ML17214A409

Forwards Rev 1 to App R Exemption Request Section, Summary of App R Analysis by Fire Area, Effective 830630.Encl Revises 830412 Fire Protection Submittal

ML17214A409
Person / Time
Site:	Saint Lucie
Issue date:	08/24/1983
From:	Robert E. Uhrig FLORIDA POWER & LIGHT CO.
To:	Eisenhut D Office of Nuclear Reactor Regulation
References
L-83-453, NUDOCS 8308300046
Download: ML17214A409 (42)

Text

REGUlATOR NFORMA'TION DISTRIBUTION S 'EM (RIDS)

AGCESSIOI4 NBR:8308300006 DOC.OATEN'3/08/2q NOTARIZED: NO DOCKET FAGIL!5g 335 -St ~ Lucia Planti Uni~t ig Flor ida Power 5 light Go+ 05000335 AUTH ~ NAME AUTHOR AFFILIATION UHRIGeR ~ E ~ F l oride,Power 8 Light Co, AECIP ~ NAME RECIPIENT AFFIlIATION EISENHUT~D ~ 6 ~ Division of Licensing

SUBJECT:

For wards Rev 1,,to App R exemption request sectioni "Summary of App R Analysis by Fire Area~," effective 830630,Enc) revises 830412 fire protection submi,t.'tel~ ~

DISTRIBUTION <<GODEj A006S .COPIES >RECEIVED'LTR. ' ENCL,

"' SIZE)~

TITLE: OR Submittal j Fir e i rotection ' " ~

NOTES>

RECIPIENT lGOPIES RECIPIENT 'COPIES IO CODE/NAME CTTR ENCl ID,CODE/NAME LTTR ENCL NRR ORB3 BG 01 <<3 INTERNAL; ELD/HDS2 1 0 IE FILE 06 1 1 IEINHITNEYg L 1 1 NRR F IORAVANT07 '2 2 NRR NAMBAGH 0 NR CE6 09 2 2 NRA/DL DIR 1 1 EG FILE 00 ROH2 1 EXTERNALS ACRS 11 3 3 LPDR 03 1 1 NRC,.PDR 02, 1 NSIG 05 ,i NTES 1 TOTAL NUMBER OF COPIES REQUIRED! lTTR 21 ENCL 19

II

~ A ) f (( f i

" l r) MI( M

)t l  : >lf>~i Il )<< I', M Il( ]

0 M" f' 'I 'l '0',) MIM l il(S f I f) t l ~ ~cv1 4 )

')JI,,I )l il>>MM I') fg>> (')') f I 0MM IM(fM f'e' 9 f'I ~ ~ $ T

((

0 ((>> f( c(M( QP Pj I

q april f f 'g 0<<w floe)MI') Ic( ) M,r) p, ') )I.I(A A '$ f MM c)",) (I' "III j ir I((MMN c)((/ f 'I jri ) S(M

~g) f ~ ((K M((>> ft ggg][Mo f ),'M II P'lf (~cl l(f 1 k ll M,i(, I($ 'j'c)M'(,MM,,(

iiAC f W=')'I P( "0 M '.M 3 f (( o I Mc'0 f f I' w

~,

)-(Y ( Ik) M(M l((

g M( j'll M* i I('%

'i)T

( M (( 4 g )I, 'l 4 g

~II'hyD)<<M y 3 )~Y )

l)iM lc

((

M P>

~ e(,"f T( JIM

),l(ll'( "ci II fii '1

( JI

>fr jfc

-0 BOX 14000, JUNO BEACH, FL 33408 FLORIDA POWER & LIGHT COMPANY August 24, 1983 L-83-453 Office of Nuclear Reactor Regulations Attention: Mr. Darrell G. Eisenhut, Director Division of Licensing U. S. Nuclear Reoulaiory Commission Washington', D. C. 20555

Dear MIr. Eisenhui:

Re: St. Lucie Unit No i Docket No. 50-335 Ap endix R Exemption Re uesis - Revision I In a letter dated April l2, l983 (L-83-227) Florida Power E, Light Co. submitted a Fire Protection submittal which contained several sec ions. Please find enclosed revision I to iha submittal which revises ihe section entitled, "The Summary of Apoendix R Analysis by Fire Area".

Snould you have any questions concerning this letter please do noi hesitate io contact us.

Very truly yours, E. Uhrig Vice President Advanced Systems and Technology PEU/RJS/PPC/sms Attachment cc: J. P. O'Reilly, Region II.

Harold F. Reis, Esquire llOI 8308300046 830824 PDR ADOCK 05000335 PDR, PEOPLE... SERVING PEOPLE

FLORIDA POWER & LIGHT CO.

ST. LUCIE UNIT 1 DOCKET NO. 50-335 APPENDIX R EXEMPTION REQUESTS REVISION I EFFECTIVE: JUNE 30, 1983

FIRE AREA This ire area includes fire zones 77 (Train "A" Electr'c Penetration Area),

59 (Bat cry Room "A" ), 60 ("A" Switchgear Roon), and 44A ("A" Cable Penetration Area Extension) as shown on the attached drawings. Essenti,al equipment within this fire area, is shown in the attached essential equipment list.

The following exemptions to Appendix R to 10CFR50 'are requested:

.An exemption is requested from Section Iil-G.2.a of Appendix R for wall p netration No. 11 in the east, 3-.hour fire barrier at fire zone 77, elevation 19.00 ft, because no fire damper is provided in the ventilation duct.

Evaluation Al

1) Ionization smoke detection is provided in the Fire Area.

2) The duct penetration through the east barrier of fire zone 77 is being provided with a fire stop of approved 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rating.

3) Pire damage to the duct located in Pire Area "J" is precluded because the neavy gage duct (which is 14 gage as compared to the 22 gage of a 3-hour rated fire damper), and heavy duty support, metal heat transmission and dissipati'on characteristics and metal "'osure angles applies to the duct on both sides of the barrier would serve to render the ductwork impervious to expansion deformation or heat failure for periods of expected fire du ation. While "ocalized high off-gas temperatures can be expected in the immediate vi.cinity of a fire, air mixture dilution temperature at the duct, which is 18 ft, above the floor, is not expected to reach high temperatures.

As the ventilation duct remains intact it is c'onsidered an extension of the Pire Barrier and thus the overal'ire resistance integrity continues undiminished.

