ML18152A199
| ML18152A199 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 01/28/1997 |
| From: | Ohanlon J VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 96-588, TAC-55332, TAC-55333, NUDOCS 9702030133 | |
| Download: ML18152A199 (35) | |
Text
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VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 January 28, 1997 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 TELECOMMUNICATION SYSTEM MODIFICATION ADDENDUM TO APPENDIX R EXEMPTION NO. 1 Serial No.
NL&OS/GDM Docket Nos.
License Nos.96-588 R2 50-280 50-281 DPR-32 DPR-37 Virginia Electric and Power Company submitted Exemption Request #1, "Auxiliary Building - Partial Area Fire Detection and Lack of Fixed Fire Suppression," as part of our original Appendix R Report submittals. This exemption addresses compliance with Appendix R, Section 111.G.3, which provides separation requirements for redundant trains in the Auxiliary Building (Fire Area 17). This exemption was approved in your letter dated February 25, 1988 (Serial No.88-111 ), "Technical Exemption Requests from Appendix R, 10 CFR Part 50, Surry Power Station, Units No. 1 and 2 (TAC Nos.
55332 and 55333)." Exemption #1 is being updated to include a discussion of the new telecommunication system that was installed at the station subsequent to the submittal of the original exemption request. The telecommunication system is used to facilitate compliance with Appendix R requirements for bringing the station to cold shutdown during an emergency situation. provides the addendum to Exemption Request #1 to address the new telecommunication system, and Attachment 2 provides the technical justification for the addendum. provides an updated copy of Exemption Request No. 1 (except photographs) with the addendum incorporated.
Minor editorial and administrative changes have also been incorporated to correct typographical errors and to reflect changes made at the station since the original exemption was submitted. The overall conclusion of the updated Exemption Request is unchanged from the original in that the current configuration of equipment in the Auxiliary Building will provide a level of protection equivalent to that required by Appendix R, Section 111.G.
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..J This update is provided for your information. No new commitments are intended as a result of this_ letter. If you have any questions or require additional information, please contact us.
Very truly yours,
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James P. O'Hanlon Senior Vice President - Nuclear Attachments cc:
Regional Administrator U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, N.W.
Suite 2900 Atlanta, Georgia 30323 Mr. R. A. Musser NRC Senior Resident Inspector Surry Power Station
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ATTACHMENT 1 ADDENDUM TO EXEMPTION REQUEST# 1 SURRY POWER STATION
.I ADDENDUM TO EXEMPTION REQUEST# 1 SURRY POWER STATION The following changes are being made to Exemption Request # 1, Auxiliary Building -
Partial Area Fire Detection and Lack of Fixed Fire Suppression.
(Note: The page numbers referenced below refer to the originally submitted exemption request page numbers and not to the updated exemption provided in Attachment 3.)
1.
Page 1-1, add the following after the first sentence in the Description of Exemption section:
"A fire in the Auxiliary Building also has the potential to damage both the Unit 1 and Unit 2 telecommunication system antennas and trunking lines. The radio system is a backup to the normal plant communication Gaitronics system. The Units 1 and 2 Auxiliary Building antennas operate independently of each other and provide backup (alternative shutdown capability) for the opposite unit's radio system."
- 2.
Page 1-4, replace the last sentence in the Safe Shutdown Equipment Section with the following:
"This area also contains the instrument cables for indication of parameters at the Remote Monitoring Panel, as well as ventilation system components required for cooling of safe shutdown equipment. Also located in the Auxiliary Building is the telecommunication system antennas and cable trunk lines.
The tele-communication system is utilized to assist with compliance to Appendix R requirements for bringing the station to cold shutdown during an emergency situation. The telecommunications system provides support for both hot and cold shutdown operations."
- 3.
Page 1-4, replace the Fire Hazards Analysis Section with the following:
"The fire hazards analysis is divided into several sections. The first four sections explain the configuration of the charging pump system in the Auxiliary Building including physical and-electrical separation.
The next area of the analysis explains other shutdown components found in the Auxiliary Building.
The remainder of the analysis describes the combustible loading of Fire Area 17 and the fire protection features."
- 4.
Page 1-9, the following should be inserted after the last bullet at the top of the page:
The communication system within the Auxiliary Building consists of each Unit's cable trunk lines and antennas (See Figure 1-4).
There are 4
antennas (one per floor) located in the Auxiliary Building with 2 antennas dedicated per Unit on alternate floors of the Auxiliary Building.
The Unit 1 cable trunk line is routed outside from the roof of the Unit 1 Turbine Building (TB) to the elevator equipment room located on the south-west-corner of the Auxiliary Building roof.
The cable is directed down the exterior elevator -shaft wall and enters through the Auxiliary Building west wall on elevation 45 ft. - 1 O in. Once inside the building, the cable is installed along the west wall of the building and is directed down
- to the 13 ft.-0 in. elevation through existing floor penetrations. Antennas-are connected to the cable trunk line on the 45 ft.- 10 in. and 13 ft.- 0 in.
elevations. In the northwest corner of the Auxiliary Building, elevation 13 ft.- 0 in., the cable "tees" and one line goes into Unit 1 Cable Vault/Tunnel (CV/T) and the other line is directed east along the north wall of the Auxiliary Building and into Unit 2 CV/T.
