areas which could be evaluated using our standard method of review, and have determined
. that the existing protection for the following areas is equivalent to that required by Section III.G:
1)
Fire Area 3 - Intake Structure 2)
Fire Area 4 - Diesel Oil Storage Tanks 3).
Fire Area 5 - Component Cooling Pumps 8 Heat Exchangers These three areas are evaluated in Section 4.0 through 6.0 of this report.
The remaining areas analyzed to the reference failure-criteria do not adequately demonstrate that a level of fire
'protection equivalent to the technical reouirements of Section III.G has been provided.
The Licensee's request for exemption in the following areas should therefore be denied:
1)
Fire Area 1
- Steam trestle and auxiliary feedwater pumps.
2)
Fire Area 26 Containment 3)
Fire Area 31 - Shutdown heat exchanger 1B 4)
Fire Area 32 - Shutdown heat exchanger 1A 5)
Fire Area 33 - Pipeway 6)
Fire Area 34 7)
Fire Area 35
- 1A emergency core cooling system
- 1B emergency core cooling system
-8)
- Fire Area 36-; Main hallway -0.5'levation 9)
Fire Area 39 - Gas-decay= tank 10)
Fire Area 27 - Aerated waste storage tank 11)
Fire Area'.38 - Charging pump 1C 12)
Fire Area 75 - Charging pump 1B 13)
Fire Area 76 - Charging pump 1A 14)
Fire Area 43 - Control building personnel 15)
Fire Area 44 - Radio chemistry lab 16)
Fire Area 54 - Laundry and decontamination 17)
Fire Area 49 - Volume control tank 18). Fire Area 55 - Main hallway elevation 19.5'9)
Fire Area 50 - Demineralizers 20)
Fire Area 47 - Class 1f AB switchgear 21)
Fire Area 57 - Battery charger, inverter and cable spreading room.
4.0 Fire Area 3
-. Intake Structure 4.1 Discussion This is an outdoor area that contains the Intake Structure, Chlorine Building and a storage building.
The concrete intake structure deck abele'vation is 16.5'.
The safe shutdown related components in this area are the three intake cooling water (ICW) pumps.
These pumps rest on concrete pedestals approximately 31" high.
All three pumps are enclosed in a common steel tornado missile barrier approximately 20'igh, 9'ide and 37'ong.
This tornado missile barrier is surrounded by grating which drains to the Intake Canal below.
Openings at the top and bottom of the missile barrier allow for free convection cooling of ICH pump motors.
4 r There are four circulating water punps on 14 ft. centers, and three intake cooling water pumps on approximately 14 ft. centers.
Two screen wash pumps on approximately 6 ft. centers are located 4.5 ft. south of
'the southernmost intake cooling water pump.
A separation of r
approximately 6'xists between a circulating water pump and the closest..
ICW pump.
A 6 inch curb surrounding each circulating water pump directs any leakage from the respective pump away from the ICW'pump enclosure and into the deck grating.
'<<g P
Safe shutdown related cables in the area are those associated with the ICW pumps.
These cables.are routed in three separate manhole
- systems, each containing the cables for one ICW pump.
The manholes are located a
r minimum of 14 ft. from the circulating water pumps.
The, cables from the
. manholes to the ICW pump motor terminal boxes are routed in galvanized steel conduit and are encased in concrete from the manholes up to the
. intake. structure, deck.
g.
<<p
<<r The combustigles in the area consist of 235 qts. of lubricating oil in each of the four circulating water pump motors, 53 qts. in each of the three cooling water pump motors, and four qts. in each of the two screen wash pump motors.
The area is provided with portable fire extinguishers and manual hose i
stations.
The Licensee proposes to install a three hour rated fire wall between ICW pump A and ICW pump B, and to provide a one hour barrier around any A-train cables in the vicinity of the C-train pump.
The Licensee bases this exemption request on the inherent fire resistance provided by the steel missile barriers, coupled with the
'ocation of the pumps in an open area.
4.2 Evaluation In the service water intake structure, the licensee proposes to provide a partial three hour fire barrier, however the separation of redundant pumps is less than the 20 feet specified by Section III.G.
