ML17213B089
| ML17213B089 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 02/25/1983 |
| From: | Robert E. Uhrig FLORIDA POWER & LIGHT CO. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8303040346 | |
| Download: ML17213B089 (16) | |
Text
Ci
~"-4 REGULATOR ORMATION DISTRIBUTION'RIDS)
AGCBSSION NOR;8303040306 DOC,DATE: 83/02/25 NOTARI'ZED:
NO FACIL:50-389 Sts Lucie Plant<
Uni,t 2< Florida Power 8 Light Co.
AUTH ~ NAME AUTHOR AFFILIATION UHRIGg R ~ E, Florida 'Power 8 Light Co, RBC IP ~ NAME RECIPIENT AFFIL'IATION EISENHUTiD ~ G ~
Division of Licensing
SUBJECT:
Forwards Rev 1.to 820714 deviation -requests for exemption from Section III"G of 10CFRSO App R
L three new deviation requestspper results of completed detailed engineering design.
DI'STRIBUTION CODE:
B002S COPIES RECEIVED:LTR.J 'NCL,3 SIZE:
TITLE: Licensing "Submi ttal: Fir e
~Pr otection OTE: 4eipeJ ifig8$
DOCKET A'5000389 RECIPIENT
'COPIES ID CODE/NAME LTTR ENCL LIC BR 03 BC 1
1 RECIPIENT ID 'CODE/NAME NERSESiV ~
01 COPIES LTITR ENCL 1
1 INTERNAL: ELD/HDS2 NRR/DE/CEB 06 04 1:0 2
'2 1
1 IE FILE 07 NRR/DSI/ASB RGN2 1
1 1
1 1
1 EXTFRNAL: ACRS NRC PDR NTIS 10 02 b
6
,1 1
1 1
LPDR NSIC 03 05 1
1 ITOTAL NUMBER OF 'COPIES REQUIRED:
LTTR 19 ENCL 18
Cw, f <T 7
pt,,>,,
~, lg I.. I)'i
- "4%1 T
~"~i4~lXg 5:
>I',"i
~ A.g 9""i r j
'1')~>o
~ lil"r'lo(",l q5 4fn"> qgflof
~ Argy
~
~ 9<~
'J>II ghl j$, 3lh
<<IoH f>Is)
,o,)
<<~le>>r j A aowu'> os.roof'4
, I~'llTl<IJI 3~ki I "'"GI'tlJ3~<
I )
rntonooi J to norerv'r~t
.sl.<<
)!'
s I~
~
f
)IJ $
-Ac*'lJ~ i lh
~.~ 'r '>re
.0, 0 qgl'tl It3 At< ~ RI0 3
"~
q TV<4~~ 3c; l 3 nuffn~~xo ~ot
<~)<.olip~q no'r4orvot>>
l<l)A>>4 od I v~~f ah~onao l
>o f do tv'9~
<49n 991~)4 A
>~
<5')4 0< @ 3l(~Y YV v~llJ f'IOK$39V
~'~nkzonni<~
I~) o~ f ) o4qh
~ygfg fq 1ns
>0
<<!f lu~og qg~~>~,'troop~'l
~ np f @~jib
- 1J ]t
- lhl>>. jJ'~3
>/TJ:
3 >VI )J )~l P3I4>OJ P~09A:3rl~)3 ',<<~III) >li)lil) nor4o~fowq ~or 3: lr>>)firvrjuH vnrans>r,):3 jl Ff
- cl <I Ji<
P )I'< )J JJ" j oTI I T.'~ Hl <) J')3H J3A )
Wl Ta
,>JIk
~)~~AXI cl<'X>~~~t>
p)n~f JIB
I i4 l
1q I
OX 14000, JUNO BEACH, FL 33408 Q l/j'eg FLORIDAPOWER & LIGHTCOMPANY February 25, 3.983 L-83-89 Office of Nuclear Reactor Regulations Attention: Hr. Darrell G. Eisenhut, Director Division of Licensing U.S. Nuclear Regulatory Commission 4'ashington, D.C.
20555
Dear 51r. Eisenhut:
RE:
ST.
LUCIE UNIT NO.
2 DOCKET NO. 50-389 APPENDIX R - FIRE HAZARD ANALYSIS REVISION 1
By letter L-82-282 dated 7/14/82, FP&L provided an evaluation supporting requests for exemption from Section III-G of Appendix R to 10CFR50.
