ML17215A757
| ML17215A757 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 02/21/1985 |
| From: | Williams J FLORIDA POWER & LIGHT CO. |
| To: | Thompson U Office of Nuclear Reactor Regulation |
| References | |
| L-85-72, NUDOCS 8502270014 | |
| Download: ML17215A757 (34) | |
Text
RECIPIENT ID CODE/NAME 07 09 04 02 03 05 REGULATOIOINFORttATION DISTRIBUTION OBTEN (RIOR) h ~
ACCESSION NBR 85022700i 9 DOC ~ DATE 85/02/21 NOTARIZED NO FACIL:50-389 St, Lucia Planti Unit 2< Florida Power F Light Co.
AUTH,NORE
'8JTHOR AFF fLIATION
..WILLIAMSiJRW. 'l'brida Power 8 Light Co RECIP. NAME
'REfigfIEN;.r AFFILIATION THOMPSONiU ~ L, Davis'ion of Licensing h'UBJECT:
Forwards Rev 5 to fire hazard analysis,Rev includes addi technical Justification for structural steel deviations proviously requested>addi editorial corrections 8 deviat request previously deletedB
~/P n
.. O'ISTRJQOTIQN CODE:
A006D COPIES RECEIVED: LTR SIZE:
';'-'.:",TI-WLE.';.'OR Su6m>P t'ale-pire Protection h
~
"CO RE C I P I EN T'-',
COPX&S COPIES ID CODE'/NAME '-:: + LT;7:R."-A)CL LTTR ENCL NRR ORB3" BC, 01".;"
.Ji.,$
INTERNAL~, ACRS 11>>.
.".3.";,.q g "~'DM/LFMB 1
0 ELD/HDS2 -.,
l~,;e. 0 ',IE.HHITNEYeL 1
1 NRR HOLONXCH
'2; ':'2
~44RR"WAMBACH 06 1
0 2
2 NRR/DL DIR 1
1
~RBG FI 1
RGt42 1
P EXTERNAL: LPDR lt 1
NRC~PDR 1
1 NSIC 1
DOCKET 05000389 05000389
~gt
~ t I',
hh N
'TOTAL NUMBER OF COPIES REQUIRED:
LTTR
...,P0h-. ENCL
I' I
1 W
h
~
t A
W tl t I
Wht'
'W h
It W
W II h
I I
it t
FLORIDAPOWER & LIGHT COMPANY
/KB 2 1
108d L-85-72 Office of Nuclear Reactor Regulation Attention: Mr. U.L. Thompson, Director Division of Licensing U. S. Nuclear Regulatory Commission Washington, D.C. 20555
Dear Mr. Thompson:
RE:
ST. LUCIE UNIT 2 DOCKET NO. 50-389 FIRE P ROTECTION Attached is Revision 5 to the Fire Hazard Analysis for St. Lucie Unit 2.
Please replace the previous pages with the revised pages attached.
All additions and changes are identified by revision bars in the margins.
Revision 5 includes additional technical justification for the structural steel deviations previously requested, additional editorial corrections, and a deviation request which was previously deleted.
Should you have any questions regarding this submittal, please advise.
Very truly yours,
~
~
~
~
J.. Williams, Jr.
Group Vice President Nuclear Energy Department JWW/SJR/pw Attachment I
cc:
Dr. J. Nelson Grace, Region II Harold F. Reis, Esquire 0014 850221 DOCK 05000389 PDR nDQ PDR F
PEOPLE... SERVING PEOPLE
J
Conclusion A1 Based on our evaluation, the existing fire barrier provides adequate separation.
The installation of a fire damper in the ventilation duet at penetration No.
3 would not augment or materially enhance the safety of the plant, since it would not aid in preventing fire migration between Fire Areas "A"and "J". Therefore, we conclude, this is an acceptable deviation to Appendix R to 10CFR50, Section III-G.2.a.
Deviation A2 A deviation is requested from Section III-G.2.a of Appendix R for exterior penetrations because no fire dampers or penetration seals are provided.
Evaluation A2 1)
Fire Zone 35 has negligible combustible loading.
2)
Ionization type smoke detection is provided as shown on Drawings 2998-G<13.
3)
Fire Area "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.
5)
A steel missile shield enclosure for each roof-top ventilator provides additional fire protection.
6)
Exterior Walls do not separate redundant trains of systems necessary to achieve and maintain hot shutdown.
Conclusion A2 Based on our evaluation, the existing barrier provides adequate separation.
The installation of fire dampers or penetration seals in exterior penetrations Fire Area "A" would not augment or materially enhance the safety of the plant.
