ML18040B233
| ML18040B233 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 11/22/1988 |
| From: | Keiser H PENNSYLVANIA POWER & LIGHT CO. |
| To: | Butler W Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML17156A950 | List: |
| References | |
| PLA-3117, NUDOCS 8812120172 | |
| Download: ML18040B233 (56) | |
Text
ACCELERATED 'DISTRlRUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:8812120172 DOC.DATE: 88/11/22 NOTARIZED: NO DOCKET, g FACIL:50-387 Susquehanna Steam Electric Station, Unit 1, Pennsylva 50-388 Susquehanna Steam Electric Station, Unit 2, Pennsylva 05000387'5000388' AUTH. NAME AUTHOR AFFILIATION KEISER,H.W. Pennsylvania Power & Light Co.
RECIP.NAME RECIPIENT AFFILIATION R BUTLER,W.R. Project Directorate I-2 I"
SUBJECT:
Forwards listed addi info re plant fire protection review tg/"
rept. D DISTRIBUTION CODE: A006D COPIES RECEIVED:LTR I ENCL L SIZE: 86 TITLE: OR/Licensing Submittal: Fire Protection NOTES:LPDR 1 cy Transcripts. 05000387/j LPDR 1 cy Transcripts...J,.=
05000388'ECIPIENT COPIES RECIPIENT COPIES D ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD1-2 LA 1 0 PD1-2 PD 5 5 THADANI,M 1 1 INTERNAL: ACRS 3 3 ARM/DAF/LFMB 1 0 NRR WERMEIL,J 1 0 NRR/DEST/ADS 7E 1 1 NRR/DEST/PSB 8D 1 1 -ABSTRACT 1 1 OGC/HDS2 1 0 EG 'Fl 01 1 1 EXTERNAL: LPDR 1 1 NRC PDR 1 1 NSIC 1 1 NOTES 2 2 R
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NOTE TO ALL "RIDS" RECIPIEÃIS:
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~E ROOM HELP US TO EKHJCE WASTE.'XÃI'ACZ 'THE DOCUMENT OONTROL DESK, P1-37 (EXT. 20079) TO ELIKBQXE YOUR NAME FMM DISTKH3UTION LISTS POR DOCUMERZS YOU DON'T NEEDf TOTAL NUMBER OF COPIES REQUIRED: LTTR 22 ENCL 18
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~egg, Pennsylvania Power 8 Light Company Two North Ninth Street ~ Allentown, PA 18101-1179 ~ 215/770-5151 Harold W. Keiser Senior Vice President-Nuclear 215i770-4194 NOV 22 688 Director of Nuclear Reactor Regulation Attn: Dr. W. R. Butler, Project Director Project Directorate I-2 Division of Reactor Projects Mail Station Pl-137 U.S. Nuclear Regulatory Commission Washington DC 20555 SUSQUEHANNA STEAM ELECTRIC STATION RESPONSE TO QUESTION ON REV 3 TO THE SUSQUEHANNA SES FIRE PROTECTION REVIEW REPORT PLA-3117 Docket Nos. 50-387 FILES R41-2, 8013, PS-1, A17-15 and 50-388
Dear Dr. Butler:
Your staff has requested additional information for their review of the Susquehanna SES Fire Protection Review Report. Enclosed is the following:
- 1) A copy of the procedure E0-100-009, Plant Shutdown from Outside Control Room. The steps addressing loss of suppression pool temperature indication and actuation of suppression pool cooling.
This item addresses your questions regarding Deviation Request No. 2.
- 2) A copy of the proposed revision to Deviation Request No. 7, Fire Spread Limitations.
- 3) A color coded copy of drawing identifying fire areas/zones covered by Deviation Request No. 14.
- 4) A copy of the proposed revision to Table 7.2 of the Fire Protection Review Report. The proposed revision provides delineation of the requirements from which deviations are being taken.
At the request of the staff, we have reviewed the applicability of Deviation Request No. 34. After consideration, this deviation request is withdrawn.
With respect to multiple high impedance faults, Susquehanna does not have specific procedures for restoration of faults. We believe our method of restoring systems and operator training is adequate to address this issue.
Systems are restored under the direction of the shift supervisor.
8812120172 881122 PDR ADOCK,05000387 r F PDC
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PLA-3117 Dr. W. R. Butler Also enclosed is a set of revised Fire Protection Review Report Pages. This package includes pages originally omitted from the original submittal and revisions resulting from the modification process as follows:
o Section 3.1.1.1 was revised to indicate that reactor vessel makeup is part of Paths 1 6 3.
o Section 4.5 was revised to properly depict the availability of remote manual activation capability from the control room of the deluge systems in the HPCI and RCIC pump rooms. The deluge systems in the HPCI and RCIC pump rooms are being modified so that they cannot be manually activated from the control room.
o Section 5.0, Table 5.0-1, items A-5, E.3(a) and F.l(a) have been revised to provide additional information on the design of fire protection systems with respect to damage to safety related equipment in the event of failure or inadvertent operation.
o Section 6.0 pagination was corrected.
o Fire Zone 1-7B, previously designated as a buffer zone in Subsection 6.2.1.2 has been redesignated as a zone not serving as a buffer zone.
o Section 7.1, Table 7.1-1 has been revised to properly reflect (1) the commitment for fire proofing of structural steel in the 125V and 250V Battery Rooms. (See Deviation Request No. 6) (2) the deletion of Deviation Request No. 34 o Table 7.2, Deviation Request Index was revised as follows:
(1) A listing of xequirements deviated from was added.
(2) Deviation Request No. 34 was withdrawn.
Attachments 1 through 5 of Deviation Request No. 3 were inadvertently omitted from the original report and, included in f
this submittal.
II Deviation Request No. 6 has been revised to include structural steel beams above the 125V and 250V Battery Rooms. Analysis has demonstrated that there are not enough combustibles in these rooms to jeopardize the integrity of the steel beams located therein.'
The tables in Deviation Request No. 6 have been renumbered.
o Deviation Request No.7, Fire Spread Limitations, was rewritten.
o Attachment 1 to Deviation Request No. 11 was inadvertently omitted from the original report and is included in this submittal.
o Fire Zone 2-1I was deleted from Deviation Request No. 14 since fire detection does exist in this zone. Deviation Request No. 14 also underwent other administrative changes to correct typographical errors and to add clarity.
0 I p) ~ v tf pI P
PLA-3117 Dr. W. R. Butler o Deviation Request No. 24 has been revised to clarify wrapping requirements for raceways. Additionally, two figures omitted from the original submittal are included.
o Deviation Request Nos. 27 and 28 have been revised to add the terminal boxes to components of instrument racks 1C004, 1C005, 2C004, and 2C005.
o Figure C-213432, Sheet No. 1 of Deviation Request No. 29, was added to the report. This sheet was inadvertently left out of the original document.
o Typographical errors in Deviation Request No. 30, Page DR30-8 were corrected.
o Deviation Request No. 34 has been withdrawn.
Very truly yours, H. W. Keiser Attachment(s)
NRC Region I Mr. F. I. Young NRC Sr. Resident Inspector Mr. M. C. Thadani NRC Project Manager
H I'
SSES-FPRR The support functions either remove heat or supply power to the process system functions of reactivity control, reactor coolant makeup, reactor depressurization, and heat removal.
