ML17298B609
| ML17298B609 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 12/07/1984 |
| From: | Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | Knighton G Office of Nuclear Reactor Regulation |
| References | |
| ANPP-31378-EEVB, NUDOCS 8412110301 | |
| Download: ML17298B609 (62) | |
Text
REGULATO INFORMATION DISTRIBUTION STEM (RIDS)
ACCESSION NBR:8412110301-DOC,DATE+ 84/12/07 NOTARIZED:
YES DOCKET FACIL:STN"50 528 Palo Verde Nuclear. Stations Unit 1< Ar)zona Publ) 05000528 STN-50 529 Palo Verde. Nuclear Stations Unit 2~ Arizona Publi 05000529 "STN<<50 530 Palo Verde-Nuclear Stations Unit 3i Arizona Publi 05000530 AUTH'BYNAME,,
AUTHOR AFFILIATION VAN BRUNT~E~,E',
Arizona Public,.Service'Co
~
'REC IP ~ NAMEl RECIPIENT AFFILIATION KNIGHTONg G ~ W ~
Licensing Branch 3
SUBJECT:
Forwar ds info r e>> Amend 13 to 'FSAR'n response~ to request for info, re fire protection program.resolution of fir e dampet operability problems will be addressed in final deficiency rept to be provided by 841217
~
DISTRIBUTION CODE:
B002D COPIES RECEIVED:LTR
'NCL SIZE; TITLE! Licensing Submi t ta 1: Fire-Protection NOTES:Standardized plant ~
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'TOTAL" NUMBER'F COPIES REQUIRED:'TTR 20, ENCL'8
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Arizona Public Service Company ANPP-31378-EEVB/VEQ December 7, 1984 Director of Nuclear Reactor Regulation Mr. George M. Knighton, Chief Licensing Branch No.
3 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Units 1, 2, and 3
Fire Protection Docket Nos.
STN 50-528/529/530 File:
84-056-026 G.1.01.10
Reference:
FSAR Amendment 13, (ANPP-29978 TFQ/KEJ) dated August 1, 1984
Dear Mr. Knighton:
Xn response to a request by the NRC staff concerning the PVNGS Fire Protection
- Program, enclosed is the following information regarding FSAR Amendment 13, Section 9B.
l.
A list of deviations in Table 9B;3-1, Comparison of PVNGS to Appendix A of NRC BTP APCSB 9.5-1.
2.
A list of deviations to National Fire Protection Association (NFPA)
Standards.
3.
A comparison of present commitments in Appendix 9B to previous commitments, with regard to BTP APCSB 9.5-1, Appendix A.
4.
The staff question regarding the resolution of fire damper operability problems will be addressed in the final report for DER 84-56 which is expected to be transmitted to the NRC by December 17, 1984.
Members of our staff will be meeting with the NRC staff on December 13, 1984 to discuss this submittal and any remaining concerns they may have on fire protection.
Very truly your 84i2ii0301 84i207 PDR ADOCK 05000528 F
',~
EEVB/WFQ/mb Attachment
(~,
E. E.
Van Brunt, Jr.
APS Vice President Nuclear Production ANPP Project Director (jj00&
~l
Mr. G.
W. Knighton Fire Protection ANPP-31378 Page 2
ceo E.
A. Licitra D. J. Kubicki A. C. Gehr R. P.
Zimmerman (w/a)
(w/a)
(w/a)
(w/a)
0 I
1<
ANPP-31378 STATE OF ARIZONA
)
) ss.
COUNTY OF MARICOPA)
I, Edwin E.
Van Brunt, Jr.,
represent that I am Vice President, Nuclear Production of Arizona Public Service
- Company, that the foregoing document has been signed by me on behalf of Arizona Public Service Company with full authority to do so, that I have read such document and know its
- contents, and that to the best of my knowledge and belief, the statements made therein are true.
e a
Edwin E.
Van Brunt, Jr.
Sworn to before me this~7 day of 1984.