4) There is no more than 5 'ft of duct in Fire Area "J" between penetration Nos. 11 and 19. In this area the duct is continuous with no registers and has a fire damper in penetration No. 19.

Fire Area "J" has very limited combustible loading.

6) Fire Area "J" is a high radiation area and therefore personnel access is limited, thus reducing the probability of transient combustibles being introduced.

'Conclusion Al I

Based on our evaluation, the existing fire barrier. provides adequate separation. The 'nstallation of a fi,re damper in the ventilation duct at penetration No. 11 would not augment or materially enhance the safety of the an, sin p lant since it would not aid in preventing fire migration between Fire Areas "A" and "J" . Therefore, we conclude, this is an acceptable exemption to Appendix R to 10CFR50, Section III-G.2.a.

Exem tion A2 An exemption is requested from Section III-G.2.a of Appendix R for ceiling penetration Nos. 62-3, 4 and 5 in fire zones 59 and 60 because no fire dampers or penetration fire seals are provided.

Evaluation A2 Fire Zone 59 has negligible combustible loading.

2) Fire Zone 60 is provided with ionization smoke detection. Fire Zone 59 is being provided with ionization smoke detection. Rl

3) Fire A"ea "A" as well as'the outdoor area above the fire barrier is.

lightly trafficked, thus reducing the probability of transient combustibles being introduced.

4) Roof-top fires are not a significant hazard based on the lack of combustible storage and heat dissipation from fires in transient combustibles. Where concentrations of combustible material, such Rl as oil in plant transformers or diesel generator fuel oil storage /

tanks, are in the plant yard adequate spacial separation from important plant facilities is provided a'nd the flow of combustible liquids is directed to or confined a safe distance from important plant facilities as autlined in the Fire Hazaid Analysis Report.

5) A steel missile shield enclosure for each roof-top ventilator provides additional fire protection.

Conclusion AZ Based on our evaluation, the existing'ir+ barrier provides adequate separation of these fire areas. The installation of fire dampers or penetration fire seals in the ventilation exhausts at penetration Nos. 62-3, 4 and 5 would not augment or materially enhance the safety of the plant.

Therefore, we conclude, this is an acceptable exemption to Appendix R to 10CFR50, Section III-G.2.a.

0

~ FIRE AiKA B "This f ire area is f ire zone 57 (cable spread .room) as shown on the attached drawings. Essenti.al equipment wi th' this fire area is shown in the attached essent'al equipment list.

The following exemption from Appendix R to 10CFR50 is requested:

An exe ption is requested from Section III-G.2a of Appendix R because a 3-hour rated fire door is not provided at the entry on the west wall of this fire

'rea, on elevat'on No. 43.00 feet, and no fire damper or penetration'fire seal is provided in the HVAC exhaust.

Evaluation Bl

1) Outdoor exposure fires, are not postulated in the plant yard based on the lack combustible storage adjacent to buildings. Where concentrations of combustible materials (such as oil 'in the Turbine Generator Building) exist, fire detection and automatic suppression systems are provided and the flow of combustible liquids is confined as outli.ned ir the Fire Hazard Analysis Report.

2) The doorway and exhaust is over 20 ft abovegrade which permits heat dissipation.

3) Ionization type smoke detection and an automatic Halon 1301 suppression system is provided in this fire area.

4) A postulated fire involving i.n-situ or. transient combustibles in

~ Fire Area "B" would not affect the nonessential Turbine-Generator Builcing because of the large physical separation and the heat dissipation effects of the atmosphere.

5) The hot shutdown panel, which provides alternate shutdown capabil'ty for a fire in this area, is located in fire zone 56 of Fire Area "C". These fire areas will be totally separated by a 3-hour rated'ire barrier.

Conclusion Bl A fire in Fire Area "B" will not impair the availability of the hot shutdown panel {A-Train) and therefore, establishes an alternative shutdown capabil'ty which meets the criteria of Appendix R, Section III-L. The installation o .a fire door and damper and penetration fire seal in the west wall of Fire Area "B" would not augment or materially enhance the safety of the plant.

Therefore, we conclude that this is an acceptable exemption from Appendix R to 1GCFR50, Sections III-G.2.a.

FIRE AFZA "C" This fire area includes fire zones 55W (Cable Loft), 78 (Train B Electrical Penetration Area), 43*; 44*, 54* (RAB Personnel Areas), 56 (Train B Switchgear Room), and 58 (Train B Battery Room), as shown on the attached drawings. Essential equipment within this fire area is shown in the attached essential equipment list.

The following exemptions to Appendix R to 10CFR50 are requested:

Exemption Cl An exemption is requested from Section III-G.2.a of Appendix R for exterior wall and roof penetrations because no fire dampers or penetration fire sea's or doors are provided.

Evaluation Cl

1) Fire Area "C" is provided with ionization smoke detection.

2) Outdoor exposure fires are not postulated in the plant yard based on the lack of combustible storage adjacent to buildings and on the .

height of penetration above grade which allows for heat dissipation. Where concen"rations of combustible material, such as oil in plant transformers or 'diesel generator fuel oil storage.

tanks, are in the plant yard adequate spacial separation from ~

important plant facilities and/or fire suppression systems are provided and the flow of combustible liquids is directed to or confined a safe distance from important plant facilities as outlined in the Fire Hazard Analysis Report.

3) A postulated fire involving in-situ or transient combustibles in Pire 'Area "C" does not require 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated dampers or penetration fire seals or doors due to the non-essential nature of the'urbine Generator Building and large physical separation, the yard area and the additional'issipation of heat to tne atmosphere.

Conclusion Cl Based on our evaluation, the existing .fire barrier provides adequate separation. The installation of fire dampers, penetration fire seals and doors at exterior penefrations would not augment or materially enhance the safety of the plant since they would not aid in the preventing fire migration through the fire barrier. Therefore, we conclude, this is an acceptable exemption to Appendix R to 10CFR50, Section III-G.2.a.

An exemption is requested from Section III-G.2.a of Appendix R for the hatch at Column RAJ/RA5 because a steel hatch cover of 1/4 inch minimum thickness is being provided a" elevation 19.5 feet.

Evaluation C2

1) The hatch cover is 'ocated in the fire barrier between Fire Are-s "C" and "0", both of which have ionization smoke detection.

2)' 1/4 inch minimum th'ckness steel hatch cover is provided.

