ML17310A272

Submits Revised Deviation Requests to Commitments Associated w/10CFR50,App R for NRC Review & Approval,Per Generic Ltr 86-10,covering post-fire Shutdown RCS Process Variables & Circuit Separation Between Two Fire Zones

ML17310A272
Person / Time
Site:	Palo Verde
Issue date:	04/29/1993
From:	Conway W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
102-02493-WFC-J, 102-2493-WFC-J, GL-86-10, NUDOCS 9305060398
Download: ML17310A272 (79)

Text

ACCELERANT D DOCUMENT DISTRIBUTION SYSTEM REGUL RY INFORMATION DISTRIBUT1. SYSTEM (RIDE)

.i ACCESSION NBR:9305060398 DOC.DATE: 93/04/29 NOTARIZED: NO DOCKET g FACIL:STN-50-528 Palo Verde Nuclear Station, Unit 1, Arizona Publi 05000528 STN-50-529 Palo Verde Nuclear Station, Unit 2, Arizona Publi 05000529 STN-50-530 Palo Verde Nuclear Station, Unit 3, Arizona Publi 05000530 AUTH. NAME AUTHOR AFFILIATION CONWAY,W.F. Arizona Public Service Co. (formerly Arizona Nuclear Power RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Submits revised deviation requests to commitments associated D w/10CFRSO,App R for NRC review & approval,per Generic Ltr 86-10.

DISTRIBUTION CODE: A006D COPIES RECEIVED:LTR TITLE: OR/Licensing Submittal: Fire Protection I ENCL L SIZE:

NOTES:STANDARDIZED PLANT 05000528 A Standardized plant. 05000529 Standardized plant. 05000530 0 RECIPIENT COPIES RECIPIENT COPIES D ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PDV LA 1 0 PDV PD 1 1 TRAMMELL,C 2 2 TRAN,L 2 2 INTERNAL: ACRS 3 3 NRR/DSSA/SPLB 1 1 NUDOCS-ABSTRACT 1 1 OC LE5B 1 0 OGC/HDS1 1 0 REG FIL 01 1 1 EXTERNAL: NRC PDR 1 1 NSIC 1 1 D

D NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTEI CONTACT THE DOCUMENT CONTROL DESK, ROOM PI-37 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEEDI TOTAL NUMBER OF COPIES REQUIRED: LTTR 16 ENCL 13

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Arizona Public Service Company P,O. BOX 53999 ~ PHOENIX. ARIZONA 85072<999 102-02493-WFC/JNI WILLIAMF. CONWAY EXECUTIVEVICE PRESIDENT April 29, 1993 NUCLEAR U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-37 Washington, DC 20555

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Units 1, 2, and 3 Docket Nos. STN 50-528/529/530 10 CFR 50 Appendix R, New and Revised Deviations File: 93-056-026 Arizona Public Service Company (APS) hereby submits, for NRC review and approval, new and revised deviation requests to APS'ommitments associated with 10 CFR 50, Appendix R. These .

deviations are in accordance with Generic Letter 86-10, Enclosure 1, Interpretations of Appendix R, Items 1 through 6. F If you have any questions, please call Thomas R. Bradish at (602) 393-5421.

Sincerely, WFC/JNI/rv

Enclosures:

1) New and Revised Appendix R Deviation Requests

2) 10 CFR 50.59 Evaluation cc: J. B. Martin J. A. Sloan C. M. Trammell

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ENCLOSURE 1 NEW AND REVISED APPENDIX R DEVIATION REQUESTS

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New and Revised Appendix R Deviation Requests This enclosure includes the following deviation changes, listed by the applicable UFSAR section.

These deviations will be included in the UFSAR changes to Appendix 9B, "Fire Protection Evaluation Report":

9B.2.0.F- A new generic deviation. During the post-fire shutdown reactor coolant system process variables may exceed the limits described in 10 CFR 50 Appendix R, Section III.L and the guidance provided by Generic Letter 86-10. There is no adverse effect on the ability to achieve and maintain safe shutdown in the event of any postulated fire as a result of this deviation.

9B.2.1.B.5- Adds detail regarding circuit separation between two Fire Zones (Fire Zones 86A and 86B), in the dead space compartment between the Auxiliary Building and Control Building.

9B.2.2.B.2- Clarification to the deviation for the Train B, Zone 86B, east wall adjacent to the Corridor Building revising information on circuits located in the Corridor Building.

9B.2.3.B.3- Credits one additional operator action (isolation of main steam) in the Control Room on the same panel as the reactor trip, prior to Control Room evacuation.

9B.2.15.B.2 - Discusses the addition of the Train E charging pump to the analysis.

9B.2.15.B.8- Provides clarifications on details of the Auxiliary Building separation and protection within Fire Area XV.

NOTE:

To facilitate review, existing UFSAR deviation statements attached are in ordinary (non-bold) type, new material is indicated in bold type and deleted material from the existing deviation is lined out strike-etC.

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I PVNGS UPDATED FS I

FIRE HAZARDS ANALYSIS performed in the outside yard areas can be easily performed by t' utilizing a hand-held lantern. The lanterns will be readily available in or near the control room and .regularly maintained I, 'i ~ '

5 'I to ensure proper operation and will only need to be energized for the relatively short time that an operator is outside the plant buildings. In addition to utilizing hand-held lanterns for illumination in these outside areas, pole-mounted security lights are installed in the outside 'yard areas which, though not provided for Appendix R compliance, also provide a reliable source of yard illumination for traversing. The security lights are supplied by their own backup diesel generator which would not be affected by the fires identified scenarios. Access/egress routes through plant in the abovePENCE)

I~ ~ I buildings will continue to be provided with fixed 8-hour

/hAADtfeVgog battery-powered emergency lights, as will the safe-shutdown areas inside the plant buildings.

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/jvSBP ~ 9B.2.1 FIRE AREA I 9B.2.1.1 Fire Area Descri tion A. Area Boundary Descriptions Fire Area I (figures 9B-l, 9B-3, 9B-4, 9B-5, and 9B-6) contains train A components found in the control building. This fire area includes Zones 1,

~ 5 3A 4Ag 'Ap 6Ag 7Ag 8A 9A 10A 1 1A 15A 1 SAN 20 and 86A (figures 9B-8, 9B-9, 9B-10, 9B-11, and 9B-12) .

At elevation 74 feet 0 inch, Fire Area I is below grade and bounded to the north by a 3-hour rated

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barrier common to Fire Area XV, to the east by a 3-hour rated barrier common to Fire Area II (the east wall of Zone 86A is a nonrated barrier common to Fire Area II), and to the west and south by nonrated, exterior walls. The west walls of Zones 3A March 1993 9B ~ 2-11 Revision 5

9B.2 FIRE HAZARDS ANALYSIS'B.

2.0 INTRODUCTION

F. A deviation is requested from Section III.L using the guidance provided in Generic Letter 86-10, Questions 3.8.4 and 5.3.10, to the extent that it requires the reactor coolant system process variables, as discussed below, to be maintained within those predicted for a normal loss of AC power and the reactor coolant make-up function to be capable of maintaining the reactor coolant level within the level indication in the pressurizer.

DISCUSSION 10 CFR 50, Appendix R, Section III.L states:

"1. (b)... During the postfire shutdown, the reactor coolant system process variables shall be maintained within those predicted for a loss of normal a.c.

power, and the fission product boundary integrity shall not be affected; i.e.,

there shalt be no fuel clad damage, rupture of any primary coolant boundary, of rupture of the containment boundary.

2. the performance goals for the shutdown functions shall be:

a. The reactivity control function shall be capable of achieving and maintaining cold shutdown reactivity conditions.

b. The reactor coolant makeup function shall be capable of maintaining the reactor coolant level above the top of the core for BWRs and be within the level indication in the pressurizer for PWRs. J

c. The reactor heat removal function shall be capable of achieving and maintaining decay heat removal.

d. The process monitoring function shall be capable of providing direct readings of the process variables necessary to perform and control the above functions.

e. The supporting functions shall be capable of providing the process cooling, lubrication, etc., necessary to permit the operation of the equipment used for safe shutdown functions."

Generic Letter 86-10, Question 3.8.4 states:

"The damage to the system in the control room for a fire that causes evacuation of the control room cannot be predicted. A bounding analysis should be made to assure that safe conditions can be maintained form outside the control room."

A bounding analysis was performed for the control room fire scenario to assure that

'safe shutdown conditions could be maintained from outside the control room. This

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bounding analysis (Reference Calculation 13-MC-FP-318, 10 CFR 50 Appendix R lll.G/III.L Compliance Assessment and 13-MC-FP-317, 10 CFR 50 Appendix R Operational Considerations) assumed the worst case spurious actuations as well as loss of all automatic function (such as ESFAS, DG auto start and sequencing) of components where the control circuits could be affected by a fire in the control room.

This conservative analysis indicated that the required reactor coolant system process variable and their indication, i.e., pressurizer level, RCS temperature and pressure could exceed those predicted for a loss of offsite power. These transients could occur until positive control of equipment affected by the fire and restoration of charging flow is established within 30 minutes.