The Unit 2 cable trunk line originates on the roof of Unit 2 TB and enters the TB through-its north wall. The cable is directed from the TB through
-the Cable Spreading Room and into the southeast corner of the Auxiliary Building. Once in the building the cable is installed along the east wall of the building and is directed down to the 27 ft.-6 in. and 2 ft.-0 in.
elevations through existing floor penetrations. Antennas are provided on elevations 27 ft.-6 in. and 2 ft.-0 in. through "tee" connections to the cable trunk line. The cable "tees" along the east wall of the building at the 13 ft.-0 in. elevation, and one line runs west into the Unit 1 CV/T and the other line is routed into Unit 2 CV/T.
The Unit 1 and Unit 2 communication cable and antenna system, except
- for the -13 ft. elevation, are-routed on alternate floors and along opposite walls of the Auxiliary Building providing a horizontal separation of more than 50 ft.
On the 13 ft. elevation, the containment back-up antenna cables can be disconnected if damaged, and spare antenna cable is provided to allow for cross-connecting each unit's antenna system."
- 5.
Page 1-11, the following should be inserted after the last bullet at the top of the page:
The Unit 1 and Unit 2 communication cable and antenna system, except for the 13 ft. elevation, are routed on alternate floors and along opposite walls of the Auxiliary Building providing a horizontal separation of more than 50 ft.
On the 13 ft. elevation, the containment back-up antenna cables can be disconnected if damaged, and spare antenna cable is provided to allow for cross-connecting each unit's antenna system."
- 6.
Page 1-11 and 1-12, revise items 2 and 3 of the Conclusions and add a new item 4 as follows:
"2.
Fire detection is provided in strategic locations, in areas where there are concentrations of combustibles and near shutdown components in the Auxiliary Building. The current configuration will provide warning of a fire that will alert station personnel and enable the fire brigade to respond to an alarm.
- 3.
The configuration of Fire Area 17 (including heavy concrete construction, restricted
- access, low overall combustible
- loading, and compartmentalization) m1rnm1zes exposure to the systems and components used to support safe shutdown.
- 4.
The Unit 1 and Unit 2 communication cable and antenna system are electrically independent of one another and, except for the 13 ft. elevation, are routed on alternate floors along opposite walls of the Auxiliary Building providing a horizontal separation of more than 50 ft.
On the 13 ft.
elevation, the containment back-up antenna cables can be disconnected if damaged, and spare antenna cable is provided to allow for cross-connecting each unit's antenna system."
- 7.
Page 1-13, add an additional bullet to Item B., Safe Shutdown Equipment, in the Summary Evaluation Table as follows:
"Unit 1 and Unit 2 telecommunication cable and antenna systems"
- 8.
The attached figure should be added as Figure 1-4.
ATTACHMENT 2 JUSTIFICATION FOR ADDENDUM EXEMPTION REQUEST# 1 SURRY POWER STATION
JUSTIFICATION FOR ADDENDUM EXEMPTION REQUEST# 1 SURRY POWER STATION Exemption Request No. 1 of the Appendix R Report discusses compliance with Appendix R,- Section 111.G.3, to obtain separation of redundant trains.
A new telecommunication system.was recently installed at the station, and therefore was not discussed in the original submittal. The telecommunication system is utilized to assist with compliance to *Appendix R requirements for bringing the station to cold shutdown during an emergency situation. The telecommunication system provides support for both hot and cold shutdown operations.
Surry Power Station is a two-unit plant that uses common buildings such as the Auxiliary Building to house similar equipment for both units.
In the case of the telecommunication system, the existing station radio system was replaced with a new system that employs radio trunking technology.
Units' 1 and 2 telecommunication systems are cross-connected to provide redundancy and to provide for more efficient use of radio communication.
There are four (4) antennas located in the Auxiliary Building (common to both units),
with two (2) antennas dedicated per unit on alternate floors of the Auxiliary Building. A coaxial cable trunk line for each unit's communication system runs through the Auxiliary Building on alternate floors. The two (2) Auxiliary Building antennas associated with that unit's trunk line connect to the trunk line via a cable and an in-line "tee."
The primary radio system, consisting of the trunking controllers and repeaters, is located at a new microwave tower site which is located in the station switchyard. Under normal system operation, radio -traffic is managed by the central controller and passes through the trunking repeaters.
In the event of a failure of the primary system, conventional emergency service will be maintained by backup repeaters installed within the plant protected area. The switch over to the backup repeaters is initiated by station personnel by manually connecting the backup feed connection.
The three new conventional backup repeaters are located in the same area as the existing repeaters in the Cable Spreading Room. They-utilize the same power feeds (semi-vital bus) and are provided with battery backup.
Units' 1 and 2 communication cable and antennas are routed in separate fire areas with the exception of the Cable Vaults and the Auxiliary Building. In the Cable Vaults, the communication system consists of cables which feed antennas inside the Containment Buildings. Junction boxes were installed in the electrical penetration area of the cable vaults in order to connect, when needed, the backup containment antenna of one unit to the primary antenna system of the opposite unit. A fire in either cable vault could cause both the primary and secondary emergency communications to its respective
l containment to be damaged. A backup coaxial cable and antenna are available in the Auxiliary Building to reestablish communications within the Cable Vaults to containment when needed.