Based on subsequent meetings and discussions
'with the staff, several modifications to the document were required and insertion of the attached pages establishes Revision 1 to our deviation requests.
In addition, three new deviation requests are enclosed which are required as a result of completed detailed engineering design.
If you have any questions regarding this submittal, please contact us.
Very truly yours, Robert E. Uhrig Vice President Advanced Systems and Technology REU/RJS/PPC/mp Attachment cc:
J.P. O'Reilly, Region II Harold F. Reiss, Esquire b 8SP225 303gg03~
pgOOggaq
@9'DOGl pOR
~ F PEOPLE... SERVING PEOPLE
ATTACHMENT.
As an explanation of the attached it is noted that additions and modification to the original exemption requests are designated "RI." Modifications are further identified by underscoring.
The following summarizes the revisions by Fire Area:
Fire Area A, deviation A3 Newly identified deviation Fire Area C, deviation C4 Thermal wrap for ducts Fire Area C, deviation C5 Two hour conduit wrap in B Switchgear Room Fire Area H., deviation H3 Two hour conduit wrap Fire Area K, deviation Kl Added evaluation items 9 thru 13 Fire Area N, deviation Nl Newly identified deviation Changed charging pump separation Changed height of 3-hour partition Deleted Eval. Nl 6 Fire Area Q, deviation Q2 Corrected penetration number Corrected reference to Fire Area F Fire Area 0, deviations 05 and 06 Newly identified deviations Fire Area M-M, deviation M-M 1 Changed type of detection Fire Area M-M, deviation M-M 2 Deleted
E
~
t
3)
Combustible loading is xone 48 is low.
Conclus n C3 Based on ou evaluation, the existing fire barrier provides adequate separation.
e installation of fire dampers in the duct/louvers at penetration Nos+5, 18, 19, and 17 would not augment or materially enhance the safety of the plsqt.
Therefore we conclude, this is an acceptable deviation to Appendix R to 1 CFR50, Section III-G.2.a.
Deviation C4 A deviation is requested om Section III-G.2.a of Appendix R for wall penetration Nos. 4, 6 (west hour fire barrier) and 3 (north 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire barrier) at fire xone 48 bees se no fire damper is provided in the ventilation duct.
Evaluation C4 1)
Ionization smoke detectio is provided in Fire Area "F" (Control Room).
2)
Fire Area "F" is constantly at nded and access by plant personnel is controlled.
a 3)
Fire Area "C" is lightly trafficke
, thus reducing the probability of transient combustibles being int oduced.
4)
The combustible loading in fire zone 8 of Fire Area "C" and Fire, Area "F" is low.
5)
Fire Zone 34 has a significant cable load d ionization smoke detection is provided.
The ma5or communicat on from fire xone 34 to fire zone 48 is through the vertical 14 gag duct at penetration 62-1.
A fire, smoke, or heat generated in fire one 34 would have to traverse the penetration countercurrent to the ventilation air flow, breach the vertical 14 gage duct, and initia a
conflagration in fire zone 48 prior to impacting the 14 gage continuous ducts in fire xone 48.
Due to early noti )cation of a fire in fire xone 34 and low combustible load in fire 'xone 48, such a scenario is not postulated.
6)
Each'uct penetration is provided with a fire stop of app oved 3
hour.rating.
7)
.The ducts are continuous in Fire Area "C" with no registers.
8)
Fire damage to the ducts located in Pire Area "C" is precluded because the heavy gage duct, (which is 14 gage as compared to the 22 gage of a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated fire damper),
and heavy duty support, metal heat transmission and dissipation characteristics, and metal closure angles applied to the ducts on both sides of the barrier
would serve to render the ductwork impervious to expansion deformation or heat failure for periods of expectd fire duration.
While localized high off-gas temperatures can be expected in the immediate vicinity of a fire, air mixture dilution temperature at the ducts, which are 13 feet above the floor, is not expected to reach high temperatures.
As the ventilation ducts remain intact they are considered extensions of the Pire Barrier and thus the overall fire resistance integrity continues undiminished.
Conclusion C4 Based on our evaluation, the existing fire barrier provides adequate separation.
The installation of fire dampers in the ventilation ducts at
penetration Nos. 4, 6 and 3 would not augment or materially enhance the safety of the plant since they would not aid in preventing fire migration between Pire Areas "C" and "F".
Therefore, we conclude, this is an acceptable deviation to Appendix R to 10CFR50, Section III-G.2.a.
