ML19256F848

Forwards Responses to Paragraphs 3.19,3.1.20,3.2.1,3.2.2, 3.2.8 & 3.2.9 Re Fire Protection SER & Amends to Ol.Balance of Response to Paragraph 3.2.1 Delayed Due to Manpower Commitments of TMI Requirements

ML19256F848
Person / Time
Site:	Calvert Cliffs
Issue date:	12/21/1979
From:	Lundvall A BALTIMORE GAS & ELECTRIC CO.
To:	Reid R Office of Nuclear Reactor Regulation
References
013-261-0, 13-261, NUDOCS 7912260220
Download: ML19256F848 (350)

Text

BALTIMORE GAS AN D ELECTRIC COMPANY GAS AN D ELECTRIC BUILDING B ALTI M O R E, M A RYLAN D 21203 Anmun E. Luwov4LL,Ja.

December 21, 1979 v,cc p.c,.oc=r Sweet' Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attention: Mr. Robert W. Reid, Chief Operating Reactors Branch #4 Division of Operating Reactors

Subject:

Calvert Cliffs Nuclear Power Plant Units No. 1 C 2, Docket No. 50-317 C 50-318 Fire Protection Safety Evaluation Report and Amendments to Facility Operating License File: 013-261-0, L-037-F

Reference:

(a) NRC letter dated September 14, 1979 from Reid to Lundvall, same subject (b) BGCE letter dated November 13, 1979 from Lundvall to Reid, same subject Gentlemen:

In accordance with our referenced letters above, enclosed please find forty (40) copies of our responses to paragraphs 3.19, 3.1.20, 3.2.1 (partial), 3.2.2, 3.2.8, and 3.2.9. The balance of the response for para-graph 3.2.1, " Fire Hazards Analysis" is delayed due to manpower commitments to Three Mile Island requirements and will follow under separate cover.

Very truly yours,

/

Enclosure cc: J. A. Biddison, Esquire G. F. Trowbridge, Esquire Messrs. E. L. Conner, Jr. - NRC J. W. Brothers - Bechtel jh} 7912260 /

3.1.19 3.1.19 Fire Detection in Safety-Related Areas (4.2, 5.1, 5.2, 5.3, 5.4, 5.5, 5.6, 5.7, 5.8, 5.9, 5.14, 5.19, 5.21, 5.27) The licensee has proposed to install appropriate fire detection devices in some additional safety-related areas. We will further evaluate this modification when the design details become available.

Response

Reference the response to SER Item 3.2.1, " Fire Hazards Analysis", and in particular the methodology discussion on Category A through D and Criteria 5. Table 1 lists " Proposed Plant Modifications for Fire Protection Upgrade" and identifies those rooms that are to be equipped with fire / smoke detection. The fire / smoke detection sys-tems will incorporate various types of detection such as heat, smoke, and flame detectors appropriate to the occupancy protected. Credit is taken for sprinklers, in combination with appropriate water flow alarms, as providing required fire detection when installed at the ceilings of rooms to protect both equipment and cables. 1638 306

3.1.20 3.1.20 Unprotected Doorways (4.9.1, 5.1, 5.2, 5.4, 5.5, 5.7, 5.16, 5.18, and 5.22) UL or FM listed fire doors of appropriate ratings will be installed, or acceptable alternate provided to protect the unprotected doorways in fire barriers separating various safety-related plant areas, including five doorways in the computer rooms currently provided with nonfire rated bullet-proof doors.

Response

Reference the response to SER Item 3.2.1, " Fire llazards Analysis", and in particular the methodology discussion on criteria 2. Con-clusion of the analysis shows that no listed fire doors are to be replaced. Several existing unrated doors are to be upgraded or the installation of wet pipe sprinkler systems in areas with unrated doorways will be used in lieu of rated doors. The use of bullet-proof doors in the control room complex is for security purposes and since this area is continuously manned on a 24 hour basis, detection of an incipient fire would be prompt enough to mitigate any significant damage due to a fire and certainly before safe shutdown would be jeopardized. 1638 307

3.2.2 3.2.2 Acequacy of Detector Installations (4.2) The licensee will provide the results of a study or tests to verify that proper consideration has been given to such factors as ceiling height and configuration, ventilation air flow rate and pattern, location and arrangement of plant equipment and combustibles, etc. , in determining the type, number and location of the existing and the proposed fire detector installations.

Response

The existing smoke detection system is a PYR-A-LARM system con-sisting of DIS-3/5A ionization detectors wired to Model FIU-6 Fire Indicating Units and Model ZIU-6 Zone Indicating Units. The wiring system is designed in accordance with NFPA 72D Class d circuitry. The PYR-A-LARM devices are tested and listed by the Underwriters' Laboratories and the Factory Mutual System. The Los Angeles Fire Department performed comparative independent tests of fire response capability of the DIS-3/SA detector which indicated superior response times to other types of detectors. The layout, spacing, and mounting of the existing fire detection systems was determined by reprcsentatives of the Pyrotronics Com-pany and its sales engineering representatives. The design organi-zation took into consideration such factors as the burning charac-teristics of combustibles in the area, cable tray and equipment location, ceiling shape and height, HVAC air distribution patterns and velocities, and room air change rates. Detector sensitivity tests were performed following installation of the detectors and each individual detector installation wiring; mounting and sen-sitivity was verified by an experienced representative of Pyro-tronics . These tests are recorded and filed. To assure the adequacy of the fire protection system design and installation, independent review was performed and documented by experienced fire protection engineers of the Architect / Engineer organization, Bechtel Power Corporation; the owner, Baltimore Gas and Electric Company; and the insurer, Nuclear Energy Property Insurance Asso-ciation (trading now as the American Nuclear Insurers'). The fire detection system has been re-evaluated and as shown on the attached table, detector coverage is one half to one third the maximum coverage recommended by Pyrotronics in their current manual, "PYR-A-LARM Application Engineering Fundamentals". There is one exception, the Control Room, which reflects that this room is constantly attendeo. The detectors in this room were located over specific equipment areas to give prompt response in areas out of direct line-of-sight of the operators. The table does not list the existing smoke detection systems for the Cable Spreading Rooms as this system will be redesigned to release the proposed Halon 1301 Total Flooding System. 1638 308

3.2.2 3.2.J 'i ha uuccessful bidder on the proposed new Fire and Smoke Detec+. ion System will be required to test and verify that the new detectors will respond to the anticipated fires from fixed as well as postu-lated trans .t combustibles. The testing for response character-istics will consider the physical parameters of the installation such as detector spacing, type of ceiling, ventilation character-istics and mounting details. The successful bidder will be required to furnish written certification that the new system is adequate for the intended purpose. 1638 309

SMOKE DETECTOR COVERACE MAXIMtIM ALLOWED ACntAL SMOKE AIR C0VERACE EXISTING DETECTOR' CHANGES PER DETECTOR COVERAGE ZONE ROOM PER IlotlR (sq. ft.)* (sq. ft.) 1 U.1 Computer Room No. 431 15 475 237 3 U.2 Computer Room No. 406 15 475 237 6 Main Control Room 37 210 197 7 Log & Test Equipment Room El. 45' 13 575 323 8 Log & Test Equipment Room E1. 55' 9 800 323 9 Chart & Instrument Room E1. 56' 10 730 243 14 U.1 Electrical Penetration Room No. 429 1 900 384 15 U.1 Electrical Penetration Room No. 423 1 900 318 16 U.1 Switchgear Room E1. 45' 5 900 469 17 Cable Chase in 0 900 196 18 U.2 Electrical Penetration Room No. 409 1 900 384 19 U.2 Electrical Penetration Room No. 414 1 900 288 20 U.2 Switchgear Room E1. 45' 5 900 480 21 Cable Chase 28 . 0 900 196 26 U.1 Electrical Equipeent Room El. 69' 3 900 560 27 Horizontal Cable Chase No. 1 0 900 427 28 Cable Chase 1A 0 900 210 29 Cable Chase IC 0 900 144 30 U.2 Electrical Equipment Room El. 69' 3 900 560 31 Horizontal Cable Chase No. 2 0 900 427 32 Cable Chase 2A 0 900 210 33 Cable Chase 2C 0 900 144 34 U.1 Switchgear Room El. 27' 6 900 630 35 U.2 Switchgear Room El. 27' 6 900 630 78 Service Building Record Storage Room El. 45' 8 900 368

• Based on Pyrotronics publication

__4 " Application Engineering Fundamentals" Cys Table 37. (All rooms have smooth  ;, (fa surface ceilings.) g, CD

3.2.8 3.2.8 Radiological Consequences of Fire (4.14, 5.3, 5.7, 5.9, 5.20, 5.24, 5.25) The licensee will provide the results of a study of radiological consequences of a fire in areas containing radioactive materials (including a fire in a charcoal or a HEPA filter), or other areas where a fire could cause the release of radioactive materials. Additional modifications will be provided in areas where a fire could cause the re? ease of radioactive materials that could pre-clude the normal usage or occupancy of areas surrounding the plant.

Response

During the analysis and review of the plant to complete the response to SER Item 3.2.1, " Fire Hazards Analysis", the radiological conse-quences of a fire was entertained and the various radioactive mate-rials (combustible as well as noncombustible) were categorized into the following: (1) Radioactive materials contained within pipes, pumps, tanks, and vessels. (2) Charcoal and HEPA type filters. (3) Spent resins. (4) Wastes such as coveralls, gloves, boots, paper, and plastic. Radioactive materials contained within pipes, pumps, tanks, and vessels (including the spent fuel in the pool) are not released during a fire as these means of material confinement are not assumed to burst or leak during a fire. This position is appar-ently shared by the hRC as demonstrated in SER Section 5. The only credible discharge from a closed system would be from the plant radioactive liquid and gaseous discharge systems. These systems each have two valves in series which fail closed on loss of electric power or air supply. Discharge piping contains an on-line radiation monitor which will close the valves on a high radiation reading. Additionally, the discharge piping contains normally locked shut isolation valves which are only opened after a tank is sampled and its activity level is determined to be acceptable for discharge. Therefore, it the radiation monitors should fail, an unacceptable discharge would not occur. As an additional safeguard against fire damage to the liquid waste sys-tem, a wet pipe sprinkler system is proposed in Room 106. The gaseous waste system is in a fire area which has no postulated fire loading, Rooms 207 and 208. Charcoal and HEPA type filters were reviewed with a tatal of 16 charcoal filters installed in the plant: six inside containment, two in the control room HVAC system, four in the penetration room exhaust systems, two in the fuel pool exhaust system, and two in the ECCS pump room exhaust systems. All filters are normally by-passed. The filters in containment, and those for the penetration 1638 311

3.2.8 room exhaust system, and those for the ECCS pump room, are used only during post-accident conditions. The containment filters are provided with high temperature alarm and manually actuated emergency cooling water suppression systems. The spent fuel pool filters are used during fuel handling evolu-tions and after fuel handling accidents. The control room filters are used only on detection of high radiation in the control room ventilating system. Charcoal filters are contained in steel casings. TN amount of combustibles in the area of these filters, other than the filters themselves, is low HEPA and other filter media used in the plant are of fire resistive materials. After removal, these filters are packaged in Federally approved containers for the appropriate radioactive level and held in the Bailing Waste and Drumming Room 418 which is protected by a wet pipe sprinkler system until removal is arranged. Based on this and the NRC's acceptance of the installation as stated in SER Section 4.4.2, no significant release can be expected. Spent resins are stored in steel tanks and transferred in steel pipes. Transfer of this material is done by directly piping the material into a Federally approved disposal cask in a specially designed room, within the waste disposal area, shielded for radiation and devoid of any combustible material. The casks are stored in the waste disposal area which is pro-tected by a wet pipe sprinkler system until shipment. Based on the existing method of handling and storage, no release of radio-activity can be expected. Wastes are stored in steel 55 gallon drums :.upplied vith fusible link tops or steel cabinets. The use of these special tops will prevent the spread of fire into or out of the drum and will pre-clude the dispersion of airborne radioactive contaminates. A survey of the plant shows a majority of the drums having a dose rate of less than 1 millium/ hour with the major isotcpes being Cobalt 58 and 60. These isotopes form a particulate which is readily removed by sprinkler sprays, filters and by plate out. Based on this, radioactive releases due to a fire involving these types of materials would not provide a release in excess of site boundary limits nor would it preclude the normal usage or occupancy of any area of the plant. 1638 312

3.2.9 3.2.9 Effects of Fire on Radiation Monitors The licensee will provide the results of a study to demonstrate that the radiation monitor will remain operational when exposed to smoke and/or heat of a potential fire.

Response

The radiation monitoring system is not required to place the plant in a safe shutdown condition or to maintain it in a safe shutdown condition. As demonstrated in the results of a study for the radiological consequences of a fire, there exist only minimal areas where a postulated fire could cause the release of radioactive materials. It is also stated that these releases do not result in a condition which exceeds the requirements of 10CFR20. CONTAIN>ENT RADIATION SIGNAL: Four independent radiation area detectors located within the con-tainment ar) provided and, upon coincident of two-out-of-four trip signals or manual initiation from the control room, actuation occurs to isolate and secure the containment purge system. These devices are designed to operate in a LOCI environment for 100 per-cent relative humidity at 273 F and will provide audible and visual alarms if the radiation levels exceed a pre-set value or if the detector malfunctions. Due to separation between locations for the area monitors and the containment volume available, a postu-lated fire that could conceivably effect all four system channels is not considered credible. The smoke resulting from a fire will not effect the system function. A device malfunction for any rea-son will provide a single input to the 2 out of 4 coincident logic, such that a second device malfunction will isolate and secure the containment purge system. WASTE PROCESSING AREA AND STAIN PLANT VENT: The waste processing area ventilation exhaust fans discharge is provided with a continuous off-line gaseous radiation monitor system. This system ex+racts a sample from the ventilation sys-tem, analyzes the sample via a geiger-mueller tube and returns the sample to the ventilation system prior to the main exhaust pleminum. A flow indicating switch is provided to indicate mal-function of the system. The system will operate normally under the following environment conditions: +400 F minimum to 1200F maximum, sample temperature 167 F maximum and smoke atmosphere. bb l3

3.2.9 The plant vent is monitored for particulate, iodine, and gaseous activity. The equipment continuously withdraws a representative sample from the plant vent and passes the sample through a moving filter paper having a collection efficiency of 99 percent for particle sizes greater than 1.0 micron. The amount of deposited activity is continuously scanned by a lead-shielded detector. The remaining air is monitored by a separate gaseous monitor prior to returning to the plant vent. A flow indication switch is provided to indicate malfunction of the system. The gas moni-toring portion of this system is identical to the previously described waste processing system. The particulate monitoring portion of this system will operate normally under the following environment conditions: +40 minimum to 120 0F maximum and a sam-ple temperature of 140 F maximum. This portion of the monitoring system is not expected to function properly with a smoke atmos-phere from a fire. The particulate monitoring portion is provided with a normally closed bypass piping to the gas monitoring portion. Continuously on-line charcoal filters are provided in parallel with the particulate and gas analyzing system. Due to the significant volume of air flow associated with ventila-tion systems within the Auxiliary Building, dilution will reduce the resultant temperature rise caused by a fire. Further, since the majority of the plant areas served by the ventilation systems are provided with fire dampers to isolate the effects of a fire, temperatures are not anticipated to affect the gaseous monitoring portion of the main plant vent system. It should also be noted that the main plant system provides redundant monitoring for the waste processing plant areas. In the unlikely event that both of the described radiation moni-toring systems simultaneously fail, qualified plant personnel with sufficient quantities of portable radiation monitoring equipments are available to monitor effluents from the plant. 1638 314

3.2.1 3.2.1 Fire Hazards Analysis (4.1, 5.1, 5.2, 5.3, 5.4, 5.5, 5.6, 5.7, 5.8, 5.9, 3.10, 5.12, 5.13, 5.14, 5.15, 5.16, 5.17, 5.19, 5.20, 5.21, 5.23, 5.24, 5.27, 5.28, 5.30) The licensee will provide the results of an analysis to: (1) demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance, (2) identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area, (3) identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combustibles which may be introduced into or moved through the area, (4) identify the worst damage that could result from such fire, and (5) demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment. The analysis will, as a minimum, include the following considerations: (1) The possibility that redundant cables (in trays or in conduits)/ equipment may be involved in an exposure fire due to fixed or transient combustibles. (2) Effects of the fire and possible explosion, and fire fighting activities. (3) Shutdown capability without offsite power. (4) Safe shutdown consequences of possible system transients result-ing from a fire induced faulting of electrical cables. Where assumptions are made, such as operability of damaged cabling / equipment, or effectiveness of protection, etc., they will be sub-stantiated by the results of tests and/or analyses. In those plant areas where it cannot be demonstrated that safe shut-down capability can be preserved during and following the postulated fire, appropriate modification (s) will be provided to assure that the plant's shutdown capability will meet the following criteria as the minimum: 1638 315

3.2.1 (1) Following any fire, the plant can be brought to hot shutdown conditions using equipment and systems that are free of fire damage. (2) The plant shall be capable of maintaining hot shutdown condi-tions for an extended time period significantly longer than 72 hours. (3) Fire damage to systems necessary to achieve and maintain cold shutdown conditions shall be limited so that repairs can be made and cold shutdown conditions achieved within 72 hours. (4) Repair procedures for cold shutdowr. systems shall be prepared now and material needed for such repairs shall be on the site. (5) The hot shutdown condition shall be achieved with power from the offsite power system, and upon its loss, with power from the onsite power system. A dedicated power supply may be sub-stituted for the onsite power systems. (6) The power needed to achieve the cold shutdown condition may be obtained from any one of the offsite power, onsite power, and dedicated power systems. (7) When these minimum systems are provided, their adequacy shall be verified by a thorough evaluation of: (a) Systems required for hot shutdown; (b) Systems required for cold shutdown; (c) Fire damage to power distribution systems; and (d) Interactions caused by fire damage to power and water supply systems and to supporting systems, i.e., com-ponent cooling water supply.

Response

Attached find the descriptive " Fire Hazards Analysis" that delin-eates the methodology used to perform the analysis in response to Item 3.2.1. It also includes a description of safe shutdown equipment required for hot and cold shutdown. Attached also are the individual room analyses and a compilation of modifications to be incorporated in the plant as a result of the Analysis. Figures 1-11 entitled " Fire Hazards Analysis - Safe Shutdown Equipments and Raceway Locations" are incorporated as a part of this Response. 1638 316

Fila-1 CALVERT CLIFFS NUCLEAR POWER PLANT FINAL SAFETY EVALUATION REPORT

                         " FIRE HAZARDS ANALYSIS" The following " Fire Hazards Analysis" was performed in accordance with the Fire Protection Final Safety Evaluation Report, Item 3.2.1. The intent of this analysis is to provide additional detail on the adequacy of the plant capability to achieve safe shutdown in the event of a fire. The radio-logical consequences of a fire will be addressed in the response to SER Section 3.2.8.

The analysis took into account the direct concerns expressed in the SER under Sections 4.1 and the individual room evaluations described in Sec-tion 5. The approach was to first identify and then locate equipment and cables required for Hot and Cold shutdown. The location and routing of this equipment and cabling respectively is shown on figures 1 through 11. The legend on each figure identifies the appropriate safe shutdown equip-ment and raceway located within those rooms shown on the drawings. The device numbering is such that redundant equipment located on the same drawing is readily identified. It should be noted that in some cases redundant equipment will be located on different drawing figures and, therefore, in separate rooms of the plant. The followi.ng basic criteria was established for the " Fire He;ards Analysis" in order to pr ovide a unified approach to the proposed modifications for each room exclvding containment (which is addressed independently) . Fur-ther, the following criteria establishes a set of modification techniques which insures safe shutdown and provides extra protection for safety related equipmeut. " Fire Hazards Analysis" Room Categories Category A Rooms with redundant divisions of safe shutdown equipment / cable will be modified to add automatic fire suppression systems except where we have demonstrated adequate physical separation or where significant fire hazards do not exist. In the latter cases, fire detection in combination with manual fire suppression afforded by the plant fire brigade is considered sufficient. The fire suppression system will prevent the loss of either divisions unless the fire originates within one division in which case the suppression system will protect the redundant division. Wet pipe sprinkler systems will be utilized except in the rooms where discharge of fire sprinkle. systems could result in loss of reliability of equipment. 1638 317

FHA-2 Category B Rooms with only one division of safe shutdown equipment / cable will be modified to add smoke detection. Smoke detection will provide an early indication of a fire in these rooms to insure prompt response of the fire brigade to the affected room. Fire fighting procedures and pre-planned strategies are described in detail in the Calvert Cliffs Instruction 133A. The validity of the procedures and strategies for each room are verified by appropriate fire brigade drills. Safe shut-down will not be jeopardized since the redundant division is in another room. In addition, the plant operators would have early indication that one division might not be reliable and could thus effect an orderly transition to the redundant division. Category C Rooms with redundant divisions of safety related but non-safe shutdown equipment / cable will be provided with smoke detection. This will pro-vide early detection of a fire to insure prompt fire brigade response as described in Category B. Safe shutdown will not be jeopardized since the equipment and cable is not required to place and maintain the plant in cold shutdown. Category D Rooms with only one division of safety related equipment and cable (non-safe shutdown) will be provided with fire detection if significant fire loads are oresent within the area or could be introduced in the form of transient ' fire load. Criteria for Evaluation of Modifications Due to " Fire Hazards Analysis" Criteria 1 A wet pipe sprinkler system placed at the ceiling of a room which con-tains redundant safe shutdown equipment / cable will be adequate for the suppression of a fire and will not impact the function of the redundant train. Thus the continued operation of one redundant train is assured. Equipment splash shields will be used as necessary to prevent damage from water spray. Automatic sprinklers will prevent the damage of equipment / cables due to fire unless the fire originates within the equipment or cable. In this case, the sprinklers will prevent damage of the redundant equipment or cables. The ability of sprinklers to control fire and limit damage is a recognized fact throughout the fire protection community. Sprinklers are specifically recommended by the NFPA, FM and ANI for protection against fires involving high flash point combustible liquids such as those which make up the majority of transient fire loads at Calvert. Cliffs. Automatic sprinklers also provide the ability to extinguish water soluble liquids such as acetone by dilution. While extinguishment by dilution is not commonly used due to the amount of water required for most liquids (as much as four gallons of water for each gallon of flam-mable liquid), the small quantities of acetone transported through the plant combined with the proposed sprinkler density of .25 gpm per square 1638 318

FHA-3 foot make this an acceptable method of extinguishment in this case. Prior to extinguishment of either high or low flash point liquids, the cooling action of the sprinkler system provides significant pro-tection of safe shutdown equipment from heat. In conclusion, the high reliability of automatic sprinklers combined with their capa-bility of extinguishing both high flash point combustible liquids and water soluble flammable liquids provides adequate assurance that both divisions of safe shutdown related equipment will remain undamaged following an exposure fire and one division will remain undamaged fol-lowing a fire originating in the other division. Criteria 2 The addition of fire rated dcars is not necessary for rooms where a wet pipe sprinkler system is employed at one side of the doorway. Where credit is taken for automatic sprinklers in lieu of fire doors, at least one sprinkler head will be located adjacent to and immediately above the doorway to provide a water curtain to prevent extension of fire. Criteria 3 In rooms where cable trays would obstruct distribution from ceiling sprinklers, sprinklers will be located below the cable trays to sup-press transient fire hazards. In addition, automatic smoke detectors will be provided at the ceiling above the cable trays to detect inter-nally initiated fires in trays which have been demonstrated by Sandia Laboratories Tett Report " Cable Tray Fire Tests", SAND 77-ll25C, July, 1977, to be slow propagating and would allow fire brigade response as discussed in Category B. Criteria 4 For rooms which are analyzed as requiring an automatic suppression system but which would be subjected to a greater potential hazard from inadvertant actuation of a sprinkler system, an automatically actuated, total flooding HALON 1301 system shall be installed to sup-press a fire prior to damage of either redundant division unless the fire originates in one division. In that esse, the HALON 1301 system will prevent dauage to the redundant division. Criteria 5 Sprinklers placed at the ceiling of a room in combination with the appropriete water flow alarms provide the required fire detection. Criteria 6 Rooms containing redundant safe shutdown electrical raceway, not pro-tected by ceiling mounted sprinklers, HALON 1301 total flooding systems, or adequate physical separation shall require one of the two redundant raceways to be wrapped in a rated fire resistive material. The fire rated materials will provide 3 hour protection for conduits and 55 minutes for cable trays to allow fire brigade response. bb 1

FRA-4 The following analysis is presented on a room-by-room basis. Each room has been evaluated to determine which Category A through D is applicable. Modifications have been proposed, and the first five questions of the SER item 3.2.1 were answered where applicable. In all cases the analysis took into account the concerns expressed in all sixteen areas of SER item 3.2.1 " Fire Hazards Analysis" and the individual evaluations specified in SER Sec-tion 5 as they applied. The proposed modifications were summarized and are presented in tabular form on Table 1. In performing the Fire Hazards Analysis for the Auxiliary Building, it was necessary to make assumptions about the postulated transient combustible. The following three (3) cases were postulated: Case 1 A 55 gallon drum of a liquid combustible with 20,000 BTU /lb heat of combustion is spilled in the area, spreads over the entire floor and then is ignited. This case is applicable to motorized equipment such as fork lifts. A 55 gallon drum is the maximum size which foreseeably would be transported by an individual aided only by dollies or similar hand equipment. The flow of liquids to adjoining rooms has been con-sidered in individual room analyses. Case 2 An open pail with 5 gallons of the same combustible as Case 1 is located in the area where it could cause the worst damage to the plant in terms of safe shutdown capability or radiological release. The liquid is assumed to be ignited in the pail and does not spill. This case assumes a concentrated fire loading in the most sensitive part of the fire area. It was felt that 5 gallons would be the maxi-mum amount that would be transported in an open vessel since this quantity would weigh approximately 40 lbs and would thus be a mod-erate strain on the average individual. Case 3 This transient is proposed for the cask loading area on elevation 45'-0". This area provides almost unlimited access for the trans-port of transient combustibles and does provide for the access of a tractor-trailer truck. The truck would pose a transient consisting of approximately 100 gallons of #2 diesel fuel oil, eighteen tires, and the load being transported. The quantity of load combustibles cannot be predicted and therefore, will remain undefined. The following chart gives a comparison fire loading between Case 1/ Case 2 and other types of transient combustibles that could be expected to be found in the plant. 1638 320

FHA-5 Case 1 Equivalents 55 gallons comocetible liquid (8,360,000 BTU) OR-1150 lbs paper OR 1200 lbs cottonl R-1000 lbs wood OR 850 lbs duct iiIdulation 00 600 lbs charcoal OR 600 lbs PVC plastE Case 2 Equivalents 5 gallon combustible liquid (760,000 BTU) g 104 lbs paper OR 109 lbs cotton -OR 91 lbs wood OR 77 lbs duct E sulation OR-55 lbs charcoal OR 55 lbs PVC plastE 1638 321

FHA-6 DESCRIPTION OF SAFE SHUTDOWN EQUIPMENT The following list of safe shutdown equipment comprises that equipment neces-sary to insure the safe shutdown of the plant. This list assumes the loss of offsite power and gives consideration to the consequences of possible system transients resulting from fire induced faulting of electrical cables. In using this list, it should be recognized that the term " safe shutdown" is not necessarily synonymous with " safety-related." Unit 1 nomenclature is used throughout but the listing is typical for both Units 1 and 2. EQUIPMENT REQUIRED FOR HOT SHUTD0 g AFW Pump Steam Supply Valves MOV-4070 and MOV-4071 Operability of either of these valves will allow both AFW pumps to be started from the Control Room. If neither valve is operable, both AFW pumps can be started by opening manual valves which bypass MOV-4070 and MOV-4071. The auxiliary feedwater pumps may also be operated using auxiliary steam available from the unaffected unit or the aux-iliary boilers. AFW Flow Control Valves CV-4511 and CV-4512 Each valve controls introduction of auxiliary feedwater to one steam generator. If either valve fails to operate, the plant can be main-tained in hot shutdown using a single steam generator. Additionally, if neither valve is operable, auxiliary feedwater flow to each steam generators can be controlled by manual valves which bypass CV-4511 and CV-4512. Atmosphere Dump Valves CV-3938 or CV-3939 Valves will be used to remove heat from the steam generator after offsite power is lost. Prior to that time steam will be dumped to the main condenser via four turbine bypass valves. The plant can be maintained in hot shutdown with either CV-3938 or CV-3939 operable. If neither valve is available, heat removal from the steam generator will be accomplished by eight safety valves on each steam generator. Auxiliary Feedwater Pumps Either of two auxiliary feedwater pumps can supply sufficient water to both steam generators to maintain the plant in hot shutdown and effect plant cooldown. If offsite power is available, the main feed system could also serve this function.