Therefore we conclude that this is an acceptable deviation from Appendix R to 10 CFR50, Section III-G.2.a.
Deviation A3 A deviation is requested from Section III-G.2.c of Appendix R because an automatic suppression system is not provided in the fire area.
I Evaluation A3 1)
Ionization smoke detection is provided as shown on Drawings 2998-G-413.
R5 2)
Fire Zone 37 is lightly trafficked, thus reducing the probability of transient combustibles being introduced.
0 a
t/
II'
3)
The two conduit containing B train cables essential for safe shutdown identified in fire zone 37 are being enclosed in a fire barrier having a minimum of two hour fire resistance rating.
4)
Two standpipe system hose stations equipped with 100 feet of hose are located 25 ft from the south entries.
5)
Portable fire extinguishers are provided in fire zone 37.
6)
Inadvertent operation of a water type suppression system could cause undo damage to electrical equipment in the plant switchgear rooms.
7)
Fire suppression systems are provided as shown in the FSAR Figures 9.5A-8 and 9.
R5 8)
Pire suppression systems are over redundant essential cable trays and areas of concentrated cable loading.
9)
The fire ar ea is divided into several fire zones by fullheight concrete walls and floors.
While the walls and floors are not considered three hour rated fire barriers, they do provide considerable deterrent to fire propagation from adjacent portions of the fire area.
Conclusion A3 Based on our evaluation, the existing smoke detection, and early response with manual fire suppression equipment, and enclosure of the two conduit identified in a barrier having a minimum of two hour fire resistance rating provides adequate protection.
The installation of additional automatic suppression would not augment or materially enhance 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 10 CPR50, Section III-G.2.c.
Deviation A4 A deviation is requested from Section HI-G<.a of Appendix R because fire.
barrier materials do not completely cover all structural steel supporting steel conduits which are wrapped to provide separation in accordance with Appendix R.
Fire barrier materials are installed on conduit support steel for a minimum of 6 inches from the conduit attachment.
Evaluation A4 1)
An ionization type smoke detection system is provided as shown on drawing 8770-G<13.
Safety-related areas of the Reactor Auxiliary Building are covered with this system which provides both local indication and Control Room annunciation.
2)
An automatic fire suppression system is provided in Fire Zones 22 and 51*.
3)
Portable fire extinguishers and a fire standpipe system with hose stations are available for use in the area.
4)
Florida Power and Light utilizes the defense-inMepth approach to fire protection at the St. Lucie Planta Accordingly, administrative procedures are in effect which control the amount of transient combustibles in safety related areas of the plant.
Notwithstanding this fact, the postulated fire which may threaten the structural integrity of the conduit supports is an exposure fire generated from transient, flammable liquids.
The following analysis addresses this concern.
R5 a)
From the NFPA Fire Protection Handbook, 15th Edition, Figure 5+E, the "E" Time Temperature Curve indicates that 1000 F is achieved in approximately 5
minutes.
This 5 minute time increment is then considered on the "E" Fire Endurance Curve to determine the amount of combustibles necessary to generate this temperature.
A combustible loading of 0.833 Ibs/sq. ft. is extrapolated and when multiplied by the floor area of the space in question (Zone 37-A: "A"Switchgear Room = 1471 sq. ft), a value of 1225.3 lbs results (1471 sq. ft)(0.83 Ibs/sq.ft.) = 1225.3 lbs.
In order to present this data in terms of quantity of flammable liquids necessary to present a
1000 F
exposure to in situ combustibles and structural steel supporting
- conduits, a
conversion from weight to volume is necessary.
Noting from Table 5<D, of the NFPA Handbook, the "E" Temperature Curve is considered a severe fire exposure based on, among other things, flammable liquids.
Therefore, a direct conversion from weight to volume is considered acceptable.
As such, No. 2 Fuel Oil was selected as the flammable liquid.
With a weight per gallon of 7.3 Ibs/gal a quantity of 168 gallons results (1225.3 Ibs)/(7.3 lbs/gal)=
168 gaL This is determined to be incredible because of the large amount of liquid necessary and the fact that administrative controls would exclude such a gross violation of plant procedures.
3a
5)
In the unlikely event that a failure of administrative controls permits excessive amounts of transient combustibles to enter safety related areas and in the even more unlikely event that ignition of these materials occurs, the amount of combustibles involved would not be expected to generate enough heat to affect the integrity of the structural steel conduit supports.