3) Fire damage to the hatch cover is precluded because the metal thickness, heat transmission and dissipation characteristi.cs serve to render the cover impervious to deformation or heat failure for periods of expected fire duration. Phile localized high off-gas temperatures can be expected in the immediate vicinity of, a fire, air mixture dilution and the cooling effect of manually applied hose stations will mi.t'gate the effects and duration of a fire.

Conclusion C2 Based on our evaluation, the provision of a 1/4 in. minimum thickness steel hatch cover provides adequate separation of fire area. The use of materials of greater fire resistance for the hatch cover would not augment or materially enhance the safety of the plant since "0"

it "C".

would no aid in preventing f're migration between Fire Areas and Therefore, we conclude, this is an acceptable exemption to Appendix R to 10CFR50, Section III-G.2.a.

Exem tion C3 An exemption. is requested from Section III-G.2.a of Appendix R for the entries to the holdup tanks provided.

on elevation 19.50 ft {zone 41) because no fire doors are Evaluation C3 Fire Area "C" is provided with ionization smoke detection.

2) Pire "one 41 contains negligible combustible load.

3) The entries to fire zone 41 are insi'de labyrinthine entry corridors with wire mesh access doors.

4) The holdup tanks contain several thousand gallons of water which would tend to rapidly dissipate heat geneiated by a fire in Fire Area "C" through the tank wa3.ls into the contained ~ater.

5) There is no continuity of combustibles in fire one 41, which w 11 mitigate the propagation of fire from Fire Area "C" to adjacen Fire Area "E".

Conclusion C3 Based on our evaluation the existing fire barrier provides adequate separation. The installation of fire doors at the entries.to holdup tank room would not aug-ent or materially enhance the safety of the plant since they would not aid in preventing fire migration through the entries. Therefore, we concludeq this is an acceptable exemption to Appendix R to 10CFB50, Section Iil-G.2.a.

FIR" AREA D This fire area is the A-Train Electrical Equipment Room located within the nf's 0 fire conzines of e zone 57* as a shown on the attached drawings. Essential equipment is listed in the attached essential equipment list.

st.

This fire area is totally enclosed in 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated barriers, providing se a~a"ion from the redundant B-Train electrical equipments in Fire Area "B".

This fire area meets the criteria of Appendix R, Section'III-G..a.

II-G.2.a.

f f ire area includes ire zones 46 (Containment <<rge) "7 (AB Sw>

Room), 49 (RAB Uolume Conrrol Tank), 48 (RAB Lerdown ?leai Kxchan g er)), 61 (RAB HVAC Equipment Room), 41 (RAB Holdup Tank), 55 '(Corridor east of column line RAH), 50 (Demineralizers), 51 (Drumming Station), 52 (Boric Acid Concentrators),) 62 (Resin sin Addition Tank) and 80 (Steam Generator Blowdown Tank) as shown on the attached drawings. Essential equipment within this w'in f is ire area is shown on the attached list.

The following exemptions from Appendix R ro 10CFR50 are requested.

Exemption El

-, An exemption is requested from Section III-'.2.a o f App endix i R for the hatch at Column RAC/RA4 because a stee'atch cover of 1/4 inch minimum thickness. is being provided at elevation 19.50 feet.

Evaluation El

') Th hatch cover separates Fire Areas "E" and "0", both of which have ionization smoke detection.

2) A 1/4 inch minimum thickness steel hatchcover is provided.

3) Fire damage to the hatch cover is precluded because the metaa1 thickness, heat transmission and dissipation characteristics serve d he over imperv-'ous to deformation or heat failure or periods of expected fire duration..While localizedd hig hi h ooff--gas as ttempera er rures u can be expected in the immediate vicinity of a fire, air mix u e dilution and the cooling effect of manual y app ie ixture hose streams will mitigate the effects and duration oof a f ire.

Conclusion El Based on our evaluation, the provision of a 1/4 in. minimum thickness steel hatch cover provides adequate separation of fire areas. e . The use of materia s o f grea t er fi re resistance for the hatch cover would not augment or materially enhance the safety of the plant since '=it would not aid in the preventing f lre

a. i migration between Fire Areas "E" and "0". Therefore, we conclude, this is an acceptable exemption to Appendix R to 10CFR50, Section III-G.2.a.

Exemption E2 An exe ption is requested from Section llI-G.2.a of supp endix R because no fire doors or dampers or penetration fire seals are provided at exterior wall penetrations.

Evaluation E2 Outdoor exposure fires are not postulated " n the plant yard based on the lack of combustible storage adjacent to buildings. %here concentrations of combustib}e.mate ial (such as oil in the Turbine Generator Building) exist, fire detection and automatic suppression systems are provided and the flow of combustible liquids is confined as outlined in the Fire Hazard Analysis Report.

2) A postulated fire involving in-situ or transient combustible's in Fire Area "E" would not affect the nonmssential yard area because of the heat dissipation effects of the atmosphere.

Conclusion E2 Based on our evaluation, the existing fire barrier provides adequate separation. The installation of the fire doors, dampers and fire seals in exterior wall penetrations would'not augment or materially enhance the safety of the plant. Therefore, we conclude that this is an acceptable exemption from Appendix R to 10CFR50, Section III-G.2.a.

Exemption E3 An exemption is requested from Section III-G.2.a of appendix R for the entries to the holdup tanks (zone 41) because no .fire doors are provided.

Evaluation E3 See Evaluation C3 Conclusion E3 See Conclusion C3

FL.E AREA "F" This fire area f,s fire,zones 70, 71, 73 and 82 '(Control Room Envelope) as shown on the attached drawings. Essential equipment within this fire area is shown in the attached 1 is t .

The following exemptions to Appendix R to 10CFR50 are requested:

Exemption Fl An exemption is requested from Section III-G.2.a of Appendix R for exterior wall penetrations because no fire dampers or penetration seals are provided; Evaluation 'Fl

1) Outdoor exposure fires are not postulated in the plant yard based on the lack of combustible storage adjacent to buildings. Where concentrations of combustible material (such as oil in the Turbine Generator Building) exist, fire detection and automatic suppression systems are provided and the flow of combustible liquids is confined as outlined in the Fire Pmzard Analysis Report.

2) The penetrations are over 50 ft above grade which permits heat dissipation.

3) Ionization type smoke detection is provided in this fire area.