The communication system within the Auxiliary Building consists of each unit's cable trunk lines and antennas. The antenna systems are routed on opposite sides of the Auxiliary Building maintaining separation between antenna systems of generally more than 50 ft. The Unit 1 cable trunk line is routed outside from the roof of Unit 1 Turbine Building (T/B) to the elevator equipment room located on the south-west corner of the Auxiliary Building roof. The cable is directed down the exterior elevator shaft wall and enters through the Auxiliary Building west wall on elevation 45 ft.-1 O in. Once in the Building the cable is installed along the west wall of the Building and is directed down to the 13 ft.-0 in. elevation through existing floor penetrations. Antennas are connected to the cable trunk line on the 45 ft.-10 in. and 13 ft.-0 in. elevations. In the northwest corner of the Auxiliary Building, elevation 13 ft.-0 in., the cable "tees" and one line goes into Unit 1 CV and the other line is directed east along the north wall of the Auxiliary Building and into Unit 2 CV.
Unit 2 cable trunk line originates on the roof of Unit 2 T/B and enters the T/B through its north wall. The cable is directed from the T/B through the Cable Spreading Room and into the southeast corner of the Auxiliary Building. Once in the building the cable is installed along the east wall of the building and is directed down to the 27 ft.-6 in. and 2 ft.-0 in. elevations through existing floor penetrations. Antennas are provided on elevations 27 ft.-6 in. and 2 ft.-0 in. through "tee" connections to the cable trunk line.
The cable "tees" along the east wall of the building, at the 13 ft.-0 in. elevation and one line runs west into Unit 1 CV and the other line is directed into Unit 2 CV.
Separation of the Unit 1 and Unit 2 communication systems within the Auxiliary Building is similar to the separation of the charging pump system within the Auxiliary Building as currently described in Exemption #1. The Exemption explains the different fire zones within the Auxiliary Building, as well as the physical and electrical separation of the Unit 1 and Unit 2 charging pump systems. Similarly, it is not considered credible for a fire in the Auxiliary Building to disable the telecommunication system due to the following:
The Unit 1 and Unit 2 communication cable and antenna systems are in separate fire areas that meet the criteria of being physically and electrically independent of one another. The two systems are electrically independent of one another and, except for the 13 ft. elevation, are routed on alternate floors along opposite walls of the Auxiliary Building providing a horizontal separation of more than 50 ft. On the 13 ft. elevation, the containment back-up antenna cables can be disconnected if damaged, and physical independence is provided by a spare antenna cable which allows for cross-connecting each unit's antenna system.
The two cables that are in the closest proximity to each other on the 13 ft.
elevation are routed to the opposite Unit's back-up antennas inside Containment.
These antennas are not normally used, and their switch in the electrical penetration room is normally open.
The Containment back-up antennas are provided in the event of damage to the Containment main antennas (e.g., a fire inside Containment or in the electrical penetration room). If a fire on the 13 ft.
elevation of the Auxiliary Building damages both Containment back-up antenna
, cables, the cables can be -disconnected at a "tee" connection, since the Containment back-up antennas would not be needed.
If both the main and the back-up antenna cables of one Unit are damaged (e.g., a fire in the electrical penetration room or on either side of the Unit 1 or Unit 2 13 ft. elevation), the spare cable can be easily connected between a tee" connection on the opposite Unit's system to a Containment penetration on the affected Unit.
"Tee" connections are designed to be easily disconnected and reconnected.
The two Containment backup antenna cables on the 13 ft. elevation are routed in a corridor along the north side of the building. Fixed combustibles in the corridor are negligible.
Fire detection is provided in strategic locations and in areas where there are concentrations of combustibles. The current configuration will provide warning of a fire that will alert station personnel and enable the fire brigade to respond to an alarm.
The concrete construction and low combustible loading grea~ly reduce the exposure to the communication system.
A water spray deluge system and CO2 system are provided to protect against a fire involving the charcoal filters on the 45 ft.-10 in. elevation of the Auxiliary Building.
Where a cable tray crosses between fire zones, two horizontal fire stops have been provided to eliminate the tray from being considered as an intervening combustible.
In summary, the installation of the telecommunication system does not create an unreviewed safety question since the installation is consistent with the configuration described in the existing Exemption Request # 1.
' 1 Updated Appendix R Exemption Request #1 Surry Power Station Units 1 and 2
1 Rev. 3 12/96
- 1. AUXILIARY BUILDING - PARTIAL AREA FIRE DETECTION AND LACK OF FIXED FIRE SUPPRESSION SURRY POWER STATION EXEMPTION REQUEST Per the provisions of 10 CFR 50.12, Virginia Electric and Power Company (VEPCO) requests exemption from the specific requirements of Appendix R, Section 111.G.3, requiring the fire detection and fixed suppression to be provided in the fire area, room, or zone under consideration.
This request applies to Surry Power Station Units 1 and 2.
DESCRIPTION OF EXEMPTION A fire in the Auxiliary Building (Fire Area 17, which includes fire zones 17-1 a and 17-2a) has the potential to damage the charging pumps, the charging pump-component cooling water pumps, and all associated power and control cable for this equipment. A fire in the Auxiliary Building also has the potential to damage both the Unit 1 and Unit 2 telecommunication system antennas and trunking lines. The radio system is a backup to the normal plant communication Gaitronics system. The Units 1 and 2 Auxiliary Building antennas operate independently of each other and provide backup (alternative shutdown capability) for the opposite Unit's radio system.
Partial area detection is provided in. the Auxiliary Building, but no full area fixed fire suppression is provided in Fire Area 17.