Deviation C5 A deviation is requested from Section III-G.2.c of Appendix R for fire zone 34 (B Switchgear Room) because an automatic suppression system is not provided in the fire area to protect conduit containing four cables essential for safe shutdown which are enclosed in a fire barrier having a minimum of one hour fire resistance rating.
Evaluation C5 1)
Ionization smoke detection is provided throughout fire zone 34.
2)
Pire Area "C" is lightly trafficked, thus reducing the probability of transient combustibles being introduced.
3)
The four A train cables essential for safe shutdown identified in fire zone 34 are being enclosed in a fire barrier having a minimum of one hour fire resistance rating.
4)
Early response to a smoke detection alarm is assured from the control room utilizing the exterior stairway and soutwest entry to fire zone 34, one level below the control room.
5)
A standpipe system hose station equipped with 100 feet of hose is located in fire zone 34 at the southwest entry.
6)
Portable fire extinguishers are provided in fire zone 34 and access to the fire zone from the northeast entry with additional hose lines is available.
7)
Inadvertent operation of a water type suppression system could cause undo damage to electrical equipment in the plant switchgear rooms.
Conclusion C5 Based on our evaluation, the existing smoke detection, and early response with manual fire suppression equipment, and enclosure of the four cables identified in a barrier having a minimum of one hour fire.resistance rating provides adequate protection.
The installation of an automatic suppression system in fire xone 34 would not augment or materially enchance the safety of the plant since it would not reduce the time required for fire extinguishment.
Therefore, we conclude, this is an acceptable deviation to Appendix R to 10CFR50, Section III-G.2.c.
4)
The B train cable traverses the section of fire zone 39 northeast of Column RAD/2-RA3 alone (the redundant counterpart no longer routed in parallel), enclosed in a fire barrier of one hour fire resistance rating.
5)
The section of fire zone 39 northeast of Column RAD/2-RA3 is separated from the adjacent portion of fire zone 39 by a full height concrete wall.
%bile the wall is not considered a
3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated fire barrier it provides a considerable deterent to fire conflagration from the adjacent portion of fire zone 39.
Conclusion H3 Based on our evaluation, the enclosure of the single cable essential for safe shutdown in the section of fire zone 39 northeast of Column RAD/2-RA3 within a barrier of one hour fire resistance rating provides adequate separation of redundant trains essential for safe. shutdown.
The installation of fire detection and an automatic fire suppression system northeast of. Column RAD/2-RA3 would not augment or materially enhance the safety of the plant.
Therefore, we conclude, this is an acceptable deviation to Appendix R to 10CFR50, Section III-G.2.c.
FIRE AREA "N This fire area is fire zone 18 (charging Peap Area) as shown on the-attached drawings.
Parameters descriptive of the area, including physical description safe shutdown capability, fire hazard analysis and fire protection, are outlined in the attached matrix.
Essential equipment in this area is shown in the attached essential equipment list.
The following deviations fraa Appendix R to 10CFR50 are requested:
Deviation Nl Deviation is requested frcm Section III'.2.a af Appendix R since the redundant charging punps are not entirely separated by a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated fire barrier.
Evaluation Nl 1)
Fire Area "N" is provided with ionization type smoke detection.
2)
The charging punp cubicle access corridor is provided with a> autanatic preaction sprinkler system.
3)
The charging punps are approximately 10 ft apart separated by a 10 ft high 3'hour fire rated partition.
4)
This fire area contains a very low ccmbustible loading and as a
radiation area has limited personnel
- access, thus reducing the probability of introducing transient canbustibles.
5)
A fire on either side of the fire partitions involving in-situ and/or transient ccmbustibles would not directly impinge upon or radiate heat to the essential equipment on the opposite side.
While localized high off-gas temperatures can be expected in the vicinity of a fire, air mixture dilution temperatures which would stratify in the upper level of this area would not reach a point capable of 5eapardizing the operation of the redundant charging punps.
6)
The extension of the cubicle walls an additional 3 ft in height to approximately 10 ft high, as requested by the NRC during a previous site visit (Reference
- 4) is considered an accepted deviation.
Conclusion Nl Based on our evaluation, the 10 ft 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated partitions provide adequate separation of the redundant charging punps.
'%he extension of the walls to full height would not augment or materially enhance the safety of the plant since it would not provide additional protection for redundant charging pumps.
Theref ore, we conclude that this is an acceptable deviation frem Appendix R to 10 CFR50, Section III-G.2.a.
vs ~
Radiant energy shields are being provided between safety-related A
and B cables trays in the cable penetration area to provide se para tion.