The support system for reactor heat removal is RHR,Service Water which removes heat fiom the suppression pool in the suppression pool cooling mode and from the reactor loop through the heat exchanger in shutdown cooling. Cooling for equipment is provided by the emergency service water system through the appropriate room coolers in the Reactor Building., Control Structure HVAC is utilized to cool the Control Structure. Power is supplied by the diesel generators and the batteries to the various components with the AC and DC distribution system modifying voltages as appropriate and distributing the power.
The Nuclear Boiler Instrumentation is provided so that the reactor will SCRAM on either high reactor pressure or on low, water level. The high pressure scram is provided to protect the RPV on high pressure and to maintain the suppression pool temperature within acceptable limits. The low water level SCRAM is provided to ensure that the fuel maintains its integrity.
gg> jae4 /a 43.
In addition, automatic reactor vessel makeup on low level is required of the makeup system Water level instrumentation provides the ADS/Core Spray initiation. Pressure instrumentation is required to permit, core spray initiation at lower pressure.
Flow diversion has the potential to prevent safe shutdown by diverting flow from a safe shutdown system or causing a loss of coolant from the RPV. The RPV and all safe shutdown systems were reviewed for potential flow diversion paths. High/Low pressure interfaces were analyzed and spurious openings of the SRVs were considered.
Flow diversion paths were'etermined by reviewing all penetrations of the reactor pressure vessel and all safe shutdown system flow paths and identifying all lines too small to allow a significant flow diversion. All lines that would permit a significant flow diversion were then traced to a point where a determination of flow diversion could be made. This point was always a check valve, a normally closed manual valve, or an actuated valve. It was assumed that check valves function properly and prevent flow diversion and that normally closed manual valves would be in the correct position to prevent flow diversion. Actuated valves were evaluat'ed and dispositioned by one of the methods discussed in Subsections 3.3.1.3 and 3.3.1.5.
For use of each unit's remote shutdown panel. (Alternative Shutdown Path) the following assumptions were made:
The reactor is scrammed in the control room prior to control room evacuation..
Rev. 3, 6/88 3 ~ 3 3
SSES-FPRR 4.5 DELUGE SYSTEHS Deluge systems provide fire suppression capability for various areas.
Deluge systems are automatic open-head water spray systems using heat detectors to open the deluge valve. The individual systems may be manually activated ej,ther locallv, or from, the control room gpirh yhe except% Ot the ~5gC~ H~ and'~c. DOWED Coom5
~hag ~g~t M cv +ivated born We C'on~a( 8o~.
The heat detectors, which control the deluge valves, will open when temperatures in the protected area rise at an abnormally high rate or reach a fixed temperature. Heat'etector actuation is indicated on a local panel and annunciated on the control room panel. Deluge systems are reset by closing the OSSY gate valve, draining the system, resetting the deluge valve and reopening the OSSY valve.
f=PRR r- oooo SSES-FPRR Page 3 of 51 TABLE 5.0-1 (Continued)
BRANCH TECHNICAL POSITION GUIDELINE SUS UEHANNA SES CONPLIANCE considered concurrent with other'lant accidents or Two 100'apacity pumps (one electric and one diesel driven) the most severe natural phenomena. are provided, each capable of supplying the design flow rate at design pressure. By use of sectional control valves and The effects of lightning strikes should be included cross-connecting, damaged fire yard mains can be isolated.
in the overall plant Fire Protection Program. Separate supplies are provided for sprinkler and standpipe/hose reel stations.
Protection from lightning strikes is a part of the Susquehanna SES design.
- 5. Fire Su ression S stems Failure or inadvertent operation of the fire e~s pa~~usquehann~~omplianca suppression system should not incapacitate safety-related systems or components. Fire vQ4MGF45 o44on-6 ~4 suppression systems that are pressurized during normal plant operation should meet the guidelines specified in APCSB Branch Technical Position 3-1, "Protection Against Postulated Piping Failures in Fluid Systems Outside Containment."
- 6. Fuel Store e Areas The Fire Protection Program (plans, personnel, and The Fire Protection Program at Susquehanna SES was in equipment) for buildings storing new reactor fuel operation prior to fuel being received on site.
and for ad)acent fire zones which could affect the fuel storage zone should be fully operational before fuel is received at the site.
The Fire Protection Program for an entire reactor The Fire Protection Program at Susquehanna SES was in unit should be fully operational prior to initial operation prior to fuel loading.
fuel loading in that reactor unit.
'k ~ I-P4g ic'ooo9 SSES-FPRR Page 31 of 51 TABLE 5.0-1 (Continued)
BRANCH TECHNICAL POSITION GUIDELINE SUS UEHANNA SES COMPLIANCE
- 3. Water S rinklers and Hose Stand ie S stems (a) Each automatic sprinkler system and manual Sprinkler systems and manual hose station standpipes are hose station standpipe should have an connected to the plant underground water main separately so independent connection to the plant that no single active failure or crack in a moderate-energy underground water main. Headers fed from each line can impair both the primary and backup fire suppression end are permitted insilie buildings tu supply systems. Hose, standpipe, and automatic water suppression multiple sprinkler and:pgandpipe systems. systems serving a single fire area have independent When provided, such head'ers are considered an connections to the yard main system.
extension of the yard main system. The header arrangement should be such that no single Headers fed from each end are not used at Susquehanna SES.
failure can impair both the primary and backup fire protection systems. The effect of fire protection on safe shutdown equipment is addressed as part of the Susquehanna SES compliance with Each sprinkler and standpipe system should be 10CFR50, Appendix R, as discussed in this report.
equipped with OS&Y (outside screw and yoke) gate valve, or other approved shut-off valve, All sprinkler systems in safety-related buildings are and water flow alarm. Safety-related equipped with an approved shutoff valve and a water flow equipment that does not itself require alarm. All standpipes in safety-related buildings are sprinkler water fire protection but is subject equipped with approved shutoff valves.
to unacceptable damage if wetted by sprinkler water discharge should be protected by water l u SERT shields or baffles.
(b) All valves in the fire water systems should be All major fire protection control valves are provided with a electrically supervised. The electrical electrical supervision or locked in the open position with supervision signal should indicate in the the exception of normally closed valve.
control room and other appropriate command locations in the plant. (See NFPA.26, "Supervision of Valves.")
When electrical supervision of fire protection valves is not practicable, an adequate management supervision program should be provided. Such a program should include locking valves open with strict key control, tamper proof seals, and periodic, visual check of all valves.
FPgR oooo The following safety related areas are provided with sprinkler protection:
HPCI Pump Room RCIC Pump Room Diesel Generator Building Lower Cable Spreading Room Upper Cable Spreading Room
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Fire Zone 1-2b and 2-ub Fire Zone 1-3a Fire Zone 1-4a an J.
1>3b >.2,-3g ash. 2-3I Fire Zone 1-5a c nb. 2-Ga p(gz zaire o- 2'lB p(gg ZohlC 0 3OR The HPCI Pump and the RCIC Pump are protected by separate open head deluge systems designed to suppress a fire. Only one division of equipment is located in each'oom. The remainder of the areas listed above are protected by, preaction sprinkler systems, which require both a detection system and a fusible link activation to spray water, and then only the fusible links in the area of the fire would be activated.