K Notary Public My Commission Expires:
My Comrnlssion Expires April 6, 5S87
go
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II
12-06-84 FIRE PROTECTION CODE COMPLIANCE FOR PALO VERDE NUCLEAR GENERATING STATION
0
12-06-84 PVNGS FIRE PROTECTION CODE COMPLIANCE CONTENTS 1.0 PVNGS Compliance with NFPA Standards (Including Justification for Deviations)
~Pa e
2.0 Summary of FSAR Amendment 13 Changes to Previous BTP APCSB 9.5-1, Appendix A Discussions 3.0 Justification for Changes to Appendix A Compliance
-(Other than NFPA Standards) 2-1 3-1 0133t
0 PVNGS FIRE PROTECTION CODE COMPLIANCE 12-06-84 1.0 PVNGS COMPLIANCE WITH NFPA STANDARDS (INCLUDING JUSTIFICATIONS FOR DEVIATIONS) 1.1 NFPA 10 (1975).
PORTABLE FIRE EXTINGUISHERS PVNGS complies except as noted below:
A. 3-2.1 Extinguishers shall be, located so that the maximum travel distances shall not exceed those specified in Table 3-2.1, except as modified by Subsection 3-2.3.
- Deviation:
Zones 39A and 39B require more than 75 feet travel
- distance, but not more than 150 feet.
Justification:
Fire zones 39A and 39B are the pipeways at the 88'levation of the auxiliary building.
The combustible loading is negligible (less than 5 minutes).
Therefore, the existing travel distances are acceptable.
Fire hose reels are provided for primary suppression.
0133t
0
12-06-84 PVNGS FIRE PROTECTION CODE COMPLIANCE 1.2 NFPA 13 (1976).
SPRINKLER SYSTEMS INSTALLATION PVNGS complies except as noted below:
A. 2-7.
Fire department connections should be provided..
Deviation:
The fire department connections are not provided for each sprinkler system.
Justification:
The fire protection water pumping system is designed to be self-sufficient.
- However, a common header is provided at the cooling tower basin for pumping to the system, if necessary.
B. 4-3.2.2 Deflectors for sprinklers should be within 16 inches of the ceiling.
Deviation: In a few areas of the auxiliary building such as the personnel access area (140'" level) sprinklers may be slightly lower than 16 inches from the ceiling.
Justification:
Sprinklers are installed to permit full spray pattern beneath steel beams.
Maximum distance below the ceiling is approximately 22 inches.
The intent of the standard is met.
0133t 1-2
FVNQS PIRE FROTECTION CODE COMPLIANCE 12-06-84 1.3 NFPA 14 (1976)
STANDPIPE AND HOSE SYSTEMS PVNGS complies except as noted below:
A. 3-2.2 The number of hose stations for building and each section of a building shall be such that all portions of each within 30 feet (9.2 m) of a nozzle when 100 feet (30.5 m) of hose.
Class II service in each divided by Fire walks story of the building are attached to not more than
. Deviation:
Use of up to 150 feet of hose.
Justification:
Adequate hose streams are available for fire fighting with use of 150 feet of hose.
These hose lengths are shown in FSAR Section 9B.
B. 4-1.2 Valves of approved indicating type shall be provided"at the main riser for controlling branch lines for Class II service supplying more than one hose station so that in the event that the branch is broken during the fire, the fire department may shut oFf this branch, conserving the water for their use.
Deviation:
Branch lines may not be supplied with control
( isolation) valves.
Justification:
Adequate water supplies are provided.
C. 6-2,2 Valves shall be provided to permit isolating a standpipe riser without interrupting the supply to other risers from the same source of supply.
Deviation:
More than one standpipe riser may be isolated in the turbine and auxiliary buildings.
Justification:
This deviation has been discussed in the BTP 9.5-1 Appendix A Section E.3(a) comparison.
0133t 1-3
12-06-84 PVNGS PIRE PROTECTION CODE COMPLIANCE D. 6-6 Pressure Gages.
