ML18092A995
| ML18092A995 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 01/17/1986 |
| From: | Corbin McNeil Public Service Enterprise Group |
| To: | Varga S Office of Nuclear Reactor Regulation |
| References | |
| NLR-N86005, NUDOCS 8601270007 | |
| Download: ML18092A995 (35) | |
Text
Public Service Electric and Gas Company Corbin A. McNeill, Jr.
Vice President -
Public Service Electric and Gas Company P.O. Box236, Han cocks Bridge, NJ 08038 609 339-4800 Nuclear January 17, 1986 NLR-N86005
- 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 NOS. 1 AND 2 DOCKET NOS. 50-272 AND 50-311 We have performed a review of the 10CFR50 Appendix R exemption requests submitted to the NRC on January 31, 1985.
This has resulted in the need to clarify certain technical justifications utilized in supporting the adequacy of the existing and/or proposed fire protection provisions and modify several of the exemptions requests.
Changes are identified by vertical bars in the margins of the enclosures.
An exemption request is no longer required for the lA(lB)
Service Water Motor Control Center Area and corresponding pump area (fire area lFA-SWIS-lA(lB)).
Mr. Steven 1-17-86 The exemption requests for the RHR Area, 4160V Switchgear Area and the Pressurizer Pressure and Level Instrumentation Panel 335 have been revised as shown below.
- 1)
RHR Area (fire area 1FA-AB-45A) - rather than detection and suppression at the 5' doorway and corridor on elevation 55' only detection is proposed.
- 2) 4160V Switchgear Area (fire area 1FA-AB-64A) -
in addition to wrapping one train, intervening combustible will also be wrapped.
- 3)
Panel 335 - rather than relocate the adjacent panels a fire suppression system will be installed.
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. Thomas J. Kenny Senior Resident Inspector Sincerely,
ENCLOSURE 1 GENERIC EXEMPTION REQUEST
- 1.
A generic exemption is requested from the requirements of 10CFR50 Appendix R Section III.G.2a for the use of 1-1/2 hour rated doors and dampers, 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> rated ventilation ducts and ventilation duct penetration seals and non-rated equipment hatches in 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> barriers.
This Generic Exemption Request addresses all 1-1/2 hour rated fire doors and dampers, 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 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 <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> 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 Staff 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 Auxiliary Building in the RHR Area.
Since both Elevation 55' and 45' are included in 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 <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> 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 <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> barrier. Dl7/10
- 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 <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated wall, a 1-1/2 hour rated external elevator door and a 1-1/2. hour tated 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 conctete elevator enclosure is rated for 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.
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 <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated walls with 1-1/2 hour rated doors, the elevator shafts ca~not be a medium to spread a fire between fire areas.
- 5.
Non-rated doors that were installed in 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated walls *which define fire areas, will be replaced with doors that are rated for 1-1/2 hours.
All fire doors either meet the requirements, will be replaced, -0r will be modified to meet the requirements of a 1-1/2 hour rated door.
~; Ventilation duct penetrations through 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated fire walls which define fire areas will be sealed to provide a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> rating.
Where physically possible 1-1/2 hour rated fire dampers have been installed in the ducts.
There are limited cases where it is physically impossible to install a fire damper in the duct.
Dl 7 /10 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 hotirs or more."
The text refers to a figure that shows fire dampers are not required in ducts that penetrate 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 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. Gawain entitled "Fire Research for Steel HVAC Systems."
Reference is made to the Thermal Insulation 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 Laboratories listed fire dampers, fire doors and wired glass fire windows - to reshrict 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 penettate walls having a one hour fire resistance rating.
In light of the TIMA fire studies and the NFPA codes, PSE&G recognizes the ductwork to provide a one hour fire barrier throughout the Salem Station.
FIRE AREA:
1FA-AB-122A This area is defined as the Control Room, peripheral rooms, and ventilation equipment room for the Control Area.
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 operating instructions are provided for both units but due to alternate shutdown personnel requirements, both units can not be shut down simultaneously using these procedures.
EXEMPTIONS
- 1.
An exemption is requested from the requirements of 10CFR50 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 letter dated September 16, 1982.
- 2.
An exemption is requested from the requirements of 10CFR50 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 flre barrier.
The technical justification for these exemption requests is as follows:
- 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 rooms are rated for 3/4 hour.
The doors are marked as fire doors and must remain closed.
They 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. Dl7/10
- 4.
The Unit 1 ventilation equipment provides cooling for the 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 it has been confirmed that smoke does not propagate between Control Rooms when the ventilation systems are balanced.
The damper vanes are mechanically locked in posiiion to maintain the pressure balance.
- 5.
The Control Room areas are constantly manned assuring quick response to any fire in the area.
- 6.