CONCLUSIONS The bounding analysis evaluated the consequences of these transients and demonstrated that safe shutdown can be accomplished satisfactorily (reference calculation 13-MC-FP-317, 10 CFR 50 Appendix R Operational Considerations and calculation 13-MC-FP-316, 10 CFR 50 Appendix R Manual Action Feasibility) and concluded that:

1) The plant would not be placed in an unrecoverable condition,

2) Fuel damage would not occur, and

3) The process variables would be restored once positive control of the equipment and restoration of charging flow was established, within 30 minutes. This has been verified by a timed walk-down of procedure 4xAO-xZZ44, Shutdown Outside the Control Room Due to Fire and/or Smoke.

Therefore, there is no adverse effect on the ability to achieve and maintain safe

. shutdown in the event of any postulated fire as a result of this deviation.

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PVNGS UPDATED FS FIRE HAZARDS ANALYSIS Within the Fire Area X side of this boundary, there are negligible combustibles; the compartment adjacent to the seismic gap is a large HVAC and pipe chase with floor dimensions approximately 13 feet by 50 feet. Within Fire Area I, Zone 86A is separated from the remainder of the fire area by 2- and 3-hour rated walls. Zone 86A is separated from Zone 86B (Fire Area II) by a nonrated barrier (see Fire Area I, deviation No. 5, for the Zone 86A/

Zone 86B separation considerations) . Zonal detection and automatic deluge water spray covers the predominant in situ combustible (cable trays at elevations 100 feet 0 inch and 120 feet 0 inch). The equivalent fire severity for Zone 86A is approximately 138 minutes.

Fire team response (within 10 minutes) is expected before significant degradation of the existing fire barriers would occur. Access to Zone 86A for fire team response is available at elevation 100 feet 0 inch (through Zone 5A).

Conclusion The existing design provides equivalent protection to that required by Section III.G.2, p'(~ AQgll 7 and upgrading the existing design to a 1-hour 13E VI R77o nl rating plus suppression would not significantly

$ 8.2. I enhance protection currently provided.

8.5 n is requested to Section III.G.2 to

~g~+vlSP D HEY.7 the extent that it requz. - our rated sM7 barriers to separate circuits of redun trains.

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March 1993 9B.2-21 Revision 5

I 9B.2.1 FIRE AREA I B. Deviations from 10CFR50, Appendix R, Section III.G

5. A deviation is requested to Section III.G.2 to the extent that it requires 3-hour rated barriers to separate circuits of redundant trains.

The central wall of the dead space compartment between the auxiliary and control buildings is a fire area boundary common to Fire Area I (Zone 86A) and Fire Area II (Zone 86B) at elevations 74 feet 0 inch, 100 feet 0 inch, 120 feet 0 inch, and 140 feet 0 inch. The wall is reinfoxced concxete with a nominal 6-inch seismic gap. The seis-mic gap is covered by solid 1/4-inch steel plates bolted to each side of the concrete wall. The fit is snug and there is no path for heat or smoke to travel through the plate steel. The dead air space between the steel plates will have and insulation quality, thus minimizing radiant heat transfer to the other side as well as eliminating con-vected heat through the barrier, Zonal detection and automatic deluge water spray covers the predominant in situ combustible (cable trays at elevations 100 feet 0 inch and 120 feet 0 inch).

K.ain A cable trays are located 8 to 9 feet from the center wall in Zone'86A. %'ain B cable trays are located more than 10 feet from the opposite side of the center wall in Zone 86B. The compli-ance strategies for the components associated with the "N" raceways do not rely on components whose cables are within 10 feet of the center wall. The equ~lent-fixe-seveap total combustible (fire) loading for each of Zones 86A and 86B is 440-high. This appaxently high ~eveaty com-bustible loading is attiibuted to the calculation method, in that the combustible material is located in an area with a relatively small Hoox area combined with a high ceiling. Fire team response (within 40 20 minutes) is expected, before significant degradation of the existing fire barriers would occur. Access to Zone 86A for fire team response is available at elevation 100 feet 0 inch (through Zone 5A). Access to Zone 86B for fire team response is available at elevation 100 feet 0 inch (through Zone 5B).

The existing design provides equivalent protection to that xequired by Section III.G.2, and upgrading the existing design to a 3-hour rating would not significantly enhance the protection currently provided.

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approval for deviations from Section III G of Appendix R to the ex'tent that

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exterior walls, basemats, and roofs, which form the boundaries of fire areas, are not fire rated. The staff was concerned that an exterior fire may threaten shutdown capability. However, these construction features are not required to separate shutdown-related systems inside the plant from external fire hazards, such as oil-filled.transformers. Also, they do not separate safety-related areas from non-safety-related areas that present a significant fire threat to the safety-related areas. The staff, therefore, concludes that the walls, basemats, and roofs described in the FSAR define valid fire areas as required by Section III.G of Appendix R and they represent an acceptable deviation from Section D. 1 of BTP APCSB 9.5-1.

In the FSAR, the applicant described the construction of heating, ventilation, and air conditioning (HVAC) chase walls and stairwell walls of reinforced 'con-crete construction that have a fire rating of 2 to 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. These conditions represent a deviation from the technical requi.rements of Section III.G of Appendix R which stipulate that redundant shutdown divisions be separated by 3-hour fire-rated construction. Both the chase walls and the stairwell walls are continuous. All openings are protected by fire doors, fire dampers, or penetration seals. The interiors of the chases. and stairwell are free of any fire hazard. For a fire to cause damage to reduhdant shutdown divisions, a fire has to burn through at least a 2-hour barrier, spread vertically in the chase, and burn through at least another 2-hour-rated barrier on an upper level.

The staff, therefore, concludes that, the chase and stairwell walls provide the equivalent of a 4-hour fire barrier between shutdown divisions, and therefore, achieve literal compliance with Section III.G of Appendix R and Section D. 1 of BTP APCSB 9.5-1.

In Amendment Ho. 13 to the FSAR, the applicant described 6-in. (nominal) seismic gaps which are located in the boundary floors and walls between Fire Area I (control building) and Fire Area N (radwaste building), and between Fire Area II (control building) and the corridor building. The gaps are covered with non-fire-rated, solid, 18-gauge sheet-metal flashings on each side of a reinforced concrete stub wall or pillar. The staff was concerned that, because the gaps are not sealed with a fire-rated material, fire propagation through the gap would result in damage to redundant shutdown divisions. However, neither the radwaste building nor the corridor building contain safe shutdown equipment or cables. Therefore, fire propagation through the gap will have no effect on the ability to achieve and maintain safe shutdown.or The combustible materials on either side of the gap are either negligible are protected by an automatic deluge water spray system. Therefore, any potential fire would not be of suf-ficient magnitude to produce temperatures which would cause the metal flashings to fail. Because the flashings are tight against the stud walls and pillars, smoke and hot gases would not propagate to the adjoining area pending arrival of the fire brigade. The staff, therefore, concludes that the locations refer-enced above are valid fire areas, as required by Section III of Appendix R, and the fire area boundary construction repr esents an acceptable deviation from Section I. 1 of Appendix A to BTP APCSB 9.5-1.

compartment" A similar situation exists in the central wall of the "deadin space the The between the auxiliary and control buildings as delineated FSAR.

central wall of the dead space compartment between the auxiliary and control and Fire bui ldings is a fire area boundary common to Fire Area I (Zone 86A) ft.

Area II (Zone 86B) at elevations 74 ft, 100 ft, 120 ft, and 140 The wall 6-in. seismic The seismic gap i s is reinforced concrete with a nominal gap.

Palo Verde SSER 7 9-7

covered by solid 1/4-in. steel plates bolted tightly to each side of the con-crete wall so that there is no path for heat or smoke to travel through the steel plate. The dead air space between the steel plates will have an insulat-ing quality, thus minimizing radiant heat transfer to the other side as well as eliminating convected heat through the barrier. Existing fire protection con-sists of a fire detection system, cable tray fire suppression systems, and manual firefighting equipment as detailed in the FSAR.

The combustible materials on either side of the gap are either negligible or protected by an automat,ic deluge water spray system. Therefore, any potential fir e would not be of sufficient magnitude to produce temperatures which would cause the steel plates to fail. .Because .the plates are tight against the walls, smoke and hot gases would not spread to the adjoining area pending arrival of the fi re brigade. The staff, therefore, concludes that the wall referenced above is a valid fir e area boundary as r equired by Section III of Appendix R, and the fire area boundary construction represents an acceptable deviation from l

Section 0. of Appendix A to BTP APCSB 9. 5-1.

In Supplement No. 6 to the SER, the staff found acceptable the absence of a fire-rated sealant at the seismic gap at the containment building/auxiliary building interface because of adequate compensatory protection. In Amendment No. 13 to the FSAR, the applicant indicated that this gap will be sealed with a fire-rated sealant. With the installation of this material, the boundary construction will be in compliance with Section 0. 1 of Appendix A to BTP APCSB 9. 5-1 and is, therefore, acceptable.

In Amendment Ho. 13 to the FSAR, the applicant requested approval for a devia-tion from the technical requirements of Section III.G of Appendix R to the it

'xtent that requires that fire area boundaries be defined by fire-rated con-struction. Mechanical and electrical penetrations and the personnel access hatch in the containment boundary are not fire rated. The mechanical penetra-tions are constructed of steel with a minimum thickness of 1/8-in. The elec-trical containment penetrations are fitted with a header plate of 1.78-in.

steel. The personnel access hatch is constructed of l-in.-thick. steel. The above features, as designed in conjunction with the reinforced concrete contain-ment boundary, form a continuous barrier to the passage of flame and hot gase's from one fire area to another'. The areas on both sides of the boundary are p rotected by fire detection systems, . ) fire suppression systems, and manual f'ire-fighting equipment as 'delineated in the FSAR. Combustible materials are limite d and generally ' well dispersed throughout the areas. Where concentrated combus-t'bl i es or sigsi nificant fire hazards exist, a fire suppression system is provided.