1. 12 Condensate Storage Tank and Level Indication

     #12 Condensate Storage Tank contains sufficient water to effect cool-down of both units to cold shutdown. In addition, #11 and #21 Conden-sate Storage Tanks can be connected to the auxiliary feedwater pump suction header by opening normally closed manual valves.

1638 322

FHA-7 Reactor Coolant System Instrumentation Reactor cold leg temperature, Reactor hot leg temperature, Reactor core temperature, pressurizer pressure and pressurizer level indica-tions are needed to monitor natural circulation within the Reactor Coolant System. Cold leg temperature would normally be read from TE-ll5 and TE-125. However, TE-lllY and TE-121Y plus four safety grade Tc indications for each loop are available in the Control Room. Hot leg temperature would normally be read from TE-lllX and TE-121X. However, two additional safety grade Th indications for each loop are available in the Control Room. Reactor core temperatures are monitored by 45 core thermocouples which are read in the Control Room. Pressurizer pressure would normally be read from either PT-100X or PT-100Y. However, four additional safety grade pressure indications are available in the Control Room. Pressurizer level would normally be read with LT-llox and LT-110Y. However, LT-103 which is calibrated for cold conditions is also available. Steam Generator Instrumentation Steam generator level, steam generator pressure, and auxiliary feed-water pump discharge pressure are needed to maintain adequate steam rf nerator water inventory. Steam generator levels would normally be read from LT-1105 and LT-1106 on the main control board and in the auxiliary feedwater pump room. However, LT-ll21 and LT-llll plus four safety grade level indications for each steam generator are also available in the Control Room. Steam generator pressure would normally be read from PT-3991 and PT-4008 on the main control board and in the auxiliary feedwater pump room. However, these pressures can also be read locally from gauges in each auxiliary feedwater pump room. Additionally, four safety grade pressure indications for each steam generator are available in the Control Room. Auxiliary feedwater pump discharge pressure would normally be read from PT-4507 on the main control board. This pressure can also be read locally in each auxiliary feedwater pump room. b 323

FHA-8 Reactor Coolant System PORV's, ERV-402 and ERV-404, should be shut to preclude a reduction in RCS water inventory which could adversely impact natural circulation. ERV-402 and ERV-404 position indication is available in the Control Room. If either valve should fail open, it can be isolated by shutting its respective motor operated isolation valve. Power can then be removed from the MOV to insure it cannot also fail open. Pressurizer heaters are required to maintain subcooled condition in the Reactor Coolant System. Letdown stop valves (CV-515 and CV-516), reactor coolant pump seal leak-off stop valves (CV-505 and CV-506) and reactor coolant sample isolation valves (CV-5465, CV-5466, and CV-5467) must be shut to prevent removal of coolant from the reactor coolant system if reactor coolant charging pumps are not available. Each valve may be shut from the Control Room and each fails shut on loss of control air. Additional considerations for each valve are as follows: (1) CV-515 and CV-516 valve position and letdown lina flow indication are available in the Control Room. If eith.c s alve failed open, the other valve is redundant and would still interrupt flow. If both valves failed open, flow could be stopped by shutting manual isolation valves in the letdown line. (2) CV-505 and CV-506 valve positions and leak off header flow indica-tion is available in the Control Room. If either valve failed open, the other valve is redundant and would still interrupt flow. If both valves failed open, flow could be stopped by shutting manual isolation valves in the leakoff header. (3) CV-5465, CV-5466, and CV-5467 valve position indication is available in the Control Room. If any valve should fail open, flow could be stopped by shutting combined sample header isolation valve CV-5464. If 5465 fails open, simultaneously flow could be stopped by shutting manual isolation valves in the sample header. ADDITIONAL EQUIPMENT REQUIRED FOR COLD SHUTD0hw Diesel Generators Output of one of two installed diesel generators is required to effect cold shutdown. The diesel fuel oil transfer pump and room ventilation system must also be operable. Service water cooling for #12 diesel is normally provided by either of two Unit 1 service water subsystems. Cooling water for #11 diesel generator is normally provided by #11 ser-vice water subsystem. Either diesel can also be supplied with cooling water from the two Unit 2 service water subsystems.

FHA-9 Saltwater System one of three installed saltwater pumps must be operable to supply saltwater to the component cooling heat exchangers. Component cooling heat exchanger saltwater valves CV-5160 and CV-5206 (11 CC HX) or CV-5162, CV-5163, and CV-5208 (12 CC HX) must be opened to allow saltwater cooling of the component cooling heat exchanger. CV-5149, CV-5165, and CV-5166 must be main Mined shut. If necessary, all valves may be failed to the required positions by removing control air from their actuators. Component Cooling System One of three installed component cooling water pumps must be operable to supply component cooling water to the shutdown cooling heat exchan-ger to effect cooldown of the RCS to below 300 F. Component cooling water heat exchanger component cooling outlet valves CV-3824 (11 CC HX) or CV-3826 (12 CC HX) must be open and bypass valves CC-3823 (11 CC HX) or CC-3825 (12 CC HX) must be shut to facilitate heat transfer from shutdown component cooling HX to the saltwater sys-tems. Also, one component cooling heat exchanger component cooling outlet valve (CV-3828 or CV-3830) must be open. If necessary, these valves may be failed to the required positions by removing control air from their actuators. Shutdown Cooling System One of the two low pressure safety injection pumps must be operable to effect cooldown of the RCS to below 300 F. Both shutdown cooling return isolation valves (MOV-651 and MOV-652) must be open, one of four low pressure safety injection header isolt.- tion valves (MOV-615, MOV-625, MOV-635, or MOV-645) must be open, low pressure safety injection flow control valve CV-306 must be shut, shut-down cooling temperature control valve CV-657 must oe open, and shut-down cooling heat exchanger isolation valve CV-658 must be open to provide a shutdown cooling flowpath. The motor operated valves may be positioned as required and power removed from the operators to keep the valves in the desired position. All valves can be manually positioned as required. Chemical Volume control System One of three installed charging pumps must be operable in order to borate the RCS to required cold shutdown boron concentrations prior to cooldown and to provide makeup to the RCS during cooldown. 1638 325

FHA-10 Volume control tank outlet valve MOV-501 should be shut to prevent loss of charging pump suction when the VCT is emptied. Refeuling water tank outlet valve MOV-504 must be open to provide a source of water to the charging pump suction. Either boric acid gravity feed valve MOV-508 or MOV-509 should be open to provide boric acid to the charging pump suction. Each valve may be positioned and power removed from the operator to keep the valve in the desired position. Also, each valve can be manually operated if required. One of two heat tracing circuits for the boric acid gravity flowpath utilized should be operable. The auxiliary spray valve CV-517 must be shut to prevent spraying into the pressurizer with resultant decrease in pressure. The valve may be failed shut if necessary by removing control air from its operator. 1638 326

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PAGE 5 0F 12 ROOM NO. FIHE DETECTION FIHE SUPPHESSION OTilEH MODIFICATIONS 211&321/ Smoke Detection None None 221C326 at Ceiling 212/219 Smoke Detection Sprinklers under Trays 1. Wrap ZH conduit. Ceiling 213/220 None Sprinklers at Ceiling None 214/218 Smoke Detection None 1. Close all blockouts between 220 and at Ceiling 218 and 214 and 213. 215/217 None Sprinklers at Ceiling None 216/216A None Sprinklers at Ceiling 1. Manufacturer to select heads to avoid direct impingemr.it on heat trace panels. 222 None Sprinklers at Ceiling None U CD u u

PAGE 6 0F 12 It00M NO. FIRE DETECTION FIRE SUPPHESSION OTilEH MODIFICATIONS 223 None Sprinklers at Ceiling None 229/230 (Later) 1A/lB/2A/2B Smoke Detection Automatic Sprinklers 1. Additional access doors will be added for at Ceiling IB and 2B on elevation 69'-0". (existing) 301/304/305/307 None None None 302/306/lC/2C Smoke Detection llalon 1301 1. Interlock llalon with IIVAC. at Ceiling total flooding 2. Actuation of Italon by detectors.

3. Electrically supervise all doors.

308 None None None 309/315 None Sprinklers at Ceiling None U CO u u N

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PAGE 9 0F 12 It00M NO. FIltE DETECTION fille SUPPitESSION OTIIEH MODIFICATIONS 409 Smoke Detection Sprinklers under Trays 1. Wrap one division of shutdown cable. at Ceiling (Existing) 410 None None None 411/427 None None None 412 None None None 414/423 Smoke Detection Sprinklers under Trays 1. Wrap one division of conduit. at Ceiling (Existing) 416/421/422 Smoke Detection Preaction Sprinklers None at Ceiling at Ceiling (Existing) (Existing) 417/418 None Sprinklers at Ceiling None (Existing) 419/425/426 Smoke Detection Sprinklers at Ceiling 1. Wrap two divisions of shutdown cable. Above Trays in West of P 1.ine anc. the Areas Adja- below Trays East of cent to the P Line C)s C ntainments LN 00 6 'm W

PAGE 10 0F 12 It00M NO. FIltE DETECTION FIltE SUPPitESSION OTilEH MODIFICATIONS 420 None Sprinklers Protect Shut- None down Cable Trays 424/413 None None None 428 Smoke Detection Sprinklers at Ceiling 1. Wrap two divisions of shutdown cable. Above Trays in and Under Trays Between Areas Between P and M Lines P and M Lines 431 Smoke Detection lialon 1301 (existing) 1. Wrap one division of shutdown cable. Above Drop Ceiling Smoke Detection in Room and Sub-floor (Existing) 439/440 Smoke Detection None None at Ceiling 441 None None None U-l/U-2 Smoke Detection None None at Ceiling (Existing) u CO u LeJ Ch

PAGE 11 0F 12 It00M NO. FIltE DETECTION FIltE SUPPitESSION OTilElt MODIFICATIONS 501/502/503/ None None None 504/505/506/ 507/508/509/ 510/511/513/ 514/515/516/ 517/518/519/ 521/522/523/ 534/535 512 Smoke Detection None None at Ceiling 520 None None None 524/526 Smoke Detection Nonc 1. Class A Fire Doors. at Ceiling 525/527 Smoke Detection None None at Ceiling 528/530/ None None None 533/537 U Co LN U N

PAGE 12 0F 12 H00M NO. FIltE DETECTION fille SUPPitESSION OTiiElt MODIFICATIONS 529/532 Smoke Detection None None ut Ceiling (Existing) 531 None None None 536 None None None 603/605 None Sprinklers at Ceiling None Intake Structure Smoke Detection None None at Ceiling Turbine Building None Sprinklers at Elevation None 12'-0" and 27'-0" (Existing) Yard None None None U CO u U CD

100-1 ROOM NO. 100 FIGURE 1 ROOM DESCRIPTION Passage This room does not contain safety related equipment. It contains the following equipment and cables:

1. Three redundant divisions of safe shutdown cable per unit.

2. Two divisions per unit of safety related cable.

PROPOSED MODIFICATIONS

1. A wet pipe sprinkler system will be provided under the cable trays as required by Category A, Criteria 3 and for protection of doors and penetrations into the ECCS pump room nos. 101, 102, 118, and 119 by Criteria 2.

2. Smoke detectors will be installed above the cable trays in accordance with Criteria 3. The detectors will provide warning of an incipient fire.

3. Two divisions of safe shutdown cabling (ZH and 2C) will be wrapped with approved fire rated protective covering in accordance with Criteria 6.

SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

Separation of this room from other areas will be assured by the addi-tion of a sprinkler system, Modification 1 above, in lieu of fire doors as discussed in Criteria 2. Additional assurance is afforded by modifications and/or existing barriers in the following rooms:

a. Passage - 103 - addition of a sprinkler system.

b. ECCS Rooms - 118, 102, 119, 101 - addition of fire dampers.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Resnonse The addition of sprinklers and the wrapping of two of the three redun-dant safe shutdown cables will accomplish effective separation between redundant safe shutdown cables. 1638 339

100-2

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combus-tibles which may be introduced into or moved through the area.

Response

Based on the original Fire Protection Program Evaluation, the fixed fire loading in the corridor would result in a maximum 6 minute fire duration. The case 1 transient combustible would add an additional 7 minutes to this loading. The Case 2 transient combustible results in a lower fire loading. 4 Identify the worst damage that could result from such fire.

Response

The wet pipe sprinklers will protect the cables from an exposure fire from the floor and thus insere that safe shutdown will not be threatened by this type of fire. In the event of an internally initiated fire in a cable tray, the wrapping of two of the three redundant cable divisions will insure that this type of fire will not threaten the safe shutdown capability. Further, the addition of the smoke detectors above the cables will provide prompt detec-tien of any developing fire, and initiate the rapid response of the fire brigade.

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

A transient fire will be suppressed by che sprinkler system, such that cables will not be damaged by a fire originating on the floor as discussed in Criteria 3. In the event of a fire within a cable tray, the anproved rated fire wrapping, combined with smoke detec-tion, will insure that the fire will not spread to adjacent cable trays. Thus, the safe shutdown capability will not be threatened. Radiological consequences are discussed in the response to SER Item 3.2.8. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.1.6 of the SER.

1. Replace all unrated doors in these areas by UL or FM listed fire doors of a fire resistance rating commensurate with fire hazards on both sides of the barrier, or provide acceptable alternate protection.

1638 340

100-3

Response

The doors presently located in this area are watertight doors. In lieu of rating fire doors, which are unobtainable for watertight doors, sprinklers will be provided as discussed in Criteria 2. This system will also provide coverage in the corridor alcoves near the doors.

2. Install fire detectors in each pump room and in the corridor areas.

Response

Smoke d- tectors will be installed above the cable trays in accordance with criteria 3 (for the pump room see responses for rooms 101, 102, 118, 119, 120, and 122).

3. Separate, by additional barriers or by rerouting, redundant cab' es required for safe shutdown, or demonstrate the adequacy of cable separation in preserving safe shutdown.

Response

Two of the three divisions of safe shutdown cabling will be wrapped with approved fire rated protective covering in accordance with criteria 6. This will insure the safe shutdown capability in the event of a fire in this room. 1638 341

101-1 ROOM NOS. 101 & 119 - FIGURE 1 ROOM DESCRIPTION ECCS Pump Rooms Unit 1 - 119 Unit 2 - 101 This room contains two divisions of safety related equipment and associated cable and two divisions of safe shutdown cable in addition to the following safe shutdown equipment and associated cabling:

1. Low pressure safety injection pump 11 (21)

2. Shutdown cooling heat exchanger compoment cooling outlet valve 1(2)-CV-3828

3. Low pressure safety injection to the shutdown heat exchanger valve 1(2)-MOV-658 PROPOSED MODIFICATIONS

1. An automatic wet pipe sprinkler system will be installed in Corridor 100 in lieu of a fire rated door in accordance with criteria 2.

2. Smoke detectors will be provided as described by Category B. Detectors will also serve to initiate closure of unrated ventilation dampers for smoke control.

3. To provide complete compartmentalization, 3 hour rated fire dampers will be installed in the ventilation ducts penetrating the ceiling and the wall to Corridor 100.

4. ZC conduit containing charging pump 13 (23) power cable will be wrapped in accordance with Criteria 6 to make this room qualify as a Category B area.

5. To provide consistency in the fire rating of room boundaries, the elec-trical and piping penetrations between rooma 101 and 102 (119 and 118) will be upgraded to 3 hour ratings. Penetrations to Corridor 100 will be similarly upgraded to 3 hour ratings.

SER QUESTIONS

 -~

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetra-tions) of appropriate fire resistance.

Response

Separation between adjacent areas is accomplished by the addition of a sprinkler system, Modification 1 above, in lieu of fire doors as dis-cussed in Criteria 2 and by Modifications 3 and 5. 1638 342

101-2

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

Based on the existing arrangement of redundant equipment being in separate rooms, with Modifications 1, 3, and 5 proposed, area separa-tion is accomplished. Modification 4 indicates that, in lieu of physical separation from the ZA tray, the ZC conduit will be wrapped. These are the only redundant safe shutdown circuits in the room.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combustibles which may be introduced into or moved through the area.

Response

Per the original Fire Protection Program Evaluation, the fixed fire loading in the area would result in a fire of 2 minute duration. The case 1 transient combustible would add an additional 3 minutes to this loading. The case 2 transient combustible results in a lower fire loading.

4. Identify the worst damage that could result from such fire.

Response

A postulated fire which starts internally to MOV-658 may affect the valve operator. In addition, one division of either division of ZA or ZC cable may be affected.

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

Safe shutdown capability would not be affected since redundant equip-ment is located in another room, since valve MOV-658 can be manually operated, and since ZC cable in conduit is wrapped precluding involve-ment of two divisions at one time. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.1.6 of the SER.

1. Replace all unrated doors in these areas by UL for FM listed fire doors of a fire resistance rating commensurate with fire hazards on both sides of the barrier, or provide acceptable alternate protection.

Response

An automatic wet pipe sprinkler system in Corridor 100 will be provided in lieu of fire doors to prevent the spread of fire from one area to another as discussed in Criteria 2. Additionally, the openings to 1638 343

101-3 Corridor 100 are presently protected by watertight doors required to prevent flooding of the rooms. These doors alone would be adequate to withstand the fires postulated and described in SER Item 3 response above (i.e. , fires of 2 and 3 minute duration).

2. Install fire detectors in each pump room and in the Corridors.

Response

Smoke detectors will be installed in the ECCS Pump Rooms and Corridor 100.

3. Separate, by additional barriers or by rerouting, redundant cables required for safe shutdown, or demonstrate the adequacy of cable separation in preserving safe shutdown.

Resoonse Cables to charging pumps 11 (21) and 13 (23) are the only redundant safe shutdown cables in this room. Conduit ZC will be wrapped to pro-vide 3 hour fire protection of one of these two cables and assure safe shutdown capability. 1638 344

102-1 ROOM NOS. 102 C 118 - FIGURE 1 ROOM DESCRIPTION ECCS Pump Rooms Unit 1 - 118 Unit 2 - 102 This room contains two divisions of safety related equipment and the following single division of safe shutdown equipment and associated cabling:

1. Low pressure safety injection pump 12 (22)

2. Shutdown coolinghheat exchanger component cooling cutlet valve 1(2)-CV-3830 PROPOSED MODIFICATIONS

1. An automatic wet pipe sprinkler system will be installed in Corridor 100 in lieu of a fire rated door in accordance with Criteria 2.

2. Smoke detectors will be provided as described by Category B. Detec-tors will also serve to initiate closure of unrated ventilation dam-pers for smoke control.

3. To provide complete compartmentalization, 3 hour rated fire dampers will be installed in the ventilation ducts penetrating the ceiling and the wall to Corridor 103.

4. To provide consistency in the fire rating of room boundaries, the electrical and piping penetrations between rooms 101 and 102 (119 and 118) will be upgraded to 3 hour ratings. Penetrations to Corri-dors 100 and 103 will be similarly upgraded to 3 hour ratings.

SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

Separation between adjacent areas is accomplished by the addition of a sprinkler system, Modification 1 above, in lieu of fire doors as discussed in Criteria 2 and by Modifications 3 and 4. 1638 345

102-2

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire ares.

Response

There are no redundant safe shutdown cables in this room.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combustibles which may be introduced into or moved through the area.

Response

Per the original Fire Protection Program Evaluation, the fixed fire loading in the area would result in a fire of 2 minute duration. The case 1 transient combustible would add an additional 3 minutes to this loading. The case 2 transient combustible results in a lower fire loading.

4. Identify the worst damage that could result from such fire.

Response

CV-3830, Low Pressure Safety Injection Pump 12 (22) and associated cabling could be damaged.

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

Safe shutdown capability would not be affected since redundant equip-ment is located in another room. Radiological consequences are dis-cussed in the response to SER Section 3.2.8. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.1.6 of the SER.

1. Replace all unrated doors in these areas by UL or FM listed fire doors of a fire resistance rating commensurate with fire hazards on both cides of the barrier, or provide acceptable alternate protection.

Response

An automatic wet pipe sprinkler system in Corridor 100 will be pro-vided in lieu of fire doors to prevent the spread of fire from one area to another as discussed in Criteria 2. Additionally, the open-ings to Corridor 100 are presently protected by watertight doors required to prevent flooding of the rooms. These doors clone would be adequate to withstand the fires postulated and described in SER Item 3 response above (i.e., fires of 2 and 3 minute duration). 1638 346

102-3

2. Install fire detectors in each pump room and in the corridors.

Response

Smoke detectors will be installed in the ECCS Pump Rooms and Corridor 100.

3. Separate, by additional barriers or by rerouting, redundant cables required for safe shutdown, or demonstrate the adequacy of cable separation in preserving safe shutdown.

Response

There are no redundant safe shutdown cables in this room. 1638 347

103-1 ROOM NOS. 103 AND 116 - FIGURE 1 ROOM DESCRIPTION Units 1 and 2 - 103 - Passage Unit 1 - 116 - Elevator Lobby These rooms do not contain safety related equipment. They contain the following equipment and cables:

1. Two divisions of safe shutdown equipment per unit.

2. Three redundant divisions of safe shutdown cable per unit.

3. Two divisions per unit of safety related cable.

PROPOSED MODIFICATIONS

1. A wet pipe sprinkler system will be provided under the cable trays as required by Category A, Criteria 3 and for protection of doors and penetrations into the ECCS pump room nos. 101, 102, 118, and 119 as discussed in Criteria 2. Room 116 is an empty vestibule, containing no equipment or cabling and altough open to area 103, will not be sprinklered.

2. Smoke detectors will be installed above the cable trays in accor-dance with Criteria 3. The detectors will provide warning of an incipient fire.

3. Two divisions of safe shutdown cabling (ZB and ZC) will be wrapped with approved fire rated protective covering in accordance with criteria 6.

SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

Separation of this room from other areas will be assured by the additionoof a sprinhier aystem, Modification 1 above, in lieu of fire doors as discur, sed in Criteria 2. Additional assurance is afforded by modificctions and/or existing barriers in the following rooms:

a. Charging Pump Rooms - 115 and 105 - addition of sprinkler systems.

b. Passage - 100 - addition of a sprinkler system.

c. Machine Room - 117 - fire rated door.

16,38 348

103-2

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

The addition of sprinklers and the wrapping of two of the three redundant safe shutdown cables will accomplish effective separation between redundant safe shutdown cables. Two sets of redundant pres-sure controllers, for each unit, are required for safe shutdown and sprinkler coverage will be provided in lieu of separation as dis-cussed in Category A, Criteria 3.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combe;-

tibles which may be introduced into or moved through the are .

Response

Based on the original Fire Protection Program Evaluation, the fixed fire loading in the corridor would result in a maximum 6 minute fire duration. The Case 1 transient combustible would add an addi-tional 7 minutes to this loading. The Case 2 transient combustible results in a lower fire loading.

4. Identify the worst damage that could result from such fire.

Response

The wet pipe sprinklers will protect the cables from an exposure fire from the floor and thus insure that safe shutdown will not be threatened by this type of fire. In the event of an internally initiated fire in a cable tray, the wrapping of two of the three redundant cable divisions will insure that this type of fire will not threaten the safe shutdown capability. Further, the addition of the smoke detectors above the cables will provide prompt detec-tion of any developing fire, and initiate the rapid response of the fire brigade.

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

A transient fire will be suppressed by the sprinkler system, such that cables will not be damaged by a fire originating on the floor, as discussed in Criteria 3. In the event of a fire within a cable tray, the approved rated fire wrapping, combined with smoke detec-tion, will insure that the fire will not spread to adjacent cable trays. Thus, the safe shttdown capability will not be threatened. Radiological consequences are discussed in the response to SER Item 3.2.8. I638 349

103-3 EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.1.6 of the SER. The licensee will:

1. Replace all unrated doors in these areas by UL or FM listed fire doors of a fire resistance rating commensurate with fire hazards on both sides of the barrier, or provide acceptable alternate protection.

Response

The doors presently located in this area are watertight doors. In lieu of rated fire doors, which are unobtainable for watertight doors, sprinklers will be provided as discussed in Criteria 2.

2. Install fire detectors in each pump room and in the corridor areas.

Response

Smoke detectors will be installed above the cable trays in accordance with Criteria 3 (for the pump room see responses for rooms 101, 102, 118, 119, 120, and 122).

3. Separate, by additional barriers or by rerouting, redundant cables required for safe shutdown, or demonstrate the adequacy of cable separation in preserving safe shutdown.

Response

Two of the three divisions of safe shutdown cabling will be wrapped with approved fire rated protective covering in accordance with criteria 6. This will insure the safe shutdown capability in the event of a fire in this room. 1638 350

104-1 ROOM NO. 104 - FIGURE 1 ROOM DESCRIPTION Passage Units 1 & 2 - 104W and 104E In room 104 there is one division of Unit 1 safe shutdown cable and one division per unit of safety related cable. The entire room does not contain safe shutdown or safety related equipment. PROPOSED MODIFICATIONS

1. A smoke detection system will be installed in the passage 104 in accordance with Category B.

2. ZC conduit containing Charging Pump 13 power cable will be wrapped in accordance with criteria 6.

SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

separation from safe shutdown areas of the plant will be accomplished by the addition of sprinkler systems in adjacent rooms in lieu of fire doors as discussed in Criteria 2. (Also see response for rooms 103, 105, 115.)

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

This room contains only one division of Unit 1 safe shutdown equipment required for safe shutdown. ZC conduit as identified in 2 above will be wrapped.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combustibles which may be introduced into or moved through the area.

Response

Based on the original Fire Protection Program Evaluation, the fixed fire loading in the room would result in a maximum 6 minute fire dura-tion. The case 1 transient combustible would add an additional 7 minutes to this loading. The Case 2 transient combustible results in a lower fire loading. 1638 351

104-2

4. Identify the worst damage that could result from such fire.

Response

ZC cabling for Charging Pump 13 is protected by wrapping so that safe shutdown will not be threatened.

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

Safe shutdown capability would not be affected since cable is wrapped and cabling for redundant charging pumps is routed through other areas. Radiological consequences is discussed in response to SER Item 3.2.8. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.3.6 of the SER. The licensee will:

1. Analyze the radiological consequences of fire damage to the waste pro-cessing system cables.

Response

Refer to the response to SER Section 3.2.8.

2. Analyze the effects on safe shutdown of the loss of auxiliary feed-water pump room fans and/or heating of the boric acid system.

Response

Not applicable to this room.

3. Install fire detectors in coolant receiver tank rooms (areas 107 and 114), the corridor (area 104), and other areas containing safety related cables / components.

Response

Fire detection will be added to this room. 1638 352

105-1 ROOM NOS. 105 C 115 - FIGURE 1 ROOM DESCRIPTION Charging Pump Rooms Unit 1 - 115 Unit 2 - 105 This room contains three divisions of safety related equipment and the following safe shutdown equipment and associated cabling:

1. Charging pumps 11, 12 C 13 (21, 22 C 23)

2. 1::at tracing and controls for the boric acid injection to charging pump suction, circuits 1(2)-QHTP-27 and 1(2)-QHTS-27

3. Volume control tank outlet valve 1(2)-MOV-501 PROPOSED MODIFICATIONS

1. An automatic wet pipe sprinkler system will be installed in this room in accordance with Category A, Criteria 1 and 2.

2. To further prevent the spread of fire, curbing will be installed between the pump compartments and at the room entrance to prevent the spread of a liquid combustible from one pump compartment to another.