The only signi.ficant in-si.tu combustible in.the fire area is the pumps motor lubricating oil.
Me agree with the Licensee that the probability of ignition of the oil is low because the lubricating oil has a high flashpoint (approximately 450'F) and that sufficiently hot surfaces do
~ not exist in this fire area to cause the ignition of the lube oil.
. Because the ICM pumps are surrounded by a grating that drains to the
-.intake canal below, the possibility of a flammable liquid spill external to the missi'le barrier is low.
Additionally, the low probability of ignition of the lube oil in conjunction with the proposed parti'al three hour barrier p'rovides reasonable assurance that one. train of ICW pumps will be maintained free of fire damage.
4.3 Conclusion Based on our evaluation, we conclude that. with the proposed modifications, the level of safety provided in the service water intake structure area will be equivalent to the technical requirement of Section III.G of Appendix R and therefore, the Licensee's request should'.
.be granted.
5.0 Fire Area 4 - Diesel Oil Stora e Tanks 5.1 Discussion Fire Area 4 is the Diesel Oil Storage Tank area located at elevation 19.0'.. It includes the diesel oil storage tanks, diesel oil transfer
- pumps, and associated valves and piping.
Each tank is surrounded by a 5.5 ft. high concrete wall.and holds about 20,000 gallons of diesel fuel.'hey are built in accordance with API standards and meet the requirements of the National Fire Code.
.The fuel oil transfer pumps are located in tornado protected concrete enclosures; one north and one south of the diesel oil storage tanks.
These enclosures are approxi-mately 69 feet apart.'he in-situ combustibles in this area consist of approximately 20,000 gallons of,diesel oil contained in each tank.
Portable fire ext'inguishers and manual hose stations are provided in the area.
5.2 Evaluation This area does not comply with Section III.G because an automatic i
suppression and detection system are not provided.
The diesel oil storage tanks are separated by 21 feet and a dike capable of containing
the entire contents of the tanks.
The separation of tanks is in compliance with NFPA Std.
30, "Flammable and Combustible Liquids Code",
for the spacing of adjacent, above-ground storage tanks.
NFPA-Std.
30 does not recommend a fire extinguishing system for tanks of this size that are installed in compliance with the applicable spacing requirements.
Because of the separation distance and diking between
~ tanks, it is our opinion that there is reasonable assurance that one train will be maintained free of fire damage.
The installation of an automatic suppression and detection system would not significantly
/
enhance the level of fire protection in this area.
5.3 Conclusion Based on our evaluation, we find that the existing
- p. o ection in the diesel oil storage area provides a level of fire protec ion equivalent to the technical requirements of Section III.G, therefore, the exemption should be granted.
6.0 Fire Area 5 - Com onent Coolin Pum s
E Heat Exchan ers 6.1.
Discussion The Component Cooling Mater Area is an outdoor area located at elevation
/
28.5'ust north of the refueling water tank.
It includes the three component cooling water (CCM) pumps, the CCM heat exchangers and I
associated
- cables, valves, and piping,
. The CCW pumps are mounted on 1'I ft. high concrete pedestals which extend........,..
up to a metal grating at elevation 23.5'.
The area below the grated
platform contains piping in a dike at elevation 12.0'.
Each pump is enclosed by a steel missile between adjacent CCW pumps.
barrier.
Thee is approximately 12 feet CCW system control valves and motor operated valves are located just under the metal grating surrounding'the CCW pumps.
The combustible loading in this area consists of approximately 15 gallons of lubricating oil and four pounds of grease contained within the pump motor housings. 'ortable fire extinguishers and manual hose stations are provided in the area.
The Licensee proposes the following modifications:
1)
Install a three hour fire rated horizontal barrier..at the metal grating between the concrete pedestals of CCW pumps S and C.
2)'nstall a vertical three hour fire rated wall between CCW pumps B
and C.
