Text

Forwards Revised Exemption Requests Re Compliance W/Fire Protection Requirements of 10CFR50,App R,Per 841030 Telcon & EA Liden .Implementation Schedule for Mod Commitments Will Be Provided Upon NRC Approval of Requests
	ML18092A496
Person / Time
Site:	Salem
Issue date:	01/31/1985
From:	Liden E; Public Service Enterprise Group
To:	Varga S; Office of Nuclear Reactor Regulation
References
	NUDOCS 8502250556
	Download: ML18092A496 (36)
	v • d • e

...

e PS~G Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, New Jersey 08038 Nuclear Department January 3 1, 1 9 8 5

u. s. Nuclear Regulatory Commission Off ice of Nuclear Reactor Regulation Division of Licensing Washington, D. C. 20555 Attention:

Mr. Steven A. Varga, Chief Operating Reactors Branch, No. 1

Dear Mr. Varga:

FIRE PROTECTION -

10CFR50 APPENDIX R RESUBMITTAL OF EXEMPTION REQUESTS SALEM GENERATING STATION UNITS NO. 1 AND 2 DOCKET NOS. 50-272 AND 50-311 A meeting was held with the NRC on September 19, 1984, to obtain guidance in resolving the open items relating to Salem's compliance with the fire protection requirements of 10CFR50 Appendix R.

Based on that discussion (see letter from E. A. Liden to

s. A. Varga dated September 24, 1984) and a telephone conversation with J. Stang of the NRC on October 30, 1984, a complete resubmittal of the exemption requests is attached.

In light of additional NRC concerns identified subsequent to previous submittals of the exemption requests, alternate Appendix R criteria were utilized in the analysis for certain fire areas.

This resulted in the revision or deletion of existing exemption requests as well as incorporation of new ones.

Therefore, this submittal (Enclosure 1) supersedes all previous exemption requests.

In those cases, where the NRC has granted the exemption request from a previous submittal, it is so noted.

8502250556 850131 PDR ADOCK 05000272 F

PDR The Energy People 95-2168 (25M) 6-84

Mr. Steven 1/31/85 We have included additional information and drawings as requested by Mr. Stang for the RHR area (fire area 1FA-AB-45A) and the 4KV switchgear area (fire area 1FA-AB-64A).

A discussion of the open ended cable tray wraps and a description of the fire protection features for Panel 335 in the containment building are also provided (Enclosure 2).

An implementation schedule for the modification commitments will be provided upon NRC approval of the attached exemption requests.

Enclosures C

Mr. Donald C. Fischer Licensing Project Manager Mr. James Linville Senior Resident Inspector Sincerely, Manager -

Nuclear Licensing and Regulation

e Enclosure 1 GENERIC EXEMPTION REQUEST

1.

A generic exemption is requested from the requirements of 10CFRSO Appendix R Section III.G.2a for the use of 1-1/2 hour rated doors and dampers, 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months rated ventilation ducts and ventilation duct penetration seals and non-rated equipment hatches in 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months barriers.

This Generic Exemption Request addresses all 1-1/2 hour rated fire doors and dampers, 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months rated ventilation ducts and duct penetration seals and non-rated hatches in the station.

Specific exemption requests for individual items are not addressed in each fire area.

The technical justification for this exemption request is as follows:

1.

In several locations throughout the station, 1-1/2 hour rated fire doors and dampers are used in 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months barriers to separate fire areas.

The attached plan drawings show the location of fire doors in the Auxiliary Building.

The fire hazards analysis performed at Salem demonstrated that a potential fire in any fire area would have a. duration of less than one hour.

This exemption request was previously granted by the commission in a letter dated September 16, 1982.

2.

Equipment hatches are located at the west end of the auxiliary building on Elevations 84', 100' and 122'.

Equipment hatches are also located at the east end of the auxiliary building on Elevation 64', in the electrical penetration area on Elevation 78', in the mechanical penetration area on Elevation 78' and on Elevation 84' outside the 460V/230V Switchgear Room.

Only the hatch at the west end of the auxiliary building on Elevation 84' has redundant equipment on both sides of the hatch.

A water curtain system will be installed around this hatch to prevent*

the spread of fire from one elevation to another.

Equipment hatches are also located on Elevation 55' of the Aux. Bldg. in the RHR area.

Since both Elevation 55' and 45' are all the same fire area, no credit is taken for these hatches being a rated fire barrier.

The hatches are constructed of 3/8" steel plate.

3.

The stairway walls are 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated.

All stairway doors are rated for 1-1/2 hours.

Ventilation ducts in the stairways will be provided with a fire damper that is rated for 1-1/2 hours.*

The ventilation duct penetrations will be.sealed to provide a minimum of a one hour fire rating.

All pipe penetrations in the stairway walls will be sealed to provide a 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months barrier.

4.

The elevator at the west end of the auxiliary building is separated from all of the fire areas by a 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated wall, a 1-1/2 hour rated external elevator door and a 1-1/2 hour rated vestibule door; so, it is not considered part of the fire area.