3. To provide complete compartmentalization, a 3 hour rated fire damper will be installed in the ducting between the charging pump rooms and the miscellaneous waste rooms no. 106 and 113.

SER OUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separateo by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

Separation between adjacent areas is accomplished by the addition of a sprinkler system in lieu of fire doors as discussed in Criteria 2. With the addition of sprinklers and the fire damper, these rooms are effectively compartmentalized with the equivalent of 3 hour rated barriers.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

1638 353

105-2

Response

Sprinklers above cable trays and equipment will be provided in lieu of additional physical separation of equipment / cabling into separate fire areas as demonstrated in Category A, Criteria 1 and shown on Figure 1.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combus-tibles which may be introduced into or moved through the area.

Response

Per the original Fire Protectio Program Evaluation the fixed fire loading is approximately 4 minutes. The Case 1 transient would add an additional 4 minutes of loading. The Case 2 transient combustible would result in a lower fire loading.

4. Identify the worst damage that could result from such fire.

Response

Due to the proposed modification to add a wet pipe sprinkler system the postulated fire would be effectively suppressed before either divisions could become involved unless the fire originated within one division then the suppressor system would prevent involvement of the redundant division. A postulated fire which starts internally to device MOV-501 may affect the valve operator.

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

The proposed wet pipe sprinkler system will protect safe shutdown equipment from exposure to transient fires and will prevent fires originating within a specific division from affecting the redundant division. Since two of the three redundant charging pumps and one division of heat tracing would be available following the postulated fire, safe shutdown capability could not be jeopardized. In the event a fire originates in device MOV-501, safe shutdown will be assured through manual valve operation following suppression of the fire. Valve operation is not required until commencement of boration in preparation for cold shutdown. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.2.6 of the SER. The licensee will:

1. Replace unrated doors with UL or FM listed fire doors of a fire resistance rating commensurate with fire hazards on both sides of

  ,the barrier, or provide acceptable alternate protection.

h k

105-3

Response

Curbs and automatic wet pipe sprinkler system will be installed in lieu of fire doors to prevent the spread of fire from one area to another as discussed in Criteria 2.

2. Install fire detectors in each charging pump room.

Response

The automatic wet pipe sprinkler system will provide remote annunciation of an alarm whenever sprinkler system actuation occurs in accordance with criteria 5.

3. Provide a sprinkler system in each room to preserve the function of at least one charging pump for each unit in the event of a fire.

Response

An automatic wet pipe sprinkler system will be added.

4. Verify that drains from different charging pump compartments are not interconnected, or the drain system is provided with protection to prevent backflow of leaked oil in one compartment into another via the drain system.

Response

The drainage system has been shown to be effective in preventing backflow in the response to SER section 3.2.5. 1638 355

106-1 ROOM NO. 106 - FIGURE 1 ROOM DESCRIPTION Miscellaneous Waste Monitor Tank Room This room contains no divisions of safety related equipment but contains the following safe shutdown equipment.

1. Heat tracing on the redundant boric acid supply lines to the charging pump suction, lines 3" HC-16-2010 and 3" HC-40-2001.

PROPOSED MODIFICATIONS

1. An automatic wet pipe sprinkler system will be installed in this room in accordance with Category A and Criteria 1.

2. Fire dampers will be installed in the ducting between the miscellaneous Waste Monitor Tank Room 106 and Charging Pump Room 105.

SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

Sprinklers will be added to this room in lieu of fire doors and fire dampers installed as described in Modification 2 above. This modification will effectively compartmentalize the room with the equivalent of 3 nour rated barriers as discussed in Criteria 2.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Resnonse Sprinklers above cable trays and equipment will be provided in lieu of additional physical separation of equipment / cabling into separate fire areas as discussed in Category A and Criteria 1.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combustibles which may be introduced into or moved through the area.

1638 356

106-2

Response

The original Fire Protection Program Evaluation lists the fixed fire loading at approximately 1 minute in these rooms. The case 1 transient combustible would add another 14 minutes exposure. Case 2 transient combustible would result in a lower fire loading. .. Identify the worst damage that could result from such fire.

Response

Due to the proposed modification to add a wet pipe sprinkler system, the postulated transient fire would be effectively suppressed before either division of ssfe shutdown heat tracing could become involved unless the fire originated within one division, then the suppression system would prevent involvement of the redundant division.

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

Safe shutdown capability will not be threatened since the proposed wet pipe sprinkler system will protect safe shutdown equipment from exposure to transient fires and will prevent fires originating within a specific division from affecting the redundant division. Radiological consequences are discussed in the response to SER Section 3.2.8. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.3.6 of the SER. The licensee will:

1. Analyze the radiological consequences of fire damage to the waste processing system cables.

Response

Refer to the response to SER Section 3.2.8.

2. Analyze the effects on safe shutdown of the loss of auxiliary feedwater pump room fans and/or heating of the boric acid system.

Response

a. The auxiliary feedwater pump room fans and associated cable are not located in Room 106 (nor 113).

1638 357

106-3

b. To achieve cold shutdown, a boric acid solution must first be injected into the primary system from the boric acid storage tanks. The suctions of the charging pumps are switched from the volume control tank to two redundant flow paths from the boric acid storage tanks. One flow path is the combined discharge of the boric acid pumps and the other flow path is the combined gravity discharge piping from the boric acid storage tanks. The temperature in the redundant flow paths is maintained by redundant electrical heat tracing circuits.

In addition, each boric acid storage tank is heated by redun-dant electrical heat tracing. Loss of any single flow path or channel of heat tracing will not affect safe shutdown capability. Also, a fire which originates internally to any of these heat tracing devices will be effectively suppressed, thereby preventing the involvement of the redundant circuit. In rooms which contain redundant power cables which supply these heat tracing circuits where the transeitn fire loading is not significant, smoke detection will be provided (see rooms 107 and 114).

3. Install fire detectors in coolant receiver tank rooms (areas 107 and 114), the corridor (area 104), and other areas containing safety-related cables / components.

Response

see the responses for these rooms as applicable. 1638 358

107-1 ROOM NOS. 107 C 114 - FIGURE 1 ROOM DESCRIPTION Coolant Waste Receiver Tank No. 11 Room Unit 1 - 114 Coolant Waste Monitor Tank No. 11 Room Unit 2 - 107 These rooms do not contain safety related or safe shutdown equipment. Cabling in the room is:

1. Two redundant divisions of safe shutdown cable.

2. Two redundant divisions of safety related cabling.

PROPOSED MODIFICATIONS Due to the low fire loading, smoke detection will be added in accordance with Category A. SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

These rooms are separated from adjacent areas by minimum 1-1/2 hour rated barriers except at the open doorway which does not communicate directly with safety related areas.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

There are redundant ZA and ZB cable trays in the room hung a minimum of 24'-6" off the floor. The trays are separated by a spacing of 5' verti-cally and 3' horizontally or 1/2" thick marinite barriers were used. 1638 359

107-2

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combustibles which may be introduced into or moved through the area.

Response

Per the original Fire Protection Program Evaluation, the fixed loading is approximately 7 minutes. Because of unaccessibility, the only tran-sient that could conceivably be postulated for this area would be a small amount of trash which would have a negligible effect on the cal-culated loading. The only access to these rooms is via a permanently mounted vertical ladder. It would be physically impossible to transport a Case 1 fire to this room. Similarly, the Case 2 fire was felt to be highly un-likely since there is no dynamic equipment in this roca requiring lubrication or maintenance.

4. Identify the worst damage that could result from such fire.

Response

one division of safe shutdown cabling could be damaged.

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

Based on the height of the lowest cable trays (i.e., 24'-6"), the low fixed fire load and absence of potential transient fire load, both divisions of cables would not be damaged by fire. Only an internally initiated fire within a tray required for safe shutdown would expose safe shutdown cabling. However, this would not jeopardize the other division of safe shutdown cabling in the room. This is based on the findings of the Sandia Laboratory testing on adequacy of separation for internally initiated tray fires. Therefore, safe shutdown capa-bility will not be threatened. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.3.6 of the SER. The licensee will:

1. Analyze the radiological consequences of fire damage to the waste processing system cables.

Response

Refer to the response to SER Section 3.2.8. jh}Q }{

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2. Analyze the effects on safe shutdown of the loss of auxiliary feed-water pump room fans and/or heating of the boric acid system.

Response

a. The auxiliary feedwater pump room fans are a back-up ventilation source for the auxiliary feedwater pump room which is normally cooled by its own air conditioning unit. This back-up ventila-tion is used during a loss of offsite power and acts to cool the auxiliary feedwater pump room by recirculating the air from the adjacent HVAC equipment room. In the event the back-up fans are not available, the auxiliary feedwater pump room door can be opened which will establish a flow of tir between the turbine building and the auxiliary building and provide sufficient cool-ing under most conditions. Additional cooling can be provided using portable blowers in the turbine building.

b. To achieve cold shutdown, a boric acid solution must first be injected into the primary system from the boric acid storage tanks. The suctions or '9 charging pumps is switched from the volume control tank to two redundant flow paths from the boric acid storage tanks. One flow path is the combined discharge of the boric acid pumps and the other flev path is the combined gravity discharge piping from the boric acid storage tanks. The temperature in the redundant flow paths is maintained by redundant electrical heat tracing circuits. In addition, each boric acid storage tank is heated by redundant electrical heat tracing. Loss of any single flow path or channel of heat tracing will not affect safe shutdown capability. Automatic sprinklers will be installed in those areas which contain these redundant heat tracing circuits such that any possible exposure fire will not affect safe shutdown capability. Also, a fire which originates internally to any of these heat tracing devices will be effectively suppressed, thereby preventing the involvement of the redundant circuit. In rooms which contain redundant power cables which supply these heat tracing circuits where the transient fire loading is not significant, smoke detection will be provided (see rooms 107 and 114).

3. Install fire detectors in Coolant Waste Receiver Tank Rooms (areas 107 and 114), the corridor (area 104), and other areas containing safety related cables / components.

Response

Smoke detection will be added in rooms 107 and 114. 1639 001

108-1 ROOM NO. 108 - FIGURE 1 ROOM DESCRIPTION Pump Room This room contains one division of safety related equipment and no safe shutdown equipment or associated cable. PROPOSED MODIFICATIONS

1. Smoke detection will be added at the ceiling in accordance with Category D.

SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire ratings.

Resnonse This is not r safe shu;down related room. It is adjacent to Room 106 containing safe shutdown equipment, which is protected by a sprinkler system to give adequate separation as discussed in Criteria 2.

2. Identify the minimum separation between the redundant cables (in trays or conduits)/ equipment required for safe shutdown in each fire area.

Response

There is no safe shutdown equipment / cable in this room.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combus-tibles which may be introduced into or moved through the area.

Response

The Case 1 fire would not threaten safe shutdown capability.

4. Identify the worst damage that could result from such a fire.

Response

Not applicable based on (2.) above. I639 002

108-2

5. Jemonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

Based on (2.) above, safe shutdown capability will not be effected by a fire in this room. Radiological consequences are discussed in the response to SER Item 3.2.8. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.3.6 of the SER. The licensee will:

1. Analyze the radiological consequences of fire damage to the waste processing system cable.

Response

Refer to the response to SER item 3.2.8.

2. Analyze the effects on safe shutdown of the loss of auxiliary feedwater pump room fans and/or heatinc of the boric acid system.

Response

Not applicable to this room.

3. Install fire detectors in coolant receiver tank rooms (areas 107 and 114), the corridor (area 104), and other areas containing safety related cables / components.

Response

Sn.oke detection will be installed. I639 003

109-1 ROOM NOS. 109 C 112 - FIGURE 1 ROOM DESCRIPTION Coolant Waste Receiver Tank Room Unit 1 - 112 Coolant Wasce Monitor Tank Room Unit 2 - 109 These rooms contain no safety related or safe shutdown equipment or cable. PROPOSED MODIFICATIONS None. SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

These are not safe shutdown related rooms and they do not communicate with any safe shutdown related rooms. Therefore, separation is adequate.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

There is no safe shutdown cable or equipment in these rooms.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combustibles which may be introduced into or moved through the area.

Response

Because of limited access to these rooms (i.e., ladders), the case 1 fire would not threaten safe shutdown capability.

4. Identify the worst damage that could result from such fire.

Response

Not applicable based on (2.) above. 9 004

109-2

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

Based on (2.) above, safe shutdown capability will not be effected by a fire in these rooms. Radiological consequences are discussed in the response to SER Item 3.2.8. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.3.6 of the SER. The licensee will:

1. Analyze the radiological consequences of fire damage to the waste processing system cable.

Response

Refer to the response to SER Item 3.2.8. -

2. Analyze the effects on safe shutdown of the loss of auxiliary feedwater pump room fans and/or heating of the boric acid system.

Response

Not applicable to these rooms.

3. Install fire detectors in coolant receiver tank rooms (areas 107 and 114), in corridor (area 104) and other areas containing safety related cables / components.

Response

Not applicable to these rooms. 1639 005

110-1 ROOM NO. 110 - FIGURE 1 ROOM DESCRIPTION Coolant Wat - Receiver / Monitor Tank Pumps This roon etc.ains one division of safety related cable and no safe shutdown equipment or cable. PROPOSED MODIFICATIONS

1. Smoke detectors to be installed per Category D.

SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

These are not safe shutdown related rooms and they do not communicate with any safe shutdown related rooms. Therefore, separation is adequate.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

There is no safe shutdown cable or equipment in this room.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combustibles which may be introduced into or moved through the area.

Response

The Case 1 fire is postulated but would not threaten safe shutdown capability.

4. Identify the worst damage that could result from such fire.

Response

Not applicable based on (2.) above. 1639 006

110-2

5. Demonstrate that such damage will not have an adverse efftet on safe shutdown or cause excessive radioactive release to the environment.

Response

Based on (2.) above, safe shutdown capability will not be effected by a fire in this room. Radiological consequences are discussed in the response to SER Item 3.2.8. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.3.6 of the SER. The licensee will:

1. Analyze the radiological consequences of fire damage to the waste processing system cable.

Response

Refer to the response to SER item 3.2.8.

2. Analyze the effects on safe shutdown of the loss of auxiliary feed-water pump room fans and/or heating of the boric acid system.

Response

Not applicable to this room.

3. Install fire detectors in coolant receiver tank rooms (ereas 107 an.d 114), the corridor (area 104) and other areas containing safety related cables / components.

Response

Smoke detectors will be installed. 1639 007

111-1 ROOM NO. 111 - FIGURE 1 ROOM DESCRIPTION Waste Processing Control Room This room contains two divisions of safety related equipment / cable and no safe shutdown equipment / cable. PROPOSED MODIFICATIONS

1. Smoke detection will be added in accordance with Category C.

SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetraticas) of appropriate fire resistance.

Response

This is not a safe shutdown related room. This room is adjacent to Room 113, containing safe shutdown equipment, which is protected by a sprinkler system to give adequate separation as discussed in criteria 2.

2. Identify the minimum separstion between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

R,esponse There is no safe shutdown equipment / cable in this room.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combustibles which may be introduced into or moved through the area.

Response

The case 1 fire would not threaten safe shutdown criteria.

4. Identify the worst damage that could result from such fire.

Response

Not applicable based on (2.) above. 008

111-2

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environmant.

Response

Based on (2. ) above, safe shutdown capability will not be effected ey a fire in this room. Radiological consequences are discussed in the response to SER Item 3.2.8. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.3.6 of the SER. The licensee will:

1. Analyze the radiological consequences of fire damage to the waste processing syste, cable.

Response

Rcfer to the response to SER item 3.2.8.

2. Analyze the effects on safe shutdown of the loss of auxiliary feed-water pump room fans and/or heating of the boric acid system.

Response

Not applicable to this room.

3. Install fire detectors in coolant receiver tank rooms (areas 107 ar d 114), the corridor (area 104), and other areas containing safety related cablet/ components.

Response

Smoke detectors will be installed. 1639 009

l / 113-1 ROOM NO. 113 - FIGURE 1 ROOM DESCRIPTION Miscellaneous Waste Receiver Tank Room This room centains no divisions of safety related equipment but contains the following safe shutdown equipment:

1. Heat tracing on the redundant boric acid supply lines to the charging pump suction, lines 3" HC-16-1010 and 3" HC-40-lool.

PROPOSED MODIFICATIONS

1. An automatic wet pipe sprinkler system will be installed in this room in accordance with Category A and Criteria 1.

2. Fire dampers will be installed in the ducting between the Miscellanous Waste Receiver Tank Room 113 and Charging Pump Room 115.

SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

Sprinklers will be added to this room in lieu of fire doors and fire dampers installed as described in Modification 2 above. This modifi-cation will affectively compartmentalize the room with the equivalent of 3 hour rated barriers as discussed in Criteria 2.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

Sprinklers above cable trays and equipment will be provided in lieu of additional physical separation of equipment / cabling into separate fire areas as discussed in Category A and criteria 1.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combustibles which may be introduced into or moved through the area.

Response

The original Fire Protection Program Evaluation lists the fixed fire loading at approximately 1 minute in these rooms. The Case 1 tran-sient combustible would add another 14 minutes exposure. Case 2 transient combustible would result in a lower fire loading. 1639 010

113-2

4. Identify the worst damage that could result from such fire.

Response

Due to the prcposed modification to add a wet pipe sprinkler system the postulated transient fire would be effectively suppressed before either divisions cf safe shutdown heat tracing could become involved unless the fire originates within one division, then the suppression system would prevent involvement of its redundant division.

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

Safe shutdown capability is not threatened since the proposed wet pipe sprinkler system will protect safe shutdown equipment from exposure to transient fires and will prevent fires originating within a specific division from affecting the redundant division. Radiological consequences are discussed in the response to SER Section 3.2.8. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.3.6 of the SER. The licensee will:

1. Analyze the radiological consequences of fire damage to the waste processing system cables.

Response

Refer to the response to SER Section 3.2.8.

2. Analyze the effects on safe shutdown of the loss of auxiliary feed-water pump room fans and/or heating of the boric acid system.

Response

Refer to the response for room 106.

3. Install fire detectors in coolant receiver tank room (areas 107 and 114), the corridor (area 104), and other areas conta;ning safety related cables / components.

Response

See the responses for these rooms as applicable. Oii

117-1 ROOM NO. 117 ROOM DESCRIPTION Elevator Machine Room This room contains no safety related or safe shutdown equipment / cable. PROPOSED MODIFICATIONS None. QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

This room is enclosed by concrete walls with a Class B door. This is not a safe shutdown related room and does not communicate with any safe shutdown related rooms. Therefore, separation is adequate.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

There is no safe shutdown cable or equipment in this room.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combustibles which may be introduced into or moved through the area.

Response

The Case i fire is postulated but will not threaten safe shutdown capability.

4. Identify the worst damage that could result from such fire.

Response

Not applicable based on (2.) above. 012

117-2

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

Based on (2.) above, safe shutdown capability will not be effected by fire in this room. Radiological consequences are discussed in the response to SER Item 3.2.8. EVALUATION OF SER SECTION 5 MODIFICATIONS No modifications were required in this room. 163 013

120-1 ROOM NOS. 120 C 122 - FIGURE 1 ROOM DESCRIPTION Containment Recirculating Pipe Tunnel Unit 1 - 122 Unit 2 - 120 These areas contain two divisions of safety related equipment / cable and no safe shutdown equipment / cable. PROPOSED MODIFICATIONS

1. Smoke detectors to be installed per Category C.

2. Sprinklers will be added in piping areas 203 and 224 (immediately above the pipe tunnels) arranged such that at least one head in each system will directly impinge on the steel plates separating the pipe tunnels from the piping areas (see page 203-1) in accordance with the intent of Criteria 2.

SER OUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire rcsistance.

Response

This is not a safe shutdown related room. Sprinkler heads located in the piping areas and directed at the steel plate separating the tunnels from the piping areas will serve as a barrier between the two areas (see page 203-1).

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

There is no safe shutdown equipment / cable in this area.

3. Identify the largest fire thet can be expected in each fire area based on the fixed combustibles in the area and transient combustibles which may be introduced into or moved through the area.

Response

A Case 1 fire would not threaten safe shutdown capability. 014

120-2

4. Identify the worst damage that could result from such fire.

Response

Not applicable based on (2.) above.

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

Based on (2.) above, safe shutdown capability will not be effected by a fire in this area. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.1.6 of the SER. The licensee will:

1. Replace all unrated doors in these areas by UL or FM listed fire doors of a fire resistance rating commensurate with fire hazards on both sides of the barrier, or provide acceptable alternate protection.

Response

There are no unrated doors in this area.

2. Install fire detectors in each pump room and in the corridor areas.

Response

Smoke detaction will be installed in this area.

3. Separate, by adr? ional barriers or by rerouting, redundant cables required for safe shutdown, or demonstrate the adequacy of cable separation in preserving safe shutdown.

Response

There is no safe shutdown cable in this area. I639 015

121-1 R00\1 NOS. 121 C 123 - FIL _,,3 ROOM DESCRIPTION Containment Structure Tendon s Unit 1 - 123 Unit 2 - 121 This room contains no safety related or safe shutdown equipment / cable. PROPOSED MODIFICATION. None. SER QUESTIONS

1. Demonstrate the ac tacy of separation between adjacent fire areas that are not separ. ed by fire barriers (with protected openings and penetrations) of appropriate fire resistarce.

Response

This is not a safe shutdown related room and is not immediately adjacent to any safe shutdown related rooms. Therefore, separation is adequate.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

There is no safe shutdown equipment / cable in this area.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combustibles which may be introduced into or moved through the area.

Response

A Case 1 fire would not threaten safe shutdown capability.

4. Identify the worst damage that could result from such fire.

Response

Not applicable based on (2.) above. O I (>

121-2

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

Based on (2.) above, safe shutdown capability will not be effected by a fire in this area. EVALUATION OF SER SECTION 5 MODIFICATIONS No modifications were required in this area. 1639 017

200-1 ROOM NO. 200 - FIGURES 2 AND 6 ROOM DESCRIPTION E-W Corridor Elevation 5'-0" This area contains two divisions of safety related cable and two divi-sions per unit of safe shutdown cable (no safety related or safe shut-down equipment). PROPOSED MODIFICATIONS

1. An automatic wet pipe sprinkler system will be installed below cable trays in accordance with Category A, Criteria 3.

2. Smoke detectors will be added per Criteria 3.

3. ZA conduit containing heat tracing cables for gravity feed line to charging pump suction will be wrapped in accordance with criteria 6.

SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

Separation between adjacent areas is accomplished by the addition of a sprinkler system in lieu of fire doors as described in Criteria 2.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

Modification 3 indicates that, in lieu of physical separation from the ZB tray, the ZA conduit will be wrap 7ed. There is no redundant safe shutdown equipment in this area.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combustibles which may be introduced ir.to or moved through the area.

Response

The Fire Protection Program Evaluation demonstrated a fixed fire load-ing of approximately 5 minutes for this area. An additional 9 minutes loading would result from a Case 1 transient. I639 018

200-2

4. Identify the worst damage that could result from such fire.

Response

The new sprinkler system to be installed under cable trays will suppress a transient fire. Installation of smoke detectors at the ceiling will alert the fire brigade in tray initiated fires and any fire should be extinguished before significant damage could occur. Wrapping of one division of the redundant conduit will prevent involvement of both divisions.

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

Since redundant divisions will not be involved based on (4.) above, safe shutdown capability will not be jeopardized. Radiological con-sequences are discussed in the response to SER Section 3.2.8. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.4.6 of the SER. The licensee will:

1. Separate each pump room from other plant areas by upgrading the fire resistance of doorway openings, and electrical cable, ventilation duct and piping penetrations in the barriers to a rating commensurate with fire hazards on both sides of the barrier, or provide an acceptable alternate.

Response

An automatic wet pipe sprinkler system will be installed in lieu of fire doors to prevent the spread of fic e from one area to another as dis-cussed in Criteria 2.

2. Demonstrate, or provide appropriate modifications to assure, the com-ponent cooling capability can be preserved in the event of a fire in the area.

Response

Refer to responses for rooms 201 and 228.

3. Install fire detectors in each room and in the corridor.

Response

Smoke detectors will be installed at the ceiling in the corridor. Refer to responses for rooms 201 and 228. 019

200-3

4. Install an excess f1ce stop valve in the hydrogen line to auto-matica11y secure hydrogen in the event of a piping system rt sture.

Response

An excess flow stop valve will be installed. Refer to response to Section 3.1.14.

5. Separate at least one division of cables associated with systems identified in Section 5.4.1 from their redundant counterparts and the hazards in the area by fire rated barrier enclosures, or demon-strate the adequacy of cable separation in preserving safe shutdown.

Response

one division of redundant safe shutdown cables will be wrapped in lieu of physical separation. Sprinklers located below cable trays will suppress any transien+ fires. 1639 020

201-1 ROOM NOS. 201 AND 228 - FIGURES 2 AND 6 ROOM DESCRIPTION Component Cooling Pump Room - Unit 1 - 228 Component Cooling Pump Room - Unit 2 - 201 These rooms contain three divisions of safety related cable and the following safe shutdown equipment and associated cabling:

1. Component cooling heat exchanger saltwater valves:

1(2)-CV-5160 1(2)-CV-5162 1(2)-CV-5206 1(2)-CV-5208 1(2)-CV 5163 1(2)-CV-5165 1(2)-CV-5166

2. Component cooling pumps ll, 12, and 13 (21, 22, and 23)

3. Component cooling heat exchanger component cooling outlet valves:

1(2)-CV-3824 1(2)-CV-3826

4. Shutdown cooling heat exchanger flow control 1(2)-CV-657

5. Low pressure safety injection flow control 1(2)-CV-306 PROPOSED MODIFICATIONS

1. An automatic wet pipe sprinkler system will ha installed per Category A and Criteria 2.

2. To further prevent the spread of fire, curbs will be installed between pumps to limit spread and direct liquid combustibles to the floor drains.

3. Penetrations to the radiation exhaust vent equipment room 225 (204) will be upgraded to 3 hour rated assemblies, to provide complete compartmentalization.

1639 021

201-2 SER QUESTIONS

1. Demonstrate the adequacy of separation between aojacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

separation between adjacent areas is accomplished by the addition of automatic sprinklers in lieu of fire doors as discussed in Criteria 2. In addition, fire dampers between this room and room 225 (204) assure 3 hour fire separation.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

The wet pipe sprinkler system will be provided in lieu of additional physical separation for redundant cables / equipment as discussed in Category A, Criteria 1.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combus-tibles which may be introduced into or moved through the area.

Response

Per the original fire protection program evaluation, the fixed fire loading is approximately 3 minutes. The Case 1 transient combustible would add another 2 minutes exposure. Case 2 transient combustible would result in a lower fire loading.

4. Identify the worst damage that could result from such fire.

Response

Due to the proposed modifications, including the wet pipe sprinkler system, the postulated fire would be effectively suppressed before either division would become involved unless the fire originates within one division, in which case the suppression system will pro-tect the redundant division. Fire involvement of non-redundant, safe shutdown valves (saltwater /CCW heat exchanger) SV-5163, 5165, or 5166 (SV-5155, 5156, and 5212) would result in their going to the safe shutdown failure position. This is also true of valves associated with the L.P.S.I. flow control IP-306 and shutdown heat exchanger flow control IP-657.

201-3

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

Based on (4.) above, redundant safe shutdown divisions of cable / equipment will be effectively protected thus preventing any adverse effects on safe shutdown. Safe shutdown remains assured even with damage to safe shutdown valves as they will fail in the position advantageous to safe shutdown. Radiological consequences are dis-cussed in the response to SER Item 3.2.8. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.4.6 of the SER. The licensee will:

1. Separate each pump room from other plant areas by upgrading the fire resistance of doorway openings, and electrical cable, venti-lation duct and piping penetrations in the barriers to a rating commensurate with fire hazards on both sides of the barrier, or provide an acceptable alternate.

Response

Sprinklers provided on either side of the doorway in accordance with criteria 2, upgrading of penetrations 3 and necessary fire dampers in duct work provide adequate separation between safe shutdown areas.

2. Demonstrate, or provide appropriate modifications to assure, the component cooling capability can be preserved in the event of a fire in the area.