<<NR F'ooap SSES-FPRR Page 36 of 51 TABLE 5.0-1 (Continued)
BRANCH TECHNICAL POSITION GUIDELINE. SUS UEHANNA SES COMPLIANCE Because of the general inaccessibility of these areas during normal plant operations, protection should be provided by automatic fixed systems. Automatic sprinklers .should be installed for those hazards identified as requiring fixed suppression.
t Fire suppression systems"Fshould be provided based on the fire hazards analysis.
Fixed fire suppression capability should be provided for hazards that could )eopardize safe plant shutdown. Automatic sprinklers are preferred. An acceptable alternate is automatic gas (Halon or CO2) for hazards identified as requiring fixed suppression protection.
Operation of the fire protection systems +o f e~ E. 5 <i 5ee ~e ggqpg~ ge ~
s should not compromise integrity of the containment or the other safety-related [q gD systems. Fire protection activities in the containment areas should function in con)unction with total containment requirements such as control of contaminated liquid and gaseous release and ventilation.
An enclosure may be required to confine the agent if a gas system is used. Such enclosures should not adversely affect safe shutdown or other operating equipment is containment.
Fire detection systems should alarm and annunciate in the control room. The type of detection'used and'he location of the detectors should be most suitable to the
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>o PP<3 DEVIATION REQUEST gP. 3 SUSQUEHANNA STEAM ELECTRIC STATION - UNITS I 5 2 FIRE PROTECTION PROGRAM - CONCERN Al DOCKETS NO. 50-387 50-388 APPENDIX A - DEVIATION REQUESTS DEVIATION REQUEST NO. 3 ATTACHMENT 5
/22/88...88l2g2P172
SSES-FPRR 6.0 FIRE HAZARDS ANALYSIS
6.1 INTRODUCTION
6.1.1 Pur ose The purpose of this section is to demonstrate that a postulated fire anywhere at the plant will not affect the ability of both units to be brought and to be maintained in cold shutdown condition. Section 6.1 describes the general fire protection features used in the fire hazards analysis of each fire area.
This discussion serves as an overview to the detailed fire area analysis in Section 6.2. Section 6.2 examines each fire area within the plant and assesses the capability to safely shutdown based on the fire area aonfiguration, combustible loading, specific fire hazards, safe shutdown equipment in each dire zone within the fire area and the deviation requests which directly impact that fire gaea.
Table 6.1-1 lists each fire area in the plant and provides a description of each area, the required safe shutdown path for each area, the FPRR section where its fire hazards analysis is presented and a'=list of all the fire zones in each fire area.
6.1.2 Fire Protecdion Features r~
Our safe shutdown criteria is based, on the premise that a fire initiated within any given 'fire area will be contained within that fire area and not damage safe shutdown equipment in any other fire area. Furthermore, as presented in Deviation Request No. 7, a fire initiated in any given fire zone is postulated to spread to each adjacent fire zone which is not separated from the fire zone of origin by fire rated construction. In this manner, safe shutdown components and cables in unaffected fire areas and fire zones will be used to safely shutdown both reactors.
As discussed in Section 3.3.4, the plant was divided into specific fire areas with each fire area consisting of one or more fire zones. Fire areas were selected to optimally separate the safe shutdown components and cables in each redundant division.
This selection*,process was used. to divisionally separate those systems and coriiponents in each redundant division required for safe shutdown as identified in Table 3.1>>1.
6.1.2.1 Establishin Fire Areas-Boundaries In accordance with NRC guidelines, the term "fire area" as used in Appendix R is an area sufficiently bounded to withstand the h'azards associated with the area and, as necessary, to protect important equipment within the area from a fire outside the area.
At Susquehanna SES, a fire area is separated from all other fire Rev. 3, 6/88 6.l-g'
SSES-FPRR areas in the plant by- fire-rated construction or spatial separation. The fire rating of the fire-rated construction is designed to withstand the fire load of the fire area or arly specific combustible configuration within the fire area. Where relied upon, spatial separation between two fire areas precludes the propagation of the postulated fire from one fire area to another.
In order to determine the adequacy of the fire rating of the fire area boundaries, the physical fire area boundaries (i.e., walls and floors/ceilings) were evaluated. The majority of these barriers consist of 12" minimum thick reinforced concrete.
Fire-rated gypsum board has also been used for wall construction in some areas. Structural steel and openings in these barriers have been provided with fire rated components or have been justified by deviation requests. Spatial separation has been used as a fire area boundary where sufficient physical distance, 'lack of intervening combustibles and/or fire protection features exist to adequately separate the redundant safe shutdown equipment of two different areas. At Susquehanna SES two distinct methods of spatial separation were used; the wraparound 'zone and the buffer zone. A brief description of both concepts is provided here.
The wraparound zone exists at. three elevations in each Reactor Building. These are areas of the plant which are corridors that connect Pire Areas R-lA with R-13 (Unit 1) and R-2A with R-2B (Unit 2). The construction of a fire-rated wall is impractical d t th plant configuration in these areas. The wraparound zone was initially a spatial separation of 50 ft. between t h e two communicating fire areas. Due to field conduit routing tolerances of +8 ft., the wraparound zone was expanded 8 ft. on each side to account for cabling designed to be in the 50 foot area. Hen ce the wraparound zone became a 66 foot wide area.
Within the wraparound zone, both redundant divisions of requ ired safe shutdown cables are either protected by fire protective wrapping or justified by a fire hazards analysis. Safe shutdown components within the wraparound zone have been analyzed and are addressed in deviation xequests. The fire hazards and combustible configuration of each wraparound area was examined'o determine the acceptability of the zone as a spatial separation barrier. A fire initiated in either of the two fire areas connected by the wraparound zone will not propagate through the wraparound zone and into the adjacent fixe-free area.
Additionally, a fire initiated within the wraparound zone will not. propagate to both adjacent fire areas. Our long-term comp liance program prohibits the. location of any safe shutdown components within the wraparound zone unless a spe cific evaluation is conducted. The wraparound zone concept is presented in more detail in Deviation Request No. 4.
Rev. 3, 6/88 6. 1-8 Z.
SSES-FPRR The buffer zone concept is used in the upper elevations of both Reactor Buildings where little or no safe shutdown equipment exists. Using the buffer zone concept, fire areas are separated by two intervening fire zones (buffer zones). Within these buffer zones, both redundant divisions of safe shutdown components and cables are required to be protected or justified by analysis. The combustible loading of the buffer zones is low and there is no specific combustible configurations which would act to propagate a fire between fire areas. Deviation Request No. 7 discusses the buffer zone concept in more detail.
6.1.2.2 Combustible Loadin A fire zone specific combustible loading analysis has been performed. This analysis identifies all combustible items within each fire zone and assigns each one a conservative heat load value. All of this heat load is summarized and divided by 'the area of the fire zone to yield an equivalent fire duration in minutes. This theoretical value is the time it would take for all the combustibles to be consumed by a fire in that fire zone assuming that -the combustibles are evenly dispersed throughout the zone.
Zn our combustible loading analysis, types of combustibles were grouped into four major categories: 1) mechanical items (i.e.
lube oil in pumps or valves, charcoal, etc.), 2) cables in unwrapped cable tray, 3) electrical panels and cabinets and 4) miscellaneous items.
Under the mechanical items category, the equipment name and number is listed and the quantity of combustibles is given for each piece of equipment in either gallons of lube oil, diesel fuel oil or pounds of charcoal. Gallons of lube oil or diesel fuel oil is multiplied by 148,875 BTUs/gallon and charcoal quantity is multiplied by 14,730 BTUs/pound to establish the combustible content for each mechanical item. The combustible contents for all mechanical items are then added for the subtotal for each fire zone.