This position is held due to the fact that the amount of transient combustibles identified in item 1 above is not a credible transient fuel load and fire is not expected to involve in situ combustibles because:
a)
Any in situ flammable or combustible liquids would be enclosed in piping, pumps, motors, etc.
b)
The majority of in situ combustibles is electrical cabling.
c)
Cables are either coated with Flamastic or meet IEEE-383 flammability criteria.
d)
Solid bottom cable trays are generally utilized as the lowest tray.
e)
The results of EPRI Research Project, Assessment of Ex osure Pire Hazards to Cable Tra s dated January, 1981, (Test No. 27) indicate that damage to cables in baffled cable trays (trays having a shield or solid bottom) did not occur during the test.
The test parameters included approximately 17 gallons of No. 2 fuel oil which burned unchecked for 15 minutes.
The test data showed a
ceiling temperature of 455 F
and an average temperature at the bottom of the tray of about 1300 F and concluded, "Nevertheless, post-test inspection of the cable within the baffled tray showed no visual evidence of charring,"
indicating that cabling did not contribute to the fire.
Based on the above, ignition of major in situ combustibles is not considered probable.
6)
While not considered probable, in the unlikely event that a fire does start and involve in situ combustibles, deleterious effects of heat on structural steel supporting conduit is not considered credible due to the following reasons.
a)
The need, extent and type of structural steel fire protection is based primarily on the combustible loading of the area, design loading of the structural members and the structural steel shape, size and configuration.
b)
The fire hazards analysis at the St. Lucie Plants makes a very conservative assumption that all combustibles within an area are available for instantaneous combustion including any combustible fluids contained in operating equipment (grease, oils, etc.).
This analysis, however unrealistic, shows that no area exceeds the equivalent of an E-119 three hour fire.
A normally developing fire is characterized by flame front moving over a surface and/or flames localized to a stationary source which, depending on the continuity of fuel packages, may or may not develop to flashover.
However, it is not reasonable to assume that a credible fire condition, throughout a fire area, would approach the severity which is represented by the E-119 R5
-3b-
0 II l
time/temperature curve.
This position is held because the spacing of fuel packages would not support fire growth and the structure configuration (including volume) would tend to dilute heat from the fire plume.
In addition, intensity of fire willalso be somewhat lower because walls and ceilings would absorb significant amounts of energy rather than act as insulation or radiation barriers.
Structural steel supports are designed for seismic loading (Operating Basis Earthquake) such that values never exceed 60% of yield including the seismic loading (dead weight loading has a factor of safety of ten).
In addition to this extra loading margin, other conservatisms in design assure that even this level is not reached.
This factor of safety is addressed by SPPE Technology Report 84-1, Predicti Tem erature Rise in Pire Protected Structural Steel Beams indicating that because design stresses are increased for seismic
- concerns, fire endurance is also increased.
To wit, 'Since the critical temperature is related to the reduction in yield strength under normal design conditions, as discussed
- above, a reduction in the design stress level would result in a corresponding increase in the critical temperature."
Structural. steel inherently contains a degree of fire resistance in itself which is a function of steel mass and the exposed heated surface.
As stated in AISI Pire Protection throu h Modern Buildin Codes:
(Pifth Edition 1981)
'Substantial temperature differences, as great as 600P (333C), have been recorded during standard fire tests between upper and lower flanges of a beam.
This difference is accounted for by the direct contact of the upper flange of the beam with a concrete floor above."
R5 Test information submitted by other utilities (Louisiana Power 4 Light, Waterford Unit 3) have indicated no deleterious effects to unprotected structural steel supporting cable trays subjected to an E-119 one hour fire exposure.
Thermo-Lag fire barrier material is installed on structural steel supporting conduit for a minimum distance of 18 inches away from the attachment of the conduit to the support.
In many cases the fire barrier material either exceeds the 18 inch minimum or covers the entire support.
The postulated fire, in order to resemble an E-119 fire, would have to be confined and would therefore affect no more than one of the conduit structural supports.
This is due to the arrangement of the support spacing which is typically 6 to 10 feet on center.
Assuming loss of structural integrity of a single
- support, located within the affected
- space, the remaining supports located on each side would provide adequate support for the conduit assembly.
In addition, the conduit fire barrier systems are attached to the conduit using stainless steel tie wires or banding which willinsure that the fire barrier material remains attached to the conduit in event of support failure.
-3c-
V l
0 7)
It is unrealistic to assume that a fire could start and continue for any significant length of time without fire brigade intervention.
Summary:
Based on NFPA Fire Endurance Curves referenced in item 3 above, the quantity of transient fire loads necessary to generate a
temperature of 1000 F is not credible.
A fire involving in situ combustibles is not likely to duplicate the E-119 time-temperature curve because spacing of fuel packages would not support fire gr owth and structure configuration (volume, ventilation, heat sinks, etc.) would dilute heat from the fire.