1-1
e Rev. 3 12/96 AREA DESCRIPTION Fire Area 17 consists of the Auxiliary, Fuel, and Decontamination Buildings at Surry Power Station Units 1 and 2. The buildings are __ located side by side in north-south orientation, with Auxiliary Building to the south, the-Decontamination Building to the north, and the Fuel Building in the center (see Figure 1.1 ). This fire area contains the charging pumps, the component cooling water (CCW) pumps, the charging pump-component cooling water pumps, and the associated cabling and valves for all pumps.
Fire Area 17 is bounded to the south by the Service Building and each unit's Cable Vault/Tunnel (Fire Areas 1 and 2), to the north by the exterior, to the east by Primary Containment and the Cable Vault/Tunnel for Unit 2 (Fire Areas 16 and 2, respectively),
and to the west by Primary Containment and the Cable Vault/Tunnel for Unit 1 (Fire Areas 15 and 1, respectively). All barriers that abut adjacent fire areas are of 3-hour
-rated reinforced concrete-construction,- and electrical and piping penetrations are sealed with 3-hour rated Dow Corning silicone RTV foam, except for penetrations to the containment.
The Auxiliary Building is a four-story structure consisting of the 2 ft.-0 in., 13 ft.-0 in., 27 ft.-6 in., and 45 ft.-10 in. elevations. The CCW, charging pumps, and the charging pump-component cooling water pumps are located on the 2 ft.-0 in. elevation, with the CCW pumps in the main open floor area of this elevation, and each charging pump in a 1-2
e Rev. 3 12/96 separate cubicle accessed from the 13 ft.-0 in. elevation.
The charging pump-component cooling water pumps, two for Unit 1 and two for Unit 2 are located outside their respective units'_charging_pump cubicles as shown in Figure 1.2. Cable for these pumps are routed up to the 13 ft.-0 in. elevation, and then to the respective unit's Cable Vault/Tunnel.
The 2 ft.-0 in. and 13 ft.-0 in. elevations are subdivided into fire zones using the guidance provided by Generic Letter 86-10, Section 3.1.5, which states, "Where alternate or dedicated shutdown is provided for a room or zone, the capability must be physically and electrically independent of that room or zone." These fire zones are shown on Figures 1-2 and 1-3, and are described in more detail in the Fire Hazards Analysis section below.
The main access point in the Auxiliary Building is through its south wall on the 27 ft.-6 in. elevation via a 3-hour rated fire door. Access is provided into each unit's Cable Vault/Tunnel (Fire Areas 1 and 2) on the 13 ft.-0 in. elevation via 3-hour rated fire doors. Access is provided into the Fuel Building from the 45 ft.-1 O in. elevation; at this elevation, no fire rated barrier separates the two buildings.
The Fuel Building portion of Fire Area 17 is a two-story structure consisting of the 6 ft.-
10 in. and 47 ft.-4 in. elevations. Access to the Fuel Building is through its southern 1-3
Rev. 3 12/96 boundary at the 45 ft.-10 in. elevation from the Auxiliary Building. Additional access points are available from the exterior on the northern boundary.
The Decontamination -Building portion of* -Fire Area 17 is a three-story structure consisting of the 6 ft.-10 in., 27 ft.-0 in., and 47 ft.-4 in. elevations.
Access to the Decontamination Building is through its northern boundary from the exterior.
FIRE PROTECTION SYSTEMS An automatic detection system that alarms in the continuously manned Control Room is provided in the Auxiliary Building portion of Fire Area 17. Smoke detectors are located on each elevation of the Auxiliary Building, consisting of both ceiling-mounted smoke detectors and duct detectors. One ceiling-mounted detector and one duct detector are provided in each charging pump cubicle. Two ceiling mounted detectors are installed
- - -above each unit's-charging pump-component -cooling water pumps that also alarm in the continuously manned Control Room.
Portable extinguishers and manual hose stations are provided on all levels of the Auxiliary Building for fire fighting purposes.
The charcoal filters on the 45 ft.-10 in. elevation of the Auxiliary Building have fire suppression systems (either total flooding carbon dioxide (CO2 ) or water spray deluge systems).
1-4
Rev. 3 12/~6 The Fuel and Decontamination Building portions of Fire Area 17 are protected by automatic detection systems that alarm in the continuously manned Control Room. The Fuel Building-~_ is provided with. ceiling-mounted smoke detectors, and the Decontamination Building-is provided-with duct detection.* Automatic suppression is not provided in either the Fuel or Decontamination Buildings; however, portable extinguishers and manual hose stations are provided for fire fighting purposes.
SAFE SHUTDOWN EQUIPMENT The Auxiliary Building portion of Fire Area 17 contains charging pumps, CCW pumps, charging pump-component cooling water pumps, and the associated cabling and valves for safe shutdown purposes.
This area also contains the instrument cables for indication of parameters at the Remote Monitoring Panel, as well as ventilation system components required for cooling of safe shutdown equipment.
Also located in the
- Auxiliary Building-is the telecommunication system antennas and cable trunk lines. The telecommunication system is utilized to assist with compliance to Appendix R requirements for bringing the station to cold shutdown during an emergency situation.
The telecommunications system provides -support for both hot -and cold shutdown operations.
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Rev. 3 12/96 FIRE HAZARDS ANALYSIS The fire hazards analysis is divided into several sections. The first four sections explain the configuration of the charging pump system_ in_ the Auxiliary Building including physical* and electrical separation.