4) A postulated fire involving inmitu or transient combustibles in Fire Area "F" would not affect the non-essential Turbine Generator Building because of the large physical separation and the heat dissipation effects of the atmosphere.

Conclusion Fl Based on our evaluation, the exfsting barrier provides adequate separation.

'The installation. of fire dampers or penetration seals in exterior walls of Fire Area "F" would not augment or materially enhance the safety of the plant. Therefore we conclude that this is an acceptable exemption from Appendix R to 10CFR50, Section III-G.2.a.

An exemption is requested from Section III-G.3 of Append'x R because no fixed fire suppression. system is provided.

Evaluation F2

1) The Hot Shutdown Panel, which provides alternate shutdown capability for a fire in this area, is located in fire zone 56 of Fire Area "C". These fire areas are totally 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.

2) Fire Area "F" is provided with ionization type smoke detection.

3) Accessible fire .hose stations are located in the Turbine Building near Control Complex entries to facilitate manual firefighting capability.

4) The Fire Area is continuously. manned with senior operations personnel -including the Nuclear Watch Engineer, who is the'ire Team Leader.

5) Portable fire extinguishes are strategically located throughout the Control Room for first aid fire fighting. This includes water type, carbon dioxide and dry'hemical units.

Conclusion F2 Based on our evaluation, the existing fire protection is adequate. The installation of a fixed fire suppression system would not augment or materia'ly enhance the safety of the, plant. Therefore we conclude that th's is an acceptable exemption from Appendix R to 10CFR50, Section III-G.3.

FIR-"" *AREA "G-G" This fire area is the yard area includirg previously designated f're areas 10 (Gas Storage Building), ll (>U.sc. Oil Storage 'Buildings) 12 (Water Plant).,

(Chemistry Personnel Building), 79 (Raw Water Storage Tanks) and 81 (Area.

42 between RAB and RCB). This fire area contains no essential equipment or cables and Appendix R Section III-G does not apply.

Fire Are "H-H" This fire area is the Diesel Generator Building 1A previously designated as Fire Area 6. Essential equipment within this fire area is shown in the attached essential equipment list.

The following exemptions to Appendix R to,10CFR50 are requested:

Exem tion H-H 1.

An exemption is requested from Section III-G.2.a of Appendix R for labyrinth entries, and penetrations in the exterior fire barrier walls because no fire rated doors, penetration seals or fire dampers are provided.

Elevation H-H 1 The fire area is lightly trafficked, thus minimizing the probability of indroducing transient combustibles.

2) The fire area has thermal fire detection and a pre-action sprinkler system.

3) Outdoor exposure fires are not postulated in the plant yard based on the lack of combustible storage adjacent tc buildings.

4) Pire Area "H-H" is sepaiated from Fire Area "I-I" by a full height 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated (18 inch) inter'or rire. barrier.

5) Possible oil flow a rupture of any of the oil containing vessel in this fire area will be confined and/or safely directed away from important plant structures by floor- drains. Although highly unlikely, any oil escape would be through the lowest level of egress where it would be directed away from the premises by the site drainage arrangements.

6) All exterior penetrati'ons are'missile protected.

Concusion H-H 1 Based on our evaluation, the exterior fire barrier wall, and 24 inch thick reinforced concrete exterior walls with labyrinth entries provide adequate separation. The provision of fire rated, doors, penetra" ion seals and dampers would not augment or materially enhance the safety of the plant since would not aid in the preventing of fire migration between Fire Areas "H-H" and it "I"I" therefore, we conclude, this is an acceptable exemption to Appendix R t'o 10CFR50, Section I II-G. 2.a.

Fire Area "I"I" This fire area i the Diesel Generator Building 1B previously designated as Fire Area 7. Essential equipment within this f're area is shown in the attached essential equipment list.

The following exemptions to Appendix R to 10CFR50 are requested:

Exemptions I-I 1 An exemption is requested from Section III-G.2.a of Appendix R for labyrinth entries, and penetrations in the exterior fire barrier walls because no fire rated doors, penetration seals or fire dampers are provided.

Evaluation I-I 1 The fire area is lightly trafficked, thus minimizing the probability of introducing transient combustibles.

2) The fire area has thermal fire detection and a preaction sprink" er system.

3) Outdoor exposure fires are not postulated in the pl"nt yard basea on the lack of combustible storage ad)acent to buildings.

4) Fire Area "I-I" is separ'ated from Fire Area "H-H'y a full height; 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated (18 inch) interior fire barrier.

5) Possible oil flow from a rupture of any of the oil containing vessels in this fire area w'll be confined and/or safely directed away from important plant structures by floor drains. Although highly unlikely, any o'1 escape would be through the lowest level of egress where it would be directed away from the premises by the site drainage arrangements.

6) All exterior penetrations are missile protected.

7) The diesel building air intake is over 60'rom its redundant counterpart.

Concusion I-I 1 Based on our evaluation, the exterior fire barrier wall, and'24 inch thick reinforced concrete exterior walls with labyrinth entries provide adequate separation. The provision of fire rated, doors, penetration seals and dampers would not augment or materially enhance the safety of the plant since it would not aid in the preventing of fire migration between Fire Areas "H-1i" and " -I" therefore, we conclude, this is an acceptable exemption to Appendix R to 10CFR50, I II-G. 2. a.

. FIRE AREA "J" This fire area includes fire zones 33, 45 (RAB Pipe Tunnel) and 62B (RAB ECCS Ventilation Equipment') as shown on the attached drawings. Essential equipment within this fire area is shown in the attached essential equipment list.

The following exemptions from Appendix R to 10CFR50 are requested:

Exemption Jl An exemption is requested from Section III-G.2.a of Appendix for penetration No. ll R on elevation 19.50 f t because no fire damper is provided in the ventilation duct.

Evaluation Jl This exemptioa is evaluated as Exemption No. Al in Fire Area "A".

Conclusion Jl See Conclusion Al of Fire Area "A".

Exemptioa J2 An exemption is'equested from Section III-G.2.a of Appendix R for penetration No. l3 on elevation 42.00

.'is ft because ao fire damper or. penetration fire seal provided in the ventilation duct.

Evaluation J2 Fire Area "J" contains low combustible J.oading .

2) Outdoo" exposure fires are'ot postulated in the plant yard based on the lack of combustible storage adjacent to buildings. Where concentrations of combustible material (such as oil in the Turbine Generator Building) exist, .fire detection and. automatic suppression systems are provided and the flow of combustible liquids is confined as outlined in the Fire Hazard Analysis Report.