- 3) 'rovide a enclosure or 'thermal barrier of fire resistant iaterial (1/2 inch thick'Harinite or equivalent) for the operators of the fol'lowing valves:
HCV-14-8B HCV-14-10 HCV-14-2 HCV-14-4 4)
Provide a one hour rated enclosure for all cables and conduit
'ssociated=with'the'above listed CCW pumps and valves.
The Licensee bases the exemption request on the proposed modifications combined with the inherent fire protection provided by the pumps installation in an open area.
6.2 Evaluation This area does not comply with Section III.G because redundant CCW pumps are not separated by three hour rated fire barriers, or provided with 20 feet separation free of intervening combustibles, or one hour barriers in conjunction with automatic suppression and detection.
The Licensee proposes to separate one of the CCW pumps by the installation of partial three hour rated barriers and one hour rated cable enclosures.
.Due to the location o
the CCW pumps in an open area, it is our opinion that the possibility of a fire of sufficient magnitude to damage all pumps is low.
We therefore conclude that the proposed modifications in conjunction with the existing fire protection features provided reasonable assurance that our train of CCW cables and components will be maintained free of fire damage.
6.3 Conclusion The existing protection for the CCW pumps in conjunction with the proposed modifications provides a level of fire protection equivalent to the technical'requirements of Section III.G therefore the exemption should be granted.
I 7.0
'Containment (Fire Area. 26 7.1 Discussi on The Licensee has performed an analysis of the effects on safe shutdown-capability following a fire in the mechanical penetration room (Fire Area 45), the east electrical penetration room (Fire Area 77) and the west electrical penetration room (Fire Area 78).
The analysis identified that manual operation of shutdown cooling return valves V-3651 or V-3481 located inside containment would be required.
The Licensee requests an exemption from Section III.J to the extent that.
it requires eight hour battery powered lighting units inside containment to enable operator access to the shutdown cooling valves.
The Licensee proposes to provide dedicated portable emergency lighting for containment entry.
7.2 Evaluation Because manual operation of the shutdown cooling return valves may not be needed for. several. hours after the loss of onsite power, the benefits provided by eight hour emergency lighting units may be marginal.
Me agree with the Licensee that dedicated portable lighting units will provide acceptable illumination for containment
- access, and the installation of eight hour emergency lighting units inside containment will not greatly enhance safety.
7.3 Conclusion The proposed dedicated portable lighting units provide a level of fire protection equivalent to the technical requirements of Sectidn III.J.
The request for exemption should therefore be granted.
8.0 Fire Area 56 B-Switch ear Room 8.1 Discussion Fire Area 56 is the B Switchgear Room.
It is located in the Reactor Auxiliary Building at elevation 43.00'nd is adjacent to the following areas:
the Cable Spreading Room, the A Switchgear
- Room, and the Holdup Tank Cubicle.
This area houses the 480V-1B2 switchgear, the 4160Y-183 switchgear, and Motor Control Centers 1B-5 and 1B-6.
Power and control cables for equipment required for plant shutdown are also routed in this area.
This fire area is bounded by concrete walls, floors and ceiling.
These boundaries provide a three hour barrier except for a section of the north wall that separates the B-switchgear room from the cable spreading room (Fire Area 57),
and several outside ventilation openings that are not provided with fire dampers.
The combustible loading in the area consists of a number of cables in
.cable tray's and switchgear.
The Licensee has assumed that because the cables in the area are coated with a flame retardant coating they will not contribute to the in-situ fuel load, and has consequently not quantified the fuel load.
Portable fire extinguishers, manual hose stations and a detection system are provided in the area.
The Licensee proposes to seal all penetration openings in the boundary ivalls of Fire Area 56 and install rated fire doors and fire dampers, except on the outside ventilation openings.
8.2 Evaluation This area does not comply with Section III.G because it is not separated from adjacent fire areas by a complete three hour rated fire barrier.
The Licensee has not quantified the combustible loading in the area due to the use of flame retardant coatings.
It is our concern that the quantity of plastic cable insulation and jacket material in the switchgear room may provide a significant fuel load.
This fuel load is not reduced by the flame retardant coating; this coating only increases the amount, of energy required to the ignite the cables.
The limitations of the protection provided by fire retardant coatings are recognized by the fire protection industry.