Response

See responses to SER Questions (4.) and (5.) above.

3. Install fire detectors in each room and in the corridor.

Response

Sprinkler system water flow alarms provide the required fire detec-tion as listed in Criteria 5.

4. Install an excess flow stop valve in the hydrogen line to auto-matically secure hydrogen in the event of a piping system rupture.

Response

Refer to response to SER Section 3.1.14. 023

201-4

5. Separate at least one division of cables associated with systems identified in Section 5.4.1 from their redundant counterparts and the hazards in the area by fire rated barrier enclosures, or demonstrate the adequacy of cable separatio.. in preserving safe shutdown.

Response

As discussed in Category A, Cr',teria 1, the proposed modification to install automatic sprinklex a will prevent the loss of either division unless the fire originates in one division, in which case the sprinklers will protect the redundant division. 1639 024

202-1 ROOM NO. 202 - FIGURES 2 AND 6 ROOM DESCRIPTION Eastern Most N-S Passage This room contains two divisions of safety related cable and two divisions of safe shutdown cable per unit (no safety related or safe shutdown equipment). PROPOSED MODIFICATIONS

1. An automatic wet pipe sprinkler system will be installed under the cable trays between columns 21 and 24, and columns 32 and 35, (continuation of Room 200 system) per Category A, Criteria 3.

2. Smoke detection will be added at the ceiling for the full length of the room per Criteria 3.

3. ZA raceways required for safe shutdown will be wrapped in accor-dance with Criteria 6.

SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

The wall between Hot Machine Shop Room 223 and the Passage is 3 hour rated. The walls between the Passage and Component Cooling Rooms 201 and 228 are protected by sprinklers in those rooms. There is a sprinkler system installed at each end of the passage in Rooms 203 and 224 and another in Corridor 200 which covers the intersection between the passage and the corridor.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

Redundant cabling is separated by 25 feet horizontally. Wrapping of the ZA raceways per Modification 3, will also be provided. 1639 025

202-2

3. Identify the largest fire that can be expec ted in each fire area based on the fixed combustibles in the area and transient com-bustibles which may be introduced into or moved through the area.

Response

The Fire Protection Program Evaluation determined that there is a fixed fire loading of approximately 13 minutes. The Case 1 tran- ' sient adds 6 minutes to this load.

4. Identify the worst damage that could result from such fire.

Response

The worst damage that could occur would be the involvement of one channel of safe shutdown cable, the other channal is wrapped and preserved from damage.

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

Sprinklers below cable trays will prevent redundant divisions of cable from being involved in a transient fire per Criteria 3. Wrapping of one division of redundant safe snutdown raceways will prevent invclvement of both divisions. EVALUATIONS OF SER SECTION 5 MODIFICATIONS No modifications were' required. 1639 026

203-1 ROOM NOS. 203 AND 224 - FIGURES 2 AND 6 ROOM DESCRIPTION Piping Areas Unit 1 - 224 Unit 2 - 203 These rooms contain two divisions of safety related equipment / cable and one division of safe shutdown cable (no safe shutdown equipment). PROPOSED MODIFICATION

1. An automatic wet pipe sprinkler system will be installed east of column line N in lieu of fire doors at communicating openings to adjacent areas per Criteria 2.

SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

Spatial separation, barrier walls, and the added sprinkler system will provide adequate separation between this and adjacent safe shutdown areas per Criteria 2. 2, Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

This room contains only one division of safe shutdown cabling and no equipment is required for safe shutdown.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combus-tibles which may be introduced into or moved through the area.

Response

The original Fire Protection Program Evaluation lists the fixed fire loading at approximately 12 minutes. The Case 1 transient combustible would add another 3.3 minutes exposure. Case 2 transient would result in a lower fire loading. 1639 027

203-2

4. Identify the worst damage that could result from such fire.

Response

Due to the proposed modification to add a wet pipe sprinkler system, the postulated fire would be effectively suppressed before the safe shutdown cable could become involved, per Criteria 1. If the fire was internally initiated in the safe shutdown cable, its redundant cable would be unaffected since it is routed through adjacent rooms.

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

Safe shutdown is assured as indicated in (4.) above. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.6.6. The licensee will:

1. Separate piping areas (areas 203 and 224) fro:a other plant areas by fire barriers, complete with fire doors, fire dampers and sealed penetrations, of appropriate fire rating, or demonstrate the adequacy of cable / component separation in preserving safe shutdown.

Response

Wet pipe sprinklers will be provided in lieu of fire doors to Piping Penetration Rooms 227 (206), Radiation Exhaust Vent Equipment Rooms 225 (205), and to the corridor west of column N Room 202. Also, they will serve as a barrier with the pipe tunnel below Room 122 (120).

2. Install fire detectors in piping areas (areas 203 and 224).

Response

Sprinklers placed at the ceiling of the room in combination with a water flow alarm will provide the required fire detection as dis-cussed in Criteria 5.

3. Identify any other safety-related cables / components in the area and analyze the consequences of fire damage to these cables / components.

Response

The following safety related equipment and associated cable is located in this room. Hydraulic Accumulator Unit No. 12 (22) Hydraulic Pumping Unit No. 12 (22) 1639 028

203-3 Motor Operator for Valves MOV-4144 and MOV-4145 located in ycie Tunnel Low Pressure Safety Injection to Loops llA and llB - Flow Transmitters FT-312 and FT-322 liigh Pressure Safety Injection to Loops llA and llB - Flow Transmitters FT-311 and FT-321 None of the listed equipment is required to reach cold shutdown.

4. Verify the manual hose coverage, and install additional hose sta-tions as necessary, to assure thr all points in various rooms of this area can be reached effectively by at least one hose stream.

Response

Refer to response to SER Section 3.1.21. 1639 029

204-1 ROOM NOS. 204 AND 225 - FIGURES 2 AND 6 ROOM DESCRIPTION Radiation Exhaust Vent Equipment Room Unit 1 - Room 225 Unit 2 - Room 204 These roor.s contain three divisions of safety related equipment / cable and three divisions of safe shutdown cable (no safe shutdown equipment). PROPOSED MODIFICATIONS

1. An automatic wet pipe sprinkler system will be added below cable trays per Category A and Criteria 3.

2. Smoke detectors will be added at the ceiling in accordance with criteria 3.

3. ZB and ZC raceway will be wrapped in accordance with Criteria 6.

SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetratiens) of appropriate fire resistance.

Response

Separation of this room will be assured by the addition of a sprinkler system as discussed in Criteria 2. Fire dampers in duct work provide separation from adjacent areas.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

The addition of sprinklers and the wrapping of two of the three redun-dant safe shutdown cables will accomplish effective separation between redundant safe shutdown cables. There is no safe shutdown equipment in this area. 1639 030

204-2

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combus-tibles which may be introduced into or moved through the area.

Response

The Fire Protection Program Evaluation listed a 17 minute fixed fire load for this area. The Case 1 transient would increase this exposure by 4 minutes.

4. Identify the worst damage that could result from such fire.

Response

The wet pipe sprinklers will protect the cables from an exposure fire from the floor. In the event of an internally initiated fire in a cable tray, the wrapping of two of the three redundant cable divisions will insure that this type of fire will not spread to adjacent cable trays. Further, +he addition of the smoke detec-tors above the cables will provite prompt detection of any devel-oping fire, and initiate the rapid response of the fire brigade.

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

The addition of automatic sprinklers precludes damage to raceways from transient fires and, in combination with, wrapping two of the three redundant raceways and with no safe shutdown equipment being i~ the room, safe shutdown capability will not be threatened. Radiological consequences are discussed in the response to SER Item 3.2.8. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.7.6 of the SER. The licensee will:

1. Install fire detectors in this area.

Response

Smoke detectors will be installed at the ceiling as per Criteria 3.

2. Replace the existing unrated doors by UL or FM listed, 3 hour fire doors, or acceptable alternate protection.

Response

Automatic sprinklers will be installed in lieu of fire rated doors as discussed in Criteria 2. 1639 031

204-3

3. Separate one division of safety related cables from their redun-dant counterparts by rated fire barriers, or reroute one division of cables out of the area, or demonstrate the adequacy of cable separation in preserving safe shutdown.

Response

Two of the three safe shutdown cable divisions will be wrapped, thereby insuring that redandant safe shutdown divisions will not be affected by a postulated fire.

4. Provide the results of an analysis for the radiological conse-quences of a charcoal fire.

Response

Refer to response to SER Section 3.2.8. 1639 032

205-1 ROOM NOS. 205 and 226 - FIGURES 2 and 6 ROOM DESCRIPTION Service Water Pump Rooms Unit 1 - 226 Unit 2 - 205 These rooms contain three divisions of safety related equipment and associated cable, and two divisions of safe shutdown cable. These rooms do not contain any safe shutdown equipment. PROPOSED MODIFICATION An automatic wet pipe sprinkler system will be installed in accordance with Category A and Criteria 1 south of Column 19 in Room 226 and north of Column 49 in Room 205. SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openines and penetrations) of appropriate fire resistance.

Response

Automatic sprinkler systems will be provided in lieu of fire doors as discussed in Criteria 2. Watertight doors are installed at the Heater B./ Wull. This type of door cannot be obtained with a fire rating.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown ira each fire area.

Response

The addition of a sprinkler system in combination with existing spatial arrangement, will accomplish effective separation between recundant safe shutdown cables.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combustibles which may be introduced into or moved through the area.

Response

The Fire Protection Program Evaluation gave a fixed loading of approximately 1/2 minute; the case 1 transient will add approxi-mately 3 more minutes. 1639 033

205-2

4. Identify the worst damage that could result from such fire.

Response

The addition of a sprinkler system in the room will prevent the loss of either division unless the fire originating within one division, in which case the sprinkler system will protect the redundant division.

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

The addition of a sprinkler system, as discussed in Criteria 1, assures that safe shutdown capability will not be threatened. EVALUATION CF SER SECTION 5 MODIFICATIONS Refer to Section 5.5.6 of the SEH. The licensee will:

1. Install fire detectors in this area.

Resnonse The addition of a sprinkler system in the room together with the system water flow alarms will provide the required fire detection as per Criteria 5.

2. Demonstrate the adequacy of the fire resistance rating of steel doors separating the pump rooms from the turbine building and replace other doors by UL or FM listed fire doors of an appropriate fire resistance rating.

Response

The doors presently located at the Heater Bay are watertight doors. In lieu of rated fire doors, which are unobtainable for watertight doors, sprinklers will be provided as discribed in Criteria 2. The remaining doors will remain and sprinklers will be provided as per Criteria 2,

3. Verify the adequacy of fire resistance of electrical, piping and ventilation duct penetrations or upgrade them to a rating commen-surate with the fire hazards on both sides of the barrier.

Response

See response to SER Items 3.2.4, 3.2.6 and 3.2.7. Fixed combustibles and transient fire load effects are identified in the response to SER Question 3. The room, with the exception of the doors, is completely enclosed by concrete walls and with the addition of a sprinkler system adequate compartmentatiori is assured. 1639 034

205-3

4. Demonstrate, by tests or analyses, the separation between redundant service water pumps, including the associated cables and other com-ponents, is adequate to preserve at least one division of the service water system in the event of a fire in this area or provide alternate means of service water cooling.

Response

Service water cooling required for safe shutdown can be provided by two redundant service water subsystems on the non-fire effected unit. Other safe shutdown related cables routed through this area are protected as described in the response to SER Qi.estions (4.) and (5.). -5. Identify other safety-related cables or components which may be located in this area and analyze the safety consequences of fire damage to such cables / components.

Response

Based on the proposed modification to add an automatic sprinkler system and the evaluation of service water cooling capability, the ability to reach safe shutdown is not threatened. 1639 035

206-1 ROOM NOS. 206 AND 227 - FIGURES 2 AND 6 ROOM DESCRIPTION Piping Penetration Rocms Unit 1 - 227 Unit 2 - 206 These rooms contain two divisions of safety related equipment / cable and the following single division of safe shutdown equipment and associated cabling:

1. Shutdown cooling return isloation valve 1(2)-MOV-651.

2. Low pressure safety injection to primary loop valves 1(2)-MOV-615 and 1(2)-MOV-625.

PROPOSED MODIFICATIONS An automatic fire detection system will be installed per Category B. SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

Sprinkler systems will be provided in adjacent rooms in lieu of fire rated doors, per Criteria 2. All penetration seals are fire rated. Fire dampers are provided in ductwork.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

There is no redandant safe shutdown equipment or cabling in this room.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combustibles which may be introduced into or moved through the area.

Response

The Fire Protection Program Evaluation demonstrated that the maximum fixed fire loading would be approximately 2 minutes. An additional 5 minutes loading is postulated due to a Case 1 transient. 1639 036

206-2

4. Identify the worst damage that could result from such fire.

Response

MOV-651 Shutdown Cooling Return Isolation Valve, MOV-615 and MOV-625 Low Pressure Safety Injection to the Primary Loop and their associated cables could be damaged.

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

Safe shutdown capability would not be affected since redundant equip-ment is routed through other rooms and since MOV-658 can be manually operated. Radiological consequences are discussed in the response to SER Item 3.2.8. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.6.6 of the SER. The licensee will:

1. Separate piping areas (areas 203 and 224) from other plant areas by fire barriers, complete with fire doors, fire dampers, and sealed penetrations, of appropriate fire rating, or demonstrate the adequacy of cable / component separation in preserving safe shutdown.

Response

Refer to page 203-1,

2. Install fire detectors in piping areas (areas 203 and 224).

Response

Refer to page 203-1.

3. Identify any other safety related cables / components in the area and analyze the consequences of fire damage to these cables and components.

Response

The following safety related equipment and associated cabling are located in this room: Hot Water Heat Containment Isolation Valve MOV-6579 High Pressure Safety Injection aeader to Loop llA(21A) Isolation Valve MOV-617 High Pressure Safety Injection Header to Loop llA Isloation Valve MOV-616 1639 037

206-3 High Pressure Safety Injection Header to Loop llB Isolation Valve MOV-626 High Pressure Safety Injection Header to Loop llB Isolation Valve MOV-627 Containment Caoler 11 (21) Service Water Inlet Flow Transmitter FT 1581 C on ~ A mment Cc. t eg. .3 (23) Service Water Inlet Flow Transmitter FT ' 389 Aux 4 _.y Feedwater to S.G. 11 (21) Flow Transmitter FT 4509 Auxiliary Feedwater to S.G. 12 (22) Flow Transmitter FT 4510 The above listed equipment and associated cable are not required for safe shutdown. A fire involving this equipment, therefore, will not have an adverse effect on the ability to achieve safe shutdown. In addition, the room contains safety related equipment required for safe shutdown as described under " Room Description" and the conse-quences of damage are discussed in the response to SER Question 5.

4. Verify the manual hose coverage, and install additional hose stations, as necessary, to insure that all points in various roocs of this area can be reached effectively by at least one hose stream.

Response

Refer to response to SER Section 3.1.21. 1639 038

207-1 ROOM N9. 207 - FIGURE 6 P.s0M DESCRIPTION Waste Css Equipment Room Units 1 and 2 - 207 This room does not contain safety related or safe shutdown equipment or cable. PROPOSED MODIFICATIONS None. SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

This room is enclosed by a minimum 3 hour fire barrier, except for an open doorway to room 208. A fire originating in room 207 (a transient fire, as there are minimal fixed combustibles in this room) would not effect safe shutdown if it were to spread to room 20% as room 208 does not contain any safe shutdown equipment.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

This room does not contain redundant equipment or cables required for safe shutdown.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combustibles which may be introduced into or moved through the area.

Response

This room contains minimal combustibles. A Case 1 transient fire would have a duration of 6 minutes. The Case 2 transient combustible would result in a lower fire loading. 1639 039

207-2

4. Identify the worst damage that could result from such fire.

Response

There is no safety related or safe shutdown equipment or cable located in this room so a fire would have no effect on the ability to safely shutdown the plant.

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or case excessive radioactive release to the environment.

Response

There is no safe shutdown equipment or cable located in this room. Therefore, a fire would have no effect on safe shutdown. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.9.6 of the SER. The licensee will (statement 1, 2, and 3 do not apply to this room):

4. Install an excess flow stop valve in the hydrogen line to secure hydrogen automatically in the event of a piping system rupture.

Response

This is addressed in the response to SER Item 3.1.14.

5. Analyze the radiological consequences of a fire in the waste gas area.

Response

This is addressed in the response to SER Item 3.2.8. 1639 040

208-1 ROOM NO. 208 - FIGURE 6 ROOM DESCRIPTION Waste Gas Surge Tank Room Units 1 and 2 - 208 This room contains one division per unit of safety related equipment and its associated cable. This room does not contain safe shutdown equipment or cable. PH0 POSED MODIFICATIONS None, in accordance with Category D, as this room contains insignificant fire loading. It is unlikely that the Class 1 and 2 transients would be introduced to this room occause of high radiation levels. SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

This room is enclosed by a minimum 3 hour fire barrier, except for the open doorways to rooms 207 and 209. A Case 1 transient fire originating in room 208 would not effect any safety related or safe shutdown equipment or cables in rooms 207 or 209.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

This room does not contain redundant equipment or cables required for safe shutdown.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and trans ' =nt combus-tibles which may be introduced into or moved througl e area.

Response

This room does not contain fixed combustibles. A Case 1 transient fire would have a duration of 6 minutes. The Case 2 transient combustible would result in a lower fire loading. 1639 041

208-2

4. Identify the worst damage that could result from such fire.

Response

There is no safe shutdown equipment or cable located in this room so a fire would have no effect on the ability to safely shutdown the plant. There is only one division of safety related equipment and cable in this room so another division will be available.

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

There is no safe shutdown equipment or cable located in this room. Therefore, a fire would have no effect on safe shutdown. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.9.6 of the SER. The licensee will (only statement 5 applies to this room):

5. Analyze the radiological consequences of a fire in the waste gas area.

Response

This is addressed in the response to SER Item 3.2.8. 1639 042

209-1 ROOM NO. 209 - FIGURE 6 ROOM DESCRIPTION Equipment Hatch Area Units 1 and 2 - 209 This room does not contain safety related or safe shutdown equipment or cable. PROPOSED MODIFICATIONS None. SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

Room 209 is enclosed by a minimum 3 hour fire barrier, with the exception of :he open doorways to rooms 203, 208, and 210 Room 203 contains safe shutdown cable. The doorway to room 203 is open; however, room 203 is to be provided with sprinklers. Separation between adjacer t areas is accomplished by the addition of sprinklers in lieu of fire doors as discussed in Criteria 2. Rooms 208 and 210 do not contain safe shutdown equipment or cable. A fire originating in room 209 would not endanger safe shutdown.

2. Identify the minimum separation between the redundant ca'oies (in trays or in conduits)/ equipment required f or safe shutdown in each fire area.

Response

This room does not contain redundant equipment or cables required for safe shutdown,

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combus-tibles which may be introduced into or moved through the area.

Response

The fixed fire loading is approximately 1 minute. A Case 1 tran-sient fire would have a duration of 7 minutes. The Case 2 tran-sient combustible would result in a lower fire loading. 1639 043

209-2

4. Identify the worst damage that could result from such fire.

Response

There is no safety related or safe shutdown equipment or cable located in this room so a fire would have no effect on the ability to safely shutdown the plant.

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

There is no safe shutdown equipment or cable located in this room. Therefore, a fire would have no effect on safe shutdown. EVlsLUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.9.6 of the SER. The licensee will (only statement 5 applies to this room):

5. Analyze the radiological consequences of a fire in the waste gas area.

Recnonse This is addressed in the response to SER Item 3.2.8. 1639 044

210-1 ROOM NO. 210 - FIGURE 6 ROOM DESCRIPTION Decontamination Room Units 1 and 2 - 210 This room contains one division per unit of safety related cable. This room doss not contain safety related equipment, or safe shutdown equip-ment or cable. PROPOSED MODIFICATIONS This room will be provided with smoke detection in accordance with Category D as it is postulated that a Case 1 transient fire could be introduced to the room. SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

This room is enclosed by a minimum 3 hour fire barrier, except for the open doorways te rooms 200 and 209. Room 200 contains safe shutdown cabling, kcam 200 is to have sprinklers installed. Separation between adjacent areas is accomplished by the addition of sprinklers in lieu of fire doors as discussed in Criteria 2. Room 209 does not contain safe shutdown equipment or cable. A fire originating in room 210 will not endanger safe shutdown.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

This room does not contain redundant equipment or cables required for safe shutdown.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combus-tibles which may be introduced into or moved through the area.

Response

The fixed fire loading is approximately 1 minute. A Case 1 tran-sient fire would have a duration of 7 minutes. The Case 2 tran-sient combustible would result in a lower fire loading. 1639 045

210-2

4. Identify the worst damage that could result from such fire.

Response

There is no safe shutdown equipment or cable located in this room so a fire would have no effect on the ability to safely shutdown the plant. There is only one division of safety related cable in this room, so another division will be available.

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the envi ronment.

Response

The installation of smoke detectors will provide indication of a fire to allow prompt fire brigade response. There is no safe shutdown equipment or cable located in this room. There fo re , a fire would have no effect on safe shutdewn. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.9.6 of the SER. The licensee will (only statement 5 applies to this room):

5. Analyze the radiological consequences of a fire in the waste gas area.

Response

This is addressed in the response to SER Item 3.2.8. 1639 046

212-1 ROOM NOS. 212 AND 219 - FIGURES 2 AND 6 ROOM DESCRIPTION Western most N-S Passage and Vestibule Room 212 - Passage Room 219 - Elevator Vestibule These rooms contain two divisions of safety related cable / equipment and two divisions of safe shutdown cable and the following safe shutdown equipment:

1. Refueling Water Tank Outlet Valve MOV-504.

PROPOSED MODIFICATIONS

1. An automatic wet pipe sprinkler system will be added below cable trays per Category A and Criteria 2 and 3.

2. Smoke detectors will be added at the ceiling per Criteria 3.

3. ZB raceway will be wrapped in accordance with Criteria 6.

SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

Adjacent rooms will be separated from this area by the added sprinkler system in lieu of fire doors per Criteria 2. This system will also serve at either end of the corridor.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

The addition of sprinklers, detection, and wrapping one division of safe shutdown raceway will accomplish effective separation between redundant safe shutdown cables as discussed in Category A, Criteria 3. 1639 047

212-2

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combus-tibles which may be introduced into or moved through the area.

Response

Per the Fire Protection Program Evaluation, the fixed fire loading is approximately 13 minutes. A Case 1 transient would add another 6 minutes loading.

4. Identify the worst damage that could result from such fire.

Response

Due to the modification to add the sprinkler system below cable trays, the postulated transient fire would effectively be suppressed before either division could become involved. The addition of smoke detectors will alert the fire brigade to extinguish the fire before significant damage could occur. Wrapping of one division also assures one division remaining available. A postulated fire which starts internally to motor operated refeuling water tank outlet valve MOV-504, may affect the valve operator but the valve, which need not be operated for several hours, could be operated manually after suppression of the fire as required by plant operating conditions.

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Respcnse Based Based on (2.) and (4.) above, a fire in this area will have no adverse effect on safe shutdown. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.8.6 of the SER. The licensee will:

1. Install fire detectors in the corridor (including passage) and boric acid and tank rooms.

Response

Smoke detectors will be installed in the corridor and vestibule. Refer to pages responding to other areas.

2. Demonstrate the adequacy of separation of redundant cables, from each other and from possible exposure fire hazards, or provide approoriate modifications to preserve such.

Resoonse Refer to the responses to SER Questions 2 and 4. 1639 048

212-3

3. Install an excess flow stop valve in the hydrogen line to secure hydrogen automatically in the event of a piping system rupture.

Response

Refer to response to SER Section 3.1.14. 1639 049

213-1 ROOM NOS. 213 AND 220 - FIGURE 2 AND 6 ROOM DESCRIPTION Degasifier Pump Rooms Unit 1 - Room 220 Unit 2 - Room 213 These rooms contain no safety related or safe shutdown equipment / cable. PROPOSED MODIFICATIONS < Sprinklers will be installed in Corridor 212 in accordance with Cate-groy A, Criteria 1 and 2. SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

These rooms communicate with Corridor 212 which will have sprinklers installed in accordance with Criteria 2.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

There is no safe shutdown cable / equipment in this area.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combustibles which may be introduced into or moved through the area.

Response

There is no safe shutdown cable / equipment in this area and no identi-fied fixed combustible loading in the area. A Class 1 transient fire would not impact safe shutdown.

4. Identify the worst damage that could result from such fire.

Response

There would be no damage inflicted upon safe shutdown equipment or cable. 1639 050

213-2

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

A fire in this room would not effcet safe shutdown. EVALUATION OF SER SECTION 5 MODIFICATIONS Listed modifications in Section 5.d.6 are not applicable to these rooms. 1639 051

214-1 ROOM NO. 214 - FIGURE 6 ROOM DESCRIPTION Volume Control Tank Room - Unit 2 This room contains two divisions of safety related equipment / cable and two divisions of safe shutdown cable although they are not redundant to one another. PROPOSED MODIFICATIONS

1. Smoke detection will be installed in accordance with Category B.

2. The blockouts between this room and the Degasifier Pump Room 213 will be closed with a 3 hour rated penetration.

SER OUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and pener. rations) of appropriate fire resistance.

Response

Sprinklers will be added in corridor 212 in lieu of a fire door as per Criteria 2. With this modification and the addition of the fire seal, these rooms are effectively compartmentalized with the equiva-lent of 3 hour barriers. 2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

Although there are two divisions, there are no redundant safe shut-down cables in this room.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combus-tibles which may be introduced into or moved through the area.

Response

Per the original Fire Protection Program Evaluation, the fixed fire loading is approximately one minute. Due to the high radiation in this area, it is highly unlikely for any one to be in this area for other than urgent reasons. Because of this low incidence of per-sonnel, transient combustibles are not postulated. 1639 052

214-2

4. Identify the worst damage that could result from such fire.

Response

Loss of single divisions of non-redundant safe shutdown cable.

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

Installation of smoke detectors at the ceiling will be sufficient to alert the fire brigade ir. case of fire. As there is no redun-dant safe shutdown cable in this room, a fire will not adversely effect safe shutdown. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.8.6 of the SER. The licensee will:

1. Install fire detectors in the corridor (including passage) and boric acid and tank rooms.

Response

Fire detection will be installed in this room.

2. Demonstrate the adequacy of separation of redundant cables from each other and from possible exposure hazards, in preserving safe shutdown, or previde appropriate modifications to preserve such.

Response

There are no redundant safe shutdown cables in this room.

3. Install an excess flow stop valve in the hydrogen line to secure hydrogen automatically in the event of a piping system rupture.

Response

Refer to response to SER Section 3.1.14. 053

215-1 ROOM NOS. 215 AND 217 - FIGURES 2 AND 6 ROOM DESCRIPTION Boric Acid Pump Room Unit 1 - 217 Unit 2 - 215 These rooms contain two divisions of safety related equipment and cable and the following safe shutdown equipment and associated cable.

1. Heat tracing and heat tracing panels for the gravity feed to the charging pump (two divisions).

2. Two boric acid gravity feed valves (one division) - MOV-508 and MOV-509.

PROPOSED MODIFICATIONS A wet pipe sprinkler system will be added in accordance with category A Criteria 1 and 2. SER QUESTIONS

1. Demonstrate the adequacy of separation Letween adjacent fire areas that are not separated by fire barriers 'with protected openings and penetrations) of appropriate fire ret istance.

Response

The sprinkler systems to be installed in these rooms, in conjunc-tion with the sprinklers to be installed in Corridor 200, will serve as an adequate alternative to physical barriers for pro-viding separation, as stated in Cri teria 2.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

Sprinklers above cable trays and equipment will be provided in lieu of additional physical separation as discussed in Category A, Criteria 1. 1639 054

215-2

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combus-tibles which may be introduced into or moved through the area.

Response

Per the original Fire Protection Program Evaluation, the fixed fire loading is approximately 3 minutes. The Case 1 loading for this area would add approximately 8 minutes of fire loading resulting in a total of approximately 11 minutes.