6-6.1 An approved 3-1/2-inch (87 mm) dial spring pressure gage shall be connected with each discharge pipe from fire pump and public waterworks, at the pressure tank, at the air pump supplying pressure
- tank, and at the top of each standpipe.
Gages shall be located in a suitable place where water will not freeze.
Each gage will be controlled by a valve having arrangement for draining.
Exception:
Where several standpipes are interconnected at the
- top, a single gage properly located may be substituted for the gages at the top of each standpipe.
Deviation:
A pressure gage is not installed on standpipes.
Justification:
Gages are not required for the constantly pressurized and supervised private system at PVNGS.
Low pressure alarms and automatic fire pump operation is provided.
0133t
0
PVNGS PIRE PROTECTION CODE COMPLIANCE 12-06-84 1.4 NFPA 15 (1973).
WATER SPRAY FIXED SYSTEMS PVNGS complies except as noted below:'.
4063.
Drain Valves.
Readily accessible drains shall be provided for low points in underground and aboveground piping.
Deviation:
For the main transformers (Zone 75A) and main lube oil storage area (within Turbine Building), low point drain valves are not provided.
Justification:
Drainage is accomplished through a "Y" connection at the ground surface.
BE All underground supply piping after the automatic control valve shall be pitched 1/2 inch in ten feet to drain in the same manner as the above mentioned Standards specify for aboveground piping.
Provision shall be made to drain underground and overhead piping.
Deviation:
Piping is not pitched.
Justification:
Freezing is not a concern.
The pump out connection will permit adequate drainage.
C. Provision shall be made for test gages at or near the highest or most remote nozzle on each major separate section of the system.
At least one gage connection shall be provided at or near the nozzle calculated as having the least pressure under normal flow conditions.
Deviation:
Gage connections are not provided.
Justification:
Elevation changes are less than 20 feet.
System acceptance is by visual flow test.
Pump pressures are adequate.
0133t 1-5
PVNGS FIRE PROTECTION CODE COMPLIANCE 12-06-84 1.5 NFPA 20 PVNGS complies except as noted below:
6-3.4 6-3.4.2 Power Supply Protective Devices When power supply protective devices (fuses or circuit breakers) are installed in the fire pump feeder circuit, such devices shall not open at the sum of the locked rotor currents of the fire pump motor(s) and the necessary associated fire pump installation electrical accessory currents.
Deviation:
The pump controller circuit breakers
- comply, and are rate for 300 percent full load current for 681 amps continuously.
The feeder circuit breaker,
- however, can only be set for 260 percent full load current continuously.
Justification:
Two diesel engine driven pumps are also available and will provide 100X of required flow rate.
0 iA
4.
PVNGS PIRE PROTECTION CODE COMPK IANCE 12-06-84 1.6 NFPA 24 (1973).
OUTSIDE PROTECTION FVNGS complies except as noted below:
3601.
All control valves shall be plainly marked indicating the section or portion controlled.
To assure that valves are kept open, it is essential to provide central station proprietary valve super-visory service and/or to secure the valves in the open position using an acceptable type of seal which must be destroyed before the valve can be closed.
Weekly recorded inspections shall be made.
Deviations:
Valves are not marked indicating portions controlled.
Justification:
The required information is shown on the fire protection layout drawing(s).
0133t 1-7
pi
12-06-84 PVNGS FIRE PROTECTION CODE COMPLIANCE 1.7 NFPA 26 (1976).
RECOMMENDED PRACTICES FOR THE SUPERVISION OF VALVES CONTROLLING WATER SUPPLIES FOR FIRE PROTECTION PVNGS complies except as noted below:
2-1 Identification signs should be provided at each valve to indicate its function and what it controls.
Deviation:
No sign has been provided at each valve.
Justification:
The required information is shown on the fire protection layout drawing(s) and piping and instrumentation drawings (PSXDs).
0133t 1-8
12-06-84 PVNGS PIRE PROTECTION CODE COMPLIANCE 1.8 NFPA 30 (1976).