For cable trays, the combustible loading for the cable insulation in each fire zone was compiled. The heat released value per sq.
ft. was determined for each tray ofdepth and all trays were considered to have maximum fill 30% cable. The combustible loading for each cable 'tray was obtained by multiplying the heat release content of the cables (BTUs/sq. ft) by the surface area (sq. ft.) of the cable tray. For a 6" deep, 30% filled tray, the heat release value is 80,560 BTUs/sq ft and for a 4" deep, 30%
BTUs/sq. ft. This filled tray, the heat release value is 48,710 of cable tray within value was then multiplied by the linear feet the zone. Zn accordance with NRC guidelines cables in metal conduits do not constitute combustibles and therefore, are not included in this analysis.
Rev. 3, 6/88 6. 1-A'
SSES-FPRR Electrical panels and cabinets were listed by name and number.
All cabinets were grouped according to size or type. The combustibles in each cabinet, were conservatively estimated assuming that each cabinet. was full of the maximum amount of combustible materials which that type of cabinet could contain.
Thi's part of the analysis was considered very conservative since most cabinets actually contain less combustibles than the worst case. cabinet types. The combustible content for all electrical cabinets was subtotaled for each fire zone.
In the miscellaneous item category, the combustible content for each combustible was established utilizing information from the National Fire Protection Association - Fire Protection Handbook, 16th Edith. on. Typical examples of these miscellaneous items are poly-propylene battery cases (19,970 BTUs/pound), protective clothing (7,)50 BTUs/pound) and hydrogen (61,064 BTU's/pound or 325 BTU's/ft ) . All miscellaneous items were'ubtotaled for each fire zone.
Our analysis adds the subtotals of the four categories of
'combustibles for each fire zone giving the total combustibles in BTUs. This value is divided by the fire zone floor area to yield the fire zone fire load in BTUs/sq. ft. The equivalent fire duration in minutes is then calculated based on a value of 80,00(,
BTUs/sq l
ft for a fire of 60 minutes duration.
Although this classical approach is relied upon for a quantitative assessment of the fire severity in a given zone, can be somewhat misleading due to the size of the zone and the it
'n location and configuration of the combustibles within the zone.
lieu of solely relying upon this method of fire loading severity, the specific combustible configurations within a zone or area and the heat release rate of those combustibles provide a more" realistic determination of the fire hazards in the zone.
The purpose of the combustible loading analysis is to assure that the fire area boundaries are adequate to contain a fire w'ithin that fire area. Our combustible loading program at Susquehanna assures the integrity of our fire barriers and the compliance to deviation requests which rely on this information.
Therefore, rather than expressing specific combustible numbers for each fire area discussed in Section 6.2, each fire area discussion outlines any severe combustible configurations in the area and shows that fire barriers of the area are able to contain the fire hazards associated with the area.
Rev. 3, 6/88 6.l-g
SSES-FPRR 6.1.2.3 Fire Detection and Su ression Fire detection and suppression (manual and automatic) systems are an integral part of the plant design. The descriptions of the types of detection and suppression systems employed at Susquehanna SES are described in detail in Section 4.0. Each fire area discussion within this section includes information as to the extent and location of detection and suppression systems in that fire area.
The impact of the inadvertent operation or rupture of any fire suppression system in the plant has been evaluated and been determined that this condition would not affect the it has capability to achieve and maintain safe shutdown.
6.1.2.4 Conse uences Of A Fire In Each Fire Area Each fire area of the plant requires the 'availability of one of the safe shutdown paths as noted in Table 6.1-1. Our safe shutdown analysis and the specific supporting engineering studies evaluate and assure the availability, of the required safe shutdown path systems, components and raceway for each fire area.
In each fire area evaluated, the major safe shutdown components are listed by fire zone location. These components are broken, down into two categories. The first grouping are the safe shutdown components which are located in the fire zone but. which would not be relied upon for use in the event. of a fire in that fire zone. In other words, their redundant component is'ocated in a fire free fire area. The second grouping are the Category I components. As previously described, these .are components which are required for safe shutdown in the event of a fire in the fire zone where the component is located. All Category I components have been addressed by a deviation request, 'an engineering analysis or plant modification. Each Category I component is listed by component name and number with a reference todescription the Deviation Request in which it is addressed or a brief of the engineering analysis which justified its acceptability.
Cables required to perform a safe shutdown function have been evaluated per the methqdology described in Section 3.0. Cables designated as cable hits as described in Subsection 3.3.1.5 have been resolved by performing a plant modification (i.e. installing fire protective wrapping, cable relocation, circuit modification), a procedural action, an analysis which verified that fire-induced faults would not impact safe shutdown or by a deviation request. Each fire area description denotes which path of safe shutdown system cables has been protected in that fire area.
Rev. 3, 6/88
SSES-FPRR 6.1.2e5 S ecial Features In certain fire areas manual actions may be necessary to assure safe shutdown compliance to the Appendix R criteria. 'ach fire area description in Section 6.2 lists any specific manual actions required as the result of the Appendix R safe shutdown analysis.
This section of the report also provides a description of any other features which may be unique to that fire area.
6.1.2.6 Deviation Re uests Due to specific configurations within the plant, certain conditions do not strictly conform to the regulations set forth in Appendix R. NRC Generic Letter 86-10 states that the licensee must develop its own criteria for a deviation request threshold and that a request need not be filed for each and every possible deviation from Appendix R. The general philosophy employed at PP&L in this regard is to submit those generic and specific plant conditions which do not meet the requirements of Appendix R or ~
the intent of the Appendix R guidance documents.
In instances where it became difficult to determine the necessity of a deviation request, our general policy was to prepare and submit the request in order to clearly document, the fire protection features at Susquehanna SES.
The purpose of a deviation request is to identify non-conforming V
conditions and to provide justification to demonstrate that the
'ethods implemented at Susquehanna SES satisfy the intent- of a specific Appendix R requirement. Some deviation requests are very specific and apply to systems and/or components which do not comply with Appendix R.. Where these specific deviation requests affect a certain fire area, they are noted within the fire area discussion. The following deviationrequests are generic in nature and apply to virtually all plant fire areas:
Deviation Re uest No. Title Fire Spread Limitation 13 Redundant Raceway. Protection 20 Penetration Seals - Conduits 33 Reactor Coolant Makeup and Depressurization System Rev. 3, 6/88 6. 1-7
FpRp pooo7 SSES-FPRR 6.2 FIRE AREA DESCRIPTION Fire Area R-lA 6 2 1.]. General Descri tion pire Area R-1 A is located in the Unit 1 Reactor Building and is
+prised of fire zones which generally occupy the southern half
< <he building. This fire area is shown on Drawings E-205949 thru E 205956 in Section 8.0. -
Safe Shutdown Path 3 can be used achieve safe shutdown in the event of a fire 'in this fire area.