- The next *area of the analysis explains other shutdown components found in the Auxiliary Building. The remainder of the analysis describes the combustible loading of Fire Area 17 and the fire protection features.
Charging Pump System Surry Power Station is a two-unit plant that utilizes buildings such as the Auxiliary Building to house similar equipment for both units.
In some cases, this similar equipment has been cross-connected to allow greater flexibility and a high degree of safety.
One system that was* cross-connected (as required by the Fire Protection Safety Evaluation Report issued by the NRC in 1979 for Surry) is the charging pump system. The discharge header for each unit's charging pumps is cross-connected, but isolated by two normally closed valves. In the event one unit lost all three charging pumps, the unaffected unit's charging pumps could provide charging. Therefore, the charging pumps for Unit 1 provide alternate shutdown capability for the Unit 2 charging pumps and visa versa.
Appendix R permits the use of alternate shutdown components provided that alternate components (including cabling and associated equipment) are independent of the area, 1-6
e Rev. 3 12/96 room, or zone under consideration. In addition, fire detection and a fixed suppression system should be installed in the area, room or zone under consideration. This analysis will show that the charging pumps and their appurtenances are located in separate fire
- zones (as stated by the original Appendix R document and defined -by Generic Letter
- 86-10), and that the current fire detection configuration, even with the lack of fixed suppression, provides a level of protection equivalent to that required by Appendix R, Section 111.G.3.
Fire Zones The 2 ft. and 13 ft. elevations are each divided into two fire zones using the guidance provided by the Generic Letter 86-10, Section 3.1.5. These zones are based on the physical and electrical separation of safe shutdown components. The zone divisions are described below:
Fire zone 17-1 a is located on the 2 ft. elevation of the Auxiliary Building and includes the area located on the Unit 1 side (or west) of the centerline (running north-south) of the Auxiliary Building. The component located in this area is the Unit 1 charging pump discharge cross-connect valve. The Unit 1 charging pump cubicles are not considered part of this zone because they have heavy reinforced concrete walls and do not open to the 2 ft. elevation.
Fire zone 17-1 b is located on the 13 ft. elevation and includes the area located on the Unit 1 side (or west) of the centerline (running north-south) of the Auxiliary Building. The zone includes the Unit 1 charging pump cubicles, the Unit 1 1-7
e charging pump suction valves (11158 and 11150), and the power cables for the Unit 1 charging pumps.
Fire zone 17-2a includes Unit 2 areas located on the 2 ft.
elevation of the Auxiliary Building east. of.the centerline described above. The component located in this area is the Unit 2 charging pump discharge cross-connect valve. The Unit 2 charging pump cubicles are not considered part of this zone because they are separated from the zone by heavy reinforced concrete walls and do not open to the 2 ft.
elevation.
Fire zone 17-2b is located on the 13 ft. elevation and includes the Unit 2 area, east of the centerline of the Auxiliary Building. The zone includes the Unit 2 charging pump cubicles, the Unit 2 charging pump suction valves
- (21158 and 21150), and the power cables for the Unit 2 charging pumps.
Rev. 3 12/96 The basis for the physical separation and electrical independence of the major safe shutdown components is given below.
Separation of Pumps*and Valves The Unit 1 charging pumps are located back-to-back against the Unit 2 charging pumps on the 2 ft.-0 in. elevation. Each charging pump is totally enclosed in a cubicle, with 18 in. thick concrete walls, that reaches up to the 2 ft.-0 in. elevation ceiling. The cubicle walls rise up to the ceiling of the 13 ft.-0 in. elevation on three sides. The cubicles are open on the 13 ft.-0 in. elevation on the side facing their respective unit (i.e., Unit 1 cubicles are open on the west side, and the Unit 2 cubicles are open on the east side).
1-8
e Rev. 3 12/96 The floor and ceiling of the charging pump cubicles are 2 ft. concrete slabs. A common exhaust header duct is shared by the three charging pumps associated with each unit.
The ducts penetrate the interior walls of the cubicles just below the ceiling at elevation
- 25 ft.-6 in. No fire dampers have been provided in the individual cubicle exhaust ducts feeding into this header.
The Unit 1 and Unit 2 charging pump component cooling water pumps are located on the 2 ft.-0 in. elevation outside the west and east walls of the Unit 1 and Unit 2 charging pump cubicles, respectively. However, these pumps are not required for hot shutdown.
They are shielded from one another by the charging pump cubicle walls which are 18 in. concrete at this elevation.
In addition, they are separated by at least 65 ft.
horizontally. Access to this area is via stairs at the 13 ft.-0 in. elevation at the northwest corner of the Auxiliary Building.
The Unit 1 charging pump suction valves (MOV 1115B and MOV 1115D) are located in charging pump cubicle 1 C. The Unit 2 charging pump suction valves (MOV 2115B and MOV 2115D} are located in charging pump cubicle 2C. As explained above, these are separat~ fire zones divided by a heavy concrete barrier wall.
As shown on Figure 1-2, the Unit 1 charging pump components are located within fire zones 17-1a and 17-1b, and the Unit 2 charging pump components are located within fire zones 17-2a and 17-2b. Where there is less than 20 ft. of horizontal separation 1-9
.,., L' I<
e Rev. 3 12/96 between the components, they are separated by an 18 in. reinforced concrete wall that extends from floor to ceiling on both elevations. The charging pumps and charging suction MOVs are enclosed by the cubicle on the 2 ft.-0 in. elevation. On the 13 ft.-0 in.
elevation where one face* of the cubicle is open, exposure to the pumps *is mitigated because of the 3-foot dike in the opening and the location of the pumps on the lower elevation. In addition, each unit's cubicle opening faces in a different direction so a single fire would not expose both unit's pumps.