The penetrations and access hatch are also located at varying distances es below e ow the ceiling. This means that, the stratified hot gas layer which would form at the ceiling during fire a would not encompass the penetrations until well after a fire starts. By that time, the fire would be controlled either automatically or manually by the fire brigade. The staff, therefore, concludes that the design of the penetrations and the access hatch will withstand the effects of a postulated fire until extinguishment. The containment boundary, ther efore, is a valid fire area boundary as required by Section III.G of Appendix R, and the design of the penetrations represents an acceptable deviation from Section D.l of Appendix A to BTP APCSB 9.5-1.

I 1 tt d ted October 2 and December 10, 1984, the app1icant requested technical requirements oof Section III.G of approval for a deviation from the e Palo Verde SSER 7

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PVNGS UPDATED FS FIRE HAZARDS ANALYSIS Conclusion The existing design provides equivalent protection of that required by Section III.G.2, and upgrading the existing design for 3-hour F(g< RR& X

)P Vlfl77oe ratings would not significantly enhance the Pg.2. Q protection currently provided.

8.2 2. deviation- is requested to Section III.G 2 t

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PS vrgeZ> th extent that it requires installation of SSE r4t i 1-ho fire-rated barrier and an area-wide 5'@e7-suppre sion system.

Discuss on The east w ll of Zone 86B is a fire a ea boundary between Fire Area II and the corrido building at elevations 90 feet 0 inch, 100 fee 0 inch, 120 feet 0 inch and 140 feet 0 i ch. The boundary contain a 6- inch (nom'l) seismic gap which is covered 'th nonrate , solid, 18-gauge sheet metal flashin s on ea side of a reinforced concrete s ub ll. The metal flashings would retard e passage of heat and/or smoke. The corridor b i ding contains no safe shutdown equipment o cabl s; therefore, a postulated fire wi in the rridor building would have no ef ct upon saf shutdown capability.

Within Fire ea II, Zone 86B is s arated from the remain r of the fire area by 2- and 3-hour rated wal s. Zone 86B is separated fr Zone 86A (Fire a I) by a nonrated barrier (see Fire Area I deviation No. 5, for the Zone 86A one 86B paration considerations). Zonal detec ion and automatic deluge water spray covers the p dominant in situ combustible (cable trays at March 1993 9B.2-74 Revision 5

9B.2.2 FIRE AREA H B. Deviations from 10CFR50, Appendix R, Section III.G

2. A deviation is requested to Section III.G.2 to the extent that it requires installation of a 1-hour fire-rated barrier and area-wide suppression system.

~Di c~ujgn The east wall of Zone 86B is a fire area boundary between Fixe Area II and the corri-dox building at elevations 90 feet 0 inch, 100 feet 0 inch, 120 feet 0 inch, and 140 feet 0 inch. The boundary contains a 6-inch (nominal) seismic gap which is covered with nonrated, solid, 18-gauge sheet metal flashings on each side of a reinforced concrete stub wall. The metal flashings would retard the passage of heat and/or smoke. ~

@ay. The Corridor Building contains safety related HVAC damper control cables and non-safety related RCP control cables. The ability to achieve and

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maintain safe shutdown is demonstrated by calculations 13-MC-FP-316 and 13-MC-FP-318.

Within Fire Area Il, Zone 86B is separated from the remainder of the fire area by 2-and 3-hour rated walls. Zone 86B is separated from Zone 86A (Fire Axea I) by a non-rated barrier (see Fire Area I, deviation No.5, for the Zone 86A/Zone 86B separation considerations). Zonal detection and automatic deluge water spray covers the pre-dominant in situ combustible (cable trays at elevation 100 feet 0 inch and 120 feet 0 h).7h t \ b tibl ( ~ )I Si gf Z 86Bi 384ninutes high. The apparently high Are-seveaty combustible loading is attrib-uted to the calculation method in that the combustible material is located in an area with a relatively small floor space combined with high ceilings. Fire team response (within 44 20 minutes) is expected before significant degradation of the existing fire barriers would occur. Access to Zone 86A for fire team response is available at ele-vation 100 feet 0 inch (through Zone 5A). Because the metal flashings are tight against the concrete stub walls, smoke and hot gases would not propagate to the adjoining area pending arrival of the fire team. Therefore these boundaries form valid fire areas, as required by Section IH of Appendix R.

The existing design provides equivalent protection to that requixed by Section III.G.2, and upgrading the existing design to a 1-hour xating plus suppression would not significantly enhance pxotection curxently provided.

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approval for deviations from Section III.G of Appendix R to the extent that exterior walls, basemats, and roofs, which form the boundaries of fire areas, are not fire rated. The staff was concerned that an exterior fire may threaten shutdown capability. However, these construction features are not required to separate shutdown-related systems inside the plant from external fire hazards, such as oil-filled transformers. Also, they do not separate safety-related areas from non-safety-related areas that present a significant fire threat to the safety-related areas. The staff, therefore, concludes that the walls, basemats, and roofs described in the FSAR define valid fire areas as required by Section III.G of Appendix R and they represent an acceptable deviation from Section O.l of BTP APCSB 9.5-1.

In the FSAR, the applicant described the construction of heating, ventilation, and air conditioning (HVAC) chase walls and stairwell walls of reinforced 'con-crete construction that have a fire rating of 2 to 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. These conditions represent a deviation from the technical requirements of Section III.G of Appendix R which stipulate that redundant shutdown divisions be separated by 3-hour fire-rated construction. Both the chase walls and the stairwell walls are continuous. All openings are protected by fire doors, fire dampers, or penetration seals. The interiors of the chases. and stairwell are'free of any fire hazard. For a fire to cause damage to reduhdant shutdown divisions, a fire has to burn through at least a 2-hour bar rier, spread vertically in the chase, and burn through at least another 2-hour-rated barrier on an upper level.

The staff, therefore, concludes that the chase and stairwell walls provide the equivalent of a 4-hour fire barrier between shutdo'wn divisions, and therefor e, achieve literal compliance with Section III.G of Appendix R and Section D. 1 of BTP APCSB 9.5-1.

In Amendment No. 13 to the FSAR, the applicant described 6-in. (nominal) seismic gaps which are located in the boundary floors and walls between Fire Area I (control building) and Fire Area N (radwaste building), and between Fire Area II (control building) and the corridor building. The gapa are covered with non-fire-rated, solid, 18-gauge sheet-metal flashings on each side of a reinforced concrete stub wall or pillar. The staff was concerned that, because the gaps are not sealed with a fire-rated material, fire propagation through the gap would result in damage to redundant shutdown divisions. However, neither the radwaste building nor the corridor building contain safe shutdown equipment or cables. Therefore, fire props'gationntnrough the gap will have no effect on .the ability to achieve and maintain safe shutdown. The combustible materials on either side of the gap are either negligible or are protected by an automatic deluge water spray system. Therefore, any potential fire would not be of suf-ficient magnitude to produce temperatures which would cause the metal flashings to fail. Because the flashings are tight against, the stud walls and pillars, smoke and hat gases would not propagate to the adjoining area pending arrival of the fire brigade. The staff, therefore, concludes that the locations refer-enced above are valid fire areas, as required by Section III of Appendix R, and the fire area boundary construction represents an acceptable deviation from Section I. 1 of Appendix A to BTP APCSB-9.5-1 ~

A similar situation exists in the central wall of the "dead space compartment" between the auxiliary and control buildings as delineated in the FSAR. The central wall of the dead space compartment between the auxiliary and control buildings is a fire area boundary common to Fire Area I (Zone 86A) and Fire Area II (Zone 86B) at elevations 74 ft, 100 ft, 120 ft, and 140 ft. The wall is reinforced concrete with a nominal 6-in. seismic gap. The seismic gap is Palo Verde SSER 7 9-7

PVNGS UPDATED FS FIRE HAZARDS ANALYSIS common to the southwest HVAC chase (Fire Area I), and

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2-hour rated barriers common to the southeast outside

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,'c air and HVAC chases (Fire Area II).. The west boundary is a 3-hour rated barrier common to Fire Area X. The east boundary is a 3-hour rated barrier common to the corridor building and a 2-hour rated exterior wall. r Fire Area III does not inolude the vestibule adjacent to the corridor building. The walls of the vestibule are 3-hour rated. The ceiling above and floor below Fire Area III are 3-hour rated barriers.

Safe Shutdown Equipment Subject to Loss in the Event o Fire in Fire Area III Fire Area I contains both train A and train B safe shutdown relate equipment and cabling. In the event of a fire, the plant be brought to safe shutdown from the train B remote s down panels located in Fire Area II. It is assumed t reactor operators manually trip the reactor prior to vacuating the control room. To assure operability in endent of the control room, certain train B safe shut circuits can be disconnected from the control roo t panels located outside the ma'n contro oom.

8 Appendix R, Section III.G Deviations from 10CFRSO,

1. The main control room (Zone 17) contains redundant safe shutdown cables and equipment.

Alternative safe shutdown capability is provided as required by Section III.G.3 of Appendix R.

2. See subsection 9B.2.1 for deviations common to Fire Area I and subsection 9B.2.2 for a deviation

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common to Fire Area II.