4. Identify the worst damage that could result from such fire.

Response

Loss of one division of safe shutdown equipment and cable and heat tracing cables.

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

Due to the proposed modification :o add a wet pipe sprinkler system, the postulated fire would be effe :tively suppressed before either division could become involved unless the fire were to originate in one division, then the fire suppression system would prevent involve-uent of its redundant division. The redundant heat tracing in these areas is covered by a galvanized steel channel and by pipe insulation which will slow the transfer of heat. A high temperature condition of the heat tracing will be alarmed. If the motor operators on MOV-508 and MOV-509 are damaged, these valves, which need not be operated for several hours, could be operated manually after the fire is suppressed. Therefore, the ability to achieve safe shutdown is assured. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.8.6 of the SER. The licensee will:

1. Install fire detectors in the corridor (including passage) and boric acid and tank rooms.

Response

The proposed sprinkler system with its water flow alarms will provide the required fire detection as stated in Criteria 5. 9 055

215-3

2. Demonstrate the adequacy of separation of redundant cables, from each other and from possible exposure fire hazards, in preserving safe shutdown, or provide appropriate modifications to preserve such.

Response

See the responses to SER Questions (2.) and (5.)

3. Install an excess flow stop valve in the hydrogen line to secure hydrogen automatically in the event of a piping system rupture.

Response

This is addressed in the response to SER Item 3.1.14. 1639 056

216-1 ROOM NOS. 216 AND 216A - FIGURES 2 AND 6 ROOM DESCRIPTION Reactor Coolant Make-up Pumps Room Unit 1 - 216 Unit 2 - 216A These rooms contain two divisions of safety related equipment and cable, and the following safe shutdown equipment and associated cable:

1. Heat tracing panels for the gravity feed to the charging pump suction (2 divisions).

PROPOSED MODIFICATIONS A wet pipe sprinkler system will be installed in accordance with Category A and Criteria 1. SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

This room is enclosed by concrete walls having a minimum 3 hour fire rating. The proposed sprinkler system will also serve in lieu of fire doors to prevent a fire from spreading to other areas as discussed in Criteria 2.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

Sprinklers installed at the ceiling will assure that cable separa-tion is adequate and prevent damage to redundant cables. In addi-tion, 12' separation is provided between the redundant heat tracing panels in accordance with criteria 1. 1639 057

216-2

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combus-tibles which may be introduced into or moved through the area.

Response

As per the original Fire Protection Program Evaluation, the fixed fire loading is non-existent. However, the Case 1 transient fire loading in these rooms would be of approximately 32 minutes duration.

4. Identify the werst damage that could result from such fire.

Response

one division of heat tracing panels and associated cable could be damaged.

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

Due to the proposed modification to add a wet pipe sprinkler system, the postulated fire would be effectively suppressed before either division could become involved unless the fire were to originate in one division, then the fire suppression system would prevent involve-ment of its redundant division. EVALUATION OF SER SECTION 5 MODIFICATIONS Section 5 does not contain any modifications for this room. 1639 058

218-1 ROOM NO. 218 - FIGURE 2 ROOM DESCRIPTION Volume Control Tank Room - Unit 1 This room contains two divisions of safety related equipment / cable, two divisions of safe shutdown cable, although they are not redundant to one another, and the following safe shutdown equipment:

1. Refueling Water Tank Outlet Valve MOV-504.

PROPOSED MODIFICATIONS

1. Smoke detection will be installed in accordance with Category B.

2. The blockouts betwecn this room and the degasifier pump room will be closed with a 3 hour rated penetration.

SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

Sprinklers will be added in Corridor 212 in lieu of a fire door as per Criteria 2. With this modification and the addition of the fire seal, these rooms are effectively compartmentalized with the equiva-lent of 3 hour barriers.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

Although there are two divisions, there are no redundant safe shut-down cables in this room.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combus-tibles which may be introduced into or moved through the area.

Response

Per the original Fire Protection Program Evaluation, the fixed fire loading is approximately one minute. Due to the high radiation in this area, it is highly unlikely for anyone to be in the area for other than urgent reasons. Because of this low incidence of per-sonnel, transient combustibles are not postulated. 6 059

218-2

4. Identify the worst damage that could result from such fire.

Response

Loss of single divisions of non-redundant safe shutdown cable. A postulated fire which sta.ts internally to MOV-504 may affect the valve operator. This valve could be operated manually several hours after suppression of the fire as required by plant operating condi-tions.

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

Installation of smoke detectors at the ceiling will be sufficient to alert the fire brigade in case of fire. As there is no redundant safe shutdown cable in this room, a fire will not adversely effect safe shutdown. In the event a fire originates in MOV-504, safe shutdown will be assured through manual valve operation. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.8.6 of the SER. The licensee will:

1. Install fire detectors in the corridor (including passage) and boric acid and tank rooms.

Response

Fire detection will be installed in this tank room.

2. Demonstrate the adequacy of separation of redundant cables from each other and from possible exposure hazards, in preserving safe shut-down, or provide appropriate modifications to preserve such.

Response

There are no redundant safe shutdown cables in this room.

3. Install an excess flow stop valve on the hydrogen line to secure hydrogen automatically in the event of a piping system rupture.

Response

Refer to response to SER Section 3.1.14. 1639 060

221-1 ROOM NOS. 221/326 AND 211/321 - FIGURES 2/3 AND 6/7 ROOM DESCRIPTION Pipinr, Penetration Rooms Unit 1 - 221/326 Unit 2 - 211/321 Room 326 is directly above room 221, a steel grating separates the two cooms, they are to be considered one fire area (room). The same applies to Unit 2 (211/321). Each portion of the room contains 2 divisions of safety related equip-ment. The lower portion of the room does not contain any safe shutdown equipment. The upper portion has 1 division of the following safe shut-down equipment and associated cable:

1. MOV-635, Low Pressure Safety Injection to the Primary Loop

2. MOV-645, Low Pressure Safety Injection to the Primary Loop

3. CV-505, Reactor Coolant Pump Seal Leak Off PROPOSED MODIFICATIONS Smoke detection will be inst aled in accordance with Category B.

SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

The adjacent fire areas are separated by 3 hour rated fire walls having Kalamein doors which are commensurate with fire loads on either side. See response to SER Question (3.)

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

This room only contains one division of equipment and cable required for safe shutdown (i.e., no redundant safe shutdown cables). 1639 061

221-2

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combus-tibles which may be introduced into or moved through the area.

Response

Per the Fire Protection Program Evaluation, the fixed fire loading is approximately 5 minutes. A Case 1 transient would add 9 more minutes to this fire resulting in a total exposure of approximately 14 minutes.

4. Identify the worst damage that could result from such fire.

Response

Loss of a single division of shutdown equipment consisting of MOV-635, MOV-645 and CV-505 identified in " Room Description".

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

In the event of a fire in this room, damage to the safe shutdown equipment and/or cable will not have an adverse affect on safe shut-down since there is only one division of safe shutdown equipment and cable within the room. The redundant division is routed outside this room and wi?.1 be available to perform the intended function. In addi-tion, the safe shutdown equipment consists of motor operated valves which can be manually operated after fire suppression. Automatic fire detection provides early indication and prompt response of the fire brigade. It allows operators to effect orderly transition to the redundant division. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.6.6 of the SER. The licensee will (questions 1 and 2 do not apply to this room):

3. Identify any other safety related cables / components in the area and analyze the consequences of fire damage to these cables / components.

Response

The following valves are all of the safety related equipment in the room. 1639 062

221-3 Upper Portion (326): Valve No. Description CV-1585 Service Water Emergency Outlet Containment Cooler CV-1586 Service Water Normal Outlet Containment Cooler CV-1593 Service Water Emergency Outlet Containment Cooler CV-1594 Service Water Normal Outlet Containment Cooler CV-2180 Containment Waste Gas Header Vent Valve CV-4260 Reactor Coolant Drain Tank Pump 11 Containment Isolation CV-5464 Reactor Coolant Sample Line Containment Isolation Valve MOV-636 Normal HPSI Header to Loop 12A (22A Unit 2) MOV-637 Auxiliary HPSI Header to Loop 12A (22A Unit 2) MOV-646 Normal HPSI Header to Loop 12B (22B Unit 2) MOV-647 Auxiliary HPSI Header to Loop 12B (22B Unit 2) SV-6529 Reactor Coolant Drain Tank 11 Sample Analysis SV-6531 Pressurizer Quench Tank 11 (21) Sample Analysis Lower Portion (221): Valve No. Description CV-1584 Service Water Inlet Valve Containment Cooler CV-1592 Service Water Inlet Valve Containment Cooler SV-6507A North Primary Shield Hydrogen Sample Analysis SV-6507B South Primary Shield Hydrogen Sainple Analysis SV-6507C Pressurizer Compartment Hydrogen Sample Analysis SV-6507D East Elevation 135' Hydrogen Sample Analysis SV-6507E West Elevation 135' Hydrogen Sample Analysis SV-6507F Dome Elevation 189' Hydrogen Sample Analysis SV-6507G Containment 1 (2) Hydrogen Sample Return The above listed equipment and associated cable are not required for safe shutdown. Therefore, a fire involving this equipment will not have an adverse effect on the ability to achieve safe shutdown.

4. Verify the manual hose coverage, and install additional hose stations as necessary, to assure that all points in various rooms of this area can be reached effectively by at least one hose stream.

Response

Refer to the response to SER Item 3.1.21. 1639 063

222-1 ROOM NO. 222 - FIGURE 2 ROOM DESCRIPTION Hot Instrument Shop Units 1 and 2 - 222 This room contains two divisions of safety related cable and two divi-sions of safe shutdown cable. The room does not contain safety related or safe shutdown equipment. PROPOSED MODIFICATIONS A wet pipe sprinkler system will be added in accordance with Category A and Criteria 1, & and 5. SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

Separation between adjacent areas is accomplished by the addition of a sprinkler system in lieu of fire doors as discussed in criteria 2. This room is enclosed by concrete walls having a minimum 3 hour fire rating.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

Sprinklers above the cable trays will be provided in lieu of addi-tional separation as discussed in Category A, Criteria 1. Addi-tionally, the minimum separation between redundant cables is 15' horizontally.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combus-tibles which may be introduced into or moved through the area.

Response

The fixed fire loading is approximately 22 minutes plus 3 additional minutes for the Case 1 transient combustible resulting in a total loading of approximately 25 minutes. 1639 064

222-2

4. Identify the worst damage that could result from such fire.

Response

Due to the proposed modification to add a wet pipe sprinkler syst em, the postulated fire would be effectively suppressed before either division could become involved unless the fire originated within one division, then the suppression system would prevent involvement of the redundant division.

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

The wet pipe sprinkler system will suppress a fire in this room as demonstrated in Category A, Criteria 1 and discussed in responses to SER Questions (2.) and (4.) above. There fore , the ability to achieve safe shutdown is assured. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.9.6 of the SER. The licensee will:

1. Install fire detectors in the hot machine shop and instrument shop.

Response

The addition of a wet pipe sprinkler system will provide forefire detection as stated in Criteria 5.

2. Provide appropriately rated fire doors; fire damper; and piping, electrical cable and ventilation duct penetration seals to separate the hot machine shop and the hot instrument shop from the adjacent plant areas.

Response

The proposed addition of a sprinkler system will serve in lieu of rated doors and penetrations to contain a fire within the room in accordance uith criteria 2.

3. Provide curbs at the doorways to the hot machine shop and the hot instrument shop, or other acceptable means to contain a possible oil /nolvent spillage.

Response

Curbs have been provided at the room entrance to contain possible oil / solvent spillage. 1639 065

222-3

4. Install an excess flow stop valve in the hydrogen line to secure hydrogen automatically in the event of a piping system rupture.

Response

This is addressed in the response to SER Item 3.1.14.

5. Analyze the radiological consequences of a fire in the waste gas area.

Response

This is addressed in the response to SER Item 3.2.8. 1639 066

223-1 ROOM NO. 223 ROOM DESCRIPTION Hot Machine Shop Units 1 and 2 - 223 This room contains two divisions of safety related cable and two divi-sions of safe shutdown cable. The room does not contain safety related or safe shutdown equipment. PROPOSED MODIFICATIONS A wet pipe sprinkler system will be added in accordance with Category A and Criteria 1, 2, and 5. SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

Separation between adjacent areas is accomplished by the addition of a sprinkler system in lieu of fire doors as discussed in Criteria 2. This room is enclosed by concrete walls having a minimum 3 hour fire rating. The proposed sprinkler system will also serve to prevent a fire from spreading to other areas. Thus, adequacy of separation is assured.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

Sprinklers above the cable trays will be provided in lieu of addi-tional separation as discussed in Category A, Criteria 1. Addi-tionally, the minimum separation between redundant cables is 15' horizontally.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combus-tibles which may be introduced into or moved through the area.

Response

The original Fire Protection Program Evaluation reported a fixed loading of 10 minutes which together with the Class 1 transient results in a total fire load of approximately 13 minutes. I639 067

223-2

4. Identify the worst damage that could result from such fire.

Response

Due to the proposed modification to add a wet pipe sprinkler system, the postulated fire would be effectively suppressed before either division could become involved unless the fire originated in one division, then the suppression system would prevent involvement of the redundant division.

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

The wet pipe sprinkler system will suppress a fire in this room as demonstrated in Category A, Criteria 1 and discussed in responses to SER Questions (2.) and (4.) above. Therefore, the ability to achieve safe shutdown is assured. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.9.6 of the SER. The licensee will:

1. Install fire detectors in the hot machine shop and instrument shop.

Response

The addition of a wet pipe sprinkler system will provide for fire detection as stated in Criteria 5.

2. Provide appropriately rated fire doors; fire damper; and piping, electrical cable and ventilation duct penetration seals to separate the hot machine shop and the hot instrument shop from the adjacent plant areas.

Response

The proposed addition of a sprinkler system in the room and corridor will serve in lieu of rated doors and penetrations to contain a fire within the room in accordance with criteria 2.

3. Provide curbs at the doorways to the hot machine shop and the hot instrument shop, or other acceptable means to contain a possible oil / solvent spillage.

Response

Curbs have been provided at the room entrance to contain possible oil / solvent spillage. 1639 068

223-3

4. Install an excess flow stop valve in the hydrogen line to secure hydrogen automatically in the event of a piping system rupture.

Response

This is addressed in the response to SER Item 3.1.14.

5. Analyze the radiological consequences of a fire in the waste gas area.

Response

This is addressed in the response to SER Item 3.2.8. 1639 069

lA-1 CABLE CHASES lA, 1B, 2A, and 2B - FIGURES 3/4/5 and 7/8/9 ROOM DESCRIPTION Vertical Cable Chases Unit 1 - 1A, 1B Unit 2 - 2A, 2B This chase contains 2 divisions of safe shutdown and 2 divisions of safety related cable. The chase does not contain any safety related or safe shut-down equipment. PROPOSED MODIFICATION A wet pipe sprinkler system will be installed in accordance with Cate-gory A and Criteria 1. (Note that smoke detectors are presently installed. They will supplement the sprinklers to provide early detection of a fire). SER OUESTIONS

1. Demonstrare the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetra-tions) of appropriate fire resistance.

Response

The chase, is enclosed by concrete walls, doors, and penetrations having a minimum 3 hour fire rating. The proposed sprinklcr system will also serve to prevent a fire from spreading to other areas. Thus, adequacy of separation is assured.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Pesponse Sprinklers above cable trays will be provided in lieu of additional separation as demonstrated in the discussion of Category A, Criteria 1.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combustibles which may be introduced into or moved through the area.

1639 070

1A-2 Resnonse Per the Fire Protection Program Evaluation, the fixed loading is approximately 134 minutes. Since there is no equipment in these areas requiring lubrication and maintenance and since no area is available for storage, the transient combustible to be expected would be minimal.

4. Identify the worst damage that could result from such fire.

Response

Due to the proposed modification to add a wet pipe sprinkler system the postulated fire would be effectively suppressed before either division could become involved unless the fire oricinated within one division, then the sprinkler system would prevent involvement of the redundant division.

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioaction release to the environment.

Response

The proposed wet pipe sprinkler system will protect safe shutdown cables from exposure to transient fires and will prevent fires originating within a specific division from affecting the redundant division. Therefore, the ability to achieve safe shutdown is assured. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to section 5.13.5 of the SER. The fire protection in the cable chases is not adequt te because of the following problem:

1. Poor accessibility for fire fighting "A" chases have access at elevations 45'-0" and 69'-0", "P," chases have only one access at the elevations 45'-0". These vertical cable chases extend downward to the elevation 27'-0" and a steel platform with approximate floor area of 4' x 6' is provided inside each chase at the access on the elevation 45'-0". It is hichly unlikely that a fire in any vertical cable chase can be effectively fought from this small platform.

Each horizontal cable chase has one access which can be reached only by climbing up a vertical ladder and then weaving through piping and steel structure. It is difficult, if not impossible, to bring up portable extinguishers or manual hose lines into the horizontal cable chases. 1639 071

1A-3

Response

The bottoms of the Cable Chases are at 34'-6", the top of Chase A is at 91'-6" and Chase B at 67'-9". In "B" chase, smoke venting may not be possible because the only opening to the chase is the doorway near the lower end of the chase.

Response

Portable smoke removal equipment is available to the cable chases through the access doors, to provide adequate smoke venting for the chases. Cable Chase "B" ceiling is at the same elevation as the Electric Equipment Rooms which precludes the need for additional smoke venting capability.

3. No fire water drainage is provided for any vertical cable chase.

There is a possibility of fire water accumulation submercing cables near the bottom of the cable chases.

Response

Equipment is not located within the cable chase and undamaged cable is not effected by water. Therefore, water accumulation in the chase wouldn't have an adverse effect on the ability to achieve safe shutdown.

4. Separation of cables has not been demonstrated to be adequate to limit the fire damage to a single redundant division.

Response

Due to the proposed modification to add a wet pipe sprinkler system the postulated fire would be effectively suppressed as discussed in Category A, Criteria 1.

U1 & U2 - 1 ROOM NOS. U1 & U2 - FIGURES 5 AND 9 ROOM DESCRIPTION Horizontal Cable Chases

                                                                                  =

Unit 1 - U1 # Unit 2 - U2 This room contains one division of safety related and one division of safe shutdown cable (no equipment). PROPOSED MODIFICATIONS None. Note that smoke detectors are presently installed and provide general area coverage. - RESPONSE TO SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

All valls, doors and penetration seals are 3 hour rated.

2. Idertify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

There is only one division of safe shutdown cables in these areas and no equipment at all.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combus-tibles which may be introduced into or moved through the area.

Response

Per 'the Fire Protectior. Program Evaluation the fixed fire loading is 70 minutes. However, there is no ignition source in the area and the .I cabl,es are not self-propagating. Therefore, in the highly unlikely

                                                                                    -t possibility that a cable did ignite, the fire would be self-extinguished without a support fire underneath. No transient exposure fire is postulated due to the inaccessibility of the area.
                          ~?

1639 073

U1 & U2 - 2

4. Identify the worst damage that could result from such fire.

Response

Loss, of one cable division.

5. Demopstrate that such damage will not have an adverse effect en -

safe shutdown or cause excessive radioactive release to the .: environment. Resnonse Based on (2.) and (3.) above, only minor damage to one division can be postulated. Thus safe shutdown capability is not affected. EVALUATION OF SER SECTION 5 MODIFICATIONS There were no modifications required at this time. e 1639 074 i

         =G S

D

301-1 ROOM NOS. 301, 304, 305 & 307 - FIGURES 3 AND 7 ROOM DESCRIPTION Battery R,ooms Unit.1 - 301 & 304 Unit 2 - 305 & 307 These rooms contain one division of safety-related equipment / cable and one division of safe shutdown equipment / cable. PROPOSED MODIFICATIONS

1. Tell-tales have been installed to monitor ventilation and a procedure has been established to verify ventilation air flow twice each shift.

SER QUESTIONS

1. Demonstratethead[quacyofseparationbetweenadjacentfireareasthat

   ,       are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

           'Ihere is a minimum 1 hour separation between these areas and the adjacent areas. The rooms are equipped with Class B fire doors, 1% hour rated fire dampers and 3-hour rated walls, floors and ceilings.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire.

Response

Redundant cable and equipment is located in separate rooms.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combustibles which may be introduced into or moved through the area.

Response

Per the Fire Protection Program Evaluation, the fixed fire loading in these areas is approximately 32 minutes. Since the doors to these rooms are locked, no transient combustibles are assumed.

4. Identify the worst damage that could result from such fire.  ;

Resp'onse , loss' of one battery. 1639 075

301-2

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessible radioactive release to the environment.

Response

Since the rooms are completely redundant, loss of one room would merely needssitate reliance on the redundant room and would not jeopardize safe. shutdown capability. .; EVALUATION OF .T A SECTION 5 MODIFICATIONS Refer to SER Section 5.11.6. 'Ihe licensee will:

1. Install tell-tales at the exhaust and supply air grills in each battery room and verify the ventilation air flow twice each shift.

Response

Tell-tales have been installed to monitor ventilation and a procedure has been establishgd to verify ventilation air flow twice each shif t. 1639 076 e

         ' . .'                                                                       4 D

k s

302-1 ROOM NOS. 302, 306, 1C AND 2C - FIGURES 3/4/5 AND 7/8/9 ROOM DESCRIPTION Cable Spreading Room and Associated Chase Unit 1 - 306 and Vertical Cable Chase IC Unit 2 - 302 and Vertical Cable Chase 2C The cable chase is directly open to, and therefore forms a part of, the cable spreading room. This room contains three divisions of safety related and three divisions of safe rhutdown equipment and cable. PROPOSED MODIFICATIONS

3. An automatic total flooding Halon 1301 system will be added to sup-press a fire in the rooms and cable chases, in accordance with Category A and Criteria 4. The system will be initiated by smoke detectors located throughout the room and cable chase. System initiation will actuate closing of all HVAC dampers in the room.

Doors to the rooms will be electrically supervised. (Note that: the relay cabinets located in the room already have their own individual automatic Halon 1301 systems; the room presently has a smoke detection system). SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

This room is enclosed by 3 hour rated concrete walls. Doors and penetrations have a minimum 1-1/2 hour fire rating. This 1-1/2 hour rating is commensurate with the fire load in this room, including the addition of a Case 1 transient fire load. Fire loads identified in adjacent areas, including the addition of Case 1 transient fire loads, are less than the 1-1/2 hour rating of fire doors and dampers. The proposed Halon 1301 system will also serve to prevent a fire from spreading to other areas. Thus, adequacy of separation is assured. In addition, the dividing wall and door between units is a 3 hour minimum rated fire barrier.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

The Halon 1301 system will insure that a fire is suppressed before it can spread to other areas in the room and/or other divisions as described in Category A, Criteria 4. 1639 077

302-2

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combus-tibles which may be introduced into or moved through the area.

Response

Based on the original Fire Protection Program Evaluation, the fixed fire loading is approximately 81 minutes. The Case 1 transient adds an additional 2 minutes exposure. However, it would be extremely unlikely that a case 1 transient would be brought into the area as there isn't any equipment requiring lubrication or fuel in the vicinity of the passageways to the room or in the room itself.

4. Identify the worst damage that could result from such fire.

Response

Due to the proposed modification to add a Halon 1301 suppression sys-tem, the postulated fire would be effectively suppressed before either division could become involved unless the fire originated within one division, then the suppression system would prevent involvement of the redundant division.

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

The proposed Halon 1301 fire suppression system will limit damage to a single division of safe shutdown equipment and cable. The re fore , the ability to achieve safe shutdown is assured. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.10.6 of the SER. The licensee will:

1. Install an automatic fire suppression system in each cable spreading room, and demonstrate the adequacy of cable / equipment separation in preserving safe shutdown during and following a fire emergency.

Response

a. A Halon 1301 fire suppression system will be installed in the cable spreading room and its associated cable chase,

b. Due to the proposed modification to add a Halon 1301 fire sup-pression system, the postulated fire would be effectively sup-pressed before either division could become involved unless the fire originates within one division, then the automatic Halon 1301 fire suppression system would prevent involvement of the redundant division thereby preserving safe shutdown capbility.

1639 078

308-1 ROOM NO. 308 - FIGURE 7 ROOM DESCRIPTION Eastern most N-S Passage There is no safety related or safe shutdown cable / equipment in this area. PROPOSED MODIFICATIONS None. SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

This is not a safe shutdown related room. Separation from the cable spreading rooms and from the main steam rooms is by 3 hour rated walls. Therefore, separation is adequate.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

There is no safe shutdown cable / equipment in this room.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combus-tibles which may be introduced into or moved through the area.

Response

The Case 1 transient fire would be the largest fire as this passage is essentially free of combustibles.

4. Identify the worst damage that could result from such fire.

Response

There is no safe shutdown cable / equipment in this passageway. 1639 079

308-2

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

There is no safe shutdown cable / equipment in this room. Therefore, the ability to achieve safe shutdown is assured. EVALUATION OF SER SECTION 5 MODIFICATIONS There are no modifications required in this area. 1639 080

309-1 ROOM NOS. 309 and 315 - FIGURES 3 and 7 ROOM DESCRIPTION Main Steam Piping Room Unit 1 - 315 Unit 2 - 309 These room contain two divisions of safety related equipment / cable and the following two divisions of safe shutdown equipment and associated cabling:

1. Auxiliary Feedwater Pump Steam Supply Valves MOV-4070 and MOV-4071

2. Main Steam Pressure Transmitters PT-3991 and PT-4008 PROPOSED MODIFICATIONS A wet pipe sprinkler system at the ceiling will be added per Catecory A.

SER OUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Resnonse Sprinklers will be added in this room and will function in lieu of fire rated doors per Criteria 2.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

Sprinklers at the ceiling will be provided in lieu of additional physical separation as discussed in Category A and Criteria 1.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combus-tibles which may be introduced into or moved through the area.

Response

Per the original Fire Protection Program Evaluation the fixed fire i loading is approximately one m.nute. An additional two minutes loading would result from the Case 1 transient. 1639 08i

309-2

4. Identify the worst damage that could result from such fire.

Response

Due to the proposed modification to add a wet pipe sprinkler system, the postulated fire would be effectively suppressed before either division could become involved unless the fire originated within one division, then the sprinkler system would prevent the involvement of redundant division. A postulated fire which starts internally to either MOV-4070 or MOV-4071 may effect the valve operator. These valves or manual bypass valves could be ranually operated after suppression of the fire as required by plant operating conditions. A postulated of the main fire could damage either steam line pressure transmitters, however additional instrumentation is available to supply operators with this information.

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

The proposed wet pipe sprinkler system will protect safe shutdown equipment from exposure to transient fires and will prevent fires originating within a specific division from affecting the redundant division. In the event the fire originates in either MOV-4070 or MOV-4071, safe shutdown would be assured through manual valve operation. Steam generator outlet / main steam pressure indication is available from other instrumentation on those lines, so safe shutdown capability will not be adversely effected by loss of either PT-3991 or PT-4008. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.6.6 of the SER. The licensee will:

1. Separate piping areas (areas 203 and 224) from other plant areas by fire barriers, complete with fire doors, fire dampers and sealed penetrations, of appropriate fire rating, or demonstrate the adequacy of cable / component separation in preserving safe shutdown.

Response

Not applicable to this room. Refer to page 203-1.

                                                           +639 1        082

309-3

2. Install fire detectors in piping areas (areas 203 and 224).

Response

Not applicable to this room. Refer to page 203-1.

3. Identify and other safety related cables / components in the area and analyze the consequences of fire damage to these cables / components.

Response

The following safety related equipment and associated cabling are located in this room. Containment Purge Sample Isolation Valve CV-5292 Main Steam Line Drain 17 Isolation Valve MOV-6613 (Unit 1 only) Feedwater to Steam Generator 12 (22) Isolation Valve MOV-4517 Feedwater to Steam Generator 11 (21) Isolation Valve MOV-4516 Main Steam Isolation Valve 12 (22) Bypass MOV-4052 Main Steam Isolation Valve 11 (21) Bypass MOV-4045 Main Steam Line Drain 23 Valve MOV-6620 Main Steam Line Drain 24 Valve MOV-6621 The above listed equipment and associated cabling are not required for safe shutdown. A fire involving this equipment will not have an adverse effect on the ability to achieve safe shutdown.