The National Fire Protection Association Handbook states that, "One popular misconception is that fire retardant treatments give fire resistance rating.
This is not true since the treated material does not resist destruction and is still subject to complete consumption by exposing fire.
The treatment
- does, however, retard both the rate of burning and the rate at which fuel is contributed by the treated material."-
Tests of flame retardant coatings on cables that were conducted for the NRC at Sandia Laboratories show that the rate of fuel contribution of the burning cables is retarded to a varying degree,
- however, the entire
quantity of cable insulation will eventually be consumed during fire exposure.
The test results showed that the protection provided by fire retardant coatings varies with the type of coating.
However, heat release data measured during the tests show that coated cables ultimately contribute an amount of fuel similar to that of uncoated cables.
Based on our evaluation of several tests conducted by Sandia Labora-tories and others it is our opinion, that the heat flux from a moderate size exposure fire could result in the propagation of a fire throughout the coated cable trays.
The only means the.Licensee is proposing to control such a fire is manual action to be taken by the fire brigade.
Hanual fire fighting involving burning cable insulation may be ineffective due to the large quantities of thick, black smoke and toxic gases commonly produced in burning plastics and flame retardant coatings.
In tests, small plastic fires have produced sufficient smoke in five minutes to overcome ventilation systems, and reduce visibility in large rooms.
This reduced visibilitywill significantTy hamper fire brigade activities.
Because we do not have an indication of the in-situ fuel load including the cable jacket and insulating materials, we cannot complete our evaluation on the adequacy of the section of the north wall which is rated at lk hour instead of three hours.
Me therefore do not have
.i;-....assurance..that
.the-protectien provided by-the Section of 1$ hour'rated:
l
~
I fire wall in the B-switchgear room provides a level of'ire protection equivalent to the technical requirements of Section III.G.
We agree with the Licensee that because'here are no external fire exposures, three hour rated fire dampers need not be provided in the outside ventilation openings.
8.3 Conclusion Based on our evaluation, we conclude that the 1$ hour fire wall in the B-switchgear room does not provide a level of fire protection equivalent to the technical requirements of Section III.G, therefore the exemptions should be denied.
We also conclude that the.outside ventilation penetrations provide a
level of protection equivalent to the technical requirements of Section
. III.G and the exemption should therefore be granted.
9.0 A-Switch ear Room - (Fire Area 60) 1 9.1 Discussion Fire Area 60 is the "A" switchgear room.
It is located in the Auxiliary Building at elevation 43.00'nd is adjacent to the following areas:
The cable spreading room, the B switchgear room, the 1A battery
- room, and the HVAC equipment room.
This area houses the 480V-1A2 and 4160V-1A3 switchgear, and two motor control centers.
Control and power cables for equipment required for plant shutdown are also routed in this area.
The fire area is bounded by concrete walls, floor, and ceiling which provide a four. hour rated fire barrier, however, fire dampers installed in the HVAC ductwork are only 14 hour1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> rated.
The combustible loading in this area consists primarily of electrical cables and
\\
switchgear.
The Licensee has assumed that because the cables are coated with a flame retardant coating, they will not contribute to the in-situ fuel load, and has consequently not quantified the fuel load.
Portable fire extinguishers, manual hose stations, and a fire detection system are provided in the area.
The. Licensee proposes to upgrade the fire protection in this area by sealing all penetrations and installing three hour ratod fire doors.
Nb changes are proposed for the 14-hour fire dampers in the HYLIC ducts.
9.2 Evaluation
.This area does not comply with Section III.G because it is not separated from adjacent fire areas by a complete three hour rated fire barrier.
The Licensee has not quantified the in-situ fuel load due to the use of flame retardant coatings.
It is our concern that the quantity of plastic cable insulation and jacket material in the.switch gear room may I
provide a significant fuel load.
This fuel load is not reduced by the flame retardant coating; this coating only increases the amount of energy required to ignite the cables.
The only means the Licensee is proposing to control such a fire is manual action to be taken by the fire brigade.