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March 1993 9B.2-129 Revision 5

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9B.2.3 FIRE AREA III B. Deviations from 10CFR50, Appendix R, Section III.G

3. A deviation is requested from Section HI.L to the extent that it allows credit for only one action in the control room prior to evacuation. (See Generic Letter 86-10, Question 3.8.4.)

In accordance with the guidance of Generic Letter 86-10, Questions 3.8.4 and 5.3.10, a bounding analysis ivas performed for the control room fire scenario to assure that safe shutdown conditions could be maintained from outside the con-trol room (Ref. Calculation 13-MC-FP-318. 10CFR50 Appendix R mG/IIIL Compliance Assessment and 13-MC-FP-317, 10CFR50 Appendix R Opera-tional Considerations). This bounding analysis assumed worst case spurious actuations as well as loss of all automatic function (such as ESFAS, DG auto start and sequencing) of components whose control circuits could be affected by a fire in the control room. This conservative analysis indicated that the steam generator may overfill in approximately two minutes ifa main steam isolation signal is not initiated prior to control room evacuation. The action to isolate main steam is located on the same control board as the reactor trip push-but-ton. The action in the control room prevents a very unlikely series of events, which includes spurious actuation and failure of specific automatic functions. If these series of events were to occur, however, main steam can be isolated outside the control room, regardless of the circuit damage in the control room.

I at C

PVNGS UPDATED FS FIRE HAZARDS ANALYSIS boundary. The access hatch opens to Fire Area XI, Zone 66A, which has an equivalent fire severity of less than 51 minutes. Mechanical containment penetrations are fitted with flued heads constructed of steel with a minimum thickness of 1/8 inch. Electrical containment penetrations are fitted with a stainless steel

/

header plate with a thickness of 1.78 inches.

The special construction of the flued heads and header plates was designed to maintain the integrity of the containment building.

Conclusion The existing design provides equivalent protection to that required by Section III.G.2.

The design is standard within the industry.

2. deviation is requested from Section III.G.2 o the xtent that it requires a 1-hour rated

~v(5'C p barrie in addition to fire detection a fire 56K NCYv.

g(-(E.E' suppress'on.

Discussion Elevation 100 eet 0 inch of are Area XV contains the tra'n A and t in B charging pumps, with their associa ed p er and control electrical cables, x djacent Zones 46A and 46B, respectively.

The train A char ing pum room (Zone 46A) walls, floor, and ce'ng are of nrated, reinforced concrete co struction with a penetrations and openings, except two, sealed t an equivalent 3-hour ire boundary rating. On unsealed

~~

open' is a 22-inch wide and 14-i ch high HVAC du t penetration of the west wall loc ted 13 feet inches above the floor just south of the north March 1993 9B.2-386 Revision 5

9B.2.15 FIRE AREA XV B. Deviations from 10CFR50, Appendix R, Section III.G

2. A deviation is requested to Section III.G.2 to the extent that it requires a 1-hour rated bar-rier in addition to fire detection and fixe suppression.

~Di ~i~n Elevation 100 feet 0 inch of Fire Area XV contains the Train A, Train B and Train E charging pumps with their associated power and control electrical cables, in adja-cent Zones 46A, 46B and 46E, respectively.

. The walls, Hoor, and ceiling of these Zones are of 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated, reinforced concrete construction with all electrical and pipe penetrations sealed to an equivalent 3-hour fire barrier rating. There is a non-rated personnel doorway opening to the north side corridor from each room.

There are several unsealed HVAC duct penetrations in the pump room entry valve gallery area on the north side of the pump rooms. These HVAC ducts are not provided with fire dampers.

A horizontal distance of approximately 20 feet exists between the @VAN-ev reein-aeeess personnel doorway openings and the respective charging pumps.

. An aggregate horizontal dis-tance of at least 40 feet exists between the redundant devices.

. The total combustible loading in each of the pump rooms and the adjoining corridor, Zone 42C, is low. A smoke detec-tion and an automatic pxeaction water sprinkler system axe pxovided in each of the ave pump rooms, and a cable tray fire detection and automatic suppression system are pxovided for the cable trays running in the corridors (Zone 42C) just outside the rooms. Fire team xesponse is expected in less than 30 minutes.

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The existing design provides equivalent protection to that required by Section d'gd eeking configurations would not significantly enhance the protection currently pro-vided.

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9. 5. 1. 6 Fire Protection for Safe Shutdown Capabi 1 i ty En Supplement No. 6 to the SER, the staff evaluated certain deviations from the technical requirements of Section III.G of Appendix R pertaining to, the protec-tion of redundant shutdown systems in the auxiliary building. In Amendment Ho.

13 to the FSAR, the applicant requested approval for additional deviations to the 'extent that Section III.G requires that redundant shutdown divisions be:

(1) separated by 3-hour fire barriers; or (2) separated by 20 ft free of com-bustible material and protected by a fire detection and a fire suppression system; or (3) separated by a 1-hour fire barr ier and protected by a fire detection and fire suppression system.

r In general, the plant locations where these deviations are located can be characterized by a low in situ fire loading, with combustible materials dis-persed throughout the area. In locations where concentrated combustibles or a significant fire hazard:exists, the hazard is mitigated by the presence of an automatic fire suppression system:. These areas also have large floor-to-ceiling heights and large room volumes, which means that .the. effects of a fire, such as smoke and .hot gases, will be dissipated.

In some locations, such as an elevation 51 ft 6 in. of the auxiliary building, the separation between redundant shutdown systems is greater than 80 ft. The area is completely protected by a fire detection system and manual firefighting equipment. Because of the large separation distance, the low fire loading and existing fire protection, there is reasonable assurance that one division will remain free of fire damage until the fire is extinguished by the plant's fire brigade.

other locations, uch as Zones 46A and 468 (elevation 100 ft in the auxiliary building) the straight-line-separation distance between redundant systems is

~,(5'n less than 20 ft. However, floor-to-ceiling masonry cubicle walls partially gg enclose the systems. These walls would act to confine the fire so that not more than one division would be damaged. The areas are also protected by automatic fire suppression and detection systems. These systems provide reasonable assur-ance that any potential fire will be detected early and either suppressed auto-matically or manually by the fire brigade.

In certain locations, such as in elevation 120 ft of the auxiliary building, separation of redundant shutdown-related cables and components is approximately 20 ft or more. The areas are protected by a partial sprinkler system, which covers at least one division, and a compTete fire detection system. The appli-cant has installed a.l-hour fire-rated barrier around one division of cables.

The remaining systems consist of tanks and piping which are not readily damaged by fire. Because of the fire detection system, the staff expects a potential, fire to be detected early and suppressed manually by the fire brigade. If .

rapid fire propagation occurs, the sprinkler system will actuate and either control the fire or discharge water onto one division of shutdown systems. The

,1-hour fire barrier and the substantial construction of the rest of the shut-down components in the 'area will achieve a degree of passive protection suf-ficient to provide reasonable assurance that safe shutdown capability can be maintained free of fire damage.

The applicant has also analyzed the consequences if vertical fire propagation fire did occur in places where floor/ceiling assemblies do not form a continuous Palo Verde SSER 7 9-14

PVNGS UPDATED FS 8~

p<~v[A~~M f KEZ'8 FIRE HAZARDS ANALYSIS

$ 8.Z. is 8.F 8. deviation is requested from Section III.G.2 t

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t e extent that it requires either a 1-hour ra ed

~g nl<z-v ba ier or separation by a horizontal distan of 5~~ 20 f t or more without intervening combust'es, and fi e detection and suppression.

I Discussi Redundant . ains of safe shutdown racew y exist on all eleva ions of Fire Area XV in e auxiliary buil ing, except for eleva ion 40 feet 0 inch, which c tains no safe shut own raceway, and elevation 140 feet 0 inch, wh'ch contains only train A safe utdown condu t. Redundant safe shutdown racewa within F' Area XV are separated by a combin tion of features providing spatial separation, an the eby precluding fire spread along the shortes ath between redundant safe shutdown equipment. For example, the design employs small, fire-rat d lls to block corridors, and sealin of pi ing penetrations in nonrated walls when ither ac ion can be shown to be beneficial. An her featur is the addition of localized wate suppression i zones which have a higher l'lihood of initi ting a fire, or in those zones where additional pr ection for safe shutdown equipment is required. For Fire Area XV, th following table lists co responding zones of s fe shutdown equipment (by b ilding elevation and the maximum fire severit along the sep ation path. Fire protection fea ures which nhance the existing separation are so list . Wherever fire detection is provided fir team response is expected within 30 minutes. In all cases listed, detection is p ovided along the separation path.

(2)

March 1993 9B.2-393 Revision 5

t 9B.2.15 FIRE AREA XV B. Deviations from 10CFR50, Appendix R, Section III.G

8. A deviation is requested from Section III.G.2 to the extent that it requires either a 1-hour rated barrier or separation by a horizontal distance of 20 feet or more without intervening combustibles, and fire detection and suppression.

~i~~in Redundant trains of safe shutdown raceway exist on all elevations of Fire Area XV in the auxiliary building, except for elevation 40 feet 0 inch, which contains no safe shut-down raceway, and elevation 140 feet 0 inch, which contains only train A safe shut-down conduit. Redundant safe shutdown raceway within Fire Area XV are separated by a combination of features providing spatial separation, and thereby precluding fire spread along the shortest path between redundant safe shutdown equipment. For exam-ple, the design employs small, fire-rated walls to block corridors, and sealing of piping penetrations in nonrated walls when either action can be shown to be beneficial.