Failure of structural steel supporting conduits is not probable because of heat sinks created by concrete structures, partial fire barrier protection of conduit supports and high loading factors utilized in designing structural steel conduit supports.
R5 Pire induced failure of a structural steel conduit support would not affect the integrity of the fire barrier protecting the conduit.
Fire brigade actions willlimitthe consequences of a fire.
Conclusion A3 Based on our evaluation, the provision of fire barrier materials on the structural steel supports for wrapped conduits would not augment or materially enhance the safety of the plant.
Therefore we conclude that this is an acceptable deviation from Appendix R to 10CFR50, Section III-G-2.a.
-3d-
Deviation A5 A deviation is requested from Section III-G.2.a of Appendix R for electrical penetrations to the containment from the RAB fire zone 22 (Train "A"Electrical Penetration Area) because no penetration fire seals are provided.
All of the penetrations are sealed air tight, however they do not constitute a typical fire rated assembly.
Evaluation A5 1.
An automatic suppression system is provided in fire zone 22.
2.
Ionization type smoke detection is provided as shown on drawings 2998-G-013.
3.
Portable fire extinguishers and a fire stand pipe system with hose stations are available for use in the area.
0.
Electrical penetration nozzles and sleeves are sealed in the RAB side with 1-1/2 inch thick by 20 inch diameter ASTM Grade A-36 plates over the sleeve opening (sleeve is Schedule 80 ASME SA 106 Gr.B and is housed in a 36 inch thick concrete shell) and fillet weld to embedded plate.
Weld is the same as used on penetration header plates.
A-36 plates are designed as Seismic Category I. This seal has been air tested at -.25" W.G.
The 1-1/2 inch thick by 20 inch diameter ASTM Grade A-36 plate continuously welded over the sleeve opening forming this air tight seal, is equal to or better than a three hour fire rated assembly.
See FSAR Section 3.8.
5.
Between the 36 inch thick concrete shell and the 3-5/8 inch thick reinforced steel containment, there is an annulus of 08 inches which the penetration passes through.
The cables are covered with a 12 inch diameter sleeve as they pass through the annulus.
The annulus has negligible combustible loading.
6.
At the Reactor Containment Building side, electrical penetrations pass through a schedule 80 sleeve which is continuously welded to the 3-5/8 inch thick reinforced steel containment (reinforced for penetration purposes) on both sides.
The electrical penetrations are terminated approximately 8 inches beyond the steel containment.
A schedule 80 ASME SA 230 pipe cap is continuously welded as per ASME III, Class MC, to the penetration sleeve, sealed and air tested at approximately 00 psid.
Conclusion A5 Based upon the spatial separation provided by the annular space, the thickness of the concrete containment building wall and the 3-5/8 inch steel containment with welded steel penetration
- sleeves, a level of protection equivalent or superior to a typical 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated assembly is provided.
In addition, smoke detection equipment in this area provides early warning of any developing fire and manual fire suppression equipment is available in the area to control and extinguish such a fire.
The installation of fire rated penetration seals would not materially enhance the safety of the plant.
Therefore we conclude, this is an acceptable deviation to Appendix R to 10CFR50, Section III-G.2.a.
R5
I Mr>> '
IA<<I )
I )g a
M If I
I I t. ~,.
4
~
~.'
I: ~
If '
" (
)
C')'f IP I
ICPW
<<\\
I <<v' 'V<>
)
I ff r ~if) )pt)<<jan pm' I>>p.1
<<t I
>><<IC Cet II Cf P ~
<< fl()l=
C "
-P I tjtl.~P gA f)D()tel <<
I >> ( It'f t
~ c)j")lr fl')"I I
",I<<<<I v( tllr '
I
<<<<DI tft fff VDV ffr)jf \\reit -") )
cl f I
<<arv>>tt III'))"Mf>> If I
~
I <<
cl v<<t I ll
>>r I a
v>> ',
)
)
~
l lta
<<l V
k I ~
)
lVlr f'k
'<<<< Ic i, M
r ~ e
()>>
~ I Ivl.Pfj (>>
1,
<<D j=
~
)
=-
I
~ (
<< I
\\t <<>>
v v
rt t I
<< "I
'>>r ~ ~
w+ <<r<<t v r
f>>r
<< ~ ">>>>
fl
>>r(+
e a)i' 7 '>>I'fr r r<<)l' v)e f>>)gl<<>>(<< 'PV'>>tfgjPC) ) v 'IP
">>ir<>p>>j
'"a i
f c>>r f
>>vll()lltll)rlt)-)
C) tf It>>
t)t.,jg
<<<<'I' I"
Dt+- lr.