Fire Zones following fire zones are located in Fire Area R-lA:
Fire Zone Descri tion 1-1A Core Spray Pump Room 1-1F RHR Pump Room 1-1G Sump Room 1-2A Core Spray Pump Room 1-2C Railroad AirLock/Access Shaft 1-3A Heat Exchangek and Pump Room 1-3B-S Equipment Removal Area 1-3B-W* Equipment Removal Area 1-3C-S Equipment Access 1-3C-W* Equipment Access 1-4A-S Containment Access Area 1-4A-W* Containment Access Area 1-4E CRD Room 1-SA-S Standby Control Systems Area 1-5A-W* Access Corridor 1-5E Penetration Room 1-5H Instrument Repair Shop 1-6B** Load Center Room 1-6C** Electrical Equipment Room 6DQ* HVAC Equipment Room 1-6E HVAC Plenum Area
-6F** Spent Fuel Pool 1 7A** HVAC Equipment Area 1-7B Recirculation Fan Room P 6G** Surge Tank Vault P 6H** Cask Storage Pit 0-SA** Refueling Floor This fire zone is a wraparound area (see Deviation Request No. 4)
,<<~ This fire zone is a buffer zone (see Deviation Request No. 7)
- 6. 2-1
It
>PRIKQ FaoG4 Page 3 of 6 SSES-FPRR TABLE 7.1-1 (Continued)
CONTROL STRUCTURE FIRE AREAS DEVIATION REIEVEST. CS-Ol CS-02 CS-03 08-04 CS-05 CS-06 08-07 CS-08 CS-09 CS-l0 CS-ll 6 X X X X X X 7 X X X X X X X X X X X 8
9 10 ~
11 12 13 X X X X X X X X X X X 14 15 16 17 18 19 20 X X X X X X X X X X X 21 22 23 24 25 26 27 28 29 30 X 31 32 33 X X X -
X X X X X 36 37 X X
Page 4 of 6 SSES-FPRR TABLE 7.1-1 (Continued)
CONTROL STRUCTURE FIRE AREAS (Continued)
DEVIATION REIEUEST CS-12 08-13 08-14 CS-13 CS-16 08-17 CS-18 CS-19 CS-20 CS-21 CS-22 6 X X ~ X X
X X X
X.
X 5
X,X X y P.
7 X X X X X X 8 X X 9
10 ll 12 13 X X X X X X X X X X X 14 15 16 17 18 19 20 X X X X X X X X X X X 21 22 23 24 25 26 27 28 29 30 31 32 33 X X X X X X X X X X X 34 35 36
. 37
Page 5 of 6 SSES-FPRR TABLE 7.1-1 (Continued)
CONTROL STRUCTURE FIRE AREAS (Continued)
DEVIATION
~RE VEST CS-23 CS-24 CS-23 CS-26 CS-27 CS-2S CS-29 CS-30 CS-31 CS-32 CS-33 1
2 3
4 5
6 X )2" X
7 X X X X X X X X X X X 8 X 9
10 ll 12 13 X X X X X X X X X X X 14 15 16 17 X 18 19 20 X X X X X X X X X ' X 21 22 23 24 25 26 27 '8 29 30 31 32 33 34 35 36
~ 37
SSES-FPRR 7.2 DEVIATION REQUEST INDEX Deviation Appendix R Request Requirement No. ~sub 'ce Deviated From Battery Room Exhaust Fans Section III.J,L Suppression Pool Temperature Indication Section III.L Fire Doors-Non-Rated Section III.G.2 Wraparound Area Section III.G.2 Partial Rating of Walls and Floor/Ceiling Section III.G.2 Non Fireproofed Structural Steel Section III.G.2
'I Fire Spread Limitations Section III.G.2 One Hour Fire Barrier Wrap With Section III.G.2.a Limited Suppression Insufficient Spatial Separation Section III.G.2 of Switchgear Room Cooler Fans 10 Fire Area D-3 Boundaries Section III.G.2 HVAC Penetrations Reactor Building Section III.G.2 Fire Walls 12 Fire Barriers Without Fire DampersSection III.G.2 in Vertical Ventilation Duct Penetrations 13 Essential Redundant Raceway Section III.G.2.a,b,c Protection 14 Reactor Building Fire Zones Section III.G.2 Without. Fire Detection 15 Fire Areas Control Structure Section III.G.2c Without Fire Suppression 16 Emergency Switchgear Room Section ZII.G.2.b Cooling System Components Insufficient Spatial Separation Fire Zones '1-4A-S and 2-4A-S Rev. 3, 06/88 7 ~2 1
SSES-FPRR Deviation Appendix R Request Requirement No. ~Sub 'ect Deviated From 17 Kaowool System As An Acceptable Section III.G.2c 1-Hour Fire Barrier Wrap 18 This Deviation Request has been N/A withdrawn 19 Incomplete Fire Suppression and Section III.G.2 Fire Detection In Diesel Generator Fire Areas 20 Penetration Seals Conduits Section III.G.2 21 Control Structure Fire Zones Section III.G.2.
Without Fire Detection and/or Fire Suppression 22 This Deviation Request has been N/A
,withdrawn 23 Control Structure Fire Area CS-9 Section III.G.2 Partial Fire Suppression 24 Automatic Fire Suppression in Section III.G.2.b Fire Zone 2-5D 25 Automatic Fire Suppression and Section III.G.2.b Intervening Combustibles In Fire Zone 1-3A 26 Automatic Fire Suppression and Section III.G.2.b Intervening Combustibles in Fire Zone 2-3B-N 27 Nuclear Boiler Instrumentation In Section III.G.2.b Fire Zone 1-5A-S 28 Nuclear Boiler Instrumentation In Section III.G.2.b Fire Zone 2-5A-N 29 Category I Components in Section III.G.2.b Fire Zone 1-3C-W and 2-3C-W 30 Control Structure HVAC System Section III.G.2.b Components Fire Zones 0-29B and 0-30A 31 This Deviation Request has been N/A withdrawn Rev. 3, 06/88 7 '-2
SSES-FPRR Deviation Appendix R Request Requirement No. ~Sub 'ect Deviated From 32 Lack of Separation of Safe Section III.G.2.b Shutdown Components and Electrical Cables 33 Reactor Coolant Makeup and Section III.G Depressurization Systems (Guidance provided in IN 84-09, Para. V) 34
~ s lk&Q40 A g ~&4s 4een lv,'tQveun W/A 35 This Deviation Request has been N/A withdrawn 36 Control Structure Chiller ESW Section III.G.2.c Valves Insufficient Fire Barrier Fire Zone 1-3A 37 Control Room Raised Floor and Section III.G.2.a,b,c Control Structure Cable Chase Fire Protection FPRR/D-7.2DRI Rev. 3, 06/88 7 ~2 3
0 j=~CJQ 4kl-ac4~0 t a bP "3
( DEVIATION REQUEST NO. 3 SUSQUEHANNA STEAM ELECTRIC STATION - UNITS 1 5 2 FIRE PROTECTION PROGRAM - CONCERN 41 DOCKETS NO. 50-387 50-388 APPENDIX A - DEVIATION REQUESTS DEVIATION REQUEST NO. 3 ATTACHMENT 1
t- ggop AR h~~f a
+ QP<8 DEVIATION REQUEST NO. 3 SUSQUEHANNA STEAM ELECTRIC STATION - UNITS 1 8( 2 FIRE PROTECTION PROGRAM - CONCERN 81 DOCKETS NO. 50-387 50-388 APPENDIX A - DEVIATION REQUESTS DEVIATION REQUEST NO. 3 ATTACHMENT 2
Poo0g SSES-FPRR APPENDIX R DEVIATION RE VEST NO.