Another feature is the addition of localized water suppression in zones which have a higher likelihood of initiating a fire, or in those zones where additional protection for safe shutdown equipment is required. For Fire Area XV, the following table lists corre-sponding zones of safe shutdown equipment (by building elevation) and the ma~mm-Armeveety total combustible (fire) loading along the separation path. Fire protection features which enhance the existing separation are also listed. Wherever fire detection is provided, fire team response is expected within 30 minutes. In all cases listed, detec-tion is provided along the separation path.

Elevation 40 feet 0 inch No safe shutdown raceway located in Fire Area XV at this elevation Elevati n 1 feet in h

~ Train A safe shutdown raceway located in Zone 88A Train B safe shutdown raceway located in Zone 88B 80 feet minimum horizontal separation along south corridor between column lines AD and AH 9\'8881(ll)19888 888.* 99,8 89, 88 utE% low.

Fire detection along separation path (no automatic fire suppression provided) for all zones

~ 3-hour rated ECCS puinp room walls, and across north corridor at column line AF

~ Nonrated reinforced concrete construction wall with unsealed pene-txations across south corridor at column line AF

~ No redundant raceway below

~ Redundant raceway above uses same separation path.

levati n eet in l Train A safe shutdown raceway located in Zones 34A, 35A, 37A, and 37C Train B safe shutdown raceway located in Zones 34B, 35B, 37B, and 37D

~ 80 feet minimum horizontal separation distance along south corridor between column lines AD and AH T I b ibl (fi j I Ch g 6 g *p-

'ow.

ration path (Zone 37C, Zone 34A, Zone 35A, Zone 37A, Zone 37B, Zone 35B, Zone 34B, Zone 37D) is

~ Fire detection along separation path (no automatic suppression pro-vided) for all zones

~ 1-hour rated wall in north corridor, 3-hour rated wall along column line AE except for south corridor (open), and nonrated reinforced concrete construction between north corridor and piping penetration rooms (2-hour rated wall about stairwell)

~ Redundant raceway below uses same separation path.

~ - Redundant raceway above is a continuation of the raceway at this ele-vation.

J l vati ee't inc

~ Txain A safe shutdown raceway located in Zone 37C

~ Train B safe shutdown raceway located in Zone 37D

~ Train A and B safe shutdown raceway located in Zone 39B. (Note:

These raceways contain redundant power and control circuits for the condensate transfer pumps which are only required to be stopped to achieve and maintain safe shutdown. In the event of a fire dam-aging both train A and train B circuitry, makeup water for the essen-tial cooling water, essential chilled water, and the diesel generator systems may be added through connections provided on the fillside of each system's surge t

~). Makeup water to these systems is available &om the fire protec-tion system. This makeup capability, however, is not required for safe shutdown (refer to calculation 13-MC-FP-319) 80 feet minimum horizontal separation distance along north pipe chase between column lines AD and AH Y I b hl(fl )I di"ga g*p-ration path (Zone 37C, Zone 39A, Zone 39B, Zone 37D) is les!Waa-44BiBBtes low.

Fire detection along separation path (no automatic suppression pro-vided) fox all zones Heavy concrete construction wall between pipe chase zones and pip-ping penetration areas, 3-hour fire-rated vertical cable chases, and heavy concrete construction floor and ceiling with penetration seals fox radiation shielding. 1-houx rated ceiling below Fixe Area XVI (Zone 42A) and Fire Area XVII(Zone 42B)

Redundant raceway below is a continuation of the raceway at this ele-vation.

Redundant raceway above uses a similar separation path.

I 1

Elevation 100 feet 0 inch

~ Txain A safe shutdown raceway located in Zones 42D and 46E

~ Trains A and B safe shutdown raceway located in Zones 42C, 46A, 46B 25-foot minimum horizontal separation distance along north (Zone 42D) and south (Zone 42C) corridors for redundant circuits along with a 1-hour rated fire barrier across the corridors and fire detection and automatic cable tray suppxession provided in both zones

~ Train A safe shutdown raceway in Zone 42C running parallel with txain B cable trays in north, east, and south corridors (contains circuits for shutdown cooling system valve J-SIC-UV-653 only) is provided with a protective coating affording equivalent 1-hour rated fire barrier pxotection plus fire detection and automatic cable tray suppression.

NOTE This description is applicable to Unit 1 only. (Circuits were rerouted in Units 2 and 3 to minimize the length of race-way requiring wrapping.)

Train A charging pump conduit in Zones 46B, 46E, and the south cor-ridor of Zone 42C is provided with a pxotective coating affording equivalent 1-hour rated fire barrier protection and zonal detection and automatic suppression in Zones 46B and 46E.

Txain B charging pump conduit in Zone 46A is provided with a pro-tective coating affording equivalent 1-hour rated fire barrier protec-tion and zonal detection and automatic water suppression.

Train A safe shutdown conduit in the north end of the Zone 42C east corridor (contain circuits for the auxiliary feedwater pump turbine and flow regulating/isolation valves, area AHU and the MSIVs and ADVs) are provided with a protective coating affording equivalent 1-hour xated fire barrier protection and zonal detection and automatic water suppression.

7 I b ibl(fl )heigh p tion paths (Zone 42C, Zone 42D, Zone 46E) is Iow.

r

~ Fire detection/suppression in separation paths Zone 42C - Cable tray fire detection and automatic suppression Zone 42D - Cable tray fire detection and automatic suppression Zone 46A - Zonal fire detection and automatic suppression Zone 46B - Zonal fire detection and automatic suppression

~

p 3 ~

Zone 46E - Zonal fire detection and automatic suppression Column line AG wall between the north and south corridors is nen-rah4 reinforced concrete construction with all penetrations sealed to 33 '

3 VP penetration through the wall near column line A7. The opening is 12 inches wide by 12 inches high located 8 feet 10 inches above the Hoor.

The floors and ceilings of Zones 44, 45, 46A, and 46B and 46E are p id*~

neieated reinforced concrete construction with all penetrations sealed Fire Area XV deviation No.2.

3-3 3

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~ The 100 foot Hoor is reinforced concrete construction with sealed electrical and pipe penetrations to a 3-hour fire rating and is also a pressure boundary. There are non-fire rated penetrations which include several HVAC ducts without fire dampers, equipment and personnel hatches with steel cover plates, two stairs with doors and an enclosed concrete pipe chase at column lines A7/AC. The combustible loading on the Hoor below at the 88 foot elevation pipeway consisting of piping and valves is very low which, com-bined with the heavy concrete floor, does not present an exposure fire hazard to cables and equipment required for safe shutdown located at the 100 foot elevation.

~ The walls of Zone 46A, 46B and 46E are described in Fire Area XV deviation No. 2.

Elevation 120 feet 0 inch

~ Train A safe shutdown raceway in Zone 52A with redundant train B safe shutdown raceway in Zones 48, 51B, 53, and 50A (Note: See Fire Area XV, deviation No.4, for the Zone 48 separation consider-ations.)

Elevation 120 feet 0 inch c nt'd.

Redundant train A and train B safe shutdown raceway in Zone 52D.

The train A conduit in the north end of the Zone 52D east corridor is a continuation of the raceway described at elevation 100 feet 0 inch directly below and are provided with a protective coating aKording equivalent 1-hour rated fire barrier protection at this elevation also.

80 feet minimum horizontal separation distance along north corridor (Zones 52A and 52D) between column lines AD and AH with a 1-hour rated fire barrier across the corridor and fire detection and auto-matic cable tray suppression provided in both zones.

Additionally, there are the following barriers:

3-hour rated wall sections along column line AF between A7 and A8, and along column line AG between A8 and A10.

fi ifi~

Recrated Reinforced concrete construction wall along col-umn line A8 between AF and AG with all penetrations sealed fi- fi 'fi.

Nonrated reinforced concrete construction wall along column line A7 between AE and AF having two open HVAC ducting penetrations and an access opening from the Zone 52D corri-dor to Zone 50A.

Total combustible (fire) loading in separa-tion paths (Zone 52A, Zone 50A, Zone 51B, Zone 53, Zone 52D) is moderate, including allowance for transient combustibles.

~ Fire detection/suppression in separation paths Zone 52A - Cable tray fire detection and automatic suppression sys-tem Zone 52D - Cable tray fire detection and automatic suppression sys-tem Zone 50B - None Zone 53 - None Zone 50A - None

J Elevati n 4 eet in 1 Train A safe shutdown raceway in Zones 56B, 56C, 57N, 57J

~ and

~ 20 feet minimum horizontal distance between redundant trains located at elevations 120 feet and 140 feet. (Note: Nonrated hatch opening in floor between Zones 56C and 52D below.)

Total combustible (fire) loading in separa-tion path (Zone 568, Zone 56C, Zone 52D) is moderate.

~ Fire detection/suppression in separation path Zone 56B - Zonal fire detection and automatic wet pipe sprinkler sys-tem Zone 56C - Automatic wet pipe sprinkler system (including coverage above hatch)

Zone 52D - Area suppression in northeast corner of Zone 52D, but none directly below hatch area.