~ a v pep>><<>>
P'af PI
'l a
Il'<<ll<<r~ <<
tlc ta l<<at )'
<<Vr>>=<<<<>>
C C>>
D I
- fl
'>> I C)(f IP
~
P(). Iec,ll I)'if<<I<<)>> Ij 'aygf
>>r.
v t
<
>-
)(If'>>I f j ta t I P
I
~
.jel ef.)C>>I) rc'fj D M(DI'l I <<lc j I,giw>>t )
II<<>>
v:
I 'P
)<<flj))lIIV I ttlc<<+ le)it +, <<v ll
'lt ) )
ply" t)e (>>'r'>>i 6
(
.. v
~
~]
I'Iff) r j(I<<"<<)
f- >>A 'D r j)aa )'er)) t'Iv<<
<<Dtll<< 'it I ',,$
~'f) I <<I')l,l I
'a '-'f'I>M))j)<<(fl I( ~,I'
."'ll<Ptj )Cff g 'l(jC)'<<P,ll f >>
~'>>t q )"
ra(
)VD II'>> I
>I f'( 'I tlt)
~ <<I P
v
~ a M
C Pl'
~ r ~ I
~ <<D ~; ~,lp
<<.>><<>>r I>>
t'
~ e<<
'c 'a Mlvv>>
l r
- I I,
Df<< <<e f lll 4 ~ Iv -l ~ r ~ v I Ie ~
- All, r f p>> ~ gr lrl
~ 'I<<l <<I ~ v'<< t <<p<< I P<<j)M)(r) f(1 vpl <<<<fferfqt el ~ >>(lw<< t <<'<<;e<<<< t)t r'I'<<l/v<< f r ~ lr<<a ~ = p<<C rae<< rl>>lIIC>>$ <<>><<<<p*r<< f>>c) <<c>> c>><<e< )I p<<f>>'1 c,'f I - f, ~,I DI)4$ (>>e +t a e<<<<D>>ca <<<<r)r 'reel>> ~ ~ a ~ I lee r<<"' fr, ~ f'va c" >>, '., C>>v I'f ' "g')')')0 l -I' M>>'>>>> r* Deviation B2 A deviation is requested from Section III-G.2.a of Appendix R because fire retardant coatings are not provided for the structural steel supporting the steel conduits which are wrapped to provide separation in accordance with Appendix R. Evaluation B2 1) Ionization type smoke detection is provided as shown on Drawings 2998-G<13. 2) An automatic suppression system is provided in fire zone 52. 3) Portable fire extinguishers and a fire standpipe system with hose stations are available for use in the fire area. 4) See Evaluation A4, items 4 through 7. Conclusion B2 R5 See Conclusion A4. Deviation C5 I 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 and the fire detection is not provided throughout to protect conduit containing four cables essential for safe shutdown which are enclosed in a fire barrier having a minimum of two hour fire resistance rating. Evaluation C5 1) Ionization smoke detection is provided in portions of the fire area where cable wrap is being utilized. 2) Fire 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 two hour fire resistance rating. 4) 5) Early response to a smoke detection alarm is assured from the control room utilizing the exterior stairway and southwest entry to fire zone 34, one level below the control room. A standpipe system hose station equipped with 100 feet of hose is located in fire zone 34 at the southwest entry. R5 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. 8) Ionization smoke detection is located above cable trays in the area.') Ionization smoke detection is provided in this fire area as shown on Drawing 2998-G<13. 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 two hour fire resistance rating provides adequate protection. The installation of an automatic suppression system in fire zone 34 would not augment or materially enhance 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 10 CFR50, Section III-G.2.c. ~ k T qt I il 14 4 III ~ II ~ ~ \\ Deviation C6 A deviation is requested from Section III-G.2.a of Appendix R because fire retardant coatings are not provided for the structural steel supporting the steel conduits and ducts which are wrapped to provide separation in accordance with Appendix H. Evaluation C6 1) Ionization type smoke detection is provided as shown on Drawing 2998-~13. 2) Portable fire extinguishers and a fire standpipe system with hose stations are available for use in the area 3) See Evaluation A44, items 4 through 7. R5 Conclusion C6 See Conclusion A4. -10a- Aye Evaluation H4 1) Ionization type smoke detection is provided (as shown on Drawings 2998-G<13) and an automatic suppression system is provided in fire zones 39 and 51E. 2) Portable fire extinguishers and a fire standpipe system with hose stations are available for use in the area. 3) See Evaluation A4, items 4 through 7. Conclusion H4 R5 See Conclusion A4. Deviation H5 A deviation is requested from Section III-G.2.a of Appendix R for mechanical penetrations to the containment from the RAB fire zones 25 (Containment Purge), 39 (RAB HVAC Equipment Room) because no penetration fire seals are provided. All of the penetrations are sealed air tight, however they do not constitute a typical fire rated assembly. Evaluation H5 Portable fire extinguishers and a fire standpipe system with hose stations are available for use in this area. 2. Ionization type smoke detection system is provided as shown on Drawings 2998-G<13. 3. 4, All mechanical penetrations are sealed air tight and penetrate a 36 inch thick concrete shell from the RAB into the containment. This seal has been air tested at.25"wg. Between the 36 inch concrete shell and the steel containment, there is an annulus of 48 inches which the penetration passes through. The annulus has negligible combustible loading. At the Reactor Containment Building side, there is a 3%/8 inch thick reinforced steel containment (reinforced 3%/8 inches for penetration purposes). The penetrations pass through this steel containment, sealed air tight and tested at approximately 44 psid. Six general types of piping penetration assemblies are provided. The penetration assemblies consists of a containment vessel penetration
- nozzle, a process
- pipe, a Shield Building penetration sleeve and a shield building bellows seaL In the case of cold penetrations the containment vessel penetration nozzle is an integral part of the process pipe.