FLAMMABLE AND COMBUSTIBLE LI UIDS PVNGS complies except as noted below:
2-4.4.3 Tanks for storage of Class I or Class II liquids inside b~oildio s shall be provided with either.
(a) a normally closed remotely activated valve (b) an automatic closing heat-activated valve (c)
Another approved device to provide for quick cut-off of flow in the event of fire in the vicinity of the tank.
Deviation:
Diesel fuel oil day tank has a locked open isolation valve only.
Justification:
Shutoff for the fuel oil supply to the diesel generator will not be permitted (diesel generator operability required for design basis accident mitigation).
The day tank is surrounded with 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> barriers and provided with automatic water suppression.
0133t 1-9
PVNGS FIRE PROTECTION CODE COMPLIANCE 12-06-84 1.9 NFPA 50A (1973).
GASEOUS HYDROGEN SYSTEMS AT CONSUMER SITES.
PVNGS complies.
0133t:
1-10
e
PVNGS FIRE PROTECTION CODE COMPLIANCE 12-06-84 1.10 NFPA 12 (1973).
CARBON DIOXIDE EXTINGUISHING SYSTEMS PVNGS complies.
01335 1-11
PVNGS FIRE PROTECTION CODE COMPLIANCE 12-06-84 1.11 NFPA 80 (1975).
FIRE DOORS AND WINDOWS PVNGS complies except as noted below:
A.
1-6 Classifications and Types of Doors Deviation:
Only labelled or listed doors are used except as noted in response to FSAR Question 9A.106, and control room entry door (J319).
Justification:
Response
to FSAR Question 9A.106 has been accepted in NRC SER Supplement 86.
Additionally, door J319 at the control building 140'levation is a door of special heavy duty construction to be bullet resistant to high power rifle rating.
No fire rating label has been affixed to this door; however, the manufacturer has certified in writing that this door is constructed to 3-hour fire door standards.
Missile doors installed in fire rated walls between the control and corridor buildings at elevation 120'nd 160're solid steel (approximately 3 inches thick) and are normally kept closed during plant operation.
They do not separate redundant safe shutdown equipment.
Detection and cable tray water suppression systems are installed in the cable spreading rooms.
Therefore, adequate fire barrier protection is provided by these doors.
B.
Paragraph 2-8.2.4 Door Locks or Latches Deviation:
Manually operated latch bolts are used in some double doors where the full width is not required for normal passage.
Justification:
The inactive leaf is normally kept closed and is inspected in accordance with surveillance procedures.
0133t 1-12
h I
f' 1
I
PVNGS FIRE PROTECTION CODE COMPLIANCE 12-06-84 1.12 NFPA 72D (1975).
PROPRIETARY SIGNALING SYSTEMS PVNGS complies except as noted:
Deviation:
The deviation is defined in FSAR Appendix 9A, Questions 9A-71 and 9A-128.
Justification:
The justification for the deviation is provided in FSAR Appendix 9A, Questions 9A-71 and 9A-128.
0133t 1-13
0
12-06-84 PVNGS FIRE PROTECTION CODE COMPLIANCE 1.13 NFPA 12A (1973).
HALOGENATED FIRE EXTINGUISHING AGENT SYSTEMS-HALON 1301 PVNGS compiles 0133K 1-14
12-06-84 FVNGS PIRE FROTECTION CODE COMPLIANCE 2.0
SUMMARY
OF FSAR AMENDMENT 13 CHANGES TO PREVIOUS BTP APCSB 9.5-1 APPENDIX A DISCUSSIONS 2.1 CHANGES TO APPENDIX A A.
A.l Personnel OVERALL REQUIREMENTS OF NUCLEAR PLANT FIRE PROTECTION PROGRAM Clarifies that PVNGS Plant Manager (formerly the Director of Nuclear Operations) assigns individuals, responsible to him, for formulation and assurance of the program.
Updates the description of A/E and utility fire protection engineers.
A.3
~Backs No substantive change.
Adds credit for backup water supplies on the yard fire main.
No substantive change.