6'ON FIREPROOFED STRUCTURAL STEEL DEVIATION RE UEST:
Exposed structural steel supporting the fire area barriers identified below are acceptable and do not require fireproofing.
FIRE AREA/ZONES AFFECTED:
Tables ~ ~4,-l also refer to and ~
! -2 a series provide a list of the affected fire zones. These tables of drawings associated with each fire rated floor slab with non fireproofed structural steel showing the extent of the required fire protection.
REASON FOR DEVIATION RE UEST:
Within the Unit 1 and 2 Reactor Buildings and Control Structure, certain floor/ceiling assemblies are to be upgraded to a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rating, to separate redundant safe shutdown equipment. The structural steel supporting these floors is not protected.
JUSTIFICATION:
UNIT 01 AND 82 REACTOR BUILDINGSt Structural steel associated with each of the Unit fl and f2 Reactor Building fire barriers required to be upgraded was examined and the evaluation criteria applied to demonstrate that fire proofing of this structural steel is not required was developed in the "Summary Report for Structural Steel Evaluation". To clearly demonstrate the applicability of this criteria to the fire area barriers in question, a drawing of each area, corresponding to the Fire Zones listed in Table , is attached to this deviation request along with an area unique justifies ion for each drawing. These drawings show the barrier area in question, th structural steel members supporting the barrier and the primary combustibles relevant to each area. Each drawing's corresponding unique justifi ation references the section of the Summary Report for Structural Steel valuation that provides the basis for that justification.
Rev. 3, 6/88 DR 6-1
SSES-FPRR CONTROL STRUCTURE:
There are several floor fire barriers in the Control Structure whose structural steel beams are not fireProofed. The extent of each of these barriers vary throughout the building; they are clearly defined in the drawings referenced in Table W~." of this exemption request.
The following sections provide justification for each upgraded floor barrier where steel beams are not fireproofed.
STEEL BELOW SLABS ELEVATION 676'-0, 686'-0, 698'-0 and 714'-0 An analysis of the floor fire barriers for these elevations demonstrate that the structural steel beams are adequate for the combustible loading present in Fire Zones 0-21A, 0-22A and, 0-24E.
NOTE: Only the steel above Fire Zone 0-24E (below elevation 714'-0) is not fireproofed. The remaining main floor steel below elevation 714'>>0 is fireproofed.
The analysis for each of these fire barrier has been done utilizing the criteria developed in the "Summary Report for Structural Steel Evaluation".
In particular, Section 3.2 - Energy Balance Method and Section 3.3 - Two Horizontal Cable, Tray Criteria were utilized to demonstrate the adequacy of the structural steel beams.
Based on the results of the analysis, steel beams above Pire Zones 0-21A, 0-22A and 0-24E will 'not be adversely affected as a result of a postulated fire in any of these fire zones.
STEEL BELOW SLAB ELEVATION 754'<<0 Automatic detection and protection ia provided below the exposed structural steel. The majority of the combustibles in the area below the exposed structural steel are cables. The majority of the cables are located either below the raised (computer type) floor or along the south walls of the Control Structure where only one structural member is affected. There is approximately 20 feet between the raised computer floor and the exposed structural steel supporting elevation 754'-0. Finally, the Control Room comprises the majority of the area beneath this steel and it is continuously staffed.
Rev. 3> 6/88 DR 6-2
o>
F (p
SSES-FPRR STEEL INSIDE HVAC CHASES Structural steel beams inside the HVAC chases do not require fireproofing, The analysis which considers Fire Zones 0-24I, 0-24K and 0-28S indicate that these fire zones contain minimal amounts of combustibles; therefore, damage to the steel is highly unlikely.
STEEL BELOW SLAB ELEVATION 783'-0 Only the steel above Fire Zones 0-28A-I, 0-28A-II, 0-28B-I, 0-28B-II and 0-28H need justification. This steel (below elevation 783'-0) is considered adequate for the combustible loading present.
- 1. Fire Zone 0-28H is the Cold Instrument Repair Shop containing minimal combustibles; therefore, damage to steel due to a fire is highly unlikely.
- 2. All in-situ combustibles in Fire Zones 0-28A-I, 0-28A-II, 0-28B-I and 0-28B-II are due to various electrical panels.
The reasons for the )ustification are as follows:
a) All of the panels are separated by either a block wall, or by distance. it If a fire was to occur in one of the panels, will be delayed or contained within the panel.
b) All of these fire zones have ionization detection. This will give early indication for site personnel to respond.
Because of the nature and arrangement of the combustibles in these fire zones, it is rather unlikely to ever have a raging fire where all of the panels will be on fire at 'the same time. This in fact eliminates the possibility of generating sufficient heat to produce structural damage to the steel.
Based on the above )ustification, steel beams above fire zones 0-28A-I, 0-28A-II, 0-28B-I, 0-28B-II and 0-28H will not be adversely affected as a result of a postulated fire in any of these fire zones.
Adck At,+a~h~ a~4 A, STEEL BELOW SLAB ELEVATION 806'-0 Steel beams belo~ slab elevation 806'-0 are adequate because there are no combustibles in Fire Zones 0-22B and 0-29A. These fire zones are part of the north and south Control Structure stairwells.
Therefore, steel beams above Fire Zones 0-22B and 0-29A, below elevation 806'-0, can not be adversely affected by a fire because of the lack of combustibles.
Rev. 3, 6/88 DR 6>>3
p'goof TABLE ~ (-i SSES-FPRR Page 1 of 1 FIRE ZONE NFPA 13 BENEATH RATED TOP OF SLAB SPRINKLER PROTECTION DRAWING FLOOR SLAB ELEVATION PROVIDED llE PEIIEN CE Unit 1 Reactor build 1-1F 683'0" No C-206006 8\It. 1 683'-0" No C 206006 Sht. 2 1-3h 719'-1" Partial C-206007 Shts. 162 1-3B-W 719'-1'>> Yes C-206021 Sht. 1 1-3B-'W 719>> ]II Yes C-206021 Sht. 2 1 4A-W 749'-1" Yes C-206008 Shts. 1&3 1-4A"W 749'-1" Yes C-206008 Sht. 2 1-4A"N
~ 1-4A-W 749'-1" Yes C-206008 Sht. 4
\
1-4A-S 1-4h-W 749 '1" C-206008 Sht. 5 1-4A-N 1-4G 761>> -10n No C-206009 Shta ~ 1&2 1-SA-S 779>> -1n Yes C-206010 Shta ~ 1&2 1-5B 779>> 1>>r No C-206010 Shta>>
Unit 2 Reactor build 2-1A) C & D 670'-0 C-213472 Shts. 1&2 2-1F 683>> 0l I No C-206011 Sht. 1 2-IE 683'" No C-2060I1 Sht. 2 2-3B-N 719 '1" Yes C-206012 Shts>> 1&2 2-3B-W 719'1" Yes C-206022 Sht>> 1 2-3B-W 7] 9>> ~] II C-206022 Sht, 2 2-4A-S 749'l" Yea C-206013 Sht. 1 2-4A-W 2-4A-W 749'-1" Yea C-206013 Shta>> 2&3 2-4A-W 749'-1" Yes C-206013 Sht>> 4 2-4A-S 2-4A-W 749 '1" Yea C 206013 Sht. 5 2-4A-N 2-4G 761'-10" No C-206014 Shta. 1&2 2-SA-N 779'-1 Yea C-213469 Shta. 1&2 2-5C 2-5A-S 779 '1" C 206015 Shta 1~2&3 2 5B 2-6A 799'-1" C 206016 Sht>> 1 Rev. 3. 6/88
0 o$
(+)go >
SSES- FPRR TABLE ~b-4 Page 1 pf 1 FIRE ZONE NFPA 13 BENEATH RATED TOP OF SLAB SPRINKLER PROTECTION 0RAMING FLOOR SLAB ELEVATION PROVIDED IIEFE RE NCE Control Structure 0-21A 676'-0 No E-205986 Sht. 1 0-22A 686'-0 No E-205987 Sht. 1 0-22A (Ceil. Space) 698'-0 No E-205988 Sht. '1 0-24E (See Note 1) 714'-0 No E-205989 Sht. 1 0-24I See Note 2 Ho See Note 2 o-24K See Note 2 No See Note 2 0-28S See Note 2 No See Note 2 0-26h, E-H, P, R 754'-0 Partial E-205992 Sht. 1 0-28A-I 783'-0 E-205994 Sht. 1 0-28A-II 783'-0 No E-205994 Sht. 1 0-28B-I 783'-0 No E-205994 Sht. 1 0-28B-II 783'-0 No E-205994 Sht. 1 0-28H 783'-0 No E-205994 Sht. 1 0-22B 806'-0 No E-205995 Sht. 1 0-29B 806'-0 No E-205995 Sht. 1 NOTES:
- 1. Only the steel above Fire Zone 0-24E (below Elev. 714'-0) is not fireproofed.