4. Verify the manual hose coverage, and install additional hose stations as necessary, to assree that all points in various rooms of this area can be reached effectively by at least one hose stream.

Resnonse Refer to response to SER Section 3.1.'1. 2 I639 083

310-1 ROOM NOS. 310 AND 316 - FIGURES 3 AND 7 ROOM DESCRIPTION Piping Penetration Rooms Unit 1 - 316 Unit 2 - 310 These rooms contain two divisions of safety related equipment / cable and the follow,ng safe shutdown equipment and associated cabling con-sisting of auxiliary feedwater flow control valves 1(2)-CV-4511 and 1(2)-CV-4512 ;.nd their respective controllers. PROPOSED MODIFICATIONS

1. 7B raceway will be wrapped in accordance with Category A, Cri-teria 6.

2. Smoke detectors will be added at the ceiling in accordance with Category A.

SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

In lieu of a fire rated door, sprinklers in room 315 (309) will be installed to insure adequate separation at the water tight door to this room in accordance with criteria 2. The door to the purge air supply room 318 (312) is a Class B door which is adequate considering the low fire load as given below in the response to SER Quastion (3.) and in the write-up for room 318. The floor is steel grating. Separation of rooms 316 (206) are not required to be separated as safe shutdown equipment in these areas are not redundant to one another. Any transient combus-tible which is spilled will flow to the room below where protec-tion will be provided. All penetrations seals are fire rated.

2. Identify the minimum separation between the redundant cable (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

In lieu of physical separation from the ZA division, the ZA race-way will be wrapped per Criteria 6. 1639 084

310-2

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combus-tibles which may be introduced into or moved through the area.

Response

The Fire Protection Program Evaluation demonstrated that the maximum fixed fire load would be approximately 2 minutes. The worst loading would result from a case 2 transient.

4. Identify the worst damage that could result from such fire.

Response

One division of safe shutdown equipment and cabling could be damaged.

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

Wrapping of cabling in the ZB division will prevent damage to the redundant division. IP-4511 and TP-4512 controllers are encapsu-lated in high temperature energy resistant enclosures and would not be effected by fire. The Cv's will, if affected by fire, fail in a position advantageous to safe ahutdown. Therefore, the ability to achieve safe shutdown is assured. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.6.6 of the SER. The licensee will:

1. Separate piping areas (areas 203 and 224) from other plant areas by fire barriers, complete with fire doors, fire dampers, and sealed penetrations, of appropriate fire rating, or demonstrate the adequacy of cable / component separation in preserving safe shutdown.

Response

Not applicable to these rooms. Refer to page 203-1.

2. Install fire detectors in piping areas (areas 203 and 224).

Response

Not applicable to these rooms. Refer to page 203-1, 1639 085

310-3

3. Identify any other safety related cables / components in the area and analyze the consequences of fire damage to these cables and components.

Response

The following safety related equipment and associated cable is located in this room: Containment Purge Solenoid Valve SV 1411 Instrument Air Containment Isolation Valve MOV-2080 Service Water Emergency Outlet - Containment Cooler 11 (21) Valve CV-1582 Service Water Normal Outlet - Containment Cooler 12 (22) Valve CV-1583 Service Water Normal Outlet - Containment Cooler 11 (21) Valve CV-1581 Dcmineralizer Water Containment Isolation Valve CV-5460 Service b'ater Emergency Outlet - Containment Cooler 13 (23) Valve CV-1590 Service Water Inlet - Containment Cooler 13 (23) Valve CV-1589 Fire System Containment Isolation Valve MOV-6200 Containment Hg Purge Isolation Valve CV-6901 Component Cooling Outlet Containment Isolation Valve CV-3833 Component Cooling Inlet Containment Isolation Valve CV-3832 Containment H 2Purge Valve MOV-6903 and MOV-6901 Steam Generator 11 Bottom Blowdown Control Valve CV-40ll Steam Generator 11 Top Blowdown Control Valve CV-4010 Steam Generator 12 Top Blowdown Control Valve CV-4012 Steam Generator 12 Bottom Blowdown Control Valve CV-4013 Containment Purge Air Exhaust Solenoid Valve SV-1413 Main Steam Line Drain 17 Valve MOV-6613 Main Steam Line Drain 18 Valve MOV-6615 1639 086

                                  .                                  310-4 HPSI Header to Loop 21B Isolation Valve MOV-627 HPSI Header to Loop 21A Isolation Valve MOV-616 IIPSI Header to Loop 21B Isolation Valve MOV-626 Service Water Normal Outlet - Containment Cooler 23 Valve CV-1591 Auxiliary Feedwater to Steam Generator 22 Valve CV-4512 Auxiliary Feedwater to Steam Generator 21 valve CV-4511 The above listed equipment and associated cable, except for CV-4511 and CV-4512, are not required for safe shutdown. Consequences of damage to CV-4511 and CV-4512 are discussed in responses to SER Questions (4.) and (5.). A fire involving this equipment, there-fore, will not have an adverse effect on the ability to achieve safe shutdown.

4. Verify the manual hose coverage and install additional hose sta-tions, as necessary, to insure that all points in various rooms of this area can be reached effectively by at least one hose stream.

Hesponse Refer to response to SER Section 3.1.21. 1639 087

311-1 ROOM NOS. 311 AND 317 - FIGURES 3 AND 7 ROOM DESCRIPTION Switchgear Rooms Unit 1 - 317 Unit 2 - 311 These rooms contain three divisions of safety related equipment and cable, three divisions of safe shutdown cable and two divisions of electrical equipment. PROPOSED MODIFICATIONS,

1. A 3 hour fire rated damper will be installed in the HVAC duct.

2. Unrated blockouts will be closed with 3 hour fire rated penetration seals.

3. Two of the three redundant divisions of safe shutdown cables will be wrapped with approved fire rated material in accordance with criteria 6. Smoke detection is presently installed in the room.

SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas th'at arennot separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

Based on the proposed modifications, these rooms will form a com-plete 3 hour rated compartment with the exception of the 1-1/2 hour rated doors into the Purge Air Supply Rooms 312 and 318. The 1-1/2 hour fire rated doors will be adequate as the fire load-ing inside of room 311 is only 23 minutes and that in the Purge Air Supply Room 312 is 25 minutes.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

Two of the three redundant saf: shutdown cables will be wrapped with approved fire rated material in accordance with criteria 6. This will assure that separation is adequate and a fire cannot effect more than one division of safe shutdown cable. Two divi-sions of safe shutdown equipment are located in the room, con-sisting of disconnect switches for each division. However, in 1639 088

311-2 the event of a fire a third division, located outside of the room, will be capable of performing the required function. All other redundant equipment is located outside of this room.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combus-tibles which may be introduced into or moved through the area.

Response

As stated in the Fire Protection Program Evaluation, the fixed fire loading is approximately 20 minutes. The Case 1 transient loading is approximately 3 minutes.

4. Identify the worst damage that could result from such fire.

Response

Fire could effect only one division of safe shutdown cable as two redundant cable will be wrapped. Two divisions of safe shutdown equipment (i.e. , interlocked and keyed disconnect switches for Saltwater Pump 13 Service Water Pump 13, Diesel No. 13, Component Cooling Pump 13 and Charging Pump 13) could be damaged.

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Resoonse In the event of a fire in this room, damage to the safe shutdown equipment and/or cable will not have an adverse effect on safe shutdown. Only one division of safe shutdown cable could be affected as another division will be available to perform the intended function outside this room. The safe shutdown equipment will also have another division to perform the intended function located outside this room. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.12.6 of the SER. The licensee will:

1. Analyze the consequences of losing "A" cables in conduits above "B" switchgear concurrent with the loss of "B" division.

Response

Not applicable to this room. See response to SER Question (1.) for Room 407 (430). 1639 089

311-3

2. Demonstrate by hose reach tests that every point in switchgear rooms can be reached effectively by at least one manual hose stream.

Response

Refer to the response to SER Item 3.1.21. 1639 090

312-1 ROOM NOS. 312 AND 318 - FIGURES 3 AND 7 ROOM DESCRIPTION Purge Air Supply Rooms Unit 1 - 318 Unit 2 - 312 These rooms contain two divisions of safety related cable and no safety related equipment or safe shutdown equipment / cable. PROPOSED MODIFICATIONS Smoke detection will be installed at the ceiling per Category C. SER OUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

All penetrations and doors have a minimum rating of 1-1/2 hours which is commensurate with the fire loads on both sides of the walls.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

There is no equipment or cables in these rooms which are required for safe shutdown.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combus-tibles which may be introduced into or moved through the area.

Response

The Fire Protection Program Evaluation established the fixed fire load at approximately 13 minutes. The Case 1 transient would add another 12 minutes exposure.

4. Identity the worst damage that could result from such fire.

Response

Loss of the Purge Air HCV and the loss of offsite power. 1639 09i

312-2

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

Purge air is not required for safe shutdown and loss of offsite power is already one of the postulated design basis conditions. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to SER Section 5.14.6. The licensee will:

1. Install fire detectors in each of these rooms.

Response

Smoke detectors will be installed.

2. Separate redundant cables in each room by a fire rated barrier, reroute one divicion of redundant cables out of the room, or demonstrate the adequacy of cable separation in preserving safe shutdown.

Response

There is no equipment / cable required for safe shutdown in this room, so separation is adequate and a fire will have no adverse effects on safe shutdown. 1639 092

313-1 ROOM NOS. 313/411 AND 314/427 - FIGURES 4 AND 8 ROOM DESCRIPTION Spent Fuel Pool Unit 1 - 314/427 Unit 2 - 313/411 This room is the spent fuel pool and consists of spent fuel stored in racks and fuel transfer equipment (non-safe shutdown), which are entirely submerged within the pool water. A fire in this room is impossible. This room warrants no further analysis. PROPOSED MODIFICATIONS None SER QUESTIONS Not valid for above reasons. EVALUATION OF SEn SECTION 5 MODIFICATIONS The modifications do not apply to this room. 1639 093

y. 319-1 ROOM No. 319 - FIGURES 3 AND 7 ROOM DESCRIPTION Western most N-S Passage Units 1 & 2 - 319 This room does not contain any safety related or safe shutdown equipment. The room contains two divisions of safety related cable and one division of safe shutdown cable. PROPOSED MODIFICATIONS Smoke detection will be added in accordance with Category B. SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance. ,

Response

This room is separated from adjacent fire areas by minimum 3 hour fire rated walls and doors except for the passage ways to the following rooms:

a. No. 328, 320 - There are wire mesh doors in these passage ways, however, the rooms do not contain any safe shut down equipment or cable. So a fire in room no. 319 would not have an affect on safe shutdown by the possibility of rooms '~28 or 320 being exposed to the fire,

b. No. 325. The paseage way is open, however, the room does not contain any safe shutdown equipment or cable. So a fire in room no. 319 would not have an affect on safe shutdown by the possibility of room no. 325 being exposed to the fire.

c. No. 321, 322, 323, 324, 326 - There are non-rated doors in the passage ways to these rooms. All of the rooms have smoke detection. ~ A fire originating in room no. 319 would not affect safe shutdown by the possibility of exposing any of these rooms to the fire, as these rooms each only contain

               , one division of safe shutdown equipment and/or cable of the same division as in room no. 319.

Another division, located outside of these rooms, will be available to perform the intended function. 1639 094

319-2

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

This room contains one division of cable required for safe shut-down (i.e., no redundant safe shutdown cables). Redundant cables are located cutside of this room.

3. Identify the largest fire that can be expected in each area based on the fixed combustibles in the area and transient combustibles which may be introduced into or moved through the area.

Resnonse The fixed fire loading in this area is approximately 2 minutes. A Case 1 transient would add less than 5 minutes to the fire exposure.

4. Identify the worst damage that could result from such fire.

Response

ZB division cabling could be damaged.

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

ResDonse In the event of a fire in this room, exposure of the safe shutdown cable to the fire will not bave an adverse affect on safe shutdown since there is only one division of safe shutdown cable, and another division will be available to perform the intended function. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.15.6 of the SER. The licensee will:

1. The licensee will analyze the effect on the spent fuel cooling, and other possible safety effects, of a fire in this area.

Resoonse The safety injection punis can be aligned to supplement the spent fuel pool cooling system, in the event that cable required for the spent fuel pool cooling equipment is exposed to a fire. Therefore, cooling of the spent fuel pool will be assured. 1639 095

320-1 ROOM NO. 320 - FIGURE 3 H00M DESCRIPTION Spent Fuel Pool lleat Exchanger Room This room contains two divisions of safety related equipment / cable and no safe shutdown equipment / cable. PROPOSED MODIFICATIONS Smoke detection will be added per Category C. SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separe.ted by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

All walls and penetration seals in this room are 3 hour rated except the non-rated HVAC duct and the wire mesh door between this room and passage 319. There is only one division of safe shutdown cable (no equipment) in 319 plus there is a shield wall parallel to the wire mesh door entrance, so separation to adja-cent areas should be adequate.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

This room contains no safe shutdown cable / equipment, therefore separation is adequate.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combus-tibles which may be introduced into or moved through the area.

Response

The Case 1 transient fire would be the largest postulated fire.

4. Identify the worst damage that could result from such fire.

Response

Two divisions of safety related equipment and cable required for spent fuel cooling could be damaged. Safety injection pumps can be aligned to maintain pool temperatures within safe limits. 1639 096

320-2

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

Since there is no safe shutdown cable or equipment in this room, a fire in this area will have no adverse effects on safe shutdown. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.15.6 of the SER. The licensee will:

1. Analyze the effect on the spent fuel cooling, and other possible safety effects, of a fire in this area.

Response

This room does contain redundant safety related pumps, heat exchangers, and valves and their associated cables. In case of non-availability of the equipment, the safety injection pumps can be aligned to pass fuel pool cooling water through shutdown cooling heat exchangers and return it to the fuel pool. There would be sufficient time to make thi. +"ansition before pool temperatures rose above allowable limits. 6 097

n.

1. 322-1 ROOM NOS. 322 & 324 - FIGURES 3 AND 7 ROOM DESCRIPTION Letdown Heat Exchanger Rooms Unit 1 - 324 Unit 2 - 322 This room contains two divisions of safety related equipment / cable and one division of safe shutdown cable (no safe shutdown equipment).

PROPOSED MODIFICATIONS Smoke detectors will be added per Categories B and C. SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance. ,

Response

Room 324 (322) is separated by 3 hour rated walls from all adjacent rooms. There are rire mesh doors to rooms 319 and to the marification filter roo=s. Also, there are non-rated HVAC ducts through the wall from room 319 and above the entry (going to elevation 45 through ceilina). The duct penetration is sprinklered at elevation 45. Room 319 has only one division of safe shutdown cable; the same division as this room. The filter room is not reg ired for safe shutdown and normally is inaccessible due to high radiation from the filter. Separation is, therefore, adequate.

2. Identify the minimum seperation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

There is no safe shutdown equipment and no redundant safe shutdown cable in this room. 1639 098

322-2

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combus-tibles which may be introduced into or moved through the area.

Response

There is no significant fixed fire load because all cable is in conduit and there is no dylamic equipment in the rooms to require lubrication. Since this is a high radiatici area during opera-tion, no transients were assumed. A transient combustible spill in the corridor will not enter this room due to the step at the entrance.

4. Identify the wcrst damage that could result from such fire.

Response

A single division of safe shutdown cable could be damaged.

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

Since only one division of safe shutdown cable could be damaged, there will be no adverse effects on safe shutdown from a fire in this room. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.15.6 of the SER. The licensee will:

1. Analyze the effect on the spent fuel cooling, and other possible safety effects, of a fire in this area.

Response

Effects on spent fuel cooling are discussed in the room 319 evalua-tion. Involvement of other safety related cable / equipment would not cdversely effect safe shutdown. 1639 099

323-1 ROOM No. 323 - FIGURE 3 ROOM DESCRIPTION Valve Compartment / Passage / Ion Exchange Filter Rooms There is no safety related equipment / cable and one division per unit of safe shutdown cable in this room. There is no safe shutdown equipment in this room. PROPOSED MODIFICATIONS Add smoke detectors in the passage area per Category B. SER QUP.STIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

This area is separated from all adjacent areas by 3 hour rated walls. The passage entrance marks the interface between this area and room 319. There is no door at this location. As there is only one division of safe shutdown cable on either side of this entrance, and due to the lov fire loading, a fire rated door is not required. The purification filters room is connected to the letdown room 324 (322) via a non-rated wire mesh door. There is only one division of safe shutdown cable in room 324 (322) and no safe shutdown equipment / cable near that door in this area, so separation is adequate.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

There is no redundant safe shutdown equipment / cable in this area.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combustibles which may be introduced into or moved through the area.

Response

The fire loading in this area is negligible (6 seconds). Due to lack of accessibility and because there is no dynamic equipment requiring lubrication or maintenance, no combustible transient arm assumed. 1639 100

323-2

4. Identify the worst damage that result from such fire.

Response

A single division of safe shutdown cable could be damaged.

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

Since only one division of safe shutdown cable could be damaged, the ability to achieve safe shutdown is assured. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.15.6 of the SER. The licensee will:

1. Analyze the effect on the spent fuel cooling, and other possible safety effects of a fire in this area.

Response

Effects on spens fuel cooling are discussed in the room 319 evalua-tion. Involvement of other safety related cable / equipment would not adversely effect safe shutdown. 1639 101

325-1 ROOM NO. 325 - FIGURE 3 ROOM DESCRIPTION Elevator Vestibule Unit 1 - 325 This room does not contain safety related equipment, it contains two divisions of safety related cable. The rooms do not contain any safe shutdown equipment or cable. PROPOSED MODIFICATIONS Smoke detection will be added in accordance with Category C. SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas tnat are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

This room is separated from adjacent fire areas by minimum 3 hour fire rated walls except for the open passageway to room 319. These common rooms will have smoke detection. A fire originating in room 325 would not affect safe shutdown by the possibility of exposing room 319 to the fire, as room 319 only contains one divi-sion of safe shutdown cable. The redundant division is located outside of this area and will perform the intended function.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

This room does not contain safe shutdown equipment or cable.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combus-tibles which may be introduced into or moved through the area.

Resnonse The room does not contain fixed combustibles. A Case 1 transient would yield a fire exposure of less than 5 minutes. 6 02

325-2

4. Identify the worst damage that could result from such fire.

Response

A fire originating in room 325 could communicate to room 319 and damage one division of safe shutdown equipment.

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

Safe shutdown equipment or cable is not located in this room. If the one division of safe shutdown cable is damaged in room 319, the redundant division is routed outside this area and will per-form the intended function. The re fore , the ability to achieve safe shutdown is assured. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.15.6 of the SER. The licensee will:

1. Analyze the effect on the spent fuel cooling, and other possible safety effects, of a fire in this area.

Response

The safet3 injection pumps can be aligned to supplement the spent fuel pool cooling system, in the event that cable required for the spent fuel cooling equipment is exposed to a fire. There-fore, cooling of the spent fuel pool will be assured. 103

r..: J . . .. .T ~_ 7 ' ...... .. .. .. .... . . ...._~~~~'.T'..-- . . . . . . . . . . . 327-1 ROOM NO. 327 - FIGURE 3 ROOM DESCRIPTION Spent Fuel Pool Demineralizer Room Units 1 & 2 - 327 This room does not contain any safety related cable. It contains safety related equipment. It does not contain safe shutdown equipment or cable. PROPOSED MODIFICATIONS None. SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

This room is completely sealed by 3 hour fire rated walls.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

There is no safe shutdown equipment or cable in this room.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combustibles which may be introduced into or moved through the area.

Response

This room does not contain any fixed combustibles, and there is no access to the room, so transient combustibles cannot be brought into it.

4. Identify the worst damage that could result from such fire.

Response

A fire in this room is not possible. 1639 104

327-2

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

A fire is not possible and there is no safe shutdown equipment or cable in the room; therefore, safe shutdown is assured. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.15.6 of the SER. The licensee will:

1. Analyze the effect on the spent fuel cooling, and other possible safety effects of a fire in this area.

Response

This room is sealed and there are no fixed combustibles in the room. Therefore, a fire is not possible. 1639 105

328-1 ROOM NO. 328 - FIGURE 3 ROOM DESCRIPTION Spent Fuel Pool Filter Room Units 1 and 2 - 328 This room does not contain any safety related cable. It contains safety related equipment. It does not contain safe shutdown equipment or cable. PROPOSED MODIFICATIONS None. SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) or appropriate fire resistance.

Response

This room is separated from adjacent fire areas by minimum 3 hour fire rated walls except for the open passageway to room 319. A fire originating in room 328 would not affect safe shutdown by the possibility of exposing room 319 to the fire, as room 319 only contains only one division of safe shutdown cable. The redundant division is located outside of these rooms and will perform the intended function.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

This room does not contain . safe shutdown equipment or cable.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combus-tibles which may be introduced into or moved through the area.

Response

The room does not contain fixed combustibles. A Case 1 transient would yield a fire exposure of less than 5 minutes. 1639 106

328-2

4. Identify the worst damage that could result from such fire.

Response

A fire originating in room 328 ceuld communicate to room 319 and damage a single division of safe shutdown equipment.

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Resnonse Safe shutdown equipment or cable is not located in this room. If the one division of safe shutdown cable is damaged in room 319, the redundant division is routed outside this area and will per-form the intended function. Therefore, the ability to achieve safe shutdown is assured. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.15.6 of the SER. The licensee will:

1. Analyze the effect on the spent fuel cooling, and other possible safety effects, of a fire in this area.

Response

Equipment in this room, for spent fuel pool cooling, will not be effected by a fire. The equipment consists of piping, valves, and a filter vessel which will not be affected by fire exposure. 1639 1007

400-1 ROOM NOS. 400, 401, 402, 403, 404, 405, 406, 415, 430, 432, 434, 435, 436, 437 AND 438 - FIGURES 4 AND 8 ROOM DESCRIPTION Control Room Complex Vestibule - 400 Superintendent's Office - 401 Toilet - 402 Janitor's Storage - 403 Kitchen - 404 Control Room - 405 Computer Rooms - 406, 430 (see separate response) Passage - 415 Log and Test Instrument Room - 432/434/435/436 Chart, Instrument, Spare Parts Storage Room - 437 Viewing Gallery - 438 The bulk of this area consists of the Control Room, which contains three divisions of safety related and three divisions of safe shutdown equipment and cabic. The other rooms listed form a part of the control room complex. Their purpose is as their name states, and they do not contain any equip-ment or cable necessary for a safety related or safe shutdown purpose. SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

The overall complex is enclosed by walls having a 3 hour fire rating with two doors having a 3 hour fire rating, and an additional two doors with a 1-1/2 hour fire rating. The complex is further sub-divided by concrete walls having three steel bullet-proof doors and one 1-1/2 hour rated door to isolate the Control Room.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

This room contains redundant wiring and control equipment in consoles and cabinets, equipped with metal dividing baffles, open at the top for ventilation. The Control Room is constantly attended assuring prompt response to and quick suppression of incipient fires. This area has a low fire load automatic f fire detection, and rapid extinguishment capa-bility as is stated in the response to SER Question (4.). The re fore , present separation is adequate. 1639 108

400-2

3. Identify the largest fire than can be expected in each fire area based on the fixed combustibles in the area and transient combus-tibles which may be introduced into or moved through the area.

Response

The. combined fixed and transient fire loading within the room totals a maximum fire of 7 minutes.

4. Identify the worst damage that could result from such fire.

Response

This area is continually manned on a 24 hour a day basis. Therefore, plant personnel are able to personally and constantly monitor its contents. Personnel will be able to observe if there is an incipient fire. To supplement plant personnel, the area is provided with smoke detection as an additional warning of an incipient fire. The smoke detectors are provided in the room and in the HVAC ducts. With these two forms of detect. ion, plant personnel can rapidly detect and extinguish the unlikely fire with the local manual fire suppression systems (i.e. , hose stations , portable extinguishers) .

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

For the reasons stated in (4.) above, safe shutdown of the plant will be assured. In addition, due to the high degree of detection and the ability to rapidly extinguish a fire, contunued safe operation of the plant will be assured. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.16.6 of the SER. The licensee will:

1. Replace wooden furniture and shelves with those of metal except for work benches in the Log and Test Instrument Room (Room 435).

Response

Refer to the response to SER item no. 3.1.18.

2. Provide metal partitions to separate the adjoining panels from the computer terminal in the middle of the main panel.

Response

Refer to the response to SER item no. 3.1.18. 1639 109

400-3

3. Demonstrate that the safe shutdown capability can be preserved in the event of a fire in this area.

Response

Any Tire that could possibly begin to develop would be almost instantaneously detected, either by smoke detectors or room personnel. Due to the fact that personnel are always in the room, the fire would immediately be extinguished. Because of this, safe shutdown equipment or cable would not be exposed to a fire that could effect its intended function.

4. Replace the existing bullet-proof doors with UL listed 3 hour rated, bullet-proof fire doors, or demonstrate the adequacy of fire resistance of the existing d9ers.

Response

The use of bullet-proof doors in the control room complex is zur security purposes and since this area is continuously manned on a 24 hour basis, detection of cr.n incipient fire would be prompt enough to mitigate any significant damage due to a fire and certainly before safe shutdown would be jeopar-dized. For additional discussion, see the analysis for room 406 and the response to SER Question (1.). 1639 110

406-1 ROOM NO. 406 - FIGURE 8 ROOM DESCRIPTION Computer Room - Unit 2 This room contains no safety related/ safe shutdown equipment, and three divisions of safety related/ safe shutdown cable located above the ceiling of this room. PROPOSED MODIFICATIONS

1. Add smoke detectors above drop ceiling in accordance with Category A.

2. ZA and ZC conduit will be wrapped in accordance with Category A, Criteria 6.

NOTE: This room falls under Category A. Conduit and trays . quired for safe shutdown are located above the noncombustible dcop ceiling. Smoke detectors are presently located in the sub-floor and below the drop ceiling for general room coverage. In eddition, a Halon 1301 system is presently installed for cabinet internals and in sub-floor. SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected opeings and penetrations) of appropriate fire resistanc .

Resnonse The room is enclosed by concrete walls. The doors into the main control room 405 are 1-1/2 hour rated fire doors and the door to the Electric Switchgear Room 407 is a steel bullet-proof door. These doors are considered adequate as they are commensurate with the fire loads on either side as tabulated below: Fire Load in Minutes Room Fixed Iransient Total Computer Room 406 10 14 24 Computer Room 405 7 1 8 Elec. Switchgear Room 407 33 3 36 1639 111

406-2

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

Two of the three safe shutdown divisions will be wrapped in lieu of additional physical separation per Criteria 6. There is no safe shutdown equipment in this area.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combus-tibles which may be introduced into or moved through the area.

Response

According to the Fire Protection Program Evaluation, the fixed fire load is 10 .ninutes. A Case 1 transient fire would add 14 minutes to the fire load of this room.

4. Identify the worst damage that could result from such fire.

Response

Wrapping of two of the three redundant divisions will prevent damage of more than one safe shutdown cable.

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

The installation of automatic smoke detection in the room, below the floor and above the ceiling, will give prompt notification of fire to the fire brigade and control room operators so that fire suppression can be immediately initiated. The noncombustible drop ceiling will delay commun 3 a-tion of a transient fire to the con-cealed space containing s.- -down cable. Wrapping two of the three redundant divisions will limit drmage to one division. Therefore, the ability to achieve safe shutdown will be assured. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.16.6 of the SER. The licensee will:

1. Replace wooden furniture and shelves with those of metal except for work benches in the log and test instrument room (room 435).

Response

Not applicable to this area. 1639 112

406-3

2. Provide retal partitions to separate adjoining panels from the computer terminal in the middle of the main panel.

Response

Not applicable to this room.

3. Demonstrate that the safe shutdown capability can be preserved in the event of a fire in this area.

Response

See the response to SER Question (5.) above.

4. Replace the existing bullet-proof doors with UL list d 3 hour rated, bullet-proof fire doors, or demonstrate the adequacy of fire resistance of the existing doors.