A.4 Sin le Failure Criterion No substantive change.
~ss terna Deletes potential usage of cross zoned detectors.
Specifies seismic design criteria.
A.6 Fuel Stora e Areas No substantive change.
A.B M~ulti le-Reactcc Sites Indicates that schedular exemptions are being sought for work that will not be complete.
No substantive change.
A.9 Simultaneous Fires Identifies that the common fire pumps have a wet pipe sprinkler'ystem.
0133t 2-1
FVNGS PIRE FROTECTION CODE COMPLIANCE 12-06-84 B.
ADMINISTRATIVEPROCEDURES, CONTROLS AND FIRE BRIGADE B.l Administrative Procedures B.2 Bulk Stora e of Combusti-bles Refer to individual code compliance.
No substantive change.
B.3 Modifications and Refuelin Activities No substantive change.
B.4 Self Sufficienc
. No substantive change.,
B.5 Com liance with RG-1.101 No substantive change.
0133t 2-2
0 FVNGS PIRE PROTECTION CODE COMPLIANCE 12-06-84 C.
QUALITY ASSURANCE PROGRAM There are no substantive changes to this section.
0133t 2-3
0
FVNOS PIRE PROTECTION CODE COMPLIANCE 12-06-84 D.
GENERAL GUIDELINES FOR PLANT PROTECTION D.l Buildin Desi n
D.l.a Plant Layout Redundant safety related equipment required to shut down the unit per the design bases of section A.4 are separated per the requirements of 10CFR50 Appendix R.
D.l.b Detailed Fire Hazards Analysis No substantive change.
D.l.c Cable Spreading Rooms Adds descriptions of the devia-tions from Appendix R.
D.l.d Non-combustible Halls Clarifies use of coatings and states that spread,
- smoke, and fuel contribution can be greater than 25 but will be less than 50.
D.l.e Non-combustible Roof No substantive change.
D.l.f Suspended ceilings Identified plant changes that place cabling in concealed spaces.
Fire detection is placed in the concealed space in safety related areas.
D.l.g High Voltage Transformers Clarifies that dry type trans-formers are used in buildings with safety related systems.
D.l.h Oil Filled Transformers No substantive change.
D.l.i Floor Drains Identifies that control room is not provided with a drain and that control room and electrical switchgear do not have pedestals.
D.l.j Barrier Ratings and Penetrations Identifies the criteria for use of barriers with less than 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> ratings.
D.2 Control of Combustibles D.2.a Isolation of Safety Related Systems Adds RCP Oil Collection System, otherwise no substantive change.
0133t 2-4
12-06-84 PVN08 PIRE PROTECTION CODE COMPLIANCE D,2.b Bulk Gas Storage D.2.c Use of Plastic No substantive change.
Updated listing of plastic quantities.
D.2.d Flammable Liquids No substantive change (refer to compliance with NFPA 30).
D.3 Electrical Cable Construction Cable Tra s and Cable Penetrations D.3.a Non-combustible Materials No substantive change..
D.3.b
'D.3.c Cable Spreading Room Water Sprinkler System No substantive change.
Clarify use of sprinkler systems and use of tray covers and coatings to meet RG 1.75.
~
D.3. e Fire Breaks D.3.d Cable Tray Penetrations No substantive change.
No substantive change.
D.3.f Flame Test Clarify that PVNGS exceeds requirements.
D.3.g Cable Construction D.3.h Miscellaneous Storage D.3.i Smoke Venting No substantive change.
No substantive change.
Revise to indicate that safety related conduits are run in the condensate tunnel..
D.3.j Control Room Cabling Clarifies use of suspended ceiling and halon.
D.4 Ventilation D.4.a Smoke Removal Refer to Questions 9A-70, 9A-79, 9A-80, and 9A-96.
No substantive change.
D.4.b Single Failure D.4.c Power Supply No substantive change.
Revise to describe reliance on smoke ejectors.
D.4.d Charcoal Fire Suppression No substantive change.