There is also an elevator at the east end of the Auxiliary Building.

The concrete elevator enclosure is rated for 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months .

The external elevator door is rated for 1-1/2 hours.

Since the elevator shafts are isolated from all fire areas by 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated walls and 1-1/2 hour rated doors, the elevator shafts cannot be a medium to spread a fire between fire areas.

5.

Non-rated doors that were installed in a 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated wall for which credit is taken, will be replaced with a door that is rated for 1-1/2 hours.

All fire doors either meet the requirements, will be replaced; or will be modified to meet the requirements of a 1-1/2 hour rated door.

6.

Ventilation duct penetrations through 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated fire walls for which credit is taken will be sealed to provide a 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months rating.

Where physically possible 1-1/2 hour rated fire dampers have been installed in the ducts.

There are a couple of cases where it is physically impossible to installed a fire damper in the duct.

The National Fire Protection Association (NFPA) Code 90A-1981 "Standard for the Installation of Air Conditioning and Ventilating Systems" states that "approved fire dampers shall be provided where ducts or grills penetrate partitions required to have a fire resistance rating of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months or more".

The text refers to a figure that shows fire dampers are not required in ducts that penetrate 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months rated walls, only walls rated for 2 or more hours require a fire damper.

An article was written in "The Construction Specifier" April 1984 by Richard G. Gewain entitled "Fire Research for Steel HVAC Systems".

Reference is made to the Thermal Insula~ion Manufacturers Association (TIMA) fire tests performed at Underwriters Laboratories in December 1982.

Mr. Gewains's conclusions deduced from these tests were "Steel ducts *...

remained intact on both sides (the fire exposed and unexposed sides) of the wall.

By maintaining its structural integrity in the one-hour rated partition opening, the steel duct acted as a fire stop against the passage of flames and hot gases for one hour-with or without fire dampers".

"Steel ducts without a fire damper provide the same fire protection as Underwriters L~boratoriea lis~ed fire dampers, fire do6rs and wired glas~

fire windows -

to restrict the passage of hot gases and flames."

This provides additional evidence for NFPA 90A to maintain its provision that no fire dampers are required where steel ducts penetrate walls having a one hour fire resistance rating.

In light of the TIMA Eire studies and the NFPA codes, PSE&G takes credit for the ductwork to provide a one hour fire barrier throughout the Sale~ Station.

FIRE AREA:

1FA-AB-122A This area is defined as the control room and its peripheral rooms.

MAJOR COMPONENTS The control complex and its associated support and process control equipment.

APPENDIX R CRITERIA:

III.G.2a and III.G.3 Both the Salem Unit 1 and 2 control rooms are located in the same fire area.

The two control rooms are separated by unrated walls and a 12 foot wide corridor.

Alternate shutdown procedures are provided for both units but due to alternate shutdown personnel requirements, both units can not be shutdown simultaneously using these procedures.

EXEMPTIONS

1.

An exemption is requested from the requirements of 10CFRSO Appendix R Section III.G.3 to the extent that there is no fixed fire suppression system.

This exemption was previously granted by the NRC via leter dated September 16, 1982.

2.

An exemption is requested from the requirements of 10CFRSO Appendix R Section III.G.2a to the extent that the Unit 1 and 2 control rooms are not separated by a 3-hour rated fire barrier.

The technical justification for these exemption requests is as fol lows:

1.

An area wide fire detection system is installed in the main control room, computer room and in the process equipment room.

The detection system is being expanded to include the remaining peripheral rooms.

These rooms are the shift supervisors' office, the corridor surrounding the control rooms, the janitor's equipment room and the women's rest room.

2.

Suppression in the control room consists of portable fire extinguishers and a hose station.

3.

Although the walls separating the two control rooms are not fire walls, the doors leading to the control room are 3/4 hour ratad

~oors.

The doors are marked as fire doors and must remain closed.

The doors are also equipped with automatic door closures.

The doors will be included in the fire door list and thus will be governed as a Technical Specification item.

The restrictions on these doors are designed to prevent the propagation of smoke from one control room to the other.

\\

4.

The Unit 1 ventilation equipment provides cooling for Unit 1 control complex, the corridor between the two control rooms and the peripheral rooms that are shared by both units.

The Unit 2 ventilation equipment provides cooling for the Unit 2 control complex.

The ventilation systems for both units have been balanced to maintain equal pressure in both control rooms.

Tests have been performed and confirmed that smoke does not propagate between control rooms when the ventilation systems are balanced.

The damper vanes will be mechanically locked in position to maintain the pressure balance.

5.

The control room areas are constantly manned assuring quick response to any fire in the area.

6.

Salem Unit No. 1 and Unit No. 2 are each designed to permit an orderly shutdown operating instructions of the control room.

Alternate shutdown procedures have been developed and are in place for operating personnel use.

FIRE AREA:

lFA-AB-1228 This area is defined as Elevation 122' of the Auxiliary Building located 8 feet west of column FF.

MAJOR COMPONENTS Auxiliary Building ventilation equipment.