,3) The duct penetration is located over 35 feet above grade which permits heat dissipation.

Conclusion J2 Based on our evaluation, the existing fire barrier provides adequate separation. The installation of a fire damper in the ventilation du"t and a penetration fire seal at peretration No. I3 would'ot augment or materially enhance the safety of the plant. Therefore, we conclude, that this is an acceptable exemption from Appendix R to 10CFR50, Section III-C.2.a.

Exemption J3

~

~

An exemption is requested from Section III-G.2.a of Appendix R for penetration No. 5 on elevation -0.5 ft because no penetration fire seal or fire damper is provided in the venti" ation duct.

Evaluation J3 This exemption is evaluated as Exemption No. L2 in Fire Area "L".

Conclusion J3 See Conclusion L2 of Pire Area "L".

Exemption J4 An exemption is requested from Section III-G.2. a 'of Appendix R for watertight doors RA-7 and 8 because the fire rating of the custom manufactured doors is not Underwriters Laboratory listed.

Eva'uation J4

l. The water tight doors separate Fire Areas which have low 'in-situ combustibles and as radiation areas, have limited personnel access, which reduces the probability of introducing transient combustibles.

2. The doors are solid steel, minimum of,l/4 inch thickness..

3. Pire damage to the doors is precluded because the metal thickness, heat transmission and dissipation characteristics serve to render the doors impervious to deformation or. heat failure for periods of expected fire duration. While localized high off-gas temperatures can be expected in the immediate vicinity of a fire, air mixture.

dilution and the cooling effect of manually'applied hose streams will mitigate the effects and duration of a fire.

Conclusion J4 Based on our evaluation, the provisions or l/4 inch thick steel doors provides adequate separation of fire areas. The use of materials of greater fire resistance for the watertight doors would not augment or materially enhance the safety of the plant s'nce it would not aid in preventing fire migration between fire areas. Therefore, we conclude, this is an acceptable exemption to Appendix R to 10CPR50, Section III-C.2.a.

FIRE AREA "iC" This fire area is the Reactor Containment Building previously designated as Pire A"ea 26. Essential equipment within this fire area is shown in the attached essential equ3.pment list.

The following exemption tc appendix R to 10CFR50 is requested:

Exem tion Kl An exemption is requested from Section III&.2.d of Appendix R because the containment cables and associated non-safety circuits of redundant trains are not in all cases separated by 20 f t.

Kl 'valuation A new Reactor Cooling Pump Oil Collection System is provided to collect pressurized and unpressur-'zed leaks from each of the Reactor Coolant Pump Lube Oil Systems. This installation will confine the major portion of combustible inventory to a separate o'1 collection tank in accordance with Appendix R, Section III&

The'remaining, combustible loading in the fire area is light.

2) Pire detection i,s provided. at various key locations of consequence.

3) Redundant safety-related equipment is protected from exposure to localized combustible sources by spatial separation and/or the use of existing barriers/partitions (i.'e. concrete walls, floors and ceilings) having greater than three hours fire resistive rating.

Separation is provided to maintain independence o'f electrical circuits and equipment so that the protective function required during any design basis event can be accomplished. The degree of separation varies with the potential hazards 'n a and'etnod particular. area. This is accomplished by use of spatial separation, barriers, and. radiant energy shields where required.

4) Electrical cables are concentrated at the Penetration Areas at Elev 23.00 ft between Column Lines 6 and 8. The cables trays are immediately separated and routed to the several items of equipment.

Radiant energy shields are being provided between safety-related A and' cables trays in the cable penetration area to provide separation-

. ~

5), All cables in Fire Area "K" are coated with Flamemastic fire protect've coat'g system.

6) Fire Area "k" is a high radia"i'on area and personnel access is limited, thus minimizing the probability of introducin transient combustibles.

large free volume (2.5 mi1lion cubic feet) of Pire Area lt K

'll

7) The

' o h o t of -gas temperatures and reduces tne allows for didiissipat'on effect or" stratified hot. gases at essential componerts.

8) All instrument cable trays are covered.

Conclusion Kl e p 't Based on our evaluation, the existxng features in Pire Area "K" provige equ ~ separation for a fare in transient or in-situ combustibles-a dequate Additional modif ication would,not augment or materially ant since would not.aid in the prevention of o onents essential for safe 'shutdown.

ia enhance the safety o fire damage Therefore, we conc u e, acceptable exemption to Apperdix R to 10CPR50, Section III-G.2 d.

to redundant f

Exem tion K2 An exemption is requested from Section Il--0 of App A endix R because the Oil il Collection System is not capable of, collecting lube o from all four of the reactor coolant pump lube oil systems.

Evaluation K2

1) Per desi.gn specifications, components inside'ontainment have a

~

maximum allowablesurface temperature during normal operation of 0 P, thus reducing the probability of starting a fire.

Oil used:.

Flash Point 450'F Pire Poa.nt 480 P, Ignition Point " 530'F

2) The RCP oil collection system is required to be Seismic Category II per R.G. 1.29, paragraph C.2 ~

3) A design basis accident and a fire are.not postulated to occur simultaneously.

4) Under normal operatin assu e that.'ll RCP

~

cond'tions, it would be once.

oil systems wou" d fail at impractical to Therefore, a tank to contain all RCP oil is rot necessary.

5) Each room RCP oil system has an aLnr:..li r:". '"..ich If approxi ma rely 1> gallcns o" o '

w'~ 1 soulid

's soui d i the iil coiltzo system. Tais.ala.".m requir~s operator action

6) NRC response, 01MTch 21, 1979; SER, ,,

required the following:

Reactor Coolant Pun s Vre have requeste d that t a an a . oil collection system be provided for each of the reactor coolant pumps. 'The licensee hasdeferred action on this recommendation pend'ng the final resolution of an "PRI ud "Fvaluation and Test of Improved Fire Resistant Fluid L b i ~ts for Water Reactor Coolant Pump Hotors. If a suitable lubricant is not found, the licensee will provide a sy s em to 1 fi s or provide for the removal of potential oil leakage to a safe location by December 1980. No additiona tional information is required from the licensee (5e10).

This requires only for the removal of ~oeential oil Leakage and only to a safe. location.