~ 2-hour and 3-hour rated barrier floor above Fire Area XVI (Zone 47A) and Fire Area XVII(Zone 47B). Three (3) hour rated barrier Aoor above Analysis Area XVD (Zones 50B, 51A, 51B, 52D, 53 and 54) except for the steel plate covered hatch of concern and the 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rated walls of the duct chase west of column AH at column A7. Remainder of the floor area is near:ite4 reinforced concrete con-struction with all penetrations sealed to provide an equivalent 3-hour fire rating except for the steel plate covered hatch of concern, the unsealed sample piping chase opening into Zone 57C, and the HVAC shaft penetration in Zone ~ 57J which has a 2-hour fire rating.

Qgnclu~ion The existing design provides equivalent protection to that required by Section III.G.2, and upgrading the existing design to 1-hour rated walls, floors, and ceilings or installing area-wide detection and suppression would not significantly enhance the protection currently provided.

9.5.1.6 Fire Protection for Safe Shutdown Capability n Supplement Ho. 6 to the SER, the staff evaluated certain deviations from the echnical requirements of Section III.G of Appendix R pertaining to the protec-ion of redundant shutdown systems in the auxiliary building. In Amendment Ho.

3 to the FSAR, the applicant requested approval for additional deviations to he extent that Section III.G requires that redundant snutdown divisions be:

(1) separated by 3-hour fire barriers; or (2) separated by 20 ft free of com-ustible material and protected by a fire detection and a fire suppression system; or (3) separated by a 1-hour fire barrier and protected by a fire detection and fire suppression system.

In general, the plant locations where these deviations are located can be characterized by a low in situ fire loading, with combustible materials dis-persed throughout the area. In locations where concentrated combustibles or a significant fire hazard."exists, the hazard is mitigated by the presence of an automatic fire suppression system: These areas also have large floor-to-cei ling heights and large room volumes, which means that .the. effects of a fire, such as smoke and .hot gases, will be dissipated.

In some locations, such as an elevation 51 ft 6 in. of the auxiliary building, the separation between redundant shutdown systems is greater than 80 ft. The area is completely protected by a fire detection system and manual firefighting equipment. Because of the large separation distance, the low fire loading and existing fire protection, there is reasonable assurance that one division will remain free of fire damage until the fire is extinguished by the plant's fire brigade.

In other locations, such as Zones 46A and 468 (elevation 100 ft in the auxiliary building) the straight-line-separation distance between redundant systems is less than 20 ft. However, floor-to-cei ling masonry cubicle walls partially t f/',l5 enclose the systems. These walls would act to confine the fire so that not more 8.2 than one division wou'id be damaged. The areas are also protected by automatic fire suppression and detection systems. These systems provide reasonable assur-ance that any potential fire will be detected early ard either suppressed auto-matically or manually by the fire brigade.

In certain locations, such as in elevation 120 ft of -he auxiliary building, separation of redundant shutdown-related cables and components is approximately

/6.2 << 20 ft or more. The areas are protected by a partial sprinkler system, which at least one division, and a complete fire detection system. The appli- 'overs B,E cant has installed a 1-hour fire-rated barrier around on'e . division of cables.

The remaining systems consist of tanks and piping which are not readily damaged by fire. Because of the fire detection system, the staff expects a potential fire to be detected early and suppressed manually by the fire brigade. If .

rapid fire propagation occurs, the sprinkler system will actuate and either control the fire or discharge water onto one division of shutdown systems. The 1-hour fire barrier and the substantial construction of the rest of the shut-down components in the 'area will achieve a degree of passive protection suf-ficient to provide reasonable assurance that safe shutdown capability can be maintained free of fire damage.

The applicant has also analyzed the consequences if vertical. fire propagation did occur in places where floor/ceiling assemblies do not form a continuous fire Palo Verde SSER 7 9-14

1 I'

Al ~

barrier. At least one division would remain free of fire damage. Alternately, the applicant has upgraded the floor/ceiling assembly in such a manner that this assembly forms a continuous barrier between one elevation and the next. In some cases, such as between elevation 120 ft and 140 ft of the auxiliary building, the vertical fire barrier is not completely fire rated, such as at a steel hatchway. However, because of the existing fire protection features (fire detection, partial fire suppression, manual firefighting equipment) and the low fire load, it is the staff's judgment that the non-fire-rated construction will withstand the effects of a fire until the fire is extinguished.

The staff, therefore, concludes that although deviations have been identified in Amendment No. 13 to the FSAR, the fire protection capability for safe shut-down achieves an acceptable level of safety comparable to that achieved by full compliance with Section III.G of Appendix R.

Alternate Shutdown By letters dated September 26 and October 5 and 16, 19/4, the applicant sub-mitted the results of its spurious actuation analyses for a fire in the control room or outside of the c'ontrol room. Because of several concerns raised during the staff's review of theSe reports, the applicant provided revisions to these documents by a November 13, 1984, letter'.

In determining the ability of the plant to be safely shut down in the event of a fire, the applicant analyzed the effects of fire-induced hot shorts, open circuits, and shorts to grounds on safe shutdown capability. For the fire out-side of the control room, the evaluation was performed for each fire zone iden-tified in the submittal; for the control room fire the study considered only the electrical circuitry in the control room. Both analyses were performed for situations with and without offsite power.

Once a given spurious operation was identified, whether action or inaction of a component, the applicant determined what capabilities would be available to the operator which would assist in the identification and mitigation of the undesirable event. In addition, any time constraints that affected rectifica-tion of unwanted plant conditions were quantified. Next, those actions neces-sary to prevent the spurious operation were detailed along with any compensatory measures needed to implement the corrective actions.

. The results of the above process yielded those areas of the plant where either manual actions were acceptable or where design changes, such as rerouting or protecting cables, were necessary. In. those instances where operator actions are needed, the applicant will identify those requirements in the plant proce-dures or fire strategy book.

0n th e b asis o f its i s review of the methodology used by the applicant to'etermine those spurious operations resulting from a fire outside of or in e con ro th t ff oncludes that the PVNGS 1-3 design conforms to the technical requirements of Section III.G and III.L of Appendix R to 10 C FR 50.

During its review the staff noted that several fire areas, systems, or evalua-tion findings had been deleted in a November 13, 1984, submittal (Revision 1 to th t ) 'thout justification. In response that to staff questions, the app i-cant stated in a letter dated December 7, 1984, Fire Areas 1. 2 . 3A . an and Palo Verde SSER 7 9-15

ENCLOSURE 2

'I 0 CFR 50.59 EVALUATION

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ACTION UNDER REVIEW:

t 10CFR50.59 SCREENING AND EVALUATION Evaluation L.og No.: tZ Page

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I of gfgC tz.-'I-'EVISIOII PCN DESCRIPTIO PROPOSED CMANGE:

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10CFR50.59 SCREEN (Provide References on Response Justi%cation Page) NO YES Does the proposed change:

1. Make changes in the facility as it is described in the UFSAR'?

2. Make changes ln procedures as they are described in the UFSAR7

3. Involve test or experiments not described in the UFSAR'?

4. Require a change to the technical specITIcations7

~ Any answer to questions 1 through 3 "YES", then a 10CFR60.69 evaluation is required. Contact Document Control at ext. 82-6633 to obtain a tracking loa number and enter the number in the Evaluation Log number block above. UFSAR Change Request per procedure 93AC-OLC01 may also be required.

Answer 4 is "YES", then Technical Specification Change Request per procedure 93AC-OLC01 and NRC approval Is required prior to implementation All answers 1 through 4 are "NO", no 10CFR60.69 Evaluation required or Technical Specification change required, recommend action approval.

10CFR50.59 EVALUATION(Provide Response Justification with References)

6. May the probability ot an accident previously evaluated In the UFSAR be increased?

6. May the consequences ot an accident previously evaluated in the UFSAR be increased7

7. May the probability of a malfunction ot equipment Important to safety be increased7

8. May the consequences of a malfunction of equipment important to safety be increased'7

9. May the possibility of an accident of a different type than any previously evaluated in the UFSAR be created7

10. May the possibility of a different type of malfunction than any previously evaluated in the UFSAR be created' 11 ~ Is the margin of safety as defined in the basis for any technical specification reduced7 .

Any answer to questions 5 through 11 "YES", then an unreviewed safety question is identified. Proceed to procedure 93AC-OLC03 prior to implementation.

All answers 5 through 11 are "NQ," there is no unreviewed safety ouestion and action approvai is recommended.

If UFSAR Chapter 6/Chapter 16 is potentially affected, forward a copy ot evaluation to Nuclear Fuels Management.

i verify that the above screening/evaluation is adequate and accurate and that the undersigned have received required training.

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/Z-f5 -O'K SCREENER/EVALUATOR DATE 50 59 RE, IEViER DATE

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SCREENERIEVAI.UATOR(PRINT) 50.59 RE'.:EWER (PRINT)

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10CFR50.59'ENEW AND EVALUATION RESPONSE JUSTIFICATION PAGE 2 OF 14 ACTION UNDER REVIEW: Changes Made to UFSAR REVISION: 4 PCN: N/A Section 9B PROCEDURE/PCP/TEMP MOD. NO.: N/A OVERVIEW UFSAR Section 9B, Fire Hazards Analysis, has been revised as a result of the recently completed FHA Reconstitution Project. A detailed comparison of the 10CFR50 Appendix R guidelines against the PVNGS design was conducted". This comparison evaluated the capability to safely shut down the plant in the event of an exposure fire that could impact electrical equipment, cables, or components necessary for safe shutdown. A summary of the methodology is as follows:

1. Identify performance goals for safe shutdown

2. Identify those plant systems and flow paths required to satisfy safe shutdown performance goals 3 ~ Identify specific plant components required for safe shutdown. Include those components required to be operated and those components whose spurious actuation could adversely impact safe shutdown capability. Also consider components whose failure could result in inadvertent safety signal actuation.