In the case of hot and semi-hot penetrations, a multiple flued head is provided as an integral part of the process pipe. A guard pipe, which encloses the process pipe and directs any fluid released back into the containment, is welded to the flued head. For hot penetrations an expansion joint metal bellows is welded to the flued head the the containment vessel penetration nozzle to accommodate thermal movements. The containment vessel penetration nozzles are designed to meet the requirements for Class MC vessels under ASME Code, Section IIL 20- 5. At the terminal of a piping penetration assembly near the Shield Building a low pressure leakage barrier is provided in the form of a Shield Building bellows seal. The bellows provides a flexible membrane type closure between the Shield Building penetration
- sleeve, which is embedded in the Shield Building, and the process pipe.
The Shield Building bellows is designed to withstand a design differential pressure of five psig and provide an adequate leak-tight seal consistent with overall allowable Shield Building leakage. For additional mechanical penetration description and details see FSAR in Section 3.8. 6. All of the penetrations are sealed air tight by continuous welding with a minimum of two passes. The air tight penetration seals constitute more than a three hour fire rated assembly. Conclusion HS Based upon the spatial separation provided by the annular space, the thickness of the concrete containment building wall and the pipe penetration details described above, a level of protection equivalent or superior to a typical 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated assembly is provided. In addition, smoke detection equipment in this area provides early warning of any developing fire and manual fire suppression equipment is available in the area to control and extinguish such a fire. The installation of fire rated penetration seals would not materially enhance the safety of the plant. Therefore we conclude, this is an acceptable deviation to Appendix R to 10CFR50, Section III-G.2.a. R5 Deviation H6 A deviation is requested from Section III-G.2.a of Appendix R because the 48-inch HVAC containment purge make-up (piping and valves), the 8-inch HVAC hydrogen purge make-up (piping and valves) to the containment of RAB fire zone 25 (RAB HVAC Plenum), the 48-inch HVAC containment purge exhaust (piping and valves) and the 8-inch HVAC hydrogen purge exhaust (piping and valves) to the containment from RAB fire zone 39 (RAB HVAC Equipment Room) are not provided with fire dampers. Note that these HVAC systems utilize piping and valves instead of the usual ducts and dampers. Evaluation H6 1) Portable fire extinguishers and a fire standpipe system with hose stations are avaialble for use in this area. 2) Ionization type smoke detection is provided as shown on drawings 2998-G-413. 3) This area contains negligible combustible loading. Deviation I4 A deviation is requested from Section III-G.2.c of Appendix R because an automatic suppression system is not provided throughout the fire area. Evaluation I4 1) Pire suppression systems are shown in the FSAR figures 9.5AM and 9. 2) Fire suppression systems are over redundant essential cable trays and areas of concentrated cable loading. 3) The fire area is divided into several fire zones by fullheight concrete walls and floors. While the walls and floors are not considered three hour rated fire barriers, they do provide considerable deterrent to fire propagation from adjacent portions of the fire area. 4) Ionization type smoke detection is provided as shown on drawings 2998-~13. Conclusion I4 Based on our evaluation the installation of additional automatic fire suppression in the fire area would not augment or materially enhance the safety of the plant. Therefore, we conclude, this is an acceptable deviation from Appendix R to 10CPR50, Section III-G.2.c. Deviation I5 A deviation is requested from Section III-G.2.a of Appendix R because fire retardant coatings are not provided for the structural steel supporting the steel conduits which are wrapped to provide separation in accordance with Appendix R. Evaluation I5 1) Ionization type smoke detection is provided (as shown on Drawings 2998-G<13) and an automatic suppression system is provided in fire zone 23. 