Response

The door from the computer room to the electrical equipment room is a steel bullet-proof door. See the response to SER Question (1.) above. 1639 113

407-1 ROOM NOS. 407 AND 430 - FIGURES 4 AND 8 ROOM DESCRIPTION Electrical Switchgear Room Unit 1 - 430 Unit 2 - 407 These rooms contain two divisions of safety related equipment and cable, and two divisions of safe shutdown cable and electrical equipment. PROPOSED MODIFICATIONS ZA divisions of safe shutdown cables will be wrapped with approved fire rated material in accordance with criteria 6. Smoke detection is pre-sently installed in the room. SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

This room forms a complete 3 hour rated compartment. having Class A fire doors, with the exception of a 1-1/2 hour fire rated door into the electrical penetration room 409 and the steel bullet-proof door to computer room 406. The 1-1/2 hour fire rated door will be adequate as the fire loading in room 407, including the Case 1 transient, is only 35 minutes and that in 409 is 18 minutes. The fire load in Computer Room 406, including the Case 1 transient, is 23 minutes. Thus, the 1-1/2 hour fire rated doors and steel bullet-proof door have sufficient fire resistance to prevent a fire from spreading from one room to the other.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

one of the two redundant safe shutdown cables will be wrapped with an approved fire rated material in accordance with criteria 6. This will assure that separation is adequate and a fire cannot effect more than one civieion of safe shutdown cable. l63?9 ll4

407-2

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combus-tibles which may be introduced into or moved through the area.

Response

Per the original Fire Protection Program Evaluation, the fixed fire loading would provide an exposure of 33 minutes. The Case 1 tran-sient would add an additional 2 minutes of fire loading.

4. Identify the worst damage that could result from such fire.

Response

one division of safe shutdown equipment and cable could be damaged.

5. Demonstrate that such damage will r.ot have an adverse affect on safe shutdown or cause excessive radioactive release to the envi ronment.

Response

A fire in this room will not have an adverse effect on safe shut-down since only one division of safe shutdown equipment / cable could be affected. The other division is routed in a separate room and will be available to perform the intended function. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.12.6 of the SER. The licensee will:

1. Analyze the consequences of losing "A" cables in conduits above "B" switchgear concurrent with the loss of "B" division.

Response

The ZA cable, one of the two redundant safe shutdown cables, will be wrapped with approved fire rated material. This will prevent the loss of both divisions, as described above in response to SER Ques-tion (5.).

2. Demonstrate by hose reach tests that every point in switchgear rooms can be reached effectively by at least one manual hose stream.

Response

Refer to the response to SER Item 3.1.21. 1639 115

408-1 ROOM NO. 408 - FIGURE 8 ROOM DESCRIPTION Piping Area - Unit 2 This room contains two divisions of safety related equipment, three divisions of safety related cable, three divisions of safe shutdown cable, and the following single division of safe shutdown equipment and its associated cabling consisting of atmospheric dump valves CV-3938 and CV-3939 and their respective controllers. PROPOSED MODIFICATIONS

1. Wet pipe sprinklers will be added at the ceiling per Category A except in the area adjacent to the containment where the sprinklers will be mounted under the trays between "P" line and "M" line per Criteria 3.

2. Add smoke detectors above trays between column lines "P" and "M" per Criteria 3.

3. ZC conduit will be wrapped between column lines "P" and "M" per criteria 6.

RESPONSE TO SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) or appropriate fire resistance.

Response

This area has 3 hour rated walls, floor and ceiling, except for the communication to area 419 and corridor 410 which are open, and a 1-1/2 hour rated fire door to room 409. A sprinkler system will be provided in lieu of fire rated doors per Criteria 2.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

Except for between column lines "P" and "M", in lieu of additional physical separation, sprinklers at the ceiling provide the required separation per Criteria 1 and Category A. Between 'olumn lines "P" and "M", in lieu of additional physical separation, sprinklers will be installed under cable trays to suppress transient Case 1 fires and two divisions of redundant safe shutdown cabling will be wrapped, per Category A, Criteria 3 and 6. f fh '

408-2

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combus-tibles which may be introduced into or moved through the area.

Response

The fixed fire load is 29 minutes per the original Fire Protection Program Evaluation. The Case 1 transient would add an additional 7 minutes of fire loading.

4. Identify the worst damage that could result from such fire.

Response

One division of safe shutdown equipment and cable could be damaged.

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

The sprinklers will prevent the loss of either division from a tran-sient fire as described in Category A, Criteria 1 and 2. Sprinklers above the cable trays or wrapping of redundant cables will prevent the loss of either division unless the fire originates within one division in which case the sprinkler system or wrapping will protect the redundant division. If the atmospheric dump valves are damaged, heat removal from the steam generator can be accomplished by eight safety valves located in another area. Therefore, the ability to achieve safe shutdown is assured. EVALUATION OF SER SECTION 5 MODIFICATIONS No modifications were required. 1639 117

409-1 ROOM NOS. 409 & 429 - FIGURES 4 AND 8 ROOM DESCRIPTION Electrical Penetration Rooms Unit 1 - 429 Unit 2 - 409 This room contains two divisions of safety celated equipment and cable, and two divisions of ssfe shutdown cable. It does not contain safe shutdown equipment. PROPOSED MODIFICATIONS

1. Sprinklers will be installed under the cable trays in accordance with category A and criteria 3.

2. Smoke detection is installed above the cable trays in accordance with criteria 3.

3. One of the two divisions of safe shutdown cable will be wrapped with approved fire rated material per criteria 6.

SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

This room is enclosed by walls and penetrations having a 3 hour rating. Doors have a 1-1/2 hour rating. The proposed sprinkler system will also serve to prevent a fire from spreading to other areas. Thus adequacy of separation is assured.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

One of the two redundant divisions of safe shutdown cable will be wrapped with approved rated material. This will insure that . sepa, ration is adequate. .

                       ,                                  1639 118

409-2

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combus-tibles which may be introduced into or mcved through the area.

Response

Per.the Fire Protection Program Evaluation, the fixed fire loading is approximately 13 minutes. The Case 1 transient adds 5 more

                                                                              "^

minutes.

4. Identify the worst damage that could result from such fire.

Response

The addition of a wet pipe sprinkler system will prevent exposure of the safe shutdown cable to a transient fire from the floor area. In the event of a self induced fire in a cable tray, the wrapping of one of the two redundant safe shutdown cable divisions will ensure that this type of fire will not threaten safe shutdown. Further, the addition of smoke detectors above the cables will provide prompt detiction of any developing fire, and initiate the rapid response of the fire brigade.

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

A transient fire ignited and spreading over the floor area vill be suppressed by the sprinkler systcm such that cables will not be damaged by a fire originating on the floor. In the event of a fire within a cable tray, the three hour rated fire wrapping, combined with smoke detection, will insure that the fire will not spread to adjacent cable trays. Thus, the safe shutdown capability will not be effected. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Sec.: ion 5.17.6 of the SER. The licensee will:

1. Perform hose reach tests and provide additional interior hose stations as necessary to assure the effective manual hose coverage for all points in these rooms.

Response , Refe'r to the response to SER iten no. 3.1.21. -[

          =

1639 119

409-3

2. Separate redundant cables in each room by complete enclosure in rated fire barriers, reroute redundant cables out of each room, or demonstrate the adequacy of cable separation in preserving safe shutdown.

Response

As stated, the wet pipe sprinklers will protect the cables from _, an exposure fire from the floor and thus insure that safe shut- - down will not be threatened by this type of fire. In the event of a self-induced fire in a cable tray, the wrapping of one of the two redundant cable divisions will insure that this type of fire will not threaten the safe shutdown capability. Further, the addition of the smoke detectors above the cables will provide prompt detection of any developing fire, and initiate the rapid response of the fire brigade. 1639 120 e 4 D e e wwsee m m +, me- ,p

410-1 ROOM NO. 410 - FIGURES 4 AND 8 ROOM DESCRIPTION Passage There is no safety related equipment / cable and no safe shutdown equip-ment / cable in this area. PROPOSED MODIFICATIONS None. SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

Rooms 408 and 428 are to be sprinklered in accordance with Cri-teria 2 which will preclude fire spread from room 410 to these areas.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

There is no redundant cable / equipment in this area.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combus-tibles which may be introduced into or moved through the area.

Response

There is no fixed fire loading in this passage. A transient Case 1 fire would add an 8 minute fire exposure.

4. Identify the worst damage that could result from such fire.

Response

There would be no damage to safe shutdown or cabling. 1639 121

410-2

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

The postulated fire would be confined to room 410 which contains no safe shutdown equipment or cable. Therefore, the ability, to achieve safe shutdown is assured. EVALUATION OF SER SECTION 5 MODIFICATIONS No modifications were required in this area. 1639 122

412-1 ROOM NO. 412 - FIGURE 8 ROOM DESCRIPTION Cask Washing Pit There is no safety related equipment / cable and no safe shutdown equip-ment / cable in this area. PROPOSED MODIFICATIONS None. NOTE: This is the cask Washing Pit. It is free of combustibles and does not present a fire exposure to the balance of the plant. Further evaluation is not warranted. 1639 123

414-1 ROOM NOS. 414 & 423 - FIGURES 4 AND 8 ROOM DESCRIPTION Electrical Penetration Rooms Unit 1 - 423 .= Unit 2 - 414 This room contains two divisions of safety related equipment and cable and two divisions of safe shutdown cable. It does not contain safe shutdown equipment. PROPOSED MODIFICATIONS

1. Sprinklers will be installed under the cable trays in accordance with Category A and Crit-ria 3.

2. Smoke detection will be installed above the cable trays in accordance with Criteria 3.

3. One of the two divisions of safe shutdown cable will be wrapped with a 3-hour fire rated material.

SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

This room is enclosed by walls and penetrations having a 3-hour rating. Doors to area 419 have 1-1/2 hour rating. The door to area 416 (Unit 2 only) has a 3-hour rating. The proposed sprinkler system will also serve to prevent a fire from spreading to other areas. Thus, adequacy of separation is assured.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

One of the two redundant divisions of safe shutdown cable will be wrapped with a 3-hour rated material. This will ensure that separation is adequate.

3. Iddatify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combustibles which may be introduced into or moved through the area.

Response 69 24 Per the Fire Protection Program Evaluation, the fixed fire loading is approximately 45 minutes. The Case 1 transient adds 9 more minutes.

414-2

4. Identify the worst damage that could result from such fire.

Response

         ~

The addition of a wet pipe sprinkler system will prevent exposure of the safe shutdown cable to a transient fire from the floor area. - In the event of a self-induced fire in a cable tray, the wrapping of ., : one of the two redundant safe shutdown cable divisions will ensure that this type of fire will not threaten safe shutdown. Further, the addition of smoke detectors above the cables will provide prompt direction of any developing fire and initiate the rapid response of the fire brigade.

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

A transient fire ignited and spreading over the floor area will be suppressed by the sprinkler system such that cables will not be damaged by a fire originating on the floor. In the event of a fire within a cable tray, the three hour rated fire wrapping, combined with smoke detection, will insure that the fire will not spread to adjacent cable trays. Thus, the safe shutdown capability will not be affected. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.17.6 of the SER. The licensee will:

1. Perform hose reach tests and provide additional interior hose stations as necessary to assure the effective manual hose coverage for all points in these rooms.

Response

Refer to the response to SER Item No. 3.1.21.

2. Separate redundant cables in each room by complete enclosure in rated fire barriers, reroute redundant cables out of each room, or demonstrate the adequacy of cable separation in preserving safe shutdown.

Response

As stated, the wet pipe sprinklers will protect the cables from an exposure fire from the floor and thus insure that safe shutdown will nr,t be threatened by this tupe of fire. In the event of a self-induced fire in a cable tray, the wrapping of one of the two redundant cable divisions; will insure that this type of fire will not threaten the safe shutdown capability. Further, the addition of the smoke detectors above the cablek ' wi1~1 provide prompt detection of any developing fire, and initiate the rapid response of the fire brigade. Thus, separation is adequate to pre-serve safe shutdown. ~ 1639 125

416-1 ROOM NOS. 416. 421 & 422 - FIGURES 4 AND 8 ROOM DESCRIPTION Diesel Ge.nerator Rooms .

                                                                                   ~

Unit 1 & 2 - 421 - DG12 Unit 1 - 422 - DG11 Unit 2 - 416 - DG21 Each room contains one redundant division of safety-related equipment and cable and one redundant division of the following safe shutdown equipment and its associated cable:

1. Diesel Generator

2. Diesel Fuel Oil TrInsfer Pump

3. Diesel Vent Fan Each room contains a different redundant division.

PROPOSED MODIFICATIONS None. (Note: Rooms 421 and 422 have a curb installed to prevent fuel oil from co=municating from one room to the other in the event of a spillage; each room contains its own pre-action sprinkler system.) SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriat,e fire resistance.

Response

All walls, doors and penetrations are 3-hour fire rated except for the doors leading to the exterior of the building which are non-rated. The existing pre-action sprinkler system will provide additional separation assurance, as stated in criteria (2). The sprinkler system will prevent a fire outside of the fire rated door from spreading into any of the diesel generator rooms. Going the opposite way, the pre-action sprinkler system will prevent a fire inside of the room from spreading to the exterior. The nearest fixed fire load in the plant yard is startup transformer P-13000-1(2) which is located 100' away. Finally, each doorway has a labyrinth which ; will also serve to mitigate a fire across the doorway. p

                          .                                      1639 126

416-2

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

Redundant safe shutdown cables are not located in the room. je

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combustibles which may be introduced into or moved through the area.

Response

Per the Fire Protection Program Evaluation, the fixed loading in each room is approximately 107 minutes. The Case 1 transient inside a room would add another 4 minutes.

4. Identify the worst, damage that could result from such fire.

Responsc The existing pre-action sprinkler system will effectively suppress the postulated fire before the safe shutdown equipment or cable in the room could become involved.

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

A fire in the room will be suppressed by the existing pre-action sprinkler system before the single redundant safe shutdown division could become involved. Thus, there will be no adverse affect on safe shutdown. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.18.6 of the SER. The licensee will:

1. The licensee will install a curb at the doorway "oetween two adjacent diesel generator rooms to prevent a possible communication of spilled oil via the doorway.

Response

A curb has been installed between rooms nos. 421 and 422 to prevent a possible communication of spilled oil.  ; e

       ~

1639 127 e

416-3

2. In addition, the licensee vill implement an administrative procedure to prelay a 2%" hose connected to Hydrant No. 5 to provide the manual hose coverage in case of a failure in, or isolation, of the section of fire water piping serving this area.

Response '. Refer to the response to SER Item No. 3.1.10.

3. The licensee will also replace non-rated doors facing the yard area by 1 -hour rated UL or FM listed fire doors.

Response

Fire rated doors are not necessary for this doorway, as alternate means of separation has been provided. Refer to the response to SER Question No. 1 above. r' 1639 128 me s'

417-1 ROOM NOS. 417 & 418 - FIGUPI 8 ROOM DESCRIPTION Truck Ioa' ding Area / Solid Waste Handling Room This rcob contains two divisions of safety related equipment / cable and two . " . divisions of safe shutdown cable. (No safe shutdown equipment) These rooms ~ are now protected by sprinklers. PROPOSED MODIFICATIONS None. SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

Adjacent fire areas are separated by 3-hour rated walls, doors and pene-tration seals. Duct fire dampers and sprinklers are also installed. The exterior doors are not rated, but reference to the analysis for Diesel Generator Rooms 416, 421 & 422 will justify this design adequacy. The door to Room 441 is also not rated, but sprinklers in Room 417 provide adequate separation per criteria 2.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

Automatic sprinklers at the ceiling are provided in lieu of additional separation as per Criteria 1.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combustibles which may be introduced into or moved through the area.

Response

Per the Fire Protection Program Evaluation, the fixed loading is approx-imately 2 minutes. In this area, the transient loading was originally included in the above given fixed loading due to the nature of the rooms' function of processing waste material. e

                ~

1639 129

417-2

4. Identify the worst damage that could result from such fire.

Response

Based on the existence of a wet pipe sprinkler system in these rooms, the -postulated fire would be effectively suppressed before either division could become involved. Also, installed barriers would prevent a fire s I which began in one division from involving the other division.

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

Based on 2) and 4) above, there will be no adverse effect on safe shutdown from a fire in this area. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to SER Section 5.20.6. The licensee will:

1. Identify other safety-related cables in the area and analyze the possible consequences of fire damage to these cables.

Response

Two redundant divisions of safety-related heat tracing cable for the solid waste processing lines run in this room. Installed sprinklers will prevent loss of either division.

2. Provide the results of an analysis of the radiological consequences of a fire involving solid waste, in particular the spent resin stored in this area.

Response

Refer to response to SER Section 3.2.8. 1639 130 . L

         ~r                                                                        p D

MM

bl9-1 ROOM NOS. 419/425/h26 - FIGURES 4 AND d ROOM DESCRIPTION Cask and Equipment Loading Area This area contains three divisions of safety related cable and three divisions of safe shutdown cable (no safety related or safe shutdown equipment in this area). PROPOSED MODIFICATIGIS

1. An automatic wet pipe sprinkler system will be added at the ceiling west of column line "R" per Category A. A wet pipe automatic sprinkler system will be installed below the cable trays between column lines "R" and "P" adjacent to the containment as per Criteria 3

2. Smoke detectors will be added at the ceiling between column lines "R" and "P" adjacent to the containment per Criteria 3 3 ZA and ZC raceways will be wrapped per Criteria 6.

SEP, QUESTIONS

1. De=onstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

These three rooms run together as one open area. The addition of the wet pipe sprinkler system will provide separation from adjacent safe shutdown areas as per Criteria 2. A sprinkler head will be provided over the floor openings for the equipment hatch to preclude fire spread from the lower elevation as per Criteria 2.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

Wrapping of redundant raceways and provision of sprinklers provides separation per Criteria 1 and Criteria 6. 1639 131

419-2 3 Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combus-tibles which may be introduced into or moved through the area. Resoonse Per the original Fire Protection Program Evaluation, the fixed fire loading is approximately 2 minutes. The Case 3 transient adds an undefinable fire loading. Therefore, two of the three redundant raceways throughout this area have been wrapped in addition to the provision of automatic sprinklers. (See PROPOSED MODIFICATI0IG 1. and 3.). 4 Identify the worst damage that could result from such fire.

Response

Due to the proposed addition of sprinklers the postulated fire would be effectively suppressed before either division could become involved. Wrapping of redundant divisions will also prevent involvement of both divisions. 5 Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment. Resnonse Based on (2.) above, there will be no adverse effect on safe shutdown from a fire in this area. EVALUATION OF SER SECTION 5 MODIFICATI0:G Refer to Section 5.20.6 of the SER. The licensee will:

1. Identify other safety related cables in the area and analyze the possible consequences of fire damage to these cables.

Restonse There are three redundant divisions of safety related cable in this area. The wrapping of two of the three redundant divisions in addition to providing automatic wet pipe sprinklers will preclude the possibility of an exposure fire damaging any division, and internally initiated fires will damage only the division in which it originates.

2. Provide the results of an analysis of the radiological consequences of a fire involving solid waste, in particular the spent resin, stored in this area.

Resoonse 1639 132 Refer to response to Section 3 2.8 of the SER.

420-1 ROOM NO. 420 - FIGURE 4 ROOM DESCRIPT70N Coolant Waste Evaporator Room

            -                                                               =

This room contains two divisions of safety related equipment / cable " and three divisions of safe shutdown cable (no safe shutdown equip-ment). PROPOSED MODIFICATIONS An automatic wet pipe sprin~kler system will be added per Category A. RESPONSE TO SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

Separation is provided by 3 hour walls, a labyrinth type entrance arrangement and by the sprinkler systems in the adjacent rooms 419, 421, & 423 per Criteria 2.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

The minimum separation between redundant safe shutdown cable trays is approximately 3' with installed marinite fire barriers. There is no safe shutdown equipment in the room. Sprinklers will provide additional separation per Criteria 1.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combustibles which may be introduced into or moved through the area.

Response

The Fire Protection Program Evaluation lists the fixed fire loading at approximately 6 minutes. The Case 1 transient adds approximately 6 more minutes loading.

        -?                                                                    .

1639 133 m

420-2

4. Identify the worst damage that could result from such fire.

Response

Addition of sprinklers will insure that redundant cables will be unaffected by the postulated fire, per Criteria 1.

5. Demonstrate that such damage will not have an adverse effect on .:

safe shutdown or cause excessive radioactive release to the environment.

Response

The proposed wet pipe sprinkler system will protect safe shutdown cable from exposure to transient fires and will prevent fires from originating within a specific division from affecting the redundant division. Thus, safe shutdown capability will not be affected. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.20.6 of the SER. The licensee will:

1. Identify other safety related cables in the area and analyze the possible consequences of fire damage to these cables.

Response

There are two divisions of safety related heat tracing cables in this area. A fire in this area will not have an effect on safe shutdown.

2. Provide the results of an analysis of the radiological consequences of a fire involving solid waste, in particular the spent resin, stored in this area.

Response

Refer to response to SER section 3.2.8. 1639 134 a

         --                                                                    ,t
                        ~?

M

• 424-1 ROOM NOS. 424 & 413 - FIGURES 4 AND 8 ROOM DESCRIPTION Sample Ro, oms

                                                                                   =

Unit 1 - 424 - Unit 2 - 413 There is no safety related equipment / cable and no safe shutdown equipment / cable in this area. PROPOSED MODIFICATIONS None. SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

There is no safe shutdown equipment / cable in this area, therefore separation is adequate. Sprinklers are added to room 419 which will prevent fire spread as per Criteria 2.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

There is no redundant cable / equipment in this area.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combustibles which may be introduced into or moved through the area.

Response

Based on (2.) above, this is N/A.

4. Identify the worst damage that could result from such fire.

Res onse  ; Ba' add on (2.) above, this is N/A. 5 1639 135

                                                         =

• eew- .- .== . ..

pp

424-2

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

Based on (2.) above, there will be no adverse effects on safe shutdown from a fire in this area. ,. EVAMATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.20.6 of the SER. The licensee will:

1. Identify other safety related cables in the area and analyze the possible consequences of fire damage to these cables.

Resnonse There are no safetf related cables in this area.

2. Provide the results of an analysis of the radiological consequences of a fire involving solid waste, in particular the spent resin, stored in this area.

Response

Refer to response to SER section 3.2.8. 1639 136 L m e'

        ;.                                                                   ."o

428-1 ROOM NO. 428 - FIGURE 4 ROOM DESCRIPTION Piping Area - Unit 1 This room contains two divisions of safety related equipment / cable, three divisions of safe shutdown cable, and the following single division of safe shutdown equipment and its associated cabling con-sisting of Atmospheric Dump Valves CV-3938 and CV-3939 and their respective controllers. PROPOSED MODIFICATIONS

1. Wet pipe sprinklers will be added at the ceiling per Category A except in the area adjacent to the containment where the sprinklers will be mounted under the trays between "P" line and "M" line per Criteria 3.

2. Add smoke detectors above trays between column lines "P" and "M",

per Criteria 3.

3. ZC and ZA conduit will be wrapped between column lines "P" and "M" per Criteria 6.

SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

This area has 3 hour rated walls, floor and ceilings, except for the communication to area 426 and corridor 410 which are open, and a 1-1/2 hour rated fire door to room 429. The installation of a sprinkler system in this area will be pro-vided in lieu of fire rated doors per Criteria 2.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Resnonse Except between column lines "P" and "M", in lieu of additional physical separation, sprinklers at the ceiling provide the required separation per Category A and Criteria 1. Between column lines "P" and "M", in lieu of additional physical separation, sprinklers will be installed under the cable trays to suppress transient Case 1 fires and two divisions of redundant safe shutdown cabling will be wrapped, per Category A, Criteria 3 and 6. 1639 137

428-2

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combus-tibles which may be introduced into or moved through the area.

Response

The fixed fire load is 29 minutes per the original Fire Protection Program Evaluation. The Case 1 transient would add an additional 7 minutes of fire loading.

4. Identify the worst damage that could result from such fire.

Response

one division of safe shutdown cable and equipment could be damaged.

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environ-ment.

Response

The added sprinklers will prevent loss of either division from a transient fire as described in Category A, Criteria 1 and 3. Sprinklers provided above the cables or wrapping redundant cables will prevent loss of either division unless the fire originates within one division in which case the sprinklers or the wrapping will protect the redundant division. If the atmospheric dump valves are damaged, heat removal from the steam generator can be accomplished by the 8 safety valves located in another area. 1639 138

431-1 ROOM NO. 431 - FIGURE 4 ROOM DEFCRIPTION Computer Room - Unit 1 This room contains no safety related/ safe shutdown equipment, and two divisions of safety related/ safe shutdown cable located above the ceiling of the room. PROPOSED MODIFICATIONS

1. Add smoke detectors above drop ceiling in accordance with Category A.

2. ZC conduit will be wrapped in accordance with criteria 6.

NOTE: This room falls under Category A. Conduit and trays required for safe shutdown are located above the noncombustible drop ceiling. Smoke detectors are presently located in the sub-floor and below the drop ceiling for general room coverage. In additica, a Halon 1301 system is presently installed for cabinet internals and in sub-floor. SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

The room is enclosed by 3 hour walls. The doors into the main control room 405 are 1-1/2 hour rated fire doors and the door to Electric Switchgear Room 430 is a steel bullet-proof door. These doors are commensurate with fire loads on either sides as tabulated below: Fire Load in Minutes Room Fixed Transient Total Computer Room 431 10 14 24 Control Room 405 7 1 8 Elec. Switchgear Room 420 33 3 36 1639 139

431-2

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

One of the two safe shutdown divisions will be wrapped in lieu of additional physical separation per criteria 6. There is no safe shutdown equipment in this area.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combustibles which may be introduced into or moved through the area.

Resnonse According to the Fire Protection Program Evaluation, the fixed fire load is 10 minutes. A Case 1 transient fire would add 14 minutes to the fire load of this room.

4. Identify the worst damage that could result from such fire.

Resnonse Wrapping of one of the two redundant divisions will prevent damaec of more than one safe shutdown cable.

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

The installation of smoke detection in the room, in the sub-floor space and above the drop ceiling will give prompt notification of a fire to the fire brigede and control room operators so fire suppression can be immediately initiated. The noncombustible drop ceiling will delay communication of a transient fire in the room to the concealed space containing the shutdown cables. Krapping one of the two redundant divisions will limit damages to one division. Therefore, the ability to achieve safe shutdown is assured. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.16.6 of the SER. The licensee will:

1. Replace wooden furniture and shelves with those of metal except for work benches in the log and test instrument room (room 435).

Response

Not applicable to this area. l }

431-3

2. Provide metal partitions to separate adjoining panels from the computer terminal in the middle of the main panel.

Response

Not applicable to this room.

3. Demonstrate that the safe shutdown capability can be preserved in the event of a fire in this area.

Response

See the response to SER Question (5.) above.

4. Replace the existing bullet-proof doors with UL listed 3 hour rated, ':ullet-proof fire doors, or demonstrate the adequacy of fire resistance of the existing doors.

Response

The door from the computer room to the electrical equipment room is a steel bullet-proof door. See the response to SER Question (1.) above. 1639 141

439-1 ROOM NOS. 439/440 ROOM DESCRIPTION Refueling Water Tank Pump Room Unit 1 - 439 Unit 2 - 440 This room contains two divisions of safety related equipment and cable, and it does not contain any safe shutdown equipment or cable. PROPOSED MODIFICATIONS Smoke detection will be added in accordance with Category C. SER OUESTIONS ,.

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

The walls, ceiling, and floor are 3 hour fire rated. The single exterior door is non-rated. The nearest fixed fire load is a start-up transformer P-13000-1 (2), which is approximately 100' away. This room does not contain any safe shutdown equipment. In the event of a fire in the proximity of the exterior door, the smoke detectors within the room would initiate the rapid response of the fire brigade for extinguishment of the fire. Therefore, for the preceeding reasons, the present exterior door is adequate.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

Redundant safe shutdown cables are not located in this area. i e e

439-2

3. Identify the largest fire th'at can be expected in each fire area based on the fixed combustibles in the area snd transient combus-tibles which may be introduced into or moved through the area.