7) The RCP oil collection tank is'apable of holding 225 gallons which exceeds the total capacity of one pump (190 gal.) plus reasonable.

leakage from the remaining pumps.

Conclusion K2 i

Based on our eva 1 uat on, thee existing e RCP oil collection system provides i

adequate capa bility for collecting lube oil rom all potential ial pressurize ressurized an and unpressurzze d 1 ea k age si"es in the reactor coolant pump lube o 1 sys Additional modifications would not augment or materi all ~ y enhance the safety of tne plant since it woul not ai'd in the prevention of fire damage to redundant t' f r safe shutdown. Therefore, we conclude, tthis components essentia'r >~s iss an acceptable exemption to Appendix R to 10 CFR 50,Section XII.O.

FXRE AREA "L this f ire area is fire zones 31 and 32 (Shutdown Heat Excnanger Room) as shown on the attached drawings. Essential equipment within this area is shown in the attached essential equipment list.

The following exemptions from Appendix R to 10CFR50 are requested:

Exem tion Ll An exemption is requested from Section X'lI-G.2.a of Appendix R because a full height 3 hr rated fire barrier is not provided between the redundant shutdown heat exch'angers.

Evaluation Ll

1) The shutdown heat exchangers are 16 ft apart edge to 'edge and are" separated by a 7 ft high 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated partition.

2) This fire area contains a neg'igible "n-situ combustible load and as a radiation area has limited personnel access, which reduces the probability of introducing transient combustibles.

3) This fire area is being provided with ionization type smoke detectors.

4) A fire on either side of. the fire partition involving either in-situ and/or transient combustibles could 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 tne 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 jeopardizing the operation of the redundant heat

.-'xchanger.

Conclusion Ll Based on our evaluation the existing 7 ft high 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated part'tion provides adequate separation of the redundant heat exchangers. Providing a full height 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> f'ire barrier in lieu of the existing partition would not augment or materially increase the safety of the plant since'a single fire would not cause damage to the redundant heat exchangers. Therefore, we conclude that t'his is an acceptable exemption from Appendix R to 10CFR50.

Section Ill-G.2.a.

Exemption L2 An exemption is requested rrom Section III<.2.a of Appendix R for penetrations 6, 7, 8, 16, 17 and 22 through'the barr'er between Fire Areas "L" and "0" and for penetration 5 through the fire barrier between Pire Areas "L" and "J" because no penetration fire seals or fire dampers are provided in the ventilation ducts.

Evaluation L2

1) Fire Area "L" has negligible in-situ combustibles and as a radiation area?as limited personnel access, whicn reduces the probabili y of introducing transient combustibles.

2) Fire Area "0" is provided with ionization type smoke detection.

Fire Area "L" is being provided with similar detection.

The major component of the combustible load outside Fire Area "L" consists of horizontal cable trays which are a minimum of 8 ft above the floor. A fire in this area would be quickly detected and mitigated by first aid manual standpipe hose application. Wile localized high off-gas temperatures could be produced in the area of a fire, air mixture dilution temperatures which might enter Fire Area "L" would stratify in the upper levels of this area and would not reach a point capable of jeopardizing the operation of the heat exchanger s ~

Conclusion L2 Based on ou evaluation the existing fire barrier provides adequate separa ion. The installation of fire dampers in the ventilation ducts at penetrations 5, 6, 7> 8, 16, 17 and 22 or penetration fire seals would not augment or materially increase tne safety of the plant since they would not provide material protection for'the heat exchangers. Therefore, we conclude that this is an acceptable exempt'on from Appendix R to 10CFR50, Section III&.2.a.

Exemption L3 An exemption is requested from Section III< 2 a of Appendix R ror watertight door RA-7 and 61 because of fire rating of the custom manufactured door is not Underwriters Laboratory listed.

Evaluation L3 See Evaluation J4(RA-7) and Evaluation 1Q(HA-61) .

Conclusion L3 See Conclusion Ji(RA-7) and Conclusion H2(RA-61) ~

I PIRE AREA "H" I

This fire area is fire zones 34 and 35 (RAB ECCS Room) as shown on the, ttached drawings. Essential equipmen" within this fire area is shown in the attached essential equipment list.

The following exemptions to Appendix R to 10CFR50 are requested:

Exem tion nfl An exemption is. requested from SectS. on IIX-G.2.a of Appendix R because a full height 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated fire barrier is not provided ~

between the redundant shutdown cooling pumps.

Evaluation K.

Fire Area "Y's provided with ionization smoke detectors.

2) The Fire area has a-very low combustible loading.

3) Fire Area "8's a"radiation area and therefore personnel 'access is limited which reduces the probability of introducing transient combustib'les.

4) The redundant LPSI Pumps are physically over 20 ft apart, edge to edge.

Pedundant equipment and cable essential"for safe shutdown in this ft fire area are separated by a 20 high, 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated partition from Column RAI to RAG (reducing to 9.5 ft high from Column RAG to RAE).

A postulated fire on either side of the 20 ft high 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated partition involving transient or in-situ combustibles 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 immediate vicinity of a fire, air m'xture dilution temperatures would not reach a level detrimental to the normal operation of the LPSI Pumps.

7) Cable indicated in the. attached list, extending above the fire rated partition, is being protected or relocated.

Conclusion M.

Based on our evaluation, the existing 20 ft high 3 hour fire rated partition P rovides adequa e separation of redundant trains. The extension of the partition te full height,

~ '

would not augment or materially ~ '

enhance he sa ety of the plant since it would not aid in the containment of a fire to one train of equipment required for the shutdown. Tl)erefore, we conclude, this is an acceptable exemption to Appendix R to 10CFR50, Section III-G.2.a.

~

~

Exem tion M2 An exemption is requestet d from rom Section e llI-G.2.a of Appendix R for watertight doo"s RA-4 5 6 and 61 because the fire rating of the custom manufactured doors is not Underwriters Laboratory listed.

Evaluation M2 l) The watertight doors separate Fire Areas M and 0 and M and L (Door 61). Fire Area M and L, as radiation areas, have limited personnel access, which reduces the probability of introducing transient combustibles. Fire Areas L, M and 0 have a smoke detection system for early warning of a fire condition.

2) The door is solid steel, minimum of 1/4 inch thickness.