Thc remaining main floor steel below elevation 714'-0 is fireproofed.
- 2. Steel beams inside HVAC chases do not require fireproofing.
See the following for location:
STEEL BEll% DRAWING ELEVATION REFERENCE 714'-0 E-205989 Sht.l 729'-1 E-205990 Sht.l 741'-1 E-205991 Sht. 1 754 '-0 E-205992 Sht. 1 771'-0 E-205993 Sht. 1 Atta~h~cr 0 C.
d 1 At%a~ hm en% 8 Rev. 3, 6/88
0 SSES - FPRR peviation Request No. 6 ATTACHMENT A The structural steel beams above the 125V and 250V Battery Rooms (Fire Zones 0-28C, 0-280, 0-28E, 0-28F, 0-28G, 0-28I, 0-28J, 0-28K, 0-28L, 0-28M, 0-28N and 0-28T) do not require fireproofing due to the minimal amount of combustibles contained within each battery room. A specific fire hazards analysis was performed to evaluate the impact of the combustible configuration of each fire zone on the overhead structural steel beams. The analysis conservatively evaluated the ideal burning rates of the batteries in each room and calculated the time required to heat the structural steel beams in each room to the assumed failure temperature. Based on this analysis, fireproofing of the overhead structural steel beams is not required.
SSES - FPRR Table 6.2 ATTACHMENT 8 0-28C 783'-0" E-205944, Sht. 1 0-28D 783'-0" No E-205994, Sht. 1 0-28E 783'-0" No E-205994, Sht. 1 0-28F 0-28G 783'-Ol'o 783'-0" No No E-205994, Sht.
E-205994, SIlt.
1 1
ATTACHMENT C 0-28I 783'-0" No E-205994, Sht. 1 0-28J , 783'-0" No E-205994, Sht. 1 0-28K 783'-0" No E-205994, SIlt. I 0-28L 783'-0" No E-205994, Sht. 1 0-28M 783'-0" No E-205994, Sht. 1 0-28N 783'-0" No E-205994, Sht. 1 0-28T 783'-0" No E-205994,, Sht. 1 fm/ms 9014c (16)
SSES - FPRR APPENDIX R DEVIATION RE UEST NO. 7 FIRE SPREAD LIMITATIONS E lETIOE EEIIIIEET:
Certain fire zones can be considered to act as a fire area boundary between Fire Areas R-lA and R-1B in the Unit 1 Reactor Building and between Fire Areas R-2A and R-2B in the Unit 2 Reactor Building. The fire zones which act as the fire area boundaries are called "buffer zones."
FIRE AREAS/ZONES AFFECTED:
In the Unit 1 Reactor Building the following fire zones are considered to be buffer zones since they provide a fire area boundary between Fire Areas R-1A and R-1B:
1-6B 1-6F 0-6G 1-6C 1-7A 0-6H 1-6D 0-8A In the Unit 2 Reactor Building the following fire zones are considered to be buffer zones since they provide a fire area boundary between Fire Areas R-2A and R-2B:
2-6B 2-6E 2-7A 2-6D 2-6F 0-8A DR7-1
~ ~
REASON FOR DEVIATION RE VEST:
10CFR50 Appendix R, Section III.G requires separation of cables and equipment required for safe shutdown by a fire barrier having a 3-hour rating.
Furthermore, NRC Generic Letter 86-10 states that "the term 'fire area's used in Appendix R means an area sufficiently bounded to withstand the hazards associated with the fire area and, as necessary, to protect important equipment within the fire area from a fire outside the area." Normally, fire areas are separated by a wall or floor having a fire resistive rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. The walls of the buffer zones do not have a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rating but possess sufficient integrity of construction and spatial separation to provide a fire area boundary.
J USTI FI CATION:
The buffer zones are fire zones which occupy the upper elevations (i.e. 779',
799'nd 818') of each reactor building. Their location is shown on drawings E-205954, E-205955 and E-205956 for Unit 1 and on drawings E-205962, E-205963 and E-205964 for Unit 2. These drawings are contained in Section 8.0. They are zones which are almost entirely devoid of any safe shutdown cables or equipment and the combustible loading in all of these zones is very low.
These zones are, considered to provide I
an equivalent degree of safety as a fire rated wall for the following reasons:
DR7-2
h
)
0
- 1. In all cases, a minimum of 50 ft. horizontal separation exists between the fire zones in Fire Areas R-1A and R-1B for Unit 1 and in Fire Areas R-2A and R-2B for Unit 2.
- 2. All buffer zones have fire detection except for the following:
I-6F Spent Fuel Pool (filled with water)
I-7B Recirculation Fan Room 2-6F Spent Fuel Pool (filled with water) 0-6H Cask Storage Pit (filled with water)
- 3. All buffer zones have very low combustible loadings and there are no specific locations within these zones which have 'the potential to cause a fire hazard.
- 4. The walls which bound these zones are not fire rated yet their rf construction would contain a fire and the products of combustion reasonably well. The walls are of reinforced concrete construction, if the doors are of heavy'etal construction and the penetrations in the walls are constructed similarly as in a fire rated wall. Therefore, although not fire rated, the boundaries would inhibit the transgression of a fire from one fire area to the next.
- 5. All buffer zones have manual fire suppression equipment located throughout the area.
DR7-3
- 6. Typically, the buffer zones are situated such that a fire would have to pass through adjacent buffer zones to spread from one fire area to the next. This is considered extremely improbable based on thy specific configuration of the buffer zones with respect to the fire areas they separate.
- 7. For the purpose of the safe shutdown analysis,,the buffer zones were 1
considered to be part of both fire areas which they act to separate.
This approach is conservative since it requires protection of all safe shutdown cables or equipment in these zones regardless of safe shutdown path. In all buffer zones, both paths (1 and 3) of safe shutdown equipment are protected where necessary.