APPENDIX R CRITERIA:

III.G.2a There is no redundant equipment required for shutdown located in this fire area.

Op~ration of the ventilation equipment or the ECCS pump room coolers is required, but this equipment is located in separate fire areas.

Note:

This section is included for clarification only; there are no exemptions from Appendix R requested for this fire area.

FIRE AREA:

lFA-AB-lOOA This area is defined as the relay room, Elevation 100' of the Auxiliary Building between columns 13.8 and 11.8 and between columns AA and 8 feet west of column FF.

MAJOR COMPONENTS Relay equipment, safeguards equipment cabinets and the instrument inverters and distribution cabinets.

APPENDIX R CRITERIA:

III.G.3 Fire detection and automatic suppression (Halon 1301) equipment is installed in this area.

Alternate shutdown operating instructions have been developed to operate any equipment that may be impaired due to a fire in this area.

Note:

This section is included for clarification only; there are no exemptions from Appendix R requested for this fire area.

FIRE AREA:

lFA-AB-lOOC This area is defined as the area between Columns 14.0 and 11.8 and between 8 feet west of Column FF and 8 feet west of Column PP.

MAJOR COMPONENTS Cabling for hot and cold shutdown equipment.

APPENDIX R CRITERIA:

III.G.2c EXEMPTION

1.

An exemption is requested from the requ.irements of 10CFRSO Appendix R Section III.G. 2c to the extent that the area does not contain an area wide detection system nor an automatic suppression system.

The exemption request for the automatic suppression system was granted by the NRC via letter dated June 17, 1983.

The technical justification for this exemption request is as follows:

1.

A localized fire detection system is installed along the corridor at column 13.8 between the stairways.

Fire detectors are also located near the west wall of the fire area above the boric acid transfer pumps.

Detectors have been installed in the areas where there is the potential for a fire to start or spread -

near the pumps and in the corridor where transient combustibles may exist.

2.

Local hose stations are located near the stairways at the east and west ends of the fire area.

3.

The only redundant cables that are required for hot or cold shutdown in this fire area are those that provide control power to the diesel generators.

One train of the diesel generator control power cables will be completely wrapped with a 1-hour fire barrier.

4.

The maximum con.centrated combustible loading in this fire area is in the vicinity of the equipment hatch and elevator in the west end of the fire area.

If these combustibles were totally consumed, it would correspond to a fire severity of approximately 20 minutes.

Since detection and manual suppression equipment is located in this area, minimum damage would be caused by a fire.

There is no redundant equipment located on either side of the equipment hatch.

5.

The cable used in this area is constructed of EPR/Hypalon, and is qualified to IEEE 383 standards.

It has been shown that this type of cable does not readily propagate a flame front.

FIRE AREA:

lFA-EP-lOOG This area is defined as the Upper Electrical Penetration Area.

MAJOR COMPONENTS The control area chiller equipment, the emergency air compressor, ventilation equipment, the vital ventilation control centers and cabling for the source range neutron flux monitoring equipment.

APPENDIX R CRITERIA:

III.G.2c EXEMPTION

1.

An exemption is requested from the requirements of 10CFR50 Appendix R Section III.G.2c to the extent that there is no area wide detection system nor is their an automatic suppression system installed in this fire area.

The technical justification for this exemption request is as follows:

1.

A localized fire detection system is installed in the area, above all the major equipment.

The detectors have been installed in the areas where there is the potential for a fire to start or spread.

2.

A portable fire extinguisher is located near the doorway that leads to the relay room to provide manual suppression.

3.

The only redundant equipment located in this fire area that is required for hot or cold shutdown is cabling for the source range neutron flux monitor.

One train of the source range flux cable is completely wrapped with a 1-hour fire barrier in this area.

4.

There is a very limited amount of installed combustible materials in this fire area.

All the cabling in this area is routed in conduit.

The cables are only exposed for short distances between the component and where the conduit ends.

There is also lubricating oil (approximately 1-2 quarts) in the casings for several of the pumps and compressors in the *area. '

FIRE AREA:

1FA-MP-78I This area is defined as the mechanical penetration areas on Elevations 78' and 100'.

MAJOR COMPONENTS Piping and valves for the component cooling (CC), service water, chemical and volume control (CVCS) and residual heat removal/safety injection systems.

APPENDIX R CRITERIA:

III.G.3 EXEMPTION

1.

An exemption is requested from the requirements of 10CFR50 Appendix R Section III.G.3 to the extent that there is no fixed suppression system installed in the area.

The technical justification for this exemption request is as follows:

1.

Manual suppression is provided for this area by a hose station that is located on the west wall on Elevation 100'.

2.

An area wide fire detection system is installed on both Elevations 78' and 100'.

3.

The eves and CC valves for charging and RCP seal injection and bearing cooling are normally open and fail in the open position.

For any valve that could fail, alternate shutdown operating procedures have been written.

4.

The installed combustible loading in this area is very low.

The fire severity calculated from the concentrated loading analysis is equivalent to a seven minute fire.

5.