2) Portable fire extinguishers and a fire standpipe system with hose stations are available for use in the area. 3) See Evaluation A4, items 4 through 7. R5 Conclusion I5 See conclusion A4. ,r I ~ S It IS ui't, Conclusion J2 Based on our evaluation, the existing barrier provides adequate separation. The installation of fire dampers or penetration seals in exterior walls of Fire Area "J" would not augment or. materially enhance the safety of the plant. Therefore we conclude that this is an acceptable deviation from Appendix R. to 10CFR50, Section 111~.2.a. Deviation J3 Deleted; air tight fire doors RA7 and RA8 were inadvertently categorized as water tight doors under Deviation J3 Revision No. 2. Evaluation J3 Deleted Conclusion J3 Deleted Deviation J4 A deviation is requested from Section III-G 2.a of Appendix R for mechanical penetrations to the containment from the RAB fire zone 24 (RAB Pipe Tunnel) because no penetration fire seals are provided. All of the penetrations are sealed air tight, however they do not constitute a typical fire rated assembly. Evaluation J4 1. Fire area "J" contains negligible combustible loading. 2. Portable fire extinguishers and a fire standpipe system with hose stations are available for use in this fire area. 3. Ionization type smoke detection system is provided as shown on Drawings 2998-~13. 4. See Evaluation H5 (Items 4 thr ough 7). Conclusion J4 See Conclusion HS. ~1 a h lb Deviation K4 A deviation is requested from Section III-G.2.a of Appendix R for electrical penetrations to the RAB Fire Zones 22 (Train "A" Electrical Penetration Area) and 23 (Train "B" Electrical Penetration Area) from the containment because no penetration fire seals are provided. Allof the penetrations are sealed air tight, however they do not constitute a typical fire rated assembly. 'Deviation K4 l. Ionization type smoke detection is provided as shown on drawings 8770-G<13. 2. Portable fire extinguishers and a fire stand pipe system with hose stations (supplied by the Primary Water System) are available for use in the area. 3. At the Reactor Containment Building side, electrical penetrations pass through a schedule 80 sleeve which is continuously welded to the 3%/8 inch thick reinforced steel containment (reinforced 3%/8 inches for penetration purposes) on both sides. The electrical penetrations are terminated approximately 8 inches beyond the steel containment. A schedule 80 ASME SA 234 pipe cap is continuously welded as per ASME IO, Class MC, to the penetration sleeve, sealed and air tested at approximately 44 psid. The schedule 80 sleeve continuously welded to both sides of the 3%/8 inch steel containment forming this air tight seal constitutes more than a three hour fire rated assembly. See FSAR Section 3.8. 4. Between the 36 inch thick concrete shell and the 3%/8 inch thick reinforced steel containment, there is an annulus of 48 inches which the penetration passes through. The cables are covered with a 12 inch diameter sleeve as they pass through the annulus. The annulus has negligible combustible loading. 5. At the Reactor Containment Building side, electrical penetrations pass through a schedule 80 sleeve which is continuously welded to the 3%/8 inch thick reinforced steel containment (reinforced for penetration purposes) on both sides. The electrical penetrations are terminated approximately 8 inches beyond the steel containment. A schedule 80 ASME SA 234 pipe cap is continuously welded as per ASME III, Class MC, to the penetration sleeve, sealed and air tested at approximately 44 psid. Conclusion K4 R5 See conclusion A5. ~ t P ~ 'I 4 For additional mechanical penetration description and details see FSAR in Section 3.8. 6) All of the penetrations are sealed air tight by continuous welding with a minimum of two passes. The air tight penetration seals constitute more than a three hour fire rated assembly. Conclusion K5 See conclusion H5. Deviation K6 R5 A deviation is requested from Section III-G.2.a of Appendix R because the 48-inch HVAC containment purge make-up (piping and valves), the 8-inch HVAC hydrogen purge make-up (piping and valves) from the containment to RAB fire zone 25 (RAB HVAC Plenum), the 48 inch HVAC containment purge exhaust (piping and valves), and the 8-inch HVAC hydrogen purge exhaust (piping and valves) from the containment to RAB fire zone 39 (RAB HVAC Equipment Room) are not provided with fire dampers. Note that these HVAC systems utilize piping and valves instead of the usual ducts and dampers. Evaluation K6 1) Portable fire extinguishers and a fire standpipe system with hose stations are available for use in this area. 2) Ionization type smoke detection system is provided as shown on Drawings 2998-G<13. 3) This area contains negligible combustible loading. 