D.4.e Fresh Air Supply PVNGS complies in the powerblock although small ancillary structures do not comply.
0133t 2-5
12-06-84 PVNGS PIRE PROTECTION CODE COMPLIANCE D.4.f Stairwells Clarify availability of multiple egress routes and fire rating of single exit stairwells.
D.4.g Ventilation Rates D.4.h Breathing Apparatus D.4.i Damper Isolation Clarify ventilation capabilities.
No substantive change.
Added description of closure systems.
D.5 Li htin and Communication D.5.c Fixed Communication D.5.a Fixed Lighting D.5.b Portable Lighting No substantive change.
No substantive change.
No substantive change.
D.5.d Repeaters Clarify that PVNGS does not use repeaters.
0133t 2-6
C K
PVN08 FIRE PROTECTION CODE COMPLIANCE 12-06-84 E.
FIRE DETECTION AND SUPPRESSION E.l Fire Detection E.l.c Distinctive Alarm E.l.d
~'mergency Power E.l.a NFPA 72D E.l.b Control Room Alarm Refer to compliance with NFPA 72D.
No substantive change.
Add detail on nature of alarm.
No substantive change.
E.2 Fire Protection Water Su 1
S stems E.2.a Underground Water Yard Loop Add detail on loop design.
Refer to compliance with NFPA 24.
E.2.b Multi Unit Sites Added confirmation that a single failure does not disable fire suppression.
E.2.c Fire Pumps Identified control room alarms,
.refer also to compliance with NFPA 20.
E.2.d Fire Tanks E.2.e Water Supply E.2.f Lakes Revise low level alarm.
No substantive change.
Not applicable.
E.2.g Hydrants Clarify that all locations have fire protection without reference to 250 feet.
Refer to compliance with NFPA 24.
E.3 Water S rinklers and Hose Stand i e S stems E.3.a Independent Connections Identifies reliance of main steam support structure, fuel, and containment on outside headers.
No substantive change.
E.3.b Electrical Supervision Identifies that loop valves are not electrically supervised.
Refer to compliance with NFPA 26.
E.3.c Installation Standards Refer to compliance with NFPA 13, 14, 15, 20, 24, 26, and 72D.
0133t 2-7
C lg
12-06-84 PVNGS PIRE PROTECTION CODE COMPI IANCE E.3.d Hose Station Spacing Add description of use of multiple hose connections to common 2 1/2 inch standpipe.
Identifies shut off valves located inside served zones.
E.3.e Hose Nozzles E.3.f Foam Suppression No substantive change.
No substantive change.
E.4 Halon Su ression S stems Deleted reference to NFPA 12B (N/h PVNGS).
Refer to compliance with NFPA 12A.
E.5 Carbon Dioxide Su ression No substantive change.
E.6 Portable Extin uishers Refer to compliance with NFPA 10.
0133t 2-8
FVNGS FIRE PROTECTION CODE COMPLIANCE 12-06-84 F.
GUIDELINES FOR SPECIFIC PLANT AREAS F.l Primar and Secondar Containment F.l.a Normal Operation F.l.b Refueling and Maintenance No substantive change.
No substantive change.
F.2 Control Room Identifies the Appendix R
deviations described in 9B.2.
Adds portable fire extinguishers and specific class C nozzles.
Identifies that smoke detectors are not in the cabinets but are in the ventilation stream from each cabinet.
Discussed concealed space cable routing per D.l.j and pedestal arrangement per D.l.i.
F.3 Cable S readin Room Clarifies use of five zones in the upper cable spreading room and six zones in the lower room.
F.4 Plant Com uter Room Clarifies that PVNGS plant computer is not safety related.
F.5 Switch ear Rooms F.6 Remote Safet Related Panels No substantive change.
No substantive change.
F.7 Station Batter Room F.S Turbine Lube Oil Stora e
No substantive change.
Decreased barrier rating to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> due to the presence of an open head deluge system.
F.9 Diesel Generator Areas No substantive change.