The cable used in this area is constructed of EPR/Hypalon and is qualified to IEEE 383 standards.

It has been shown that this type of cable does not readily burn.

FIRE AREA:

1FA-AB-84A This area is defined as the 460V switchgear room, Elevation 84' of Auxiliary Building between Columns 14.0 and 11.8 and between Columns AA and 12 feet west of Column FF.

MAJOR COMPONENTS The 460V vital switchgear (Trains A, B, C), the 460V non-vital switchgear (Trains E, G), the 230V vital switchgear (Trains A, B, C), the 125VDC switchgear (Trains A, B, C) and the rod control reactor trip and bypass breakers.

APPENDIX R CRITERIA: III.G.2c and III.G.3 The floor mounted equipment is separated by 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months barriers and alternate shutdown procedures are provided should the control cables near the ceiling be damaged.

One train of the vital switchgear is required to ensure safe shutdown.

EXEMPTIONS

1.

An exemption is requested from the requirements of 10CFR50 Appendix R Section III.G.2c to the extent that no single train of switchgear is totally enclosed in a 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months fire barrier.

The technical justification for this exemption request is as

follows:

1.

An area wide fire detection system is installed in the area.

2.

The existing manual carbon dioxide suppression system in this area is being replaced with an automatic total flooding halon suppression system.

The halon discharge will be controlled by*

the existing smoke detection system.

3.

The redundant trains of 460/230V vital switchgear are separated by 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months rated partial height, partial length maronite walls.

The 125VDC switchgear are also separated from the 460/230V switchgear and from their redundant trains by maronite walls.

These partial height and length walls will prevent a floor based fire from damaging redundant floor mounted equipment before the automatic halon suppression system can extinguish the fire.

4.

The power cables from the 460/230V switchgear to the equipment exit from the bottom of the switchgear and are routed on Elevation 64'.

The cables on Elevation 84' provide remote operation of the equipment from the control room.

Alternate operating procedures have been developed to permit an orderly shutdown should the control cables be da~aged due to a fire.

The power feeds from the batteries (Elevation 100') to the Train A 125VDC switchgear are wrapped with a 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months fire barrier in this fire area.

The power feed to the Train C 125VDC switchgear is routed from below (Elevation 64' ).

The Train A 125VDC feed to start the Train A diesel generator is also completely wrapped with a* 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months fire barrier in this fire area.

5.

The cable used in this area is constructed of EPR/Hypalon and is qualified to IEEE 383 standards.

It has been shown that this type of cable does not readily propagate a flame and with the installed detection and automatic suppression system, redundant trains would not be damaged due to a postulated fire.

FIRE AREA:

1FA-AB-84B This area is defined as Elevation 84' of the Auxiliary Building between 12 feet west of column FF and column TT and between column 14.0 and column 11.8.

MAJOR COMPONENTS The No. 11, 12, 13 component cooling water pumps, the No. 11, 12 component cooling water heat exchangers, the No. 11, 12, 13 auxiliary feedwater pumps, the No. 11, 12, 13 charging pumps, the hot shutdown panel, and cabling for the ECCS pump room coolers and Auxiliary Building exhaust fans.

APPENDIX R CRITERIA:

III.G.2a and III.G.2c EXEMPTIONS

1.

An exemption is requested from the requirements of 10CFR50 Appendix R Section III.G.2c to the extent-that a complete one hour fire barrier is not maintained between redundant auxiliary feedwater system equipment.

2.

An exemption is requested from the requirements of 10CFR50 Appendix R Section III.G.2c to the extent that the automatic suppression system is not area wide.

3.

An exemption is requested from the requirements of 10CFR50 Appendix R Section III.G.2a to the extent that a complete three hour fire barrier is not maintained between redundant chemical and volume control system equipment.

The technical justification for these exemption requests is as fol lows:

1.

An area wide fire detection system is installed in the fire area.

2.

The charging pumps are separated by partial length 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated fire barriers.

The barriers completely separate the pumps except for 7'-6" at the south end of the cubicles.

The barriers also have an opening l'-6" high and 6'-3" long at the north end of the cubicle approximately 7 feet above the floor.' The opening is located above a concrete sill that extendg out: from the wall.

Piping passes through the openings *from on~ charging cubicle to the others.

To enhance the protection features, the wet pipe sprinkler system in the charging pump area will be expanded to provide full coverage around the pumps.

The power feeds for the No. 11 and 13 charging pumps enter the area from the elevation below, the power feed for the No. 12 pump is routed on the same elevation as the pumps, Elevation 84'.

3.

The Auxiliary Feedwater pumps are located in the Auxiliary Building on Elevation 84' near Column LL.

There are two motor driven and one steam turbine driven pumps.

Operation of both motor driven or the single steam turbine driven pump is required for shutdown.

The power feeds for the motor driven pumps are routed on Elevation 64' and through the floor of Elevation 84' to the pumps.

The No. 11 and No. 12 motor driven pump flow loops are controlled from panels 205 and 206 respectively.

It is postulated that a fire in this area renders both motor driven AF pump loops inoperable.

