ML19346A196

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Requests Exemption from Certain Requirements of App R, Section 6.2 to 10CFR50.Failure of Cooling Water Pumps B & C to Meet Separation Requirements Is Compensated for Automatic Fire Supression & Detection Sys
ML19346A196
Person / Time
Site: Summer 
Issue date: 06/01/1981
From: Nichols T
SOUTH CAROLINA ELECTRIC & GAS CO.
To: Harold Denton
Office of Nuclear Reactor Regulation
References
NUDOCS 8106050378
Download: ML19346A196 (7)


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J south CAROLINA ELECTRIC a gas COMPANY F

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Mr. Harold R. Denton, Director

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Office of Nuclear Reactor Regulation t

U. S. Nuclear Regulatory Comission Washington, D. C.

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Subject:

V. C. Summer Nuclear Station Docket No. 50/395 Fire Protection Review SER Open Item 1.6.10

Dear Mr. Denton:

The fire hazard evaluation for Virgil C. Summer Nuclear Station was completed in accordance with Appendix A to Branch Technical Position APCSB 9.5-1 to provide a fire safe plant.

In a meeting with the NRC Staff in November,1979 SCE&G agreed to provide all the requirements that were requested at that time-by the Staff. The NRC Staff indicated that if thi.s were done, the fire system would be acceptable. Measures to meet these requirements have been, or are being, implemented.

Subsequent to the events outlined above, Appendix R to 10 CFR Part 50 was issued.

In our letter to Mr. Denton on January 30, 1981 we reported that an initial review indicated general compliance with minor exceptions which were-l listed.

In our letter to Mr. Denton dated April 20, 1981, comitment was made to comply with Parts G, J and 0 of Appendix R, with deviations therefrom to be resolved in a manner acceptable to the NRC Staff. The requirements of Appendix R, l

Section G.2, are discussed below in relation to fire protection provided for j

the V. C. Summer Nuclear Station and hplication for Exemption is made for differences identified.

Requirements:

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"2.

Except as provided for paragraph G.3 of this section, where cables or equipment, including associated non-safety circuits that could prevent operation or cause maloperation due to hot shorts, open circuits, or shorts to ground, or redundant trains of systems necessary to achieve and maintain hot shutdown conditions are located within the same fire area outside of primary l

containment, one of the following means of ensuring that i

one of the redundant trains is free of fire damage shall be provided:

a.

Separation of cables and equipment and associated non-safety circuits' of redundant trains by a fire barrier having a 3-hour rating. Structural steel forming a part o

of or supporting such fire barriers shall be 81060509 protected to provide fire resistance equivalent V

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I Mr. Harold R. Denton June 1,1981-Page Two to that required of the barrier; b.

Separation of cables and equipment and associated non-safety circuits of redundant trains by a horizontal distance of more than 20 feet with no intervening combustible _or fire hazards.

In addition, fire detectors and an automatic fire suppression system shall be installed in the fire area;or c.

Enclosure of cable and equipment and associated non-safety circuits of one redundant train in a fire barrier having a 1-hour rating.

In addition, fire detectors and an automatic fire suppression system shall be installed in the fire area;"

Exemption Requested:

Application is made for exemption to the above requirements in the specific cases and to the extent described below:

1.

Component cooling water pumps B & C do not meet the above separation requirements.

2.

HVAC equipmet' water chiller pumps do not meet the above separation requirements.

3 Automatic fire suppression systems are provided for the Auxiliary Building and the Intermediate Building only in those areas identified in item 1 below.

4.

Fire detection systems are provided for the Auxiliary Building and the Intermediate Building only in those areas identified in item 4 below.

Fire zones and fire areas within the Intermediate and Auxiliary Buildings are identified in a list included as Attachment I to this letter. Also listed are the safe shutdown equipment and/or cable and the fire loading within each zone or area.

Rational For The Exemption Request:

The following fire protec'. ion is provided in the Auxiliary Building and in the Intermediate Building:

1.

Automatic Fire Suppression and Detection Systems are provided in:

1 a.

Zone 9, hallway, south end of the Auxiliary Building.

l b.

Fire Area IB-9, chilled water pump room in the Intermediate Building.

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Mr. Harold R. Denton June 1,1981 Page Three c.

Zone 5, general floor area in the Intermediate Building, including area in which are located component coooling water pumps B & C.

2.

Manual Sprinkler Systems are provided for the following:

a.