F.10 Diesel Fuel Oil Stora e
Specifies that the distance from the tanks to the diesel generator building is less than 50 feet.
0133t 2-9
12-06-84 FVNOS PIRE PROTECTION CODE COMPf IANCE F.ll Safet Related Pum s
Identifies that the pumps Zone 78 (underground diesel fuel tank and pump) do not have a fire detection system as the pumps are inside the tanks.
Describes Appendix R
deviations discussed in 9B.2.
F.12 New Fuel Area F.13 S ent Fuel Pool Area F.14 Radwaste Buildin No substantive change.
No substantive change.
No substantive change.
F.15 Decontamination Areas Adds discussion on laundry and decontamination building.
F.16 Safet Related Water Tanks Identifies that the outdoor PVNGS tanks do not have portable extinguishers or local standpipes due to low fire loading and proximity of hose houses.
F.17 Coolin Towers F.18 Miscellaneous Areas No substantive change.
No substantive change.
0133t 2-10
12-06-84 FVNGS PIRE PROTECTION CODE COMPLIANCE G.
SPECIAL PROTECTION GVIDELINES G.l Weldin and Cuttin No substantive change.
G.2 Ion Exchan e Resins Identify that dry ion exchange resins are not stored in a PVNGS powerblock.
G.3 Hazardous Chemicals G.4 Radioactive Materials No substantive change.
No substantive change.
0133t 2-11
12-06-84 FVNG5 PIRE PROTECTION CODE COMPLIANCE 3.0 JUSTIFICATION FOR CHANGES TO APPENDIX A COMPLIANCE (OTHER THAN NFPA STANDARDS)
Re uirement PVNGS Non-Com liance Items A.4 E.3(a)
Existing design (auxiliary building) can permit single failure to impair both primary and backup fire suppression.
Justification:
~
to correct the existing design a
DCP to add longer hoses (150 feet in six cases) and isolation capability will be completed prior to 4/1/85.
D.l(a)(2)
D.2(a)
Separation developed For redundant safe shutdown equipment.
Separate fire areas are not developed for other safety-related systems.
Justification:
e criteria of Appendix A, paragraph 4.2 and App.
R, section,III.G are met.
~
Appendix A, paragraph A.4 does not require fire to be postulated concurrent with a plant accident D.l(f)
D.3(j)
F.2 Concealed spaces (i.e., false ceiling above control room) are not devoid of combustibles.
(See drawings 13-E-ZJC-061, 13-A-ZJD-506, and SER page 9-35, section 9.5.1.5)
Justification:
~
ionization smoke detectors are provided above false ceiling 0133t 3-1
4
12-06-84 FVNGS PIRE PROTECTION CODE COMPLIANCE Re uirement PVNGS Non-Com liance Items a
exposed cables are limited to a small quantity of lighting power supply cables and those IEEE 383 rated cables for the plant multiplexer o
manual fire fighting capability is facilitated by the presence of removable ceiling panels o
vertical cables running from the upper cable spreading room are enclosed in metal ducts Electrical switchgear and control room equipment not on pedestals.
Justification:
, o alternate shutdown capability is provided independent of the control room (per Appendix R,Section III,G)
~
no automatic water suppression in switchgear area (uses C02/Halon)
~
redundant train of switchgear is available in separate fire area
~
drains are provided in both switchgear areas D.1(j)
As requested for Appendix R.
Justification:
~
deviations from three hour criteria have been identified and justified in request for Appendix R deviations.
0133t 3-2
12-06-84 PVN05 PIRE PROTECTION CODE COMPLIANCE Re uirement PVNGS Non-Com liance Items
~
surface mounted damper and missile door deviatons were justified in letters ANPP 30680, dated September 27, 1984 and ANPP 31310, dated December 4, 1984 D.3(c)
Automatic water sprinkler systems are not used for cable, trays within the containment.
Justification:
~
line-type and ionization detectors provided potential adverse consequences during normal operation preclude automatic suppression system D.4(a) smoke removal by manual action using fixed and/or portable exhaust equipment.