4. ~

Identify cables whose fire. induced failure or faults could adversely impact safe shutdown capability and determine their associated locations.

5. Determine survivability of plant safe shutdown capability in the event of fires in predetermined plant areas.

6. Justify compliance based upon component redundancy, operator actions, fire rated enclosures, and licensing evaluations or deviations.

The predetermined area (mentioned in 5 above) in the latest analysis is called an analysis area. An analysis area is a subset of a fire area and contains one or more fire zones as

I 1

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10CFR50-59 REVIEW AND EVALUATION RESPONSE JUSTIFICATION PAGE 3 OF 14 ACTION UNDER REVIEW: Changes Made to UFSAR REVISION: 4 PCN: N/A Section 9B PROCEDURE/PCP/TEMP MOD. NO.: N/A previously described in the UFSAR. The analysis areas were chosen to ensure successful safe shutdown paths.

In addition to the changes to Section 9B resulting from the re-evaluation, the.SARCN incorporates changes to the descriptions of several fire zones on the 140 foot elevation of the Auxiliary Building resulting from the remodeling done under DCP 1, 2, 3-FA-ZA-142. This DCP remodeled the 140 foot elevation to provide a one-way traffic pattern in and out of the primary processing areas. This was done in accordance with Radiation Protection (RP) technician island concept to best control processing of

.personnel in and out of the Radiologically Controlled Area (RCA).

These changes do not affect fire area or analysis area boundaries.

The changes made to the UFSAR do not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

DESCRIPTION OF CHANGES The following is a general description of the changes made to UFSAR Section 9B:

Chan es Resultin from Safe Shutdown Re-evaluation 1~ Section 9B.1.3 was revised. to describe the methodology used in the evaluation.

2 ~ Section 9B.1.4 now describes the Fire Hazards Analysis format and contains definitions.

3 ~ Table 9B.1-3, Safety Function Success Paths, and Figures 9B-37 through 9B-50 were deleted. This information is now contained in Calculation 13-MC-FP-315 and Drawings 13-M-FPR-001 through -021.

4 ~ Table 98.1-4, Listing of Active Safe Shutdown Equipment, was deleted. This information is now contained in 13-MC-FP-315.

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10CFR50.59 REVIEW AND EVALUATION RESPONSE JUSTIFICATION PAGE 4 OF 14 ACTION UNDER REVIEW: Changes Made to UFSAR REVISION: 4 PCN: N/A Section 9B PROCEDURE/PCP/TEMP MOD. NO.: N/A

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5. The following changes were made to each fire area description:

a ~ The analysis areas contained in the fire area were added to the fire area description.

b. The list of safe shutdown equipment subject to loss in the event of a fire was deleted. This information is now contained in Calculation 13-MC-FP-318 and summarized on an analysis area basis.

c ~ A discussion of each analysis area contained within the fire area was added. This discussion includes a description of the analysis area location and boundaries, the systems which have components and/or cable in the area, and a summary and conclusion.

6. The fire zone discussions were revised by deleting the safety-,related, equipment and components required for safe shutdown within the fire zone. This information has been superseded by the discussion of each analysis area. The safety-related equipment and components not required for safe shutdown and non-safety related equipment and components contained in the zone were not deleted.

7.. The following deviation clyrifications and new deviations were added:

a ~ Fire Area I Deviation 5: This deviation is generally correct for Train A/B separation issues.

However, with the addition of N Train components the deviation requires the following clarification.

Train A cable trays are located 8'9" to 8'11" from the center wall. Train N cable trays are located approximately 3" from the center wall. The Train N trays contain cables for the following components that are subject to fire damage:

I 10CFR50.59 REVIEW AND EVALUATION RESPONSE JUSTIFICATION PAGE 5 OF 14 ACTION UNDER REVIEW: Changes Made to UFSAR REVISION: 4, PCN: N/A Section 9B PROCEDURE/PCP/TEMP MOD NO.: N/A

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J-CHN-UV-501 J-CHE-HV532 J-CHE-FV241 244 J-CHN-UV527 J-CHE-PDV240 J-CHE-UV231P J-NCN-UV099 J-RCE-HV431 PZR Heaters J-CHE-HV536 The compliance 5trategies for these components (except for J-NCN-UV99) do not rely on redundant equipment located in 86A. The compliance strategy for the loss of J-NCN-UV99 credits the Train A ex-core neutron monitoring system.

been shown that a return to However, it has criticality is not possible. Therefore, from a systems standpoint this deviation can be revised. The fire protection systems and physical plant arrangements remain the same.

b. Fire Area II Deviation 2: This deviation is correct except that as a result of the revisions to the safe shutdown equipment list, the corridor building now contains cables for the following safe shutdown components.

Reactor Coolant Pumps Train A/B damper controls The deviation needs to be revised to reflect the as built condition of the plant.

The HVAC interaction is being addressed by an existing CRDR. The compliance strategy for the RCPs in the corridor building credits an action in TB-4 to secure the pumps. The compliance strategy for the RCPs in fire zone 86B indicates that control of the RCPs remains available from the Control Room. If the fire were to propagate between 86B and the corridor building the compliance strategy although different is still credible. Therefore, from a systems standpoint this deviation can be revised.

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10CFR50.59 REVIEW AND EVALUATION RESPONSE JUSTIFICATION PAGE 6 OF 14 ACTION UNDER REVIEW: Changes Made to UFSAR REVISION: 4 PCN: N/A Section 9B PROCEDURE/PCP/TEMP MOD. NO.: N/A c ~ Fire Area XII Deviation 7: Although the original Safe Shutdown Analysis took credit for the floor separating the Fire Zones 72 and 74A, the non-rated hatch was not specifically evaluated in a deviation request. This deviation is being added to address the non rated hatch. This deviation is acceptable for the following reasons:

Nar8: The non-rated hatch is covered by a 1/2"

~gg Svn<cr~~u ~5 Few S~&~mo~ OZ thick steel plate reinforced with Se~o~.u structural T sections. The plate

~Poede77 /> overlaps the opening by approximately 6" 5jg~M ~IMi A(~v- 5'v,p~ ~ &~~

AprE~Dix R B~~~~~4-all around and is fastened down'.with 1/2" Bolts at 6 inch centers.

A 4" high curb surrounds the opening.

g-io - gZ Fire Zone 72 has smoke detection and an automatic preaction sprinkler syst: em.

fire Zone 74A has smoke detection and an automatic preaction sprinkler system.

The total combustible fire loading in both zones is low.

Fire Area XV Deviation 8: This is correct for Train A/B separation issues however with the addition of N Train components the deviation requires clarification.

Deviation 8 credits varying separation distances in which neither A nor B trains are located. The N train components do no meet these separation distances. However, for all fire zones, except 52A and 52D, the N train components which do not meet the deviation separation criteria are located on both sides of the "separation boundary". In fire zones 52A and 52D the following components subject to fire damage are located in the area

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10CFR50.59 REVIEW AND EVALUATION RESPONSE JUSTIFICATION PAGE 7 OF 14 ACTION UNDER REVIEW: Changes Made to UFSAR REVISION: 4 PCN: N/A Section 9B PROCEDURE/PCP/TEMP MOD. NO.: N/A which is identified as "not containing safe shutdown components".

J-CHE-HV53 2 J-CHE-FV241 243, J-CHN-UV231P J-CHE-PDV240 J-CHE-UV527 J-CHE-HV536 J-CHE-HV239 The compliance strategies for these components do not credit redundant components on the other side of the separation boundary. Therefore, from a systems standpoint this deviation can be revised.

The fire protection systems and other physical plant characteristics in the deviation remain the same.

e. Fire Area XV Deviation 2: This deviation was revised to include the non-rated features in the B

'nd E .Charging pump rooms. The original deviation only credited the A/B train separation. Since the Reconstitution effort added the E Charging pump to the Safe Shutdown list the deviation was revised to discuss the HVAC duct wall penetrations not provided with fire dampers. The justification for the deviation remains the same as the existing deviation.

A bounding analysis for the Control Room fire scenario was conducted during the Appendix R reconstitution. The results of the analysis indicated that the process variables may not stay within those predicted for a loss of normal ac and the potential exists for overfilling the steam generator Control if Room an MSIS is not initiated in the prior to evacuation.

The justification for these deviations is as follows:

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10CFR50.59 REVIEW AND EVALUATION RESPONSE JUSTIFICATION PAGE 8 OF 14 ACTION UNDER REVIEW: Changes Made to UFSAR REVISION: 4 PCN: N/A Section 9B PROCEDURE/PCP/TEMP MOD. NO.: N/A Additional Action in the Control Room:

~ The action in the control room prevents very unlikely series of. events, which includes spurious actuation and the failure of specific automatic functions (ESFAS) in accordance with the guidance of Generic Letter 86-10 Questions 3.8.4 and 5.3.10.

The action is taken on the same board (B05) within the control room as the Reactor trip action, and

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The Control Room action is immediately followed-up by an action in the DC Equipment Room which will isolate main steam regardless of the circuit damage in the Control Room.