In conclusion, it can be stated that the spatial separation, construction techniques and low combustible configurations enable the buffer zones listed in this deviation request to act as a fire area boundary. Therefore, a fire initiated in Fire Area R-1A of the Unit 1 Reactor Building may impact the buffer zones but will not spread into any other fire zone in Fire Area R-IB.
Similarly, a fire initiated in Fire Area R-1B may impact the buffer zones but will not spread into any other fire zone in Fire Area R-1A. The same assurance can be stated for Unit 2.
fxm/ms j086i (16)
DR7-4
SSES-FPRR The SGTS*Equipment Room Vent fans OV118A/B and the associated damper actuators/flow switches are located within 10 feet of each other. The redundant flow switches FSL 07841A/B are located greater than 10 feet above the floor and therefore are outside of the zone of influence of a transient fire. Since the fans and actuators are not outside the zone of influence, the alcove where this equipment is located is identified as an area where transient combustibles are administratively kept to a minimum.
This precaution in conjunction with protection of the area through utilization of administrative controls which provide verification that no combustibles are present in the area or are appropriately removed provides adequate to ensure that a transient combustible fire will not disable the SGTS Equipment Room Vent System.
CONCLUSIONS:
In order to ensure that the Control Structure HVAC System will
'perform its intended safe shutdown'function, the following modifications were required: /
- 1) The area around the Battery Room Exhaust fans OV116A/B on Elevation 783'-0" is identified as an area where transient combustibles are prohibited. This area is protected through utilization of administrative controls which provide verification that no combustibles are present in the area.
- 2) A heat shield wall was constructed between OB136 and OC877B on Elevation 783'-0".
- 3) The Control Structure Chilled Water flow transmitter FT 08623B on Elevation 783'-0" has been relocated go feet from any Division I component with no intervening combustible.
- 4) A curb was installed between the redundant Control Structure Chillers OK112A/B on Elevation 806'-0". As an added precaution, a"row of sprinklers was added in front of the
'chillers.
5)
~f0~
The SGTS Equipment Room Vent system temperature switch(s)
TSH/TSL feet 1A(B) on Elevation 806'-0" was relocated m any redundant equipment with no intervening
~q,l combustibles.
- 6) The area around the SGTS Equipment Room Vent fans OV118A/B on Elevation 806'-0" was identified as an area where transient combustibles are prohibited. This area is protected through utilization of administrative controls which provide verification that no combustibles are present in the area.
Rev. 3, 6/88 DR30-8
W4a png e jets let~ infcationa (p 4,'(,fg SSES-FPRR APPENDIX R DEVIATION REQUEST NO. 34 EMERGENCY LIGHTING TO PERFORM LOCAL MANUAL SCRAM D VIATZON REQUEST:
A de iation from Section ZZI.J of Appendix R to 10CFR50 i that emerg cy lighting utilized for local manual scram is ac eptable to be ss than 8 hours.
FIRE AREAS ZONES AFFECTED:
This deviatio request applies for a fire in the ollowing fire zones:
Unit 1: 0-2 (Lower Relay Room - Fire A a CS-28) 0-25 (Lower Cable Spreading Ro Fire Area CS-30) 0-27C Upper Cable Spreading om- Fire ARea CS-10) 0-27E ( per Relay Room - Fi Area CS-33)
Unit 2: 0-24G (Low r Relay Room - ire Area CS-5) )
Room- Fire Area CS-29) 0-25A 0-27A (Lowe (Upper Cable Spre clay Roo - ing Fire Area CS-31) 0-27B (Upper C le S eading Room- Fire Area CS-32)
REASON FOR DEVIATION REQUEST:
The local manual scram func ion w ld be necessitated by a fire in the Unit 1 or 2 upper lower r ay room, or the Unit 1 or 2 upper or lower cable spr ading room. Zn the extremely unlikely event that this postul ed fire rende d automatic and Control Room manual scram ino erable, a local m ual scram would be performed by the pl t operators by vent the instrument air header.
10CFR50 Appendi R, Section ZZI.J requires th emergency lighting with n 8>>hour power supply be availab in areasin needed to operate s fe shutdown equipment. Emergency CRD Master ontrol Panel area as well as access li an hting egress the paths thereto Scram ii necessary for operators to perform a Loca Manual the extremely unlikely event that the postul ed fire:
creates hot shorts disabling the automatic and m ual scram pilot solenoid valve circuitry, and b) creates open circuits or shorts-to-ground disabling b h Division I and IZ backup scram valve circuitry, and Rev. 3, 6/88 DR 34-1
f'~g~ ~~ l>eccl ln~en+ioz a/j o(e Ie+g J SSES-FPRR creates open circuits or s orts-to-ground disabling t
.ATWS/ARI solenoid valve circuitry.
The cram Function, whether automatic or manual, is require to be ac mplished at the beginning of any fire scenario whic require safe shutdown of the reactor.
EXISTING AR NGEMENT:
Adequate emerg cy lighting- exists to allow access f om the Control Room to he Remote Shutdown Panels (RSP) f both Unit 1 and 2 at elevatio 683'-0" of the Reactor Buildin . Access from this point to elev tion 719'-0" is available via he northwest stairwell for Unit and the southwest stairwel for Unit 2.
Both stairwells are uipped with self-contain d battery supplied emergency lighting.
In Unit l. at the 719'-0 elevation, the CRD Master Control Panel access and 'egress paths a e illuminated b three (3). emergency, DC lighting units powered fro a separate D source. The CRD Master Control Panel located in Fi e Zone 1-4A is illuminated by a wall mounted emergency light g unit w th a self-contained battery, approximately 10 fee east the panel.
In Unit 2 at the 719'-0" elevati the CRD Master Control Panel access and egress paths are ill ated by four (4) emergency DC lighting units powered by a sep at DC source. Illumination of the CRD Master Control Panel 1 cated n Fire Zone 2-4A-W is supplied by the fourth emerg cy DC u t, mount'ed approximately 23'outheast of the panel.
The CRD Master Control P els for both Uni 1 and 2 are open panels thereby increasi g ease of access and he illumination of the valves required to perform the local manua scram function.
JUSTIFICATION:
When required e local manual scram function is perf ed at the beginning of he fire scenario assuming an automatic o Control Room manua scram has. not yet occurred. Upon loss of no al reactor b lding lighting and essential AC lighting, the b tery supplie emergency DC lighting and individual battery suppli emerge cy lighting is immediately available. Because the loca manu action will be performed at the initiation of the fire sh down scenario, the lighting is not required to be rated for 8 h urs.
Rev. 3, 6/88 DR 34-2
SSES-FPRR Both Units 1 and 2 provide installed emergency lighting for
's and egress to their CRD Master Control Panels by m of batter plied emergency lighting adequately'spaced ong the operators'.
The installed batt supplied emerge ghting unit at the CRD Master Control Panel o nit 1 es illumination of the Manual Scram valves. En the installed station battery supplied emergency DC Manual Scram va .
tin The installe it provides illumination to the ergency lighting allows for prompt an e execution of the Manua ram operation.
Modi ion to the existing emergency lig configuration not significantly enhance the execution o e local manual scram safe shutdown operation.
P<ge lax fp.en in+en innp/lg Jelcfg Rev. 3, 6/88 DR 34-3