6)
Vertical cable tray runs are being provided with fire stops installed every 20 feet along the vertical rise.
7)
Pire Area "K" is a high radiation area and personnel access is limited, thus minimizing the probability of introducing transient combustibles.
8)
The large free volume (2.5 million cubic feet) of Fire Area "K" allows for dissipation of hot off~as temperatures and reduces the effect of stratified hot gases at essential components.
Oonclusion Kl Based on our evaluation, the existing features in Pire Area "K" provide adequate separation for a fire in transient or inmitu combustibles.
Additional modification would not augment or materially enhance the safety of the plant since it would not aid in the prevention of fire damage to redundant components essential for safe shutdown.
Therefore, we conclude, this is an acceptable deviation to Appendix R to 10CFR50, Section III-G.2.d.
FIRE AREA "
This fire area is fire zone 44 (Component Cooling Water Surge Tank Roan) as shown in the attached drawings.
Parameters descriptive of the fire area, including physical description, safe shutdown capability, fire hazard analysis and fire protection are outlined in the attached matrix.
Essential equipment within this fire area is shown in the attached essential equipment list.
The following deviations to Appendix R to'0CFR50 are requested:
Deviation 1
h deviation is requested fran Section IIIW.2.a of Appendix R for penetration No. 1 in the North fire barrier of Fire Area "Q" because no fire damper is provided.
Evaluation Ql 1)
The fire area has negligable ccmbustible loading.
2)
The fire area is very lightly trafficked, thus minimizing the probability of introducing ccmbustibles.
3)
Outdoor exposure fires are not postulated in the plant yard based on the lack of canbustible storage adjacent to buildings and on the height of penetration above grade which allows for heat dissipation.
Where concentrations of ccmbustible material, such as oil in plant transformers or diesel generator fuel oil storage tanks, are in the plant yard adequate spacial separation fran important plant facilities is provided and the flow of canbustible liquids is directed to or conf ined a saf e distance fraa important plant facilities as outlined in the Fire Hazard hnalysis Report.
(Reference 5) 4)
h postulated fire involving in-situ and/or transient caabustibles within Fire Area "Q" does not require a fire damper at penetration No. 1 due to the non Sssential nature of the yard exterior to the penetration.
Conclusion Ql Eased on our evaluation, the existing fire barrier provides adequate separation; The installation of a fire dsnper in the duct at penetration No. 1 would not augment or materially enhance the safety of the plant.
Therefore, we conclude, this is an acceptable deviation to Appendix R to 10CFR50, Section III&.2.a.
Deviation Q2 h deviation is requested fran Section III'.2.a of Appendix R for wall penetrations 3, 4 and 6 because no fire dampers are provided in the ventilation ducts.
Evaluation Q2 See Evaluation Pl See Conclusion Pl
0
FIRE AREA "M-M" Ihis fire area is the intake cooling vater punp area previously designated as Pire Area 13.
Parameters descriptive of the fire area including physical description, safe shutdown capability, fire hazard analysis analysis and fire protection, are outlined in the attached matrix.
Essential equipment within this fire area is shovn in the attached Essential Equipment List.
The folloving deviations fran Appendix R to 10CFR50 are requested:
Deviation M-M 1 A deviation fran Section III'.2.b af Appendix R is requested because no autanatic suppression system is provided.
Evaluation M-M 1 1)
Pire Area "M-M" is provided vith ionization type smoke detection.
2)
This fire area is lightly trafficked, thus minimizing the probability of introducing transient ccmbustibles.
3)
Ihe fire area has lov canbustible load and no continuity af ccmbustibles.
4)
The punps are over 10 ft apart edge-tomdge; Cable and conduit is embedded in concrete but exposed for a short length at each punp.
5)
A postulated fire involving in"situ and/or (transient'anbustibles vill be prevented fran spreading at the punp level by the floor openings and curbs separating each punp.,
6)
This fire area vas revieved by the NRC during a site visit (Reference
- 4) and determined to be an acceptable deviation.
7)'he punp roan is designed for natural ventilation which precludes the buildup of heat.
Conclusion M"M 1 Based on our evaluation, the existing arrangement provides adequate protection for the redundant Intake Cooling Mater Punps.
The installation af an
. autanatic suppression system vould not augnent or materially enhance the safety af the plant since the area design prevents the migration af a fire.
Therefore, ve conclude that this is an acceptable deviation fran Appendix R to 10CFR50, Section III-G.2.b.