Safe shutdown can be attained with the turbine driven pump.

This pump is enclosed and separated from the redundant motor driven pumps by a 12" concrete wall (3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated) and a 3/16" steel missile barrier.

The concrete wall is 6'-5" high and the remainder of the enclosure is the steel barrier.

The concentrated combustible loading in the area corresponds to a fire severity of approximately 15 minutes outside the No. 13 pump barrier and less than 5 minutes inside the barrier.

In addition to the barrier a redundant detection and suppression system is installed above the motor driven pumps and also in the turbine driven pump cubicle.

Both suppression systems are the preaction sprinkler type.

One is activated by smoke detectors and fusible links and the other is activated by a pneumatic pilot system and fusible links.

At present both systems are located below the cable trays.

To meet the requirements of NFPA-13, the sprinklers associated with the system activated by the smoke detectors will be relocated to within 18" of the ceiling.

The detectors are presently located on the ceiling.

This will provide complete suppression for a postulated fire in the cable trays or in the floor mounted equipment.

The turbine driven pump and flow loop is controlled from Panel 207 which is located outside the No. 13 AF pump enclosure.

The pump turbine is controlled by a governor valve MS53, a trip valve MS52 and a stop valve MS132.

The governor valve is hydraulically controlled and fails open.

The trip valve must be manually opened, but is provided with an automatic trip closure.

The stop valve is air operated and fails open on loss of control air.

It is possible that a hot short in the cabling for these valves could cause the turbine driven pump to fail.

The cables that could cause a hot short rendering the pump inoperable will be protected to prevent such an incident.

This includes any circuits that are located in Panel 207.

By protecting these circuits in Panel 207, the existing FS-195 wrap on Panel 207 can be removed.

There are no other controls i~

this panel that could render auxiliary feedwater inoperable..

All the flow control valves fail in the open position and alternate operating instructions are written should these valves stroke to the closed position.

A fire in this area can not damage all three trains of auxiliary feedwater.

The hot shutdown panel, panel 213, is also located in this area.

This panel is presently wrapped with FS-195.

Instrumentation is located in this panel which is completely isolated from the control complex.

This panel is required only should a fire be located in the control or relay rooms that could render the equipment in these areas inoperable.

Should a fire near the hot shutdown panel damage the panel, indication and control in the control room would remain operable.

Since a local fire near the panel will not impact the operation and indication systems in the control room.

The fire wrap on panel 213 will be removed.

4.

Local hose stations are provided at the east and west ends of the Auxiliary Building near the stairways.

5.

The No. 11 component cooling water pump and the No. 11 component cooling heat exchanger are enclosed in a 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated cubicle with _one exception.

The ventilation duct penetrations will be sealed with a ceramic fiber material (similar to Kaowool) or with an expanded silicon rubber material to meet a one hour barrier.

All piping and cable tray penetrations will be sealed to provide a three hour rated fire barrier.

The existing non-rated dcor leading to the auxiliary building corridor will be replaced with a door that is rated for 1-1/2 hours.

A 1-1/2 hour rated horizontal slide fire door will be installed to separate the valve room from the No. 11 component cooling loop.

The power cables for all the CC water pumps enter the cubicles from the e.levation below.

Ventilation ducts penetrate the component cooling water cubicle walls.

There are three ducts that penetrate the wall between the two component cooling rooms.

Two of the ducts are part of the auxiliary building ventilation system and are 11 x 18 and 11 x 40 inches in size.

The remaining duct is for the No. 11 CC pump room cooler and is 11 x 46 inches in size.

The two auxiliary building ventilation ducts continue into the safety injection pump cubicle.

All ducts in this area are constructed of 16 gage sheet steel.

All the ducts are seismically supported by one inch steel angle.

The generic exemption request addressed the use of one hour rated ventilation ducts and ventilation duct penetration seals in a three hour barrier.

FIRE AREA:

1FA-EP-78C This area is defined as the electrical penetration area on Elevation 78'.

MAJOR COMPONENTS The East Motor Control Centers, the pressurizer heater buses and cabling.

APPENDIX R CRITERIA:

III.G.2c EXEMPTION

1.

An exemption is requested from the requirements of 10CFR50 Appendix R Section III.G.2c to the extent that a one hour fire barrier is not maintained between all the redundant equipment.

The technical justification for this exemption request is as follows:

1.

An area wide fire detection system is installed in the area.

2.

The existing manual carbon dioxide suppression system in this area is being replaced with an automatic total flooding halon suppression system.

3.

The only equipment that is required for hot standby or cold shutdown is cabling for instrumentation and power cables for the containment fan coil units.

4.

The cables in this area are constructed of EPR/Hypalon and are qualified to IEEE 383 standards.

It has been shown that this type of cable does not readily burn.

5.

There are three redundant trains of steam generator level, pressurizer level, source range neutron flux monitors and containment fan coil units (CFCU).

There are four redundant trains of pressurizer pressure, Thot and Tcold" One train of each of the above will be wrapped with a one hour fire barrier.