3) Fire damage to the door is precluded because the metal thickness, h t tr nsmission and dissipation characteristics serve to render the door impervious'o deformation or heat failure for per ods o expected fire duration. While localized -high off-gas temperatures can be expected in the immediate vicinity of a fire, air mixture dilution and the cooling effect of manually applied hose streams will migitate the effects -and duration of a fire.

Conclusion M2 Based on i our eva 1 uat on, th e p rovisi'ons o of l/4 inch thick steel doors. provides t

a d equate separation sepa a n of f fire areas. The use of materials of greater. fire resista ce for t e wa zor the watertight doors would not augment or materially enhance the safety of the plant since it would not aid in preventing iree migra mi ration between fire areas. Th ere f ore, we conclude this is an acceptable exemption to Appendix R to 10CFR50, Section XXI"G.2.a.

This fire area is fire zones 38, 75, 76 and 36A. (charging Pump Area) as shown on the attached drawings. Essential equipment in this area is shown in t e attached essential equipment list.

The following exemptions from Appendix R to 10CFR50 are requested:

Fxemption is requested from Section III-G.2;a of Appendix R since the redundant charging pumps are not separated 'by a full height 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 Hl

1) Fire Area "N" is being provided with ionization type smoke detection.

2) The charging pumps are approximately 10 ft apart separated by a 7 ft high 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated partition pith labyrinth entries from the common access corridor.,

3) This fire area contains a very low combustible loading and as a radiation area has limited personnel access, thus reducing the probability of introduci'ng transient combustibles.

4) A fire on either side of the fire partitions involving in-situ and/or transient combustibles 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 jeopardizing the operation of the redundant charging pumps o

5) Cable indicated in the attached list, extending ab'ove the fire rated partition, is being protected or relocated.

Conclusion Nl Based on our evaluation, the 7 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 tne redundant charging pumps. The extension of the walls to full height would no" augment or materia'y enhance the safety of the plant since it would not provide additional protection for redundant charging pumps. Tnerefore, we conclude that this is an acceptable exemption from Appendix R to 10 CFR50, Section III-G.2.a.

0 Exemption N2 A ~

x tion is reauested from Section III-G",2.b of Appendix R because no sprinkler system is prov'-ded in the common access corridor (zone( o ).

36A).

Evaluation N2 I) Fire Area "N" has negligible in-situ combustibles and as e radiation area has limited personnel access, therefore reducing the probability of introducing transient combustibles.

2) The access corridor contains charging pump push button stations, separated by more than 20 ft with negligible intervening combustibles~

3) The charging pumps cubicle access corridor 's being provided with an ionization type smoke detection system.

Conclusion N2 Based on our evaluation the existing separat'on and negligible combustible load provides adequate protection for the push buttons. The addition of an automatic sprinkler system would not, augment. or materially enhance the safety of the plant since it would'ot reduce the time required for .fire extinguishment. Therefore, we conclude that this is an acceptable exemption from Appendix R to 10CPR50, Section IXI-G.2.b.

Exem t'on N3 An exemption is requested from Section XIX-G.2.a of Appendix R for watertight door RA-8 because the fire rating of the custom manufactured door is not Underwriters Laboratory listed.

Evaluation N3 - See Evaluation J4, Conclusion N3 See Evaluation J4.

F~DZ A~~A "0" This fire area includes fire zones 27, 29, 36, 37, 39, 40 and 74 as shown on the attached drawings. Essential equipment ~ithin this fire area 's shown in the attached essential equipment 1'st.

The following exemptions to Appendix R ato 10CFR50 are requested:

Exemption 01 An exemption is requested from section III-G.2.a of Appendix R for penetrations 6, 7, 8, 16, 17 and 22 through the barrier between Fire Areas "L" and "0" because no penetration fire seals or fire dampers are provided in'he ventilation ducts.

Evaluation 01 See Evaluation L2 Conclusion 01 See Conclusion L2 Exemption 02 An exemption is requested from Section XIX-G.2.a of Appendix R .for the hatch at Column RAC/RA4 because a steel hatch cover of 1/4 inch minimum thickness is being provided at elevation 19.50 feet.

Evaluation 02 See Evaluation El Conclusion 02 " See Conclusion El Exemption 03 An exemption is requested from Section IIIW.2.a o f Ap pendix R f or the ha" ch at Column RAJ/IVY because a steel hatch cover of 1/4 inch m'nimum thickness is being provided at elevation 19.'50 feet.

Evaluation 03 - See Evaluation C2 Conclusion 03 See Conclusion C2 Exemption 04 An exemption is requestec from Section III-Q.2.a of Appendix R for watertight doors RA-4, 5 and 6 because the fire rating os the custom manufactured doors is not Underwriters Laboratory listed.

Evaluation 04 << See Evaluation H-2 Conclusion 04 See Conclusion M-2

~ ~ 4 ~

0 PERK AR""A "P-P" This fSre area is the Fuel Handling Building previously desigated as Fire Area 64 through 69. This fire area contains 'no essential equipment or cables and Appendix R Section EEE-C does not apply.

FIRE a@A "0-0" This fire area is the Turbine Building previously designated as Fire Area 13 through 25. This fire area contains no essential equipment n or cables and Appendix R Section III-G does not apply.

FIRE ABACA "R-R" This fi"e area is the intake cooling water pu-p area previously-.designated as" Fire Area 3. Essential equ'pment within this fire area is shown in the attached Essential Equipment List-The following exemptions from Appendix R to 10CFR50 are requested:

Exem tion R-R 1 An exempt'on from Section III'-2.b of Appendix R is requested because no automati'c suppression system is provided-Evaluation R-R 1

1) This fire area is lightly trafficked, thus minimizing the probability of introducing transient combustibles.

2) The fire area has low combustible load ana no continuity of combustible s')

The pumps are over 13 ft apart centerline to centerline. Cable and conduit is embedded in concrete but exposed for a short length at each pump.-

4) A postulated fire involving. in-situ andlor transient combustibles will be prevented from spreading at the pump level by the f3.oor openings and curbs separating each pump.

5) The pump room is designed for natural'ventilation which precludes the buildup of heat.

6) Fire. Area R-R is being, provided with afire detection system.

Conclusion R-Rl Based on our-evaluation, the existing arrangement provides adequate protect" on for the redundant Intake Cooling Mater Pumps. Tne installation of an automatic suppression system would not augment or materially enhance the safety of the plant since the area design prevents the migration of a fire.