Hanual fire fighting involving burning cable insulation may be ineffective due to the large quantitites oj thick, black smoke and toxic gases commonly produced in burning plastics and flame, retardant I
Ip tests, small plastic fires have produced sufficient'moke in five minutes to overcome ventilation systems, and reduce visibility in large rooms.
This reduced visibilitywill significantly hamper fire brigade acti vities.
Because we do not have an indication of the in-situ fuel load,,including.
the cable jacket and insulating materials, we cannot complete an evaluation on the adequacy. of the 14 hr rated fi're dampers.
9.3 Conclusion Based on the above evaluation we conclude that the existing protection for. the A-switchgear room does not provide a level of fire protection
.equivalent to the technical requirements of Section III.G, therefore the exemption should be denied.
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10.0 Control Room, Control Room HVAC Room, Classroom Areas (Fire A'regs 70, 71, 73) 10.1 Discussion Fire Areas 70, 71, 8
?3 encompass the control room, the control room HVAC equipment room~
and the class room areas.
These areas are located at the west end of the Reactor Auxiliary Building at elevation 62.0'.
Fire Area 70 is the control room which is continuously occupied.
The majority of the instrumentation and control circuitry is mounted on a
centrally-located control panel.
This area is accessible from the turbine deck, from. the control room HVAC equipment room (Area 71) and from the class rooms/technical support center (Area 73).
It is bounded
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by concrete walls, floor, and 'ceiling.
Fire Area 71 is the control room HVAC area.
It houses the control room.
HVAC equipment, the electrical equipment rooms HVAC supply fans, and various safe shutdown related power and control cables.
This area is accessible from the control room and from outdoors.
It is bounded by concrete walls, floor and ceiling.
Fire Area 73 is the class room/technical support center area.
It houses no safe shutdown related equipment or cables.
This area is bounded by concrete walls, floor, and ceiling, and is accessible from the control room and the turbine deck.
Boundary walls are concrete, and provide a
three hour rated fire boundary.
Portable fire extinguishers, manual hose stations, and detection systems are provided in fire areas 70 and 73.
Fire area 71 does not have a
detection system.
I The Licensee proposes to seal all penetrations and install three hour rated fire doors in these areas.
The Licensee requests the following exemptions:
a)
The addition of necessary instrumentation and controls to the existing remote shutdown panel to eoable the plant to be taken to cold shutdown from that location.
'b)
,The installation of extinguishing and detection systems in'fire',
areas 70, ?1 and?3.
c)
The installation of three hour rated fire dampers in the exterior walls of these areas.
10.2 Evaluation These areas do not comply with Section III.G because they are not provided with an automatic. suppression
- system, one hour fire barriers between redundant trains of components required for safe shutdown, or an al.ternate shutdown capability independent of the area.
The control room contains the majority of the controls essential for normal. station operation and for shutdown of the plant under all anticipated conditions.
Redundant systems necessary for safe shutdown are located jn,clqse proximity within the control console and, without adequate. protection, would be damaged by a single fire of significant magnitude.
With the present design', if such a fire occurred, there is no capabi.lity to achieve safe shutdown independent of the control room.
N Administrative controls, even if they are included into the plant Technical Specifications, do not provide reasonable assurance that hazardous accumulations of flammabl'e -liquids and combustible materials will not be present in individual plant areas.
As documented in recent
y ~ Inspection and Enforcement Branch Reports, recent inspections at plants such as Davis Besse (50-346/82-03, April 1, 1982),
Duane Arnold (50-331/81-25, January 11, 1982),
O.C.
Cook (50-315/81-11, December 31,.
1981),
and Nine Mile Point (50-220/82-09),
have demonstrated that substantial quantities of hazardous substances, such as computer printout paper are located in even highly restricted and controlled entry areas.
Consequently, they do not pre'elude the need for other fire protection design features.
With regard to the control room being constantly
- manned, we do not have reasonable confidence that "prompt" fire discovery and fire fighting activities by control room operators would assure that no damage would be sustained by redundant safety related cable and equipment.