Due to the thermal loading of the cable trays, the tray ends cannot be sealed.

A postulated fire in this area would not damage all trains of equipment since all cabling in the area is constructed of EPR/Hypalon, an area wide detection system is installed and an automatic suppression system will be installed.

FIRE AREA:

1FA-AB-64A This area is defined as the 4160V switchgear room.

MAJOR COMPONENTS lA, lB and lC 4160V Vital Buses, and vital cabling.

APPENDIX R CRITERIA:

III.G.2c EXEMPTION

1.

An exemptio~ is requested from the requirements of 10CFRSO Appendix R Section III.G.2c to the extent that the suppression system installed in the fire area is manually actuated.

This exemption was granted by the NRC via letter dated 6/17/83.

2.

An exemption is requested from the requirements of 10CFRSO Appendix R Section III.G.2c to the extent that no single train of switchgear is totally enclosed in a one hour.fire barrier.

The technical justification for this exemption request is as follows:

1.

An area wide fire detection system is installed in the area.

2.

A manually actuated total flooding co2 suppression system is installed in the area.

3.

Fire barriers have been constructed between redundant switchgear sets.

These barriers are made of 2" thick maronite board and are fire rated for one hour.

The barriers are 15'-4" high.

4.

Train A cables that are required for shutdown will be wrapped as they extend beyond the fire barrier protecting the lA Vital Bus.

5.

All combustibles which cross the fire barrier between switchgear sets A and B will be protected with a suitable fire barrier.

6.

There are cables that exit the Train A cable trays above the switchgear cubicles and are routed through the ceiling.

Any of these cables that are required for shutdown are wrapped with a 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months barrier aft~r they extend beyond the floor standing barrier.

7.

The combustibles in the area consist mainly of cabling.

The cabling is constructed of EPR/Hypalon, qualified to IEEE 383 standards.

It has been shown that this type of cable does not readily propagate a flame front.

The above measures assure that a fire in Train B and C of 4KV switchgear will not compromise Train A and its cabling.

It also assures that a fire in the Train A switchgear will not compromise Trains B and C and their cabling.

FIRE AREA:

1FA-AB-64B This area is defined as the 64' elevation of the auxiliary building, west of the 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months barrier located approximately 12' west of Column FF.

MAJOR COMPONENTS Cabling for hot shutdown equipment.

APPENDIX R CRITERIA:

III.G.2c EXEMPTION 1..

An exemption is requested from the requirements of 10CFRSO Appendix R Section III.G.2c to the extent that the area does not contain an area wide detection nor an automatic suppression system.

The technical justification for this exemption request is as follows:

1.

A fire detection system is installed through0ut the area with the exception of the holdup tank rooms.

The holdup tank rooms are separated from the remainder of the area by concrete walls.

The concrete walls have open doorways for access to the tanks.

2.

The only shutdown equipment in the area is cabling for service water pumps, component cooling pumps, auxiliary feedwater pumps, charging pumps, and diesel generator power.

One train of diesel generator power will be completely wrapped in this area.

The Train C charging pump power cable is wrapped with a 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months

barrier until it exits the area.

The Train C service water power cables are wrapped with a 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months barrier until they exit the area.

One train of component cooling water pump power cable will be completely wrapped with a 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months barrier throughout the area.

3.

Local hose stations are located near the stairways at the east and west ends of the fire area.

4.

The maximum concentrated combustible loading in this fire area is in the corridor which runs the length of the area.

If these combustibles were totally consumed, it would correspohd to a fire severity of approximately 13 minutes.

Since detection and manual suppression equipment is located in this area, minimum damage would be caused by a fire.

5.

The cable used in this area is constructed of EPR/Hypalon, qualified to IEEE 383 standards.

It has been shown that this type of cable does

~ot readily propagate a flame front.

FIRE AREA:

1FA-AB-45A This area is defined as the entire elevations of 45' and 55' in the auxiliary building.

MAJOR COMPONENTS The components contained in this area are required for cold shutdown only.

These include the No. 11 and 12 RHR pumps and the No. 11 and 12 Residual Heat Exchangers.

APPENDIX R CRITERIA:

III.G.2a EXEMPTION

1.

An exemption is requested from the requirements of 10CFR50 Appendix R Section III.G.2a to the extent that redundant trains are not completely separated by 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated fire barriers.

The technical justification for this exemption request is as follows:

1.

Three hour rated barriers exist between redundant trains of RHR on Elev. 55', with three exceptions:

the heat exchanger cubicles open to a common area, an open doorway, and an unsealed cable tray penetration.

The path from one heat exchanger cubicle to the other is a total of 42 feet long and is arranged in a labyrinth so there is no direct path between redundant equipment.

The cable tray penetration will be sealed with a 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months barrier and water curtains will be installed in the doorway and in the path to the No. 12, heat exchanger.

2.

The redundant trains of RHR are separated on Elev. 45' by a two foot thick 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated concrete wall.

The wall contains two sleeved pipe penetrations.

The sleeves prevent the propagation of smoke and flames through the barrier.