Therefore, we conclude that this is an acceptable exemption from Appendix R to 10CFR50, Section III-G.2.b.

FIRE ARF.A "S-S" This rire area is the Steam Trestle Area previously designated as Fire Area l. Essential equipment within this fire area is shown in the attached e s sent al e quipmen t 1 is t .

The following exemption to Appendix R to 10CFR50 is requested:

Exe ption S-Sl An e x'emption is requested from Section III-G.2.b of Appendix R for fire detection and automatic fire suppression because a detection and automat c fire suppression system is not provided.

Evaluation S-Sl

1) The fire area is lightly trafficked thus minimizing the, probability of introducing transient combustibles.

2) The fire area has a very low combustble loading with no cont'nuity of combustibles.

3) Auxiliary Feed Mater Pump C and its associated valves and cables 'is separated from its redundant coun"erparts, Auxiliary Feede Latex Mater Pumps A and B and their associated valves and cables, by 28 feet.

4) Pum p C is located 0 within a concrete dike wall and steel missile shield. Pumps A and B are located within a separate but simila r enclosure.

5) This is an open-air structure, allowing for vertical heat dissipation to atmosphere from a fire involving in-situ and/or transient combustibles.

Conclusion S-Sl B a sed on our evaluation the existing spacing, missile shields and negiigible combustibles provide adequate separation. The installation of tire detect io n or an automatic suppression system would not augment or material'y enhance the

. sa fety or th e p 1 an t since it would not improve the natural separation already Therefore, we conclude, this is an acceptable exemption to Appen x' endix'rovided.

to 10CFR50 Section III-G.2.b.

0 EIRF. AREA "T-T" This f re area is the Diesel Oil Storage Tanks previously designated as Fire Area 4. Essential equipment within this fire area is show,. in the attached essent'al equipment list.

The following exemptions to Appendix R to 10CFR50 are requested:

~memption T-Tl An exemption is requested from Section III-G.2.b of Appendix R for fire detection and an automatic fire suppression system because detecrors and automatic fire suppression is not- provided.

Evaluation"I-X1 tx

1) The area is lightly trafficked, thus, minimizing the probability of introducing combustibles. 'I

2) . Adequate spacial'eparation from other plant equipment required for saf e shutdown is provided.

3) Outdoor exposure fires are not postulated in the plant yard igniting the diesel oil based on the lack of combustible storage adjacent to the tanks.

4) Redundant tanks are 21 feet apart, shell to shell.

5) Redundant tanks are in separate 5.5 f t high concrete dikes.

6) Tank spac'ng and diking arrangement exceeds the requirements of the National Fire 'Code (NFPA 30) .

7) NFPA 30 of the National Fire Codes does not require detection or automatic suppression for the diesel oil tanks as presently arranged.

8) An intertie is available to utilize the St Lucie Unit 2 Diesel Oil Storage Tanks.

Conclusion T-Tl Based on ou'r evaluation the existing tank spacing and dikes provide adequate separation. The .instagla'tion of f ire detection and autom tic suppression would not augment or materially enhance the safety of the plant since it would not improve the existing adequate eparation provid'd. Therefore, we conclude, this is an acceptable exemption to Appendix R to 1OCERSO, Sec'ion

I < ~

\

FIRE AREA "U-U" This fire area i.s the component cooling -area, previously designated as'Fire Area 5. Essential equipment within this area is shown in the attached essential equipment list.

The following exemptions from Appendix R to 10CFR50 are requested: '"

Exemption U-Ul An exemption is requested from Section III-G.2.b of Appendix R because no detection or automatic fire suppression system is provided.

Evaluation U-Ul This area is lightly trafficked thus the probability of introducing transient combustibles is minimized.

2) The Fire Area has a very low combustible load with no continuity of combustibles.

3) Each Component Cooling Water Pump and Heat Exchanger is mounted on an 11.5 foot high concrete pedestal surrounded by open metal grate at elevation 23.5 feet. Pump and Heat Exchanger 1A are 11 feet from Pump 1C and 30 feet from" Pump and Heat Exchanger 1B. Pump and Heat Exchanger 1B is also 11 feet from Pump 1C (distarces measured from nearest edge to nearest edge). Power cables to pumps are located in buried conduit, with a short exposed section at each pump and motorized isolation valve. 'Failure of the motori ed valves in any combination .of positions mill not affect,.system capability, therefore, cable to the va3'ves is not addressed further.

The metal grate'will. prevent, a pool fire at -the pump level, and the existing separation is considered adequate for the pumps and cable (each capable of supplying 100 percent of the col'd shutdown requirements) from an exposure fire 11.5 feet below.

Conclusion U-Ul Based on our evaluation, the existing arrangement prov'des adequate protection for'he redundant Component Cooling Water Pumps. The installation of a detection and automatic fire suppression system ~~ou}d not augment or materially enhance the safety of the plant sine'e no single fire would effect redundant equipment. Therefore, we conclude that this is an acceptable exemption to Appendix R to 10CFR50, Section III-C.2.b.

~ / ~

t /

P'~ AR:"A "V-V" This fire area is the Re ueling Vater Tank, previously designated as Fire A=ea S. Essential. equipment within this fire area is shown in the attached essential equipment list.

The tank contains in excess of 400,000 gallons of water. The heat generated from an exposure fire would be rapidly dissipated through the tank wall intc the contained water. Thus the tank is ao subject to damage from the exposure fire.

This fire area meets the criteria of Appendix R to 10CRF50, Section III-G.l.

~ a ~

e E R" A~A "i7-3v'"

4 This fire area contains the primary water tank previously designated as Pire Area 9. This fire area contains no essential equipment or cables and Appendix R Section Ill-G does not apply.

Pire Area "X-X" This fire area is, the Condensate Storage Tank Area previously designated as Pire Area 2. Essential equipment is shown in the attached essential equipment list.

The Condensate Storage Tank contains over 300,000 gallons of water. The heat generated from any exposure fire external'o the tank would be rapidly dissipated through the tank wall into the contained water. .Thus the tank is not susceptible to damage from external exposure fires.

This fire area meets the criteria of Appendix R to 10CPR50, Section III-G.1.

FIB"" APNEA "Y-Y" This fire area is the RAB Roof and RAB blowdown heat exchanger previously designated as Pire Areas 72 and 63. This fire area contains no essential equipment or cables and Appendix R Section III-6 does not apply.