Therefore, the pumps and valves associated with the charging pump system for each unit are -provided with adequate physical separation.
Electrical Separation The charging pump power feeds for Units 1 and 2 rise up from the 2 ft.-0 in. elevation, within their respective cubicles, to the 13 ft.-0 in. elevation and exit toward their respective Cable Vault/Tunnels.- The routings of the.cable on the 13 ft.-0 in. elevation is shown on Figure 1.3. The minimum separation for the Unit 1 and Unit 2 charging pump cables is greater than 40 ft. The only intervening combustibles consist of a cable tray that runs perpendicular to the "A" and "C" charging pump feeds of Unit 1 and Unit 2.
This cable tray penetrates a partial wall that extends approximately 6 ft. down from the ceiling at the 13 ft.-0 in elevation.
In order to mitigate the cable tray becoming an intervening combustible, the tray has been fire stopped at the partial height wall and at a point approximately 20 ft. east. This will prevent a fire from exposing the cable tray 1-10
Rev. 3 12/96 on both sides of both fire stops. Therefore, a minimum of 20 ft. of separation without intervening combustibles exists between the Unit 1 and Unit 2 charging pump power feeds. In addition, the B charging pump power feeds for Units 1 and 2 are routed away from the A and C charging pump power feeds* as shown on Figure 1.3. This routing adds another level of protection to ensure that two charging pumps will be available for safe shutdown in case of a fire in this area.
The power feeds for the Unit 1 and Unit 2 charging pump-component cooling water pumps are run in rigid steel conduit to the 13 ft.-0 in. elevation. Refer to Figure 1.2 for cable routing.
The cables then turn into their respective Cable Vault/Tunnels.
Separation of the two units charging pump-component cooling water pumps and their associated power feeds is a minimum of 65 ft. Physical separation is provided by the charging pump cubicles (see Figure 1.2).
The power feeds for the suction MOV's rise from cubicles 1 C and 2C to the 13 ft.-0 in.
elevation. They are then routed to their respective units' Cable Vault/Tunnel. The same reasoning used for the charging pump power feeds is applicable here, since the cables have a similar routing.
As described above, the Unit 1 and Unit 2 charging pump systems power feeds as divided into zones 17-1 b and 17-2b are electrically separate from one another.
1-11
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Rev. 3 12/96 Therefore, the current configuration of the Unit 1 and Unit 2 charging systems meet the definition of separate fire zones as given in Generic Letter 86-10, Section 3.1.5.
Other Shutdown Components in Fire Area 17 There are several other components in Fire Area 17 that are required for the Appendix R safe shutdown process. These components are identified and evaluated below:
On the 2 ft.-0 in. elevation, the CCW pumps are arranged
- side-by-side and are within 20 ft. of each other.
These
- pumps are needed only for cold shutdown.
A repair procedure has been prepared to facilitate the replacement of
-two out of the four CCW pump motors and their associated cables in case of a fire in this area. Two more spare motors and their associated cables are maintained on-site for this repair.
Therefore, in terms of Appendix R requirements, there is no need for further fire protection.
The cables for the remote monitoring panel are routed through the upper elevations of the Fuel and Auxiliary Buildings.
This panel provides indication of plant
- *parameters from *inside the respective unit's containment via the Fuel Building penetrations (see Exemption Request 17).
The remote monitoring panel provides alternate shutdown capability for indication provided in the Control Room and routed through both the Emergency Switchgear Room and the Cable Vault/Tunnel of each unit. Appendix R requires
- that the alternate capability be in an area physically and electrically independent of the area of concern (the Control Room, ESR, and CV/T) which is fulfilled, since they are in
. separate fire areas; Detection and fixed suppression is not needed for the remote monitoring panel cabling since it is not in the area of concern.
Therefore, the current configuration is acceptable in terms of Appendix R.
1-12
The Auxiliary Building Ventilation System is located on the 45 ft.-0 in. elevation of the Auxiliary Building. An Exemption Request (#18) has been submitted concerning the lack of full area detection and suppression.
The communication system within the Auxiliary Building consists of each Unit's cable trunk lines and antennas (See Figure 1-4). There are 4 antennas (one per floor) located in the Auxiliary Building with 2 antennas dedicated per Unit on alternate floors of the Auxiliary Building.
The Unit 1 cable trunk line is routed outside from the roof of the Unit 1 Turbine Building (TB) to the elevator equipment room located on the south-west corner of the Auxiliary Building roof.
The cable is directed down the exterior elevator shaft wall and enters through the Auxiliary Building west wall on elevation 45 ft.-10 in. Once inside the Building, the cable is installed along the west wall of the Building and is directed down to the 13 ft.-0 in. elevation through existing floor penetrations.
Antennas are connected to the cable trunk line on the 45 ft.-10 in. and 13 ft.-0 in. elevations. In the northwest corner of the Auxiliary Building, elevation 13 ft.-0 in., the cable "tees" and one line goes into Unit 1 Cable Vault/Tunnel (CV/T) and the other line is directed east along the north wall of the Auxiliary Building and into Unit 2 CV/T.