Alternate shutdown procedures have been developed and are in place for operating personnel use. Dl7/10
FIRE AREA:
lFA-AB-1228 This area is defined as Elevation 122' of the Auxiliary Building located 30 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 locatect in this fire area.
Operation of pump room coolers is required, but this equipment is located in separate fire areas.
Note:
017/10 This section is included for clarification only; there are no exemptions from Appendix R requested for this fire area.
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FIRE AREA:
1FA-AB-100A 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, instrument inverters and distribution cabinets.
APPENDIX R CRITERIA:
III.G.3 Fire detection and automatic suppression in the form of a double-shot Halon System is installed in this area.
Alternate shutdown operating instructions have been developed to operate any equipment that may be impaired due to a postulated fire in this area.
Note:
017/10 This section is included for clarification only; there are no exemptions from Appendix R requested for this fire area. ~
FIRE AREA:
1FA-AB-100C 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 requirements of 10CFR50 Appendix R Section III.G.2c to the extent th~t 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 (D-G's).
One hour fire barriers in the form of FS-195 wrap will be provided where redundant trains of D-G cabling interact to assure minimum system operability requirements are met.
- 4.
The maximum concentrated 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. Dl7/10
- 5.
The cable used in this area is 6onstructed of EPR/Hypalon, and is qualified to IEF.E 383 standards.
It has been shown that this type of cable does not readily propagate a flame front. 017/10
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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 ca_bling 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 e~emption 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 f6r 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.
One train of source range flux cable is completely wrapped with a 1-hour fire barrier in this area.
- 4.
The redundant Vital Vent Control Centers located in this area are separated by approximately 35 feet with negligible intervening combustibles since their associated cabling enters and exits from below.
- 5.
There is a very limited amount of installed combustible material 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. 017/10
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.c EXEMPTION
- 1.
An exemption is requested from the requirements of 10CFR50 Appendix R Section III.G.2c to the extent that there is no automatic 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 CC valves for RCP bearing cooling are normally-open motor operated valves which fail as-is.
RCP seal injection does not
'require the operation of any valves.
- 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. 017/10
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 <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> barriers and alternate shutdown operating instructions are provided should the control cables near the ceiling be damaged.
EXEMPTIONS
- 1.
An exemption is requested from the requirements of 10CFR50
- Appendix R Section III.G.2c to the extent that no-singl~'train of switchgear is totally enclosed in a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 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 will be 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 <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 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 s~itchgear 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 Dl7/10
operating instructions have been developed to permit an orderly shutdown should the control cables be damaged due to a fire.
The power feeds from the batteries (Elevation 100') to the Train A and B 125VDC switchgear are wrapped with a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> fire barrier in this fire area.
The power feed to the Train C 125VDC switchgear is routed from below (Elevation 64' ).
The Train A and B 125VDC feeds to start the Train A and B diesel generators are completely wrapped with a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 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. Dl7/10
FIRE AREA:
1FA-AB-84B This area is defined as Elevation 84' of the Auxiliary Building between 12 feet west of Columns FF and TT, and'between Column 14.0 and 11. B.
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.
APPENDIX R CRITERIA: 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~2c to the extent that a complete one hour fire barrier is not maintained between redundant Chemical and Volume Control System equipment.
The technical justification for these exemption requests is as fallows:
- 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 <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> 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 2'-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 extends out from the wall.
Piping passes through the openings from one Charging cubicle to the others.
To enhan9e the protection features, the wet pipe sprinkler system in the Charging pump area is being 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'.
Localized combustible loading is low. Dl7/10
- 3.
The Auxiliary Feedwater (AFW) pumps are located in the Auxiliary Building on Elevation 84' near Column LL.
There are two motor driven pumps and one steam turbine driven pump.
Operation of any one pump satisfies minimum system operability requirements 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.
If it is postulated that a fire in this area renders both motor driven AFW pumping loops inoperable, safe shutdown can be achieved with the turbine driven pump.
This pump is enclosed and separated from the motor driven pumps by a 12" concrete wall (3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> 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.
In accordance with the requirements of NFPA-13, where sprinklers can be raised with no overhead obstructions present, sprinklers will be raised to within 12" of the ceiling.
This will be done with both systems to maintain redundant suppression systems.
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 AFW 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.
For this reason, panel 207 is wrapped with FS-195.
However, the wrap on panel 207 is not to be misconstrued to be a one hour barrier.
This wrap is intended to protect the panel until the suppression system activates to combat the fire.
To ensure operability of a suppression system, redundant systems have been installed, as discussed above.
All the flow control valves associated with the turbine driven pump are normally-open and fail in the open position.
A fire in this area can not compromise all three trains of.AFW. Dl7/10
The Hot Shutdown Panel, Panel 213, is also located in this area.
This panel is wrapped with FS-195 to protect instrumentation located in this panel which is not completely isolated from the control complex.