Parameters Outside those expected for a normal loss of ac:

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The process variables are restored, and

~ The plant is not placed in an unrecoverable condition.

8. A new section containing miscellaneous fire zones containing safe shutdown components 8nd/or cables was added. The previous section containing miscellaneous fire zones remains but now contains only those miscellaneous zones without safe shutdown equipment.

Chan es Resultin from Remodel of 140 ft Auxiliar Buildin 1~ Fire Zone 57I was deleted. This area was incorporated into Fire Zone 57J. The boundaries of Fire Zone 57N were changed. The deletion of Zone 57I and changes in Fire 57N

,resulted in changes to the descriptions of Fire Zones 50B, 51B, 52D, 53, 54, 56B and 57L which border the deleted zone

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10CFR50.59 REVIEW AND EVALUATION RESPONSE JUSTIFICATION PAGE 9 OF 14 ACTION UNDER REVIEW: Changes Made to UFSAR .REVISION: 4 PCN: N/A Section 9B PROCEDURE/PCP/TEMP MOD. NO.: N/A

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57I and revised zone 57N:

2 ~ The access description of Fire Zone 57A and 57K were changed as the result of a door being added between them.

3 ~ The title of to Table 9B.3-1 Fire Zone 57H was changed as a and.changes result of the function of the were made room changing.

10CRF50.59 Screen and Evaluation The following provides the justification for the answers to questions 1 through 11 for both the FHA reconstitution and the remodeling done on the 140 foot of the Auxiliary Building.

Question Justification Yes. Changes have been made to the description of the facility contained in UFSAR Section 9B as a result of the safe shutdown re-evaluation and as a result of the remodeling done to the 140 foot elevation of the Auxiliary Building under DCP 1j2g3 FA ZA 142 Changes made

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to UFSAR Section 9B as a result of the safe shutdown re-evaluation and as a result of the remodeling done to the 140 foot elevation of the Auxiliary Building under DCP 1,2,3-FA-ZA-142 do not affect procedures as described in the UFSAR.

No. The changes made to UFSAR Section 9B as the result of the safe shutdown re-evaluation or as a result of the remodeling done to the 140 foot elevation of the Auxiliary Building under DCP 1,2,3-FA-ZA-142 do not involve test or experiments.

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10CFR50.59 REVIEW AND EVALUATION RESPONSE JUSTIFICATION PAGE 10 Of 14 ACTION UNDER REVIEW: Changes Made to UFSAR REVISION: 4 PCN: N/A Section 9B PROCEDURE/PCP/TEMP MODE NO ~ : N/A QUESTION JUSTIFICATION No. The changes made to UFSAR Section 9B as the result of the safe shutdown re-evaluation or as a result of the remodeling done to. the 140 foot elevation of the Auxiliary Building do not require a change to the Technical Specifications. Fire Protection has been removed from the Technical Specifications.

No. The changes to UFSAR Section 9B as a result of the safe shutdown re-evaluation or as a result of the remodeling done on the 140 foot elevation of the Auxiliary Building do not increase the probability of an accident previously evaluated.

The Appendix R Safe Shutdown Analysis Reconstitution verified that, for a fire in any given analysis area, the plant can be safely shutdown. Except as identified in corrective action documents (CRDRs), no changes have been made to the plant. The clarifications. to existing deviations and the new deviations are acceptable as discussed above.

The remodeling of the 140 foot elevation does not affect safe shutdown related conduit (Train A only) above the finished ceiling. There is no increased exposure to these conduits because the combustible loading has not changed significantly and the area is still protected below the finished ceiling by an automatic wet. pipe sprinkler system.

There is no adverse effect on plant safety as previously evaluated in the UFSAR as a result of these changes.

6 No. The changes to UFSAR Section 9B as a result of the safe shutdown re-evaluation or as a result

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QUESTION ZUSTIFICATION of the remodeling done on the 140 foot elevation of the Auxiliary Building do not increase the consequence of an accident previously evaluated.

The Appendix R Safe Shutdown Analysis Reconstitution verified that, for a fire in any given analysis area, the plant can be safely shutdown. Except as identified in corrective action documents (CRDRs), no changes have been made to the plant. The clarifications to existing deviations and the new deviations are acceptable as discussed above.

The remodeling of the 140 foot elevation does not affect safe shutdown related conduit (Train A only) above the finished ceiling. There is no increased exposure to these conduits because the combustible loading has not changed significantly and the area is protected below still the finished ceiling by an automatic wet pipe sprinkler system. There is no adverse effect on plant safety as previously evaluated in the UFSAR as a result of these changes.

No. The changes to UFSAR Section 9B as a result of the safe shutdown re-evaluation or as a result of the remodeling done on the 140 foot elevation of the Auxiliary Building do not increase the probability of a malfunction of equipment important to safety previously evaluated.

The Appendix R Safe Shutdown Analysis Reconstitution verified that, for a fire in any given analysis area, the plant can be safely shutdown. Except as identified in corrective action documents (CRDRs), no changes have been

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10CFR50.59 REVIEW AND EVALUATION RESPONSE ZUSTIFICATION PAGE 12 Of 14 ACTION UNDER REVIEW: Changes Made to UFSAR REVISION: 4 PCN: N/A Section 9B PROCEDURE/PCP/TEMP MOD. NO.: N/A r

QUESTION JUSTIFICATION made to the plant. The clarifications to existing deviations and the new deviations are acceptable as discussed above.

The remodeling of the 140 foot elevation does not affect safe shutdown related conduit (Train A only) above the finished ceiling. There is no increased exposure to these conduits because the combustible loading has not changed significantly and the area is still protected below the finished ceiling by an automatic wet pipe sprinkler system.

There is no adverse effect on plant safety as previously evaluated in the UFSAR as a result of these changes.

No. The changes to UFSAR Section 9B as a result of the safe shutdown re-evaluation or as a result of the remodeling done on the 140 foot elevation of the Auxiliary Building do not increase the consequences of a malfunction of equipment important to safety previously evaluated.

The Appendix R Safe Shutdown Analysis Reconstitution verified that, for a fire in any given analysis area, the plant can be safely shutdown. Except as identified in corrective action documents (CRDRs), no changes have been made to the plant. The clarifications to existing deviations and the new deviations're acceptable as discussed above.

The remodeling of the 140 foot elevation does not affect safe shutdown related conduit "(Train A only) above the finished ceiling. There is no increased exposure to these conduits b'ecause the combustible loading has not changed significantly and the area is still protected below the finished

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10CFR50.59 REVIEW AND EVALUATION RESPONSE JUSTIFICATION PAGE 13 Of 14 ACTION UNDER REVIEW: Changes Made to UFSAR REVISION: 4 PCN: N/A Section 9B PROCEDURE/PCP/TEMP MOD. NO.: H/A QUESTION JUSTIFICATION ceiling by an automatic wet pipe sprinkler system.

There is no adverse effect on plant safety as previously evaluated in the UFSAR as a result of these changes.

No. The changes to UFSAR Section 9B as a result of the safe shutdown re-evaluation or as a result of the remodeling done on the 140 foot elevation of the Auxiliary Building do not increase the possibility of an accident of a different type than previously evaluated.

The Appendix R Safe Shutdown Analysis verified that, for a fire in any

'econstitution given analysis area, the plant can be safely shutdown. Except as identified in corrective action documents (CRDRs), no changes have been made to the plant. The clarifications to existing deviations and the new deviations are acceptable as discussed above.

The remodeling of the 140 foot elevation does not affect safe shutdown related conduit (Train A only) above the finished ceiling. There is no increased exposure to these conduits because the combustible (fire) loading has not changed significantly and the area is still protected below the finished ceiling by an 'automatic wet pipe sprinkler system. An HVAC duct is added in the area of safe shutdown conduit (Train A auxiliary feedwater). This duct is supported for seismic category IX so there will be no new unanalyzed adverse impact on plant safety as a result of this change.

10 No. The changes to UFSAR Section 9B as a result of the safe shutdown re-evaluation or as a result

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10CFR50.59 REVIEW AND EVALUATION RESPONSE JUSTIFICATION PAGE 14 Of 14 ACTION UNDER REVIEW: Changes Made to UFSAR REVISION: 4 PCN: N/A Section 9B PROCEDURE/PCP/TEMP MOD. NO.: N/A QUESTION JUSTIFICATION of the remodeliug done on the 140 foot elevation of the Auxiliary Building do not increase the possibility of a malfunction of equipment important to safety of a different type than previously evaluated.

The Appendix R Safe Shutdown Analysis Reconstitution verified that, for a fire in any given analysis area, the plant can be safely shutdown. Except as identified in corrective action documents (CRDRs), no changes have .been made to the plant. The clarifications to existing deviations and the new deviations are acceptable as discussed above.

The remodeling of the 140 foot elevation does not affect safe shutdown related conduit (Train A only) above the finished ceiling. There is no increased exposure to these conduits because the combustible loading has not changed significantly and the area is still protected below the finished ceiling by an automatic wet pipe sprinkler system. An HVAC duct is added in the area of safe shutdown conduit (Train A auxiliary feedwater). This duct is supported for seismic category IX so there will be no new unanalyzed adverse impact on plant safety as a result of this change.

No. The Fire protection is not addressed in the technical specifications. No margins of safety reduced by these changes. There is reasonable

're assurance that at least one train of equipment necessary to achieve and maintain hot or cold shutdown will continue to be free of fire damage.

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