ML20023B702

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Exemption from Requirements for Installation of Fixed/ Automatic Fire Suppression Sys in Control Room Complex & Intake Structure
ML20023B702
Person / Time
Site: Calvert Cliffs  
Issue date: 04/21/1983
From: Eisenhut D
Office of Nuclear Reactor Regulation
To:
BALTIMORE GAS & ELECTRIC CO.
Shared Package
ML20023B700 List:
References
NUDOCS 8305060084
Download: ML20023B702 (5)


Text

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Enclosure UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of BALTIM0RE GAS AND ELECTRIC 00cket Nos. 50-317 COMPANY

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and 50-318 (Calvert Cliffs Nuclear Power Plant Unit Nos. I and 2)

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EXEMPTION 1.

The Baltimore Gas and Electric Company (the licensee) is the holder of Facility Operating License Nos. DPR-53 and GPR-69 which authorize oper-ation of the Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2.

These licenses provide, among other things, that they are subject to all rules, regulations and Orders of the Commission now or hereafter in effect.

The facility comprises two pressurized water reactors at the licensee's site located in Calvert County, Maryland.

II.

On November 19, 1980, the Commission published a revised Section 10 CFR 50.48 and a new Appendix R to 10 CFR 50 regarding fire protection features of nuclear power plants (45 FR 76602). The revised Section 50.48 and j

Appendix R became effective on February 7, 1981.

Section 50.48(c) established I

the schedules for satisfying the provisions of Appendix R.

Section III of l

Appendix R contains fifteen subsections, lettered A through 0, each of which specifies requirements for a particular aspect of the fire protection features at a nuclear power plant.

-(D305060084 830421 PDR ADDCK 05000

. Subsection III.G.2 requires that fire detectors and an automatic fire suppression system be installed in areas of the plant where cables or equip-ment of redundant trains of systems, necessary to achieve and maintain hot shutdown conditions, are located in the same fire area cutside containment and are separated by 20 feet free of intervening combustibles.

By application dated March 4, 1983, the licensee requested relief from the above require-ment as it applies to automatic fire suppression systems for the Units 1 and 2 intake structure.

Subsection III.G.3 requires that fixed fire suppressica be provided in areas where alternative shutdown capability has also been provided.

Although the March 4, 1983 application requests relief from the require-ment to provide fixed / automatic fire suppression in the control room complex pursuant to Subsection II-I.G.2, we interpret this as a request for relief pursuant to Subsection Ill.G.3. This is appropriate since an alternative shutdown means is provided for the control room complex.

The fire protection features of the control room comolex (areas 400, 401, 402, 403, 404, 405, 406, 415, 431, 432, 434, 435, and 436) were addressed in the Calvert Cliffs Fire Protection Safety Evaluation Report (FPSEF.) which the NRC issued on September 14, 1979. The FPSER indicates that the control room complex fire protection features include smoke detectors installed in (1) HVAC ducts, (2) ccntrol room ceiling, (3) the log and instrument room (presently the Technical Support Center), (4) super-visor's office, and (5) computer rooms. The computer rooms have, in addition, heat detectors located within cabinets and under the floor which actuate Halon 1301 systems protecting these cabinets and subfloor area. A manual hose ard portable extinguishers are available for manual fire suppression.

As indicated in the March 4, 1983 application, improvements have been made in the control room complex fire protection features since issuance of the FPSER. These improvements include:

(1) providing nozzles for manual hose protection con;patible with the hazards and equipment in the control room; (2) removal of all wooden furniture and shelves from the control room complex and (3) metal partitions to separate adjoining panels from the computer terminal. The existing control room oullet-proof doors, which had not previously been shown to be "3-hour rated", have been tested and approved as indicated in the NRC letter dated August 16, 1982 and the accompanying Exemption.

In addition to the above fire protection features, a review of Calvert Cliffs Technical Specification 6.2.2.a indicates that the control room must be continuously manned during all modes of reactor operation. Based upon the fire protection features provided and the existence of a continuous fire watch we conclude that any fire in the control room complex would be promptly detected and extinguished.

Therefore, the addition of a fixed fire suppression system would not significantly enhance the fire protection features of the control room complex.

The second area addressed in the March 4, 1983 application is the intake structure.

This area is important to safety since it contains the salt water pumps which provide cooling water for safety-related equipment.

The intake structure is an enclosed concrete structure having a three hour fire rating.

This area contains the circulating water pumps (six per unit) each of which is in a pit in the ficar of the structure to contain any oil which may leak from the pump.

Each pit is surrounded by a curb to prevent external flammable liquids from entering the pit. The circulating water pumps are separated from the salt water pumps by approximately 20 feet and from each other by over 30 feet.

Salt water pumps (three per unit) are located in separate concrete-lined pits below the floor level of the structure and are separated from each other by approximately 61 feet. The curbs for these pits have openings to allow access to equipment ladders. The licensee has indicated that these openings will be closed within six months to restore the integrity of the curbs. Each pump's motor is mounted approximately 14 feet above floor level i

directly above the pump.

Power cables from each salt water pump are routed in conduit to the west wall of the intake structure and are separated by a minimum of 45 feet horizontally from those of the adjacent salt water pumps. The intake structure is provided.with fire (smoke) detection and f

with portable fire extinguishers. The hose stations have sufficient hose I

to reach any fire with at least one effective water stream.

In summary, the intake structure can be characterized as having a 2

j low fire loading (approximately 16,000 BTU /ft ) and a large separation between redundant components of safety-related equipment.

Because of the

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low fire loading, large volume and ceiling height, reasonable assurance is provided that a fire in the intake structure would be detected and efficiently extinguished prior to damaging the redundant salt water pumps in this area.

Based on the above, we conclude that the installation of an automatic fire suppression system in the intake structure would not significantly improve the level of fire protection in this area.

III.

Based-on the consideration of the fire protection features of the control room complex and the intake structure, we conclude that the existing fire protection features provide fire protection that is equivalent to the technical

requirements of Subsection III.G.2 and III.G.3, respectively. On this basis, the staff concludes that the installation of fixed fire suppression systems in the control room complex and intake structure would not significantly improve the fire tuppression capability in these areas. Accordingly, relief from the technical requirements of Section III.G.

of Appendix R to 10 CFR Part 50, as these requirements relate to installation of fixed fire suppression systems for the control room complex and the intake structure, should be granted.

IV.

Accordingly, the Commission has determined that, pursuant to 10 CFR 50.12, an exemption is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest and hereby grants the following exemption with respect to the requirements of Section III.G.2 and III.G.3 of Appendix R to 10 CFR Part 50:

The installation of fixed / automatic fire suppression systems for the control room complex and the intake structure is not renoired for Calvert Cliffs Units 1 and 2.

The NRC staff has determined that the granting of this Exemption will not result in any significant environmental impact and that pursuant to 10 CFR 51.5(d)(4) an environmental impact statement or negative declara-tion and environmental impact appraisal need not be prepared in connection-with this action.

g FOR' Tile NUCLJAR REGULATORY COMMISSION

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D rr 1 1se u,

rector Division of Licensing Dated at Bethesda, Maryland this 21st day of April, 1983.

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