A postulated fire in the vicinity of the hot shutdown panel will not impact the operation and indication systems in the control room because of the redundant suppression system and the enhanced fire protection in the form of FS-195.
- 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 (CCW) pump and the No. 11 Component Cooling Heat Exchanger shall be enclosed in a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> 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 the requirements of a one hour fire barrier.
All piping and cable tray penetrations will be sealed to provide a three hour rated fire barrier.
The existing non-rated door leading to the Auxiliary Building corridor has been.replace;d.with a door that is rated for 1-1/2 hours.
A 1-1/2. hour rated* fire door has been installed to separate the valve roam from the No. 11 Component Cooling loop.
The power *c*aj;>J.es for. all the: CCW pumps enter the cubicles from the elevation
.. beTbw.*. *" i
.J*~*-
Ventilation ducts penetrate the CCW c\\l.hicie.:.~iir..i.ils *. '!There are three ducts that penetrate the wal:L:be-t;w:eeifi:*the
- two'.'Compon~nt Cooling Rooms.
Two of the ducts :ar.~... part* cit the Aux i 1 iary Building Ventilation Syst~m and ar~*ll. x 18 and II x 40 inches in size.
The remaining duct is fo~*the No. 11 CCW 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 gauge 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. Dl7/10
FIRE AREA:
1FA-EP-78C This area is defined as the Electrical Penetration Area on Elevation 7 8 I
- MAJOR COMPONENTS The East Motor Control Centers, the Pressurizer heater buses, and hot and cold shutdown 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 complete one hour fire barrier is not maintained between all the redundant equipment.
Separation is achieved by one hour barriers and greater than 20 ft. separation, but with intervening combustibles.
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 will be replaced with an automatic total flooding halon suppression system.
- 3.
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.
- 4.
Protection for cables is provided in the forms of tray and cable wrap.
Not all trays are wrapped full length.
Barriers are provided between redundant floor mounted equipment.
These and the above measures assure necessary equipment availability to achieve safe shutdown.
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. Dl7/10
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 exemption.is requested from the requirements of 10CFR50 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 10CFR50 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 C02 suppression system is installed in the area.
- 3.
Fire barriers have been constructed between redundant switchgear iets.
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 are/will be wrapped through the Train B and C areas (see also the 4160V Switchgear Room description).
- 5.
All combustibles which cross the fire barrier between the switchgear sets A and B will be protected with a one hour fire rated 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 safe shutdown are wrapped with a one hour barrier after 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. Dl7/10
The above measures assure that a postulated fire in the 4KV Switchgear Room will not compromise redundant trains. Dl7/10
FIRE AREA:
1FA-AB-64B This area is defined as the 64' elevation of the Auxiliary ~uilding, west of the 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> 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 10CFR50 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 throughout 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 shutdown equipment in the area is cabling for service w.ater 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 one hour barrier until it exits the area.
The Trairi C service water power cables are wrapped with a one hour barrier until they exit the area.
One train of component cooling water pump power cable will be completely wrapped with a one hour 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 correspond to a fire severity of approximately 13 minutes.
Since detection and manual suppression equipment is located in this area, minimum da~age would be caused by a fire.
- 5.
The cable used in this area is coristructed of EPR/Hypalon, qualified to IEEE 383 standards.
It has been shown that this type of cable does not readily propagate a flame front *
. Dl7/10
FIRE AREA:
1FA-AB-45A & B 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 RHX's.
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 <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> 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 RHX cubicles open to a common area, an open doorway, and an unsealed cable tray penetration.
The path from one RHX cubicle to the other is a total of 52 feet long with negligible intervening combustibles 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 <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> barrier.
- 2.
The Redundant RHR trains are separated on Elev. 45' by a two foot thick 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> 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 <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> 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.
Fire detectors shall be installed throughout Elevation 55' with the exception of the RHX cubicles.
- 5.
A local hose station is located at elevation 55' adjacent to the stairway wall.
- 6.
Adequate protection has been afforded to redundant cable trains to assure minimum shutdown requirements (See also the Residual Heat Removal Area description). Dl7/10
FIRE AREA:
1 FA-SWIS-lA, ( l B)
This area is defined as the lA (lB) Service Water Motor Control Center Area and corresponding pump area.
MAJOR COMPONENTS Motor control centers for Service Water equipment.
APPENDIX R CRITERIA:
III.G.2a EXEMPTION
- 1.
An exemption was originally requested from the requirements of 10CFR50 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.
This exemption request is no longer required.
The Service Water Intake Structure is designed:: so that each,.
redundant Unit 1 MCC bay is separated P-Y-a-,'C:init-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.:~~et~ee-n-.the.. No. 12 and No. 21 bays will be sealed with a door*ratetj**f.o.. r-.i:71/2 hours.