4) Fire damage to the pipes located in this area is precluded because the 48-inch standard wall pipes and the 8-inch schedule 40 pipes each have a wall thickness of approximately.375-inch (as compared to the .0312 inch thickness of a 3-hour rated fire damper). Fire damage to the pipes is precluded because the pipe thickness, heat transmission and dissipation characteristics serve to render the pipe impervious to deformation or heat failure for periods of expected fire duration. While localized high off~as temperature can be expected in the immediate vicinity of a fire, air mixture dilution at the pipes is not expected to reach high temperatures. 5) The 48-inch HVAC containment purge make-up pipe and the 48-inch HVAC containment purge exhaust pipe are provided with three remote manually operated butterfly valves in each pipe. The 8-inch HVAC hydrogen purge makeup pipe and the 8-inch HVAC hydrogen purge exhaust pipe are provided with two remote manually operated butterfly valves in each pipe. e 1 s, 4 I ~ V I I I Deviation M2 - Deleted; Air tight fire doors RAV and RA8 were inadvertently classified as water tight doors under Deviation M2 Revision No. 2. Evaluation M2 Deleted Conclusion M2 Deleted Deviation M3 A deviation is requested from Section III-G.2.a of Appendix R because fire retardant coatings are not provided for the structural steel supporting the steel conduits which are wrapped to provide separation in accordance with Appendix R. Evaluation M3 1) Ionization type smoke detection is provided as shown on Drawing 2998-G<13. 2) Portable fire extinguishers and a fire standpipe system with hose stations are available for use in the area. 'k 3) See Evaluation A4, items 4 through V. Conclusion M3 R5,', II See Conclusion A4. Deviation M4 A deviation is requested from Section 111~.2.a of Appendix R for water tight doors RA 4, 5, 6 and 23 because the fire rating of the custom manufactured doors is not Underwriter Laboratory listed. Evaluation M4 See Evaluation L3 Conclusion M4 See Conclusion L3. A Conclusion 07 Based on our evaluation the installation of additional automatic fire suppression in the fire area would not augment or materially enhance the safety of the plant. Therefore, we conclude, this is an acceptable deviation from Appendix R to 10 CPRSO, Section III-G.2.c. Deviation 08 A deviation is requested from Section III-G.2.a of Appendix R for water tight doors RA 4, 5 and 6 because the fire rating of the custom manufactured doors is not Underwriters Laboratory listed. Evaluation 08 See Evaluation L3. Conclusion 08 See Conclusion L3. Deviation 09 A deviation is requested from Section III-G.2.a of Appendix R because fire retardant coatings are not provided for the structural steel supporting the steel conduits which are wrapped to provide separation in accordance with Appendix R. Evaluation 09 1) Ionization type smoke detection is provided as shown on Drawings 2998-G<13. 2) An automatic suppression system is provided in fire zones 19 and 20. 3) Portable fire extinguishers and a fire standpipe system with hose stations are available for use in the area. 4) See Evaluation A4, items 4 through 7. Conclusion 09 See Conclusion A4. Deviation 010 A deviation is requested from Section III-G.2.a of Appendix R because no fire damper is provided in the ventilation duct located in the west wall of the charging pump cubicle access
- corridor, no fire damper is provided in the ventilation duct in the opening above the north entry of the charging pump cubicle access corridor and no fire door is provided in the north entry of the charging pump cubicle access corridor.
Evaluation 010 See Evaluation N2. Conclusion 010 - See Conclusion N2. r ~t tl lt I' L-85-72 Office of Nuclear Reactor Regulation Attention: Mr. Darrel G. Eisenhut, Director Division of Licensing U. S. Nuclear Regulatory Commission Washington, D.C. 20555
Dear Mr. Eisenhut:
RE:
ST. LUCIE UNIT 2 DOCKET NO. 50-389 FIRE PROTECTION Attached is Revision 5 to the Fire Hazard Analysis for St. Lucie Unit 2.
Please replace the previous pages with the revised pages attached.
All additions and changes are identified by revision bars in the margins.
The Nuclear Regulatory Commission audit is presently scheduled for February, 1985. Resolution of these deviations willbe an integral part of the audit. Florida Power R Light requests that the Nuclear Regulatory Commission provide formal disposition of aQ the deviations thru Revision 5 requests prior to the audit.
Your coorperation in this effort would be greatly appreciated.
Should you have any questions regarding this submittal, please advise.
Very truly yours, J. W. Williams, Jr.
Group Vice President Nuclear Energy Department JW W/SJR/pw Attachment cc:
J. P. O'Reilly, Region II Harold F. Reis, Esquire
I r'lp L
5.
I l
t-mh l
1 7 l v
S 4