Response

These is no fixed fire loading in these rooms. All cabling is silicone rubber in conduit. The Case 1 transient would add a 2

                                                                            ,.  ~

fire loading of 15 minutes. However, a Case 1 transient being brought into this room is not a realistic assumption. The room is off limits because of radiation levels, so therefore it would be detrimental to plant personnel to go into this room and store transients.

4. Identify the worst damage that could result from such fire.

Response

This room does not contain any safe shutdown equipment or cable. So a fire involving, safe shutdown equipment or cable cannot occur in this room.

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environ.ent.

Response

Since there is no safe shutdown equipment or cable in this room, there will be no adverse effect on safe shutdown. EVALUATION OF SER SECTION 5 MODIFICATIONS There were no modifications listed for this room. 1639 143

441-1 ROOM NO. 441 ROOM DESCRIPTION Solid Was,te Tank Room There is mo safety-related equipment / cable and no safe shutdown equipment / cable in tbis area. ]. PROPOSED MODIFICATIONS None. SER QUESTTONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

There is no safe shutdown equipment / cable in this area; therefore, separation is adequate. Sprinklers in Room 417 provide separation in lieu of a fira rated door to that room.

2. Identify the minimum separation between the redundant cebles (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

There is no redundant cable / equipment in this area.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combustibles which may be introduced into or moved through the area.

Response

Based on 2) above, this is n/a.

4. Identify the worst damage that could result from such fire.

Response

Based on 2) above, chis is n/a.

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment. .

Resp'onse g

               ~

Based on 2) above, there will be no adverse effects on safe shutdown from a fire in this area. 1639 144

-- ~ .. 441-2 EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.20.6 of the SER. The licensee will:

1. Identify other safety-related cables in the area and analyze the possible consequences of fire damage to these cables.

              .                                                                    =

Response .. There is no safety-related cable in this area.

2. Provide the results of an analysis of the radiological consequences of a fire involving solid waste, in particular the spent resin stored in this area.

Response

Refer to the response to SER section 3.2.8. a

              ?                                                                      ~?
                              $s r

501-1 ROOM NOS. 501, 502, 503, 504, 505, 506, 507, 508, 509, 510, 511, 513, 514, 515, 516, 517, 518, 519, 521, 522, 523, 534, & 535 -

          . FIGURES 5 AND 9 ROOM DESCRIPTION                                                                  :

Health Physics Area These rooms contain no safety related or safe shutdown equipment or cable. PROPOSED MODIFICATIONS None. SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas

                                  ~

that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

This area does not contain any safe shutdown equipment / cable and is separated from adjacent areas by three hour rated walls with Class B doors

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

This area contains no safe shutdown cable / equipment.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area snd transient combus-tibles which may be introduced into or moved through the area.

Response

Based on (2.) above, this is N/A.

4. Identify the worst damage that could result from such fire.

Response

Based on (2.) above, this is N/A.

       'i                                                       1639 146

• s s

501-2

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

Bassd on (2.) above, a fire in this area would have no adverse effect on safe shutdown.

                                                                             .=.

EVALUATION OF SER SECTION 5 MODIFICATIONS No modifications were required. (However, some question about valves in the personnel access area was mentioned. Those valves are located in Rooms 525 and 527 which are analyzed separately.) I

         '                                                                      *y
           .I b

e

512-1 ROOM NO. 512 - FIGURE 5 ROOM DESCRIPTION Control Room HVAC Equipment Room Unit.s 1 & 2 512  : h is room contains two divisions of safety-related equipment and no safe shutdown equipment. PROPOSED MODIFICATIONS

1. Smoke detection will be added in accordance with category (C).

SER OUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate firp resistance.

Response

his room is completely enclosed by 3-hour fire walls, doors, dampers and penetration seals.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

Ihere are no redundant cables or equipment required for safe shutdown in this room.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combustibles which may be introduced into or moved through the area.

Response

The fixed fire loading is approximately 7 minutes. An additional 4 minutes would result from the Case 1 transient.

4. Identify the worst damage that could result from such fire.

Response

This room does not contain any safe shutdown equipment or cable. So,  ; a fire exposing safe shutdown equipment or cable could not occur. - ite

• D

                         ,                                 1639 148

                                                                                            .. m 512-2

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

There will not be an adverse effect on safe shutdown in the event of a fire in this room as there is no safe shutdown equipment or cable located - in ?his room. , EVAUJATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.24.6 of the SER. The licensee will:

1. Perform hose reach tests and provide additional hose stations as necessary to assure effective manual hose coverage for all points in these rooms.

Response

Refer to the response to SER Item No. 3.1.21.

2. Analyze the possib'$e safety impacts of fire damage to ventilation equipment which will include, but not be limited to, control room habitability, possible effects on instruments in the control room and in other areas served by the damaged equipment, and the potential for a release of radio-active materials. Additional modification may be provided following the analysis.

Response

There is two redundant divisions of control room HVAC equipment located in this room. Exposure of any portion of the system to a fire will not effect the operation of the control room HVAC equipment. Any operational problem in a portion of the system caused by a fire in this room will not prevent the basic function of the HVAC equipment as there will always be the other redundant system to perform the function. Exposure of no more than a portion of the HVAC equipment will be assured as the room is equipped with smoke detection. The detectors will rapidly detect any incipient fire. Thus, the fire will not have a chance to involve any additional components. In conclusion, environmental conditions in the control room will remain normal.

                                                                   !639 J49 a

b a e

520-1 ROOM NO. 520 - FIGURE 5 ROOM DESCRIPTION SpentFucpPoolAreaVentilationEquipmentRoom

                                                                                   ' ~

This room contains no safety related or safe shutdown equipment or cable. PROPOSED MODIFICATIONS None. SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

There is no safe shutdown equipment or cable in this room. Separation from adjacent areas is by 3 hour rated walls. Separation from the control room HVAC equipment room is by a Class A door. The other door is non-rated, but is not connected to any rooms containing safe shutdown equipment. All ducts to other rooms are provided with fire dampers.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

There is no safe shutdown equipment / cable in this room.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combustibles which may be introduced into or moved through the area.

Response

Based on (2.) above, this is N/A.

4. Identify the worst damage that could result from such fire.

Response  ; Based on (2.) above, this is N/A. ,

              ~~

1639 150 e * *

1. $em

520-2

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

Based on (2.) above, a fire in this room will not have an adverse effect on safe shutdown. }. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.24.6 of the SER. The licensee will:

1. Perform hose reach tests, and provide additional hose stations as necessary, to assure effective manual hose coverage for all points in these rooms.

Response

s Refer to response to SER section 3.1.21.

2. Analyze the possible safety impacts of fire damage to ventilation equipment which will include, but not be limited to, control room habitability, possible effects on instruments in the control room and in other areas served by the damaged equipment, and the potential for a release of radioactive materials. Additional modification may be provided following the analysis.

Response

Damage to equipment in this area will not adversely effect safe shut-down or the control room as the room has no SSD equipment / cable and there is no connection to the C/R HVAC.

3. Remove from the area all combustibles that are not needed for routine operation or maintenance of the plant.

Response

Refer to response to SER Section 3.1.16. 1639 151 i D e-

524-1 ROOM NOS. 524 AND 526 - FIGURES 5 AND 9 ROOM DESCRIPTION Main Plant Exhaust Equipment Room Unit 1 - 524 Unit 2 - 526 These rooms contain two divisions of safety related equipment / cable and no safe shutdown cable / equipment. PROPOSED MODIFICATIONS

1. Smoke detectors will be added per Category C.

2. The doors between 524 and 525 (526 and 527) will be upgraded to Class A fire doors.

SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

This room is separated from adjacent areas by a 3 hour rated wall. The door to room 525 (527) will have a Class A rating. The damper to the Control Room HVAC Room is a fire damper. This is adequate separation.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

There is no safe shutdown _ equipment / cable in this room.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combus-tibles which may be introduced into or moved through the area.

Response

This is not applicable based on (2.) above. I f> 2

524-2

4. Identify the worst damage that could result from such fire.

Response

This is not applicable based on (2.) above.

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

Based cn (2. ) and (4. ) above, a fire in this area will not adversely effect safe shutdown. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.24.6 of the SER. The licensee will:

1. Perform hose reach tests, and provide additional hose stations as necessary, to assure effective manual hose coverage for all points in these rooms.

Response

Refer to response to SER Section 3.1.21. Additionally, the extreme north end of 524 (south end of 526) cannot be reached; however, the lack of fixed combustibles and safe shutdown cable / equipment make this acceptable.

2. Analyze the possible safety impacts of fire damage to ventilation equipment which will include, but not be limited to, control room habitability, possible effects on instruments in the control room and in other areas served by the damaged equipment, and the poten-tial for a release of radioactive materials. Additional modifica-tion may be provided following the analysis.

Response

There is no connec'_on between the HVAC equipment in this area and the Control Room ifVAC system.

3. Remove from the area all combustibles that are not needed for routine operation or maintenance of the plant.

Response

Refer to response to SER Section 3.1.16. 1639 153

525-1 ROOM NOS. 525 AND 527 - FIGURES 5 AND 9 ROOM DESCRIPTION Personnel Access Area Unit 1 - 525 Unit 2 - 527 These rooms contain no safety related equipment / cable and one division of safe shutdown equipment / cable consisting of component cooling water head tank make-up valves. PROPOSED MODIFICATIONS

1. Smoke detectors will be provided per Category B.

2. Door to room 524 (526) will be upgraded to Class A.

SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

All walls and penetration seals are 3 hour rated. The stairwell doors are fire rated for 1-1/2 hours. Doors to room 524 (526) are not rated. One end of the rooms is open to Corridor 523 for ease of access. The adjacent areas are not safe shutdown areas, however.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire ares.

Response

There is only one division of safe shutdown cable in this room. The only safe shutdown equipment is the component cooling water head tank.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combus-tibles which may be introduced into or moved through the area.

Response

The Fire Protection Program Evaluation lists negligible combus-tibles and a consequent fixed fire loading which is essentially zero. The Case 1 transient would provide approximately 7 minutes fire exposure. 1639 154

525-1 ROOM NOS. 525 & 527 ROOM DESCRIPTION Personnel, Access Area Unit 1 - 525 .: Unit 2 - 527 This room contains no safety related equipment / cable and one division of safe shutdown equipment / cable. PROPOSED MODIFICATIONS Smoke detectors will be provided per Category B. RESPONSE TO SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

All walls and penetration seals are 3 hour rated. The stairwell doors are fire rated for 1-1/2 hours. Doors to room 524 (526) are not rated. One end of the rooms is open to Corridor 523 (which is separated by 1-1/2 hour rated doors from adjacent areas) for ease of access. The adjacent areas are not safe shutdown areas, however.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

There is only one division of safe shutdown cable in this room. The only safe shutdown equipment is the Component Cooling Water Head Tank.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combus-tibles which may be introduced into or moved through the area.

Response ,

                                                                               ~

1he.tFire Protection Program Evaluation lists negligible combustibles  ! aaCa consequent fixed fire loading which is essentially zero. The .C Case 1 transient would provide approximately 7 minutes fire exposure.

525-2

4. Identify the worst damage that could result from such fire.

Response

As the Co=ponent Cooling Head Tank is the only safe shutdown equipment and there is only one division of safe shutdown cable in the area, no damage could result which could jeopardize safe chutdown. (All valves are manually operated except for the '. Component Cooling Head Tank make-up valves which fail safe in the open position upon loss of electrical power or loss of the air supply. If the valve control diaphram, the only valve component which is subject to fire damage, were to be affected by a fire, the valve would still fail safe.)

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

Since the only comp'onent in these areas which could be affected by fires would fail in the safe position, safe shutdown capability would not be jeopardized. EVALUATION OF SER SECTION 5 MODIFICATIONS No modifications to this room were required. (Refer to response to SER Question 4 of Room 525 to verify that fire damage to valves in this room would not adversely effect safe shutdown.) 1639 156 4

         '. ?-
                                                                                    ,i
                         *e e.

528-1 ROOM NOS. 528, 530, 533, 536 & 537 - FIGURES 5 AND 9 ROOM DESCRIPTION 528 - Vestibule 530 - Cask Loading Area 533 - Fuel Storage Room ~. : 536 - Miscellaneous Waste Evaporator Control Panel Room 537 - Miscellaneous Waste Evaporator Room These rooms are all located in the same area, have direct passage to each other and are separated by non-rated doors. Room No. 533 is within Room No. 530. Therefore, these rooms will be treated as one. This room does not contain any safety-related or safe shutdown equipment or cable. Safety related cables run through the area, but are embedded so they cannot receive any fire exposure. , PROPOSED MODIFICATIONS None. SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

This room is separated from other areas by minimum I hour fire rated walls, floors, ceiling and doors except for an exterior door leading to the roof of elevation 45'-0" and doors leading to the Waste Processing Area Fan Room. There is no safety-related or safe shutdown equipment or cable located on either side of these doorways. Therefore, these doors provide adequate protection for their entrance ways.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

There is no safe shutdown equipment or cable located in this room. r

       *I                                                                        I.

e

528-2

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combustibles which may be introduced into or moved through the area.

Response

The fixed fire loading would result in a fire having a duration less _ than' 5 minutes. The Case 1 transient would result in a fire having J. a duration less than .75 minutes. - 4 Identify the worst damage that could result from such fire.

Response

Ihis room does not contain any safety-related or safe shutdown equipment or cable. So, a fire threatening safe shu .down of the plant cannot occur in this room.

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause gxcessive radioactive release to the environment.

Response

There will not be an adverse effect on safe shutdown in the event of a fire in this room as there is no safe shutdown equipment or cable located in this room. EVALUATION OF SER SECTION 5 MODIFICATIONS e Refer to Section 5.25.6 of the SER. The licensee will:

1. Perform hose reach tests and provide additional modification, as necessary, to assure effective manual hose coverage for all points in this area.

Response

Refer to the response to SER Item No. 3.1.21.

2. Analyze the radiological consequences of possible fire damage to the vaste evaporator control panel.

Response

All liquid influents and effluents come from or go to the radwaste system tanks. The Miscellaneous Waste Evaporator Control Panel directs the radwaste to and from the correct tanks. Exposure of the control panel to a fire could result in transferring the liquid from the once intended tank to another tank. It would not be possible to misdirect the liquid in . such,a way to cause a spillage. s 1639 158

529-1 ROOM NOS. 529 & 532 - FIGURES 5 AND 9 ROOM DESCRIPTION Electrical Rooms , Unit 1 - 529 Unit 2 - 532 This room contains two divisions of safety related cable / equipment and one division of safe shutdown cables / equipment. PROPOSED MODIFICATIONS None. (Smoke detectors required per Categories B and C are already installed). SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

This room is separated from adjacent areas by 3 hour rated walls and penetrations, Class B doors, and fire dampers in the ductwork. As this room is not basediately adjacent to any areas containing safe shutdown equipment / cable, separation is adequate.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdcwn in each fire area.

Response

There is no redundant safe shutdown cable / equipment in this area.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combus-tibles which may be introduced into or moved through the area.

Response

From the Fire Protection Program Evaluation, the fixed fire loading . is approximately 27 minutes. A case 1 transient combustible would I addrapproximately 2 minutes.

• 1639 159

529-2

4. Identify the worst damage that could result from such fire.

Response

Existing smoke detectors will alert the fire brigade and they would be capable of extinguishing any fire before significant damage could occur.

5. Demonstrate that such damage will not have an adverse effect on  :

safe shutdown or cause excessive radioactive release to the environment.

Response

Safe shutdown capability should not be adversely effected by a fire in this area, as only one division of the redundant safe shutdown equipment / cable is located in this room. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.26.6 of the SER. The licensee will:

1. Remove from these rooms all combustible materials which are not needed for routine operation and maintenance of the plant.

Storage of combustible materials required for operation or maintenance of the plant will be limited to approximately one week's supply.

Response

Refer to Section 3.1.16 of the SER.

2. Verify the manual hose coverage.

Response

Refer to Section 3.1.21 of the SER. 160

           ~

s T' 1-D e

531-1 ROOM NO. 531 - FIGURES 5 AND 9 ROOM DESCRIP770N Waste Processing Area Fan Room

                                                                            ~

This room cc.itains no safety related equipment / cable and no safe shutdown equipment / cable. PROPOSED MODIFICATIONS None. SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

There is no safe shutdown of safety related equipment / cable in this room. There are no adjacent rooms containing safe shutdown equipment / cable. Therefore, separation is adequate.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

There is no safe shutdown cable / equipment in this room.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combus-tibles which may be introduced into or moved through the area.

Response

Based on (2.) above, this is N/A.

4. Identify the worst damage that could result from such fire.

Response

Based on (2.) above, this is N/A. . 1639 161 e me

531-2

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

Based on (2.) above, a fire in this room will have no adverse effect on safe shutdown.  : EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.26.6 of the SER. The licensee wi'.1:

1. Perform hose reach tests, and provide additional hose stations as necessary, to assure effective manual hose coverage for all points in these rooms.

Response ,

                         ~-

Refer to response to Section 3.1.21 of the SER.

2. Analyze the possible safety impacts of fire damage to ventilation equipment which will include, but not be limited to, control room habitability, possible effects on instruments in the control room and in other areas served by the damaged equipment, and the potential for a release of radioactive materials. Additional modification may be provided following the analysis. ,

Response

There is no connection with the CR HVAC system.

3. Remove from the area all combustibles that are not needed for routine operation or maintenance of the plant.

Response

Refer to response to Section 3.1.16 of the SER. 1639 162

        ,i                                                                    -[.

603-1 ROOM NOS, 603 & 605 ROOM DESCRIPTIONS Auxiliary Feed Pump Rooms Uni.t 1 - 603 =_

                                                                               ~~

Unit 2 - 605 Ihis room contains two divisions of safety-related equipment and cable, and the following two divisions of safe shutdown equipment and associated cable:

1. Auxiliary Feed Pumps

2. Emergency Control Panel PROPOSED MODIFICATIONS

1. A wet pipe sprinkl,er system will be installed in each room in accordance with category (A) *and criteria (1).

SER OUEST70NS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

Ihe room is enclosed in a concrete structure with walls, floor and ceiling having a minimum 3-hour fire rating except for the water tight doors. Presently, water tight doors are unavailable with a fire rating. However, separation of this ream from other areas will be assured by the proposed addition of a sprinkler system per Criteria 2.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

The addition of sprinklers at the ceiling will accomplish effective separation between redundant safe shutdown cables

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combustibles which may be introduced into or moved through the area.  ;

Re onse . Per the original Fire Protection Program Evaluation, the fixed fire loading gives an exposure of 2 minutes. A Case I transient would yield an exposu're of 11 minutes. , 1639 163

603-2

4. Identify the worst damage that could result from such fire.

Response

Due to the proposed modification to add a wet pipe sprinkler system, the postulated fire would be effectively suppressed before either division could become involved.

5. Demonstrate that such desage will not have an adverse effect on safe -*

shutdown or cause excessive radioactive release to the environment:

Response

The proposed wet pipe sprinkler system vill protect safe shutdown equipment from exposure to transient fires and will prevent fires originating within a specific division from affecting the redundant division. EVALUATION OF SER SECTION 5 MOLIFICATIO':S Refer to Section 5.27.6 pf the SER. The licensee will:

1. Install a fire detection system in each of these rooms.

Response

The proposed sprinkler system combined with its water flow alarms will provide the required fire detection, as stated in criteria (5).

2. Demonstrate by tests or analyses that separation between redundant ,

auxiliary feed pumps and associated piping, valves and cables is adequate to preserve the function of at least one pump against a fire in the room, or provide additional modification to preserve such function.

Response

The proposed addition of a wet pipe sprinkler system will insure that separation between redundant auxiliary feed pumps, piping valves and cables is adequate so that a fire cannot threaten the safe shutdown capability.

3. Enclose at least one division of other safety-related cables in a rated barrier unless the function of such cables can be duplicated by other cables routed outside of the rooms, or demonstrate the adequacy of cable separation in preserving safe shutdown.

Response

The proposed sprinkler system will prevent a fire from enlarging and threatening other areas so that safe shutdown will be assured. e 1639 164

Intake Structure - 1 INTAKE STRUCTURE - FIGURES 10 AND 11 Unit I and Unit 2 share a co::zmon structure. There are two divisions of safety related equipment / cable per unit and the following safe shutdown equipment and Nsociated cable: SaltIWater Pumps 11, 12, 13 (21, 22, 23)  : PROPOSED MODIFICATIONS Fire detection will be added. This is a Category A room, however, based on the large spacial separation of pumps and associated conduit / cable and on only one of three pumps being required for safe shutdown, it is concluded that adequate separation precludes the need of sprinklers. SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not beparated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

This area is separated from adjacent areas by 3 hour rated walls and penetrations. There are no safe shutdown areas adjacent to water tight doors. Therefore, separation is adequate.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

The Salt Water Pump motors are located 15 feet above the floor level in wall alcoves on a floor grating and are separated from each other by 61 feet horizontally. The conduit / cable feeding each pump is - routed at the ceiling level, approximately 22 feet above the floor, and traverses the intake structure to the opposite wall, inbetween the circulating water pumps, where it down turns and enters the floor slab. The salt water pumps themselves are located in a pit below the floor level.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combustibles which may be introduced into or moved through the area.

Response ',- Pe he original Fire Protection Program Evaluation the fire loading in l-this room is approximately 12 minutes. The Case 1 transient combus-tibles add approximately 1 minute tc that load. 1639 165

Intake Structure - 2

4. Identify the worst damage that could result from such fire.

Response

Due to the physical separation of safe shutdown equipment / cable and the " low fire load, a fire in this area would affect only one division.

5. Demonstrate that such da= age will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Respo ns e Based on (2.) and (4.) above, a fire in this area will not have an adverse effect on safe shutdown. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to section 5.21.6 of the SER. r' The licensee will:

1. Install a fire detection system in this area.

Response

Fire detectors will be installed.

2. Demonstrate, or install additional hose stations to ensure, that all points in the intake structure can be reached by at least one effective hose stream.

Response

Refer to response to SER section 3.1.21.

3. Demonstrate by the results of additional testing or analyses that separation of redundas - cables is adequate to preserve the safe shutdown capability of the plant against a fire in this area.

Response

The Salt Water Pump motors are located 15 feet above the floor level in wall alcoves on a floor grating and are separated from each other by 61 feet horizontally. The conduit / cable feeding each pump is routed at the ceiling level, approximately 22 feet above the floor, and traverses the intake structure to the , opposite wall, inbetween the circulating water pumpe, where it  ; dowp turns and enters the floor slab. The salt water pumps , th'esselves are located in a pit below the floor level. " 1639 166

TB-1 ROOM NO. TURBINE BUILDING ROOM DESCRIPTION Turbine, Building Unit,s 1 & 2 - This building does not contain safety-related or safe shutdown equipment or 2* cable except for the Auxiliary Feedwater Pump Rooms No. 603 & 605. These rooms are addressed separately and contain safety-related and safe shutdown equipment and cable completely within the rooms and not within the general turbine building area. PROPOSED MODIFICATIONS None. SER QUESTIONS

1. Demonstrate the adrqucy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

All doors and walls between the turbine building and the auxiliary building are minimum three-hour fire rated. This will insure that all safety related and/or safe shutdown areas are separated from the turbine building by fire barriers. The auxiliary feedwater pump rooms also have sufficient fire barriers.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

There is no redundant cables or equipment in this area.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combustibles which may ; introduced into or moved through the area.

Response

The lack of safe shutdown or safety-related equipment or cable supersedes the need for this identification.

4. Identify the worst damage that could result from such fire. -

Re's'p onse The lack of safe shutdown or safety-related equipment or cable supersedes the need for this identification.

                                                                    !639 i67

TB-2

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

There is no safety-related or safe shutdown equipment or cable located in this building, so a fire will not have an effect on safe shutdown. - EVALUATION OF SER SECTTON 5 MODIFICATIONS Refer to Section 5.28.6 of the SER. The licensee will:

1. The licensee will perform hose stretch tests and install additional interior hose stations as necessary to insure that all points in the turbine building can be reached by at least one effective hose stream.

Response

Refer to SER Item No. 3.1.21.

                          ?

1639 168: e

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TB-1 ROOM NO. TURBINE BUILDING ROOM DESCRIPTION Turbine Building Units 1 and 2 This building does not contain safety related or safe shutdown equipment or cable except for the Auxiliary Feedwater Pump Rooms No. 603 and 605. These rooms are addressed separately and contain safety related and safe shutdown equipment and cable completely within the rooms and not within the general turbine building area. Automatic sprinklers are presently installed in the Turbine Room at elevation 12'-0" and 27'-0" to protect against lube oil fires. PROPOSED MODIFICATIONS None. SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

Doors and walls between the turbine building and the auxiliary build-ing are minimum three-hour fire rated at elevation 27'-0" and above. At elevation 12'-0", watertight doors separate the turbine building from rooms 205 and 226. All safety related and/or safe shutdown areas are separated from the turbine building by adequate fire barriers. The auxiliary feedwater pump rooms also have adequate fire barriers per Criteria 2.(see analysis of rooms 603 and 605).

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

There is no redundant cables or equipment in this area.

3. Identify the largest fire that can be expected in each fire area based on the fixed combuctibles in the area and transient combustibles which may be introduced into or moved through the area.

Response

The lack of safe shutdown or safety related equipment or cable super-sedes the need for this identifit1; tis n. b lhh

TB-2

4. Identify the worst damage that could result from such fire.

Response

The lack of safe shutdown or safety related equipment or cable supersedes the need for this identification.

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

There is no safety related or safe shutdown equipment or cable located in this building, so a fire will not have an effect on safe shutdown. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.28.6 of the SER. The licensee will:

1. The licensee will perform hose stretch tests and install additional interior hose stations as necessary to insure that all points in the turbine building can be reached by at least one effective hose stream.

Response

Refer to SER Item 3.1.21. 1639 170

Yard - 1 YARD There is no safety related equipment / cable and the following safe shutdown equipment and associated piping: Condensate Storage Tanks ll, 12, 21 PROPOSED MODIFICATIONS None. SER QUESTIONS

1. Demonstrate the adequacy of separation between adjacent fire areas that are not separated by fire barriers (with protected openings and penetrations) of appropriate fire resistance.

Response

Not applicable.

2. Identify the minimum separation between the redundant cables (in trays or in conduits)/ equipment required for safe shutdown in each fire area.

Response

condensate storage tank 21 is approximately 20 feet from tank 11 (outside wall to outside wall). Condensate storage tank 12 is enclosed in a tornado, seismic Class 1, concrete structure located greater than 50 feet from tanks 11 and 21.

3. Identify the largest fire that can be expected in each fire area based on the fixed combustibles in the area and transient combus-tibles which may be introduced into or moved through the area.

Response

The largest fire would result from a propane-air mixture explosion in the propane tank sterage area.

4. Identify the worst damage that could result from such fire.

Response

The worst damage would be loss of Condensate Storage Tanks No. 11 and No. 21. 1639 171

Yard - 2

5. Demonstrate that such damage will not have an adverse effect on safe shutdown or cause excessive radioactive release to the environment.

Response

As Condensate Storage Tank No.1219 located 90 ft, distant from- the propane storage area and is housed in a tornado protected, ., seismic Class I, reinforced concrete structure with 2 foot thick walls and roof and reinforced concrete labyrinth type entrances, it will remain intact following the postulated explosion / fire, thereby assuring safe shutdown capability. EVALUATION OF SER SECTION 5 MODIFICATIONS Refer to Section 5.30.6 of the SER. The licensee will verify that at least one condensate storage tank would be available for safe sh stdown following the explosion of a propane-air mixture in che aren north of the turbine building.

Response

As Condensate Storage Tank No.12 is located 90 ft. distant from the propane storage area and is housed in a tornado protected, seismic Class I, reinforced concrete structure with 2 foot thick walls and roof and reinforced concrete labyrinth type entrances, it will remain intact following the postulated explosion / fire, thereby assuring safe shutdown capability. 1639 172 a e

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