A ventilation duct also penetrates the 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated wall.

The openings around the duct will be sealed with a ceramic (similar to Kaowool) or with an expanded silicon rubber material to provide a one hour barrier.

The generic exemption request addresses the use of one hour rated ventilation ducts and ventilation duct penetration seals.

3.

Fire detectors are installed around the RHR pumps.

4.

A local hose station is located at elevation 55' adjacent to the stairway wall.

FIRE AREA:

lFA-SWIS-lA (lB)

This area is defined as the lA (lB) service water motor control center area.

MAJOR COMPONENTS Motor control centers for service water equipment.

APPENDIX R CRITERIA:

III.G.2a EXEMPTION

1.

An exemption is requested from the requirements of 10CFRSO Appendix R Section III.G.2a to the extent that the sealed wall penetrations in the service water intake structure motor control center area do not constitute a three-hour barrier.

The technical justification for this exemption request is as follows:

1.

An area wide fire detection system is installed in the motor control center bays.

2 The service water intake structure is designed so that each redundant Unit 1 MCC bay is separated by a Unit 2 bay.

Likewise, each redundant Unit 2 MCC bay is separated by a Unit 1 bay (The MCC bays are arranged No. 22, No. 12, No. 21 and No. 11 from northwest to southeast).

The enclosed drawing shows the arrangement of the bays.

The doorway between the No. 12 and No. 21 bays will be sealed with a door rated for 1-1/2 hours.

The Generic exemption request discusses the use of 1-1/2 hour rated doors in 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months barriers.

This provides assurance that a fire will not damage all the redundant trains of service water control.

All of the remaining doors in 'the intake structure are of the non-rated watertight design.

3.

The walls in the intake structure which separate redundant equipment are rated for 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months with the exception of the wall penetrations.

The wall penetrations are sealed with 18 inches of an unrated epoxy which is utilized for flood protection purposes. FIREAREA/l