The Generic Exemption Request discusses bhe.U:s*e of 1-1/2 hour rated doors in 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> barriers.
This wall also contains penetrations sealed with 18 inches of an unrated epoxy utilized for flood protection purposes.
3 1/2 inches of epoxy will be removed and filled with an o.z. Gedney U.L. classified 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated seal. Therefore, the exemption requested is no longer required. 017/10
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ENCLOSURE 2 The following is the additional information requested by the NRC.
RESIDUAL HEAT REMOVAL AREA The Residual Heat Removal (RHR) System is divided into Trains A and B.
Both trains are located in Fire Area lFA-AB-45.
The majority of the RHR system is located on Elevation 45'.
The system cross-tie, electrical cabling and component cooling valves controlling supply to the Residual Heat Exchangers (RHX) are located on Elevation 55'.
RHR Trains A and B are separated on both elevations by concrete walls.
The concrete wall on Elevation 45' is two (2) feet thick with two (2) sleeved pipe penetrations.
The sleeved penetrations could conduct energy across the fire barrier; however, there are no combustibles situated near the penetration to ignite.
Therefore, there is no means for a fire to spread to both trains via the sleeved penetrations.
The concrete wall also contains a ventilation duct penetration.
Any openings around the ventilation duct shall be sealed to provide a minimum one hour barrier.
Fire detection exists near the sleeved penetrations and around the RHR pumps, assuring early response by the fire brigade.
A local hose station is situated very close to the access hatch to Elevation 45' and is available to combat any potential fire in the area.
There is no direct communication between the two RHR trains on Elevation 45'.
Each RHR train area communicates with the respective train area on Elevation 55' via a personnel access hatch in the floor of Elevation 55' and via the RHX cubicles.
The redundant RHR trains are separated on Elevation 55' by a two (2) feet thick concrete wall.
This wall contains openings for a cable tray 1A602, two (2) sleeved pipe penetrations, and an open doorway.
The cable tray opening shall be sealed to provide a three (3) hour barrier.
The sleeves will prevent the spread of fire from one RHR train through the penetration to the other RHR train.
Adequate protection has been afforded to cabling for required equipment and supplemental support equipment such that the separation between redundant trains across the doorway in the concrete wall exceeds 20 feet with negligible intervening combustibles.
Also, throughout the remainder of the area, the combustible loading is very light.
Fire detection shall be installed at Elevation 55' to further enhance the fire protection features and ensure quick response of the fire brigade in controlling any potential fire.
A local hose station ensures quick suppression by the fire brigade of any potential fire. Dl7/10 1
The RHX cubicles open to a common area on Elevation 55'.
Train A opens into the area via a 20 ft corridor which has a wire mesh door to control access.
Train B opens into the common area via a 20 ft corridor which has a wire mesh door to control access.
The corridors contain negligible combustibles, and the wire mesh doors prevent the placement of combustibles in the corridors.
The corridors which lead to the RHX cubicles are separated by approximately 12 feet with negligible intervening combustibles.
This makes the total separation between RHR trains via the RHX approximately 52 feet with negligible intervening combustibles.
The separation between trains and the negligible intervening combustibles provide sufficient protection between redundant RHR trains.
To further increase the level of fire protection, fire detection shall be installed at Elevation 55', as mentioned above.
The detection will allow a quick response from the fire brigade, reducing the already small consequences of a fire in the area.
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 ~rain B or c.
A fire in either Train B or C areas would not affect Train A since all trays which cross the Train A/B barrier will be wrapped as they cross the barrier, and all Train A cable trays will be 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 rubber 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 all the Train A trays shall be wrapped in the B/C train areas and all the open ends of the trays are located in the Tray 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 Dl7/10 2
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, there will be no unwrapped cable trays that pass through all three switchgear zones.
All Train A cable trays required for hot standby or cold shutdown will be 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 compromise safe shutdown.
OPEN ENDED CABLE TRAY WRAPS The NRC previously expressed concerns about cable trays that were wrapped with a one hour barrier with the ends of the trays 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 where permissible with regard to thermal loading considerations.
Trays which carry the Dl7/10 3
turbine driven auxiliary feedwater pump stop and trip valve control cables will be completely wrapped where necessary, including any tray ends where permissible with regard to thermal loading considerations.
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 potentially impact redundant channels of pressurizer pressure and level.
To address this concern, a suppression system will be installed in the vicinity of Panel 335.
This protection is considered adequate since the panel is located inside Containment where access is controlled and limited during plant operation.
Consequently, the potential for transient combustibles to be located near the panel is extremely low.
Water will be supplied to the suppression system by remote-manual opening of the Fire Protection Containment isolation valves from the Control Room upon indication of a fire near the panel. Dl7/10 4
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