The Unit 2 cable trunk line originates on the roof of Unit 2 TB and enters the TB through its north wall.
The cable is directed from the TB through the Cable Spreading Room and into the southeast corner of the Auxiliary Building. Once in the building the cable is installed along the east wall of the building and is directed down to the 27 ft.-6 in. and 2 ft.-0 in.
elevations through existing floor penetrations. Antennas are provided on elevations 27 ft.-6 in. and 2 ft.-0 in. through "tee" connections to the cable trunk line. The cable "tees" along the east wall of the building at the 13 ft.-0 in. elevation, and one line runs west into the Unit 1 CV/T and the other line is routed into Unit 2 CV/T.
1-13 Rev. 3 12/96
The Unit 1 and Unit 2 communication cable and antenna system, except for the 13 ft. elevation, are routed on alternate floors and along opposite walls of the Auxiliary Building providing a horizontal separation of more than 50 ft.
On the 13 ft. elevation, the containment back-up antenna cables can be disconnected if damaged, and spare antenna cable is provided to allow for cross-connecting each Unit's antenna system.
Rev. 3 12/96 As shown by the evaluation, the other safe shutdown components in Fire Area 17 either currently meets Appendix R criteria or have a separate exemption request. Therefore, the remainder of the analysis will primarily consider the charging pump system as the safe shutdown component of concern in the fire area.
Building Configuration The Auxiliary Building is a noncombustible structure that is primarily constructed of reinforced concrete on the lower two elevations.
The floors are either concrete or expanded metal grating that allows smoke and heat to rise away from the lower elevations.
The combustible loading on all four elevations of the Auxiliary Building is low. The Equivalent Fire Severity is less than 10 minutes for elevation 2 ft.-0 in. and less than 25 minutes for elevation 13 ft.-0 in. The combustible loading information is taken from the 1985 Combustible Loading Analysis for Surry. Lube oil and cable insulation are the primary combustibles.
The lube oil contribution is calculated at the "worst case" 1-14
y lt..J J' e
Rev. 3 12/96 condition (i.e., oil change time), when there is transient lube oil in the area. This oil is not normally present while the unit is operating. The cable insulation has fire retardant qualities as described in Section B of the Preface to Exemptions.
The equivalent fire severities for the upper two elevations is approximately 30 minutes for the 27 ft.-6 in. elevation and 15 minutes for elevation 45 ft.-0 in.
Again, cable insulation makes up the majority of the combustible load along with the charcoal filter on the 45 ft.-0 in. elevation.
The low combustible loadings on each floor coupled with the open grating and noncombustible construction will reduce the exposure to the charging system and other safe shutdown components in the Auxiliary Building.
The combustible loadings of the Fuel and Decontamination Buildings are not considered since they pose no exposure threat to the 13 ft.-0 in. and 2 ft.-0 in.
elevations of the Auxiliary Building. Heavy concrete walls provide separation between the Fuel and Auxiliary Buildings on these two elevations.
Fire Detection Fire detectors are installed at various locations in.the Auxiliary Building, although their layout does not meet NFPA-72E spacing. The detectors are primarily located in the vicinity of the cable trays at elevation 13 ft.-0 in. and 27 ft.-6 in. Detectors are located in 1-15
Rev. 3 12/96 each charging pump cubicle and above each charging pump-component cooling water pump. The detectors in their present configuration are designed to respond to fires that
_ may expose the cable tray or _power feed cables to the charging system. This early warning will allow the fire brigade additional time to respond and limit fire damage.
Exposure to the individual charging pumps from a fire outside the individual cubicle is not considered due to the construction of the cubicle.
Full area detection in the remaining sections of fire Area 17 is not needed to achieve a level of protection equivalent to that required by Appendix R for the following reasons:
The charging system components are located on the lowest two elevations of the Auxiliary Building. Exposure from a fire on the upper elevations is unlikely. In addition, exposure to the charging pump systems from either the Fuel or Decontamination Buildings is not credible. The only opening to these buildings from the Auxiliary Building is on the 45 ft.-0 in. elevation.
The average combustible loading throughout the Auxiliary Building is considered low.
The Unit 1 charging system is separated from the Unit 2 charging system by at least 40 ft. free of intervening combustibles or by heavy concrete walls.
The Unit 1 and Unit 2 communication cable and antenna system, except for the 13 ft. elevation, are routed on alternate floors and along opposite walls of the Auxiliary Building providing a horizontal separation of more than 50 ft.
On the 13 ft. elevation, the containment back-up antenna cables can be disconnected if damaged, and spare antenna 1-16
i
)
'l_) I*
e cable is provided to allow for cross-connecting each unit's antenna system.
Suppression Rev. 3 12/96 The only suppression systems in Fire Area 17 protect the charcoal filters on elevation 45 ft. of the Auxiliary Building. Physical and electrical separation of the Unit 1 and Unit 2 charging pump systems has been established without the need for a fixed fire suppression system throughout Fire Area 17.
The early warning of a fire condition provided by the detection system will enable the station fire brigade to reach the fire earlier on the fire growth curve. The earlier the fire is attacked, the faster it can be extinguished with a minimal amount of extinguishing agent. Portable fire extinguishers and manual hose stations are located through Fire Area 17.
CONCLUSION VEPCO has determined that the current configuration will provide a level of protection equivalent to that required by Appendix R, Section 111.G.3. The technical bases which justify the exemption are summarized below:
- 1.