Zone 6, truck bay, and drumming station / compactor area in the Auxiliary Building.

b.

Charcoal filter plena in the Auxiliary Building for the following HVAC Systems:

1.

Reactor Building purge exhaust 2.

Reactor Building charcoal clean-up 3.

Auxiliary Building charcoal exhaust 4.

Fuel Handling Building charcoal exhaust 3.

The lh hour fire rated barriers were provided for one division

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where redundant safe shutdown circuits or equipment are separated by less than 20 feet and no 3-hour barrier, with very low fire loading or without intervening combustibles, except in the cases noted in items 5 and 6 below.

4.

Ionization detectors were added for equipment areas where redundant, safe shutdown equipment was not separated by 3-hour fire rated barriers.

Ionization detectors are provided in the following areas of the Auxiliary Building:

a.

RHR pump area elevation 374'.

b.

Charging / safety injection pump area elevation 388'.

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c.

Cooling units area for charging pump rooms elevation 400'.

d.

Corridor Area and Switchgear room elevation 463'.

j Ionization detectors are provided in the following areas of-the Intermediate Building:

i a.

Elevation 412'.

1.

Room 12-02, General Floor Area 2.

Room 12-10, Turbine Driven Emergency Feedwater Pump Room.

3.

Room 12-12, Chiller A Room.

Mr. Harold R. Denten June 1,1981 Page Four 4.

Room 12-13, Chiller Pump Room 5.

Room 12-14, Chiller C Room 6.

Room 12-15, Chiller B Room b.

Elevation 423'6", Room 236-01 Emergency Feedwater Pump Cooling Units.

c.

Elevation 436' l.

Room 36-01, Switchgear Room 2.

Room 36-03 and Room 36-03A Control Room Evacuation Panel Area, d.

Elevation 463' Switchgear Room.

5.

Radiant shield walls of one-hour construction were provided between component coooling water pumps B & C and HVAC equipment water chiller pumps.

6.

A horizontal "M" board fire barrier was provided over service water booster pump "A" in addition to automatic sprinklers and ionization detectors to separate redundant "B" circuits.

In consideration of the separation and protection provided as described above, and the low fire loading in the affected areas, we have concluded that the l

plant is presently very well protected from.a fire protection standpoint, and could be safely shut down with an ii situ or exposure fire in any area of the plant. Additionally, the protection provided is in accordance with measures stated to be acceptable by the NRC S'.aff in the meeting between SCE&G and the Staff in November,1979.

We request the Staff review the above exemption requests and let us know your conclusion as soon as possible.

If you have any questions, please let us know.

Very truly yours, T. C. Nichols, Jr.

GW:TCN:pj Attachment cc:

V. C. Summer A. R. Koon C. H. Fischer M. N. Browne H. N. Cyrus B. A. Bursey T. C. Nichols, Jr.

Dr. J. Ruoff D. A. Nauman J. L. Skolds W. A. Williams, Jr.

J. B. Knotts, Jr.

R. B. Clary N PCF 0..S. Bradham File

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ATDCIMITT I AUXILIARY BUILDING Safe Shutdown Safe Shutdown Fire Zone / Area Equiptent Cable Fire Ioad Zcne 1-StWmmmt MIR Ptmps A & B Yes 7,200 B W/ft

-J 374'-0" RHR Cooling Units A & B Zone 2-Sub-Basenent Charging Ptmps A, B & C Yes 11,900 B W/ft 388'0" 2

-Yes 12,700 B W/ft Zone 3-Becirculation Valve Rocm 397'-0" 2

Zone 4-Charging Cooling Units A, B & C, Yes 2,100 B'IU/ft Pump Boom Cooling Instrunentation Units 2

Zone S-Bassnent RHR Heat Exchanger A & B Yes 29,200 BW/ft 412'-0" MI, Instrunentation 2

Zcne 6-Mezzanine Boric Acid Ptmps A & B Yes 31,500 BW/ft J

436'-0" Instrunentation Zone 7-Drumting None None 15,000 BW/ft Station 436'-0" Zone 8-Hot Machine None None Shop 436'-0" 2

Zone 9-Operating Instrunentation' Yes 40,240 BW/ft Floor Boric Acid Tanks A & B 463'0" 480 v. SwitchgearjMotor control Center i

2 Zone 10-Ventillation None hone 24,400 BW/ft Equipnent IcVel 485'-0" l

ATDCDENT I INIERMED"NX BUIIDING Safe Shutdown Safe Shutdown

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Fire Zone / Area Equipment Cable Fire Ioad IB-1 through IB-6 Pedundant Safe Shutdown Equipnent is separated by 3-hour fire barriers.