The uncertainties concerning the location of the fire, the degree of physical separation of redundant trains, fire propagation
- speed, the fire damageability of cable and equipment, the timeliness and effectiveness of operator actions and extinguishing efforts, prevent the prediction of damage from fire or fire suppresants.
Consequently, the continuous presence of control room operators and the availability of portable fire extinguishers by themselves, would not assure that redundant trains would be free of significant fire damage.
- However, these considerations, coupled with the provision of an alternate 8
shutdown capability, have been determined to be sufficient justification for granting an exemption from the requirement. for a fixed fire suppressi-on-=.system--in-control.
rooms;-"
Although the licensee has the capability to take local control of essential
- systems, the control room is nut electrically isolated from the control stations therefore, a fire in the control room or in the area of any emergency control station c'ould affect both areas, thus
'esulting in th'e inability to safely shutdown the plant.
Because the nature of the electrical panels in this area make protection in accordance with Section III.G.2 of Appendix R impractical, the licensee should provide alternate shutdown system for the area in accordance with Section III.G.3 of Appendix R.
The alternate shutdown system should meet the requirements of Section III.L of Appendix R.
The alternate shutdown capability should be electrically and physically isolated from the control room so that a fire in the control room or in the area of alternate shutdown capability which destroys, redundant circuits will not affect the ability.to safely shut down the plant from the other area.
With the alternate shutdown capability installed, a suppression system is not required in the area.
The Licensee has not demonstrated that cold shutdown can be achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> by utilizi6g the number of operating shift personnel, exclusive of fire brigade
- numbers, needed to perform the necessary operation.
We agree with the Licensee that three hour rated fire dampers need not be installed in external ventilation openings, as there are no outside
'ire exposures.
10.3 Conclusion Based on our evaluation, we conclude that the current level of fire protection provided for safe shutdown capability in the control room complex is not equivalent to the protection required by the technical requirements of Section III.G of Appendix R.
Therefore, the Licensee's request for exemption should be denied.
- Me also conclude that the current level of fire protection provided for the external ventilation openings is equivalent to the technical requirements of Section III.G.
Therefore, the Licensee's request should be granted.
11.0 Cit Water Stora e Tank Area (Fire Area 79) 11..1 Discussion The city water storage tank area is an outside area located in the northwest corner of the plant site at elevation 19'. It is accessible for 'fire. fighting and houses two 500,000 gal city water storage
- tanks, two city water transfer
- pumps, two domestic water pumps, the 1A and 1B fire pumps, and all associated valves and cables.
All pumps are mounted on individual concrete foundations,
- however, the ground surface in between pumps is gravel.
The two fire pumps are located about 30 feet apart and approximately 30 feet from the domestic water pumps.
Both sets of pumps are on the east side of the storage tanks.
The city water transfer pumps are located on the west side of the storage tanks.
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No safe shutdown related equipment or cables are routed through this
- area, however, the fire water pumps and their associated cables are categorized as equipment to be protected to mitigate the consequences of a postulated fire, and an exemption from the separation requirements'f Section III.G is therefore requested.
11.2 Evaluation This area does not comply with Section III.G because a three hour rated barrier is not provided between the 1A and 1B fire pumps.
The fire
- pumps, however, are not components needed to safely shutdown the plant.,
Compliance with Section.III.G is therefore not required.
It is our opinion that the current separation of the fire pumps is adequate for redundant fire extinguishing components.
11.3 Conclusion Based on the information that the Licensee provided for the city water stbrage tank area, an exemption from Section III.G is not needed.