Justification:
o Smoke removal is an integral part of fire brigade training.
D.4(c)
Normal HVAC power supply and controls do not run outside the fire area served, by the system.
Justification:
o essential HVAC available and runs outside aFFected fire area e
normal HVAC fails (under loss of electrical power) in a manner which does not adversely affect essential HVAC operation
~
portable smoke ejectors will be utilized in event of fire 0133t 3-3
12-06-84 FVNGS PIRE FROTECTION CODE COMPLXANCE Re uirement PVNGS Non-Com liance Items D.4(f)
Stairwells rated for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
Justification:
o Two hour stairwells are adequate.
E.2(c)
Separation between redundant pumps is 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
Justification:
e Wet pipe sprinkler provided in the two diesel driven pump rooms.
Already approved in
- SER, page 9-31.
E.3(a)
Single failure can impair both primary and backup fire protection systems.
Justification:
~
150 foot hose in aux.
(6 cases)
~
yard hose houses (approximatey 80 feet away) provide backup for fuel building.
E.3(d)
Some interior manual hose lengths exceed 75 feet (but no greater than 150 Feet) and some hose stations are spaced at greater than 100 feet.
Justification:
a as accepted in SER supplement 6 (plus those proposed in the response to Appendix A Section A4 as discussed above)
E.4 Halon check weighing done at 6 months rather than quarterly.
0133t 3-4
12-06-84 FVNGS FIRE PROTECTION CODE COMPLIANCE Re uirement PVNGS Non-Com liance Items Justification:
~
PVNGS complies with NFPA 12A criteria for semi-annual check weighing.
F.l(a)
Smoke detectors are not provided ahead of the air filters.
Justification:
~
line-type detectors, temperature detectors, and ionization detectors are provided as backup to specific hazard detection F.2 Exceptions taken to 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated walls, floor, and ceiling in CR.
Justification:
~
deviations already requested for 10CFR50, Appendix R
Fire detection is outside CR cabinets rather than inside Justification:
a approved per SER Supplement 6
F.3(a)(5)
Aisle separation is lesp than 3 x 8 feet.
Justification:
~
actual 2'6" x 7'6" (minimum) which meets intent F.5 Switchgear rooms not fully separated from the remainder of the plant by 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> barriers.
Justification:
o deviation already requested per 10CFR50, Appendix R
0133t 3-5
O.
0 12-06-84 PVNOS PIRE PROTECTION CODE COMPLIANCE Re uirement PVNGS Non-Com liance Items F.8 Exception taken to 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated barrier.
Justification:
o two hour barrier provided
~
no equipment in Turbine Building is safety-related
~
open head deluge system and automatic wet pipe sprinkler system F.ll Fire detection not provided for Zone 78A, 78B (diesel fuel oil tank and transfer pump).
No hose station/portable extinguishers near tank.
Justification:
o diesel fuel oil transfer pump located within tank, and tank installed underground
~
tank access sealed to prevent unauthorized entry F. 13 Detectors not provided directly over spent fuel pool.
Justification:
~
for maintenance considerations
~
to minimize operator exposure F.14 Door A204 not 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated.
Justification:
~
approved per SER Supplement 86 F.15 Decontamination/laundry facility is not provided with detection systems or hose stations.
0133t 3-6
12-06-84 0
PVNGS FIRE PROTECTION CODE COMPI rANCE Re uirement PVNGS Non-Com liance Items Justification:
~
building is physically separated from radwaste and other buildings.
4 e
portable extinguishers are provided with yard hydrants as a backup
~
building readily accessible for fire fighting
~
HEPA filters are provided for exhaust air and are alarmed in the control room upon significant change in pressure (i.e.,
caused by filtration of smoke particles).
No detection in zone 57H (special decontamination room aux.
el. 140'0")
Justification:
e wet pipe'prinkler system installed G.2 Detection by smoke and heat detection not provided.
Justification:
o wet pipe sprinkler system installed 0133t 3-7
0 I
/I r