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! 1 F'A -1)(;- !CO & I It fA-!lG *100 Fl The following is the additional information requested by the NRC.
RESIDUAL HEAT REMOVAL AREA Enclosed is a drawing of Fire Area 1FA-AB-45A, the RHR cubicles.
This drawing shows the relative location of the pumps, heat exchangers, cable trays and pump power cables.
The redundant trains of RHR will be separated by a 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated barrier. Where the barrier does not meet the 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months criteria, water curtains or fire barriers will be installed.
An exemption is requested for those areas where the 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months barrier is incomplete.
It should be noted that the equipment located in this fire area is required for cold shutdown only.
Thermal ionization detectors are located in the vicinity of the RHR pumps.
A local hose station is located near the stairway on Elevation 55'.
The RHR pumps are separated by a two foot thick full height concrete wall on Elevation 45'.
On Elevation 55', the r~dundant trains are also separated by a two foot thick concrete wall with several exceptions.
Separation between the* redundant RHR equipment on Elevation 45' is maintained by a two foot thick, three hour fire rated concrete wall.
The wall is penetrated by an 8" and 12" pipe.
Although the penetrations are not sealed with a fire barrier, they are sleeved so that no fire or smoke can damage both trains of equipment.
A ventilation duct also penetrates the three hour rated fire wall.
Any openings around the duct will be sealed with a ceramic fiber material (similar to Kaowool) or with an expanded silicon rubber material to provide a one hour barrier.
On Elevation 55', the redundant equipment is separated by a two foot thick, three hour fire rated wall with the following exceptions:
1.
A cable tray penetrates the wall between the RHR sump tank and the No. 11 Loop.
The penetration is not sealed with a fire barrier.
This penetration will be sealed with a fire resistant material to provide a three hour rating.
2.
There is a five foot wide doorway that is open to both trains of RHR.
A water curtain will be installed in this doorway to prevent the propagation of smoke and flames.
3.
Both heat exchanger cubicles open to a common area on Elevation 55'.
A water curtain will be installed in the corridor 'between the two heat exchangers to prevent the propagation of smoke and flames.
The redundant RHR pump power cables are routed through Elevation 55'.
The cables are routed completely in conduit.
The cables are physically separated by approximately 52 feet.
The fire loading in this area is very low.
Based on a concentrated loading, the fire severity is approximately 2 minutes.
In addition, a radiation shield also provides protection for the Train B cable.
Although the shield is not fire rated, it does provide additional protection against a postulated spreading fire.
The RHR heat exchanger cubicles are physically separated by approximately 42 feet by a concrete labyrinth arrangement.
There are no installed combustibles located in the heat exchanger cubicles.
Installation of a water curtain will prevent a fire. from damaging both trains of equipment.
There are two hatches associated with each train of RHR.
The hatches are located on the floor of Elevation 55'.
One hatch is a personnel hatch for access to Elevation 45' and the other is the equipment hatch for the RHR pump.
There is no redundant equipment located on either side of the hatches.
The same protection is provided to prevent a fire spreading from one train to_ the other via the hatches as was stated above, namely, low or non-existant combustible materials, partial three hour fir-e barrier, a water curtain where the barrier is compromised and local detection and manual suppression systems.
4160 V SWITCHGEAR ROOM Enclosed is a drawing of Fire Area 1FA-AB-64A, the 4160V switchgear room.
The drawing shows the relative location of the switchgear cubicles, the cable trays and the fire barriers.
The criteria, utilized for ensuring a safe shutdown should a fire occur in this area, was to separate Train A from the Train B and C equipment.
Protection is provided such that a fire in the Train A area will not propagate to Train B or C.
A fire in either Train B or C areas could destroy both the Train B and C equipment since there are unwrapped cable trays that communicate with both these trains.
A fire in either Train B or C areas would not affect Train A since there are no intervening combustibles between Train A and B or C, and ill Train A cable trays are wrapped with a one hour fire barrier through the Train B and C areas.
As shown in the drawing, the tray ends of the Train A cable trays are closed as they penetrate through the wall into the Auxiliary Building.
The fire barrier material that is wrapped around the tray is attached directly to the wall to provide a complete one hour seal.
In addition, expanded silicon rubbe~ completely seals the.
cable tray in the wall to provide a fire rating equivalent to the wall.
The Train A tray ends are not wrapped in the Train A switchgear area.
The tray ends are not required to be wrapped since only the Train A trays are wrapped and all the open ends of the traya are.located in the Train A area.
Any postulated fire that could damage these cables has been assumed to damage the switchgear cubicle.
Safe shutdown is assured since the fire cannot spread to the Train B or C equipment.
The highest wrapped tray that is required for shutdown is at Elevation 79'-3", 2'-9" below the ceiling.
The floor standing barriers are 15'-4" high.
They extend to within 2'-8" of the ceiling.
There are cables that exit the Train A cable trays above the switchgear cubicles and are routed through the ceiling.
Any of these cables that are required for shutdown are wrapped with a one hour fire barrier after they extend beyond the floor standing barrier.
The trays that contain cables for hot standby or cold shutdown equipment are listed below:
Train A:
Train B:
Train C:
1C803, 1C808, 1C806, 1C801 1C818, 1C845, 1C842, 1C816 1C830, 1C831, 1C828 Also required for cold shutdown is the Train A RHR pump cable, 1A7D-A.
This cable is routed in conduit after leaving cable tray 1C803.
The conduit shall be completely wrapped with a one hour fire barrier in the Train C area.
As shown on the drawing, ther~ are no unwrapped cable trays that pass through all three switchgear zones.
All Train A cable trays required for hot standby or cold shutdown are wrapped beyond the floor standing barrier that protects the Train A cubicle.
At present tray 1C801 and cable 1A7D-A are not wrapped.
These items will be wrapped.
There is an area wide thermal ionization detection system and a manually operated total flooding carbon dioxide suppression system installed in the fire area.
All cabling is constructed of EPR Hypalon and is qualified to IEEE 383 standards.
This cable does not readily burn and retards the spread of flames.
With the use of the detection and suppression systems and the fire barrier and cable wrap, a postulated fire will not damage redundant trains of equipment required for safe shutdown.
OPEN ENDED CABLE TRAY WRAPS The NRC previously expressed concerns about cable trays that were wrapped with a one hour barrier but the ends of the trays were left open.
The three areas of concern were in the 4KV switchgear room, the auxiliary building and in the electrical penetration area.
In the 4KV switchgear room, the Train A cable trays are completely wrapped including the tray ends in the Train B&C switchgear areas.
The tray ends are not wrapped in the Train A switchgear area (see the above section for more discussion).
In the auxiliary building, the tray system for one diesel control power cable will be completely wrapped including the tray ends.
The trays that carry the auxiliary feedwater stop and trip valve control cables will also be completely wrapped including any tray ends.
In the electrical penetration area, due to the thermal loading in the cable trays, it is impossible to wrap the tray ends.
To enhance the existing fire protection features in this area, the manual suppression system will be replaced with an automatic suppression system.
PRESSURIZER PRESSURE AND LEVEL INSTRUMENTATION Located on Elevation 100' of the containment near column line A4 outside the Polar Crane Wall is Panel 335.
The panel is sectionalized into four compartments by 10 gauge steel plates.
Each compartment contains a channel of pressurizer pressure and level.
The NRC has expressed concern that a postulated fire in the vicinity of this panel could destroy all channels of pressurizer pressure and level.
Located adjacent to Panel 335 are Panels 782-lE and 783-lE which contain a transmitter for pressurizer level and pressure respectively.
Each transmitter provides a signal for an indicator located in the hot shutdown panel.
These transmitters are redundant to those located in Panel 335.
To meet the Appendix R criteria, panels 782-lE and 783-lE will be relocated to Elev. 78'.
This will provide the assurance that at least one train of pressurizer pressure and level will remain operable following a postulated fire.
Should a fire occur on Elevation 100', Panels 782-lE and 783-lE will remain operable.
Similarly should a fire occur on Elevation 78',
Panel 335 will remain operable.
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ML18092A496

Text

Dear Mr. Varga:

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