~Summa r Based on our evaluation, the following exemption requests should be granted:
1)
Fire Area 3 - Intake Structure 2)
Fire Area 4 - Diesel Oil Storage Tanks 3)
Fire Area 5 -
CCM Pumps 5 Heat Exchangers 4). Fire Area 26 - Containment (III J) 5). Fire Area 56 - B-Switchgear Room (3-hour fire dampers)
Based on our evaluation, the following exemption request is not.needed:
1)
Fire Area 79.- City Mater Storge Tanks and Fire Pumps Based on our evaluation, the following exemption requests should be denied:
1)
Fire Area 1 Steam Trestle
.2)
Fire Area 26-3)
Fire Area 31-4)
Fire Area 32-
- 5) 'ire Area 33-6),
Fire Area 34-7)
Fire Area 35-8)
Fire Area 36-Containment
( III G)
Shutdown Heat Exchanger-8 Shutdown Heat Exchanger-A I
Pi peway A-ECCS B-ECCs Yiain Hallway -5'levation 9)
Fire Area 39 - Gas Decay Tank
- 10) Fire Area 27 - llaste Storage Tank ll) Fire Area 38 - C-Charging Pump
- 12) Fire Area 75 - B-Charging Pump
- 13) Fire Area 76 - A-Charging Pump
- 14) Fire Area 43 - Control Building Personnel
- 15) Fire Area 44 - Radio Chemistry Lab
- 16) Fire Area 54 - Laundry 17)= Fire Area 49 - VCT
- 18) Fire Area 55 - Hain Hallway, +19.5'levation
- 19) Fire Area 50 - Demineralizes
- 20) Fire Area 47 - AB Switchgear
- 21) Fire
- 22) Fire
- 23) Fire
- 24) F.ire
- 25) Fire Area 57 - Battery Charger, Inverter Area 60 - A Switchgear Area 56 B Switchgear (14 fire wall)
Area 70 - Control Room Area 71 - Control Room HVAC
- 26) =Fire Area 73 - TSC References (1)
(2)
(3) 1 thcKinnon, G.
P. editor, Fire Protection
- Handbook, 14th edition National Fire Protection Association, Boston, l1ass.,
1976, pp.5-67.
- Klamerus, L. J.,
"A Preliminary Report on Fire Protection Research Program Fire Retardant Coatings Tests,"
Sand 78-0518, Sandia Laboratories, Albuquerque, New Mexico, 1968, pp. 35-46.
"Burn Node Analysis of Horizontal Cable Tray Fires" SAND 81-0079 NUREG/CR-2431 February 1982.
Summary:
This test series was conducted to investigate the burning of cables in cable trays in rooms where adequate ventilation for combustion is not available.
The test results show that a reduction in'flames and the occurrence of deep-seated fires is more likely in a descending smoke layer.
The tests also showed that reignition may occur upon readmission of fresh air.
(4)
"Fire Research on Grouped Electrical Cables" SAND 79-0031 January 1979.
Summary:
This paper summarizes the activities of Sandia National Laboratories research through January 1979 in regard to nuclear power plant cable testing criteria.
Both a small scale and full scale tests are described for use in evaluating cable fire retardancy.
(5)
"Categorization of Cable Flammability - Part 1:
Laboratory.
Evaluation of Cable Flammability Parameters" EPRI NP-1200 October
'1979.
Summary:
This study was a laboratory scale investigation of flammability parameters such as rate of heat release sensitivity to external heat flux of 22 types of electrical cables.
The results of this study were used to select cables for full scale cable try fire tests.
(6)
(7)
"Assessment of Exposure Fire Hazards to Cable Trays" (EPRI-NP-1675 January 1981.
Summary: This study evaluated the potential hazard to cable trays from external heat flux sources.
The results show that damageability can be predicted based on the ceiling height and floor area of the room, the height of cables above the floor, the ventilation rate, and the heat release rate of the combustible.
"A study of Damageability of Electrical Cables in Simulated Fire Environments" EPRI-NP-1767 Harch 1981.
Summary:
This study investigates how electrical cables may melt, expand, disintegrate, or short circuit in a heated environment, even before ignition occurs.
Critical heat flux and radiant energy parameters are derived for expressing the degree of'able damage potential.
Several tests conducted for the NRC fire protection research
. --..-.--.p'rogram-;-which -as "of"this
- data -final iest-reports have---not-yet"been issued.
These tests are:
- 1. "Replication Experiments for Fire Protection System" Conducted July 1981 at Underwriters Laboratories, Northbrook, IL.
- 2. "Evaluation of twenty-foot Separation as a Fire Protection System" May 1982, Underwriters Laboratories, Northbrook, 1L.
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