2 Zone 1 HVAC Water Chillers A, B, & C and Yes 6,600 B'IU/ft IB-7 through IB-9 HVAC Water Oliller Punps in each Chiller Elev. 412'0" Room and 2

' 163 B'IU/ft in Chiller Putp Roms (4.2 gallons of oil in each purp_ motor) 2 Zone 2 Turbine Driven Dnergency Feedwater Yes 13,100 B'IU/ft Turbine Driven Punp and 'Ibrbine Emergency Feed-water Putp Rocm 2

Zom 3 None Yes 5,200 B'IU/ft East Penetration Access Area 2

Zom 4 Nom Yes 69,200 B'IU/ft West Pemtration Access Area 2

Zone 5 Cmponent Cooling Water Heat Yes 43,000 B'IU/ft General Floor Exchangers A & B Area 412'0" Compomnt Cooling Water Punps A, B & C Service Water Booster Putps A & B l

Ittor Driven Dnergency Feedwater Punps 7 & B 2

Zom 6 Air Hedling Unit A in Rocm A Yes 40,600 B'IU/ft Batte.f.y Foom Unit B in Rom B Ventillation l

Equiptent Fire Area IB-10 l

Rocm A & B Elevation 423'0" 2

l Zone 7 Cooling Unit A Yes 5,700 B'IU/ft -Rm.A Service Water Cooling Unit B 28,600 B'IU/ft -Rm B l

Booster Putp l

Cooling Equip.

Rocm A & B Elev. 426'0" Zone 8 2

Switchgear 7200V ESP Switchgear B Yes 15,300 B'IU/ft i

Rocm B Elev. 436'0" 480V ESF Switchgear B EEF bCC - B.-.y.. w m.. g. w p 9 g, m.3 3 Q p p g g 3fg g c,~

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ATDOE1ENT I Safe Shutdown Safe Shutdown Fire Zore/ Area Equipment Cable Fire Ioad Zone 9 Cmponent Coolirg Water Ptmp Yes Rocm A 2

Speed Switch Rocins Speed Switches A, B and C 10,500 BW/ft A, B. C. Elevation C.C. Water Punp C Room B 2

436'0" Transfer Switch in Rocm C 10,000 B W/ft accm C 15,600 B W/ft2 IB-14, IB-15 and CREP-A Reactor Protectic'n Under-Yes 50,800 B W/ft in j

IB-15A CREP and frequency and Under Vel sge Relay Rocm 36-03A 2

Switchgear Rocrns, and Transformer Panels CREP-B 35,700 BW/ft in j

Elevation 436'0" Rom 36-03B 2

52,400 B W/ft in Room 36-03 Zone 10 Main Steam Power Relief Valve and Yes Very Iow - Cable East Penetration Instrunentation Insulated in Access Area Cbnduit.Not -

Elevation 436' 0" Quantified Zone 11 2

West Penetration Main Steam Power Relief Valve and Yes 34,700 B W/ft Access Area Instrunentaticn Elevation 436' 0" 2

Zone 12 Main Steam Power Relief ilve Yes 20,600 BW/ft General Floor Area 436'-0" IB 16 & IB 17 ESF Switchgear Yes Room A 2

Switchgear Cooling Cooling Units 14,000 B W/ft thits Rooms A & B Room B 2

Elevation 451' 0" 14,000 B W/ft l

IB-18 and IB-19 Spesi Switchrocm Cooling Units Yes Rocn A 0

Rocm B Speed Switchroca 2

Cooling Units 3,700 BW/ft Rocxus A & B 451'-0" l

2 IB-20 Switchgear 7200V ESF Switchgear A Yes 95,000 BW/ft Rocm A 480V ESF.Ssitchgear A Elev. 463' 0" 480V MCC - A 2

IB-21 Reactor Trip Switchgear Yes 58,100 BW/ft CRDM Switchgear Recm Elev. 463'0" Zone 13 2

l West Pmetration None Yes 24,000 BW/ft l

Access Area 463'0" See Virgil C. Sumer Nuclear Staticn Fire Protecticn Evaluation for further details regarding these fire zcnes and fire areas, l -

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