The Unit 1 and Unit 2 charging pump systems are in separate fire zones that meet the criteria of being physically and electrically independent of one another.
- 2.
Fire detection is provided in strategic locations, in areas where there are concentrations of combustibles and near shutdown components in the Auxiliary Building. The current configuration will provide warning of a fire 1-17
l
'>>./ t,,
J Rev. 3 12/96 that will alert station personnel and enable the fire brigade to respond to an alarm.
- 3.
The configuration of Fire Area 17 (including heavy concrete construction, restricted
- access, low overall combustible
- loading, and compartmentalization) m1mm1zes exposure to the systems and components used to support safe shutdown.
- 4.
The Unit 1 and Unit 2 communication cable and antenna system are electrically independent of one another and, except for the 13 ft. elevation, are routed on alternate floors along opposite walls of the Auxiliary Building providing a horizontal separation of more than 50 ft.
On the 13 ft.
elevation, the containment back-up antenna cables can be disconnected if damaged, and spare antenna cable is provided to allow for cross-connecting each unit's antenna system.
Attached are photographs for the exemption requested which show either the general area and/or specific equipment in the area of concern (Photograph Nos. 8406132, 8406133, 8406134,8406137,8406135,840733,840730).
1-18
Rev. 3 12/96
SUMMARY
EVALUATION TABLE FIRE AREA: 17 DESCRIPTION: Auxiliary, Fuel and Decontamination Buildings A.
Area Description 1.
Construction
- a.
- b.
C.
Walls Floor Ceiling B.
Safe Shutdown Equipment C.
Fire Hazards Heavy reinforced concrete - Fire area to fire area Un-insulated metal siding - Exterior walls Heavy reinforced concrete Unrated exterior Six charging pumps and associated cables and valves Four charging pump-component cooling water pumps and associated cables and valves Four component cooling water pumps and associated cables and valves Instrument cables for indication parameters at the remote monitoring panel Unit 1 and Unit 2 telecommunication cable and antenna systems 1.
Types of Combustibles
- a.
Auxiliary Building 1-19
cable insulation lubricating oil Class A combustibles grease charcoal
- b.
Fuel Building cable insulation Class A combustibles grease D.
Existing Fire Protection 1.
Detection Rev. 3 12/96 Ceiling-mounted and duct smoke detectors in Auxiliary Building Ceiling-mounted detectors in Fuel Building Duct smoke detector in Decontamination Building
- 2.
Automatic Suppression CO2 and water at charcoal filters
- 3.
Manual Suppression Extinguishers and hose stations on each level of the Auxiliary Building Extinguishers and hose stations in the Fuel and Decontamination Buildings 1-20
84*VS*0113.
P095*E*OOO 15 1
FUEL BUILDING FIRE AREA i 7 AUXILIARY BUILDING DEGON BUILDING 16 2
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FIREARl::A 17 Engineering Planning and Management, Inc.
- flOURENO..
, 1.1 Tlqe 9peen StrNt,,flftlirqha111, MA
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NOTE:
FIRE ZONE 17-fa FIRE ZONE 17-20.
. I 1-CH-P*1A I 2-CH-P-1A I 13'*0" ~
I 1*CH*P*18 2-CC*P*2A I 2-CH-P-181 I 1-CH*P-1C I 2-CH-P-1C I 8
)(
I
- I 65' I
UPTO I
I 13'*0" EL. 2'-0" AUXILIARY BUILDING INDICATES THE LOCATION OF THE CHARGING PUMP CROSS-CONNECT VALVES.
REPRESENTS FIRE ZONE BOUNDARY.
VIRGINIA ELECTRIC & POWER COMPANY SURRY POWER STATION UNITS 1&2 n
13'*0" 2-CC-P-213 UPTO 13'-0" REV. 2 I 0/85 '
FIREAREA 17 FIGURE NO AUXILIARY BUILDING ELEV. 2 1-0 11 1.2
NOTE:
REPRESENTS FIRE ZONE BOUNDARY.
FIRE ZOflE 17-1 b I *
- 8 FIRE Z<N:: 17-2 b I
I I
- I PARTIAL WAll Pt.AN £L. t:r-G" AUXILIARY BUILDING VIRGINIA ELECTRIC & POWER COMPANY SURRY POWER STATION UNITS 1&2 REV. 2 I 0/85 FIREAREA 17 FIGURE NO AUXILIARY BUILDING ELEV. 13 1
- 0 11 1.3
,......:.i",'.:.:-*... ~-* -----------
e~-: *.......
MAIN RCP-4C UNIT *1 PBX ROOM EL. 27' EL. 13' EL. 45' HARDWIRE CENTRAL SITE STATION SWITCHYARD UNIT
- 1 CONTAINMENT BACK-UP SYSTEM ELECTRICAL PENETRAT ION ROOMS BACKUP 150' SPARE.
ANTENNA CABLE EL. 13' AUXILIARY BUILDING MAIN UNIT *2 EL. 2' EL. 27-6' 2-CO-AMP-1 SERVICE BUILDING U2 CABLE SPREAD ROOM TURBINE BUILDING
. ROOF EL. 45' UNIT *2 THRU ROOF RCP-3D VIRGINIA ELECTRIC & POWER CO.
SURRY POWER STATION UNITS 1 & 2 APPENDIX R BLOCK DIAGRAM COMMUNICATION SYSTEM FIGURE 1-4