ML20024C111

Notifies That Procedures 1405.16 & 2405.16 Electrical Penetration Fire Barriers, Revised Per 830405 Ltr. Procedures Reflect Insp Requirements for Barriers Instituted from App R Analysis.Procedures Implemented After 830603

ML20024C111
Person / Time
Site:	Arkansas Nuclear
Issue date:	05/31/1983
From:	John Marshall ARKANSAS POWER & LIGHT CO.
To:	Seidle W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
0CAN058317, CAN58317, NUDOCS 8307120269
Download: ML20024C111 (2)

Text

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ARKANSAS POWER & LIGHT COMPANY POST OFFICE BOX 551 LITTLE ROCK, ARKANSAS 72203 (501)3714000 May 31, 1983 BCAN058317 Mr. W. C. Seidle, Chief Reactor Project Branch #2 U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011

SUBJECT:

Arkansas Nuclear One - Units 1 & 2 Docket Nos. 50-313 and 50-368 License Nos. DPR-51 and NPF-6 Supplemental Response to Item 2 of Inspection Reports 50-313/82-33 and 50-368/82-33 Gentlemen:

Please refer to our letter (0CAN048307) dated April 5, 1983, in which we stated procedures 1405.16 and 2405.16, " Electrical Penetration Fire Barriers," would be revised by May 31, 1983.

Those procedures have been revised, but several unresolved items must be addressed prior to their implementation. The procedures currently reflect the inspection requirements for barriers instituted as a result of our Appendix R analysis. We requested an exemption for all barriers and suppression / detection systems in our March 28, 1983, letter (see attached BCAN038322) to NRR for approximately one year, in order to enable us to reanalyze ANO pursuant to new guidance obtained from the staff regarding 10CFR50 Appendix R. We have completed our analysis basad on the new barrier requirements, and a rigorous engineering evaluation regarding modifications and schedules is nearing completion. We are unable to implement the revised procedures until June 30, 1983, as the issue of inspecting fire barriers scheduled for future implementation in accordance with exemptions to the schedule requirements of Appendix R has not been properly addressed. We plan to indicate in the procedure which barriers are scheduled for

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I B307120269 B30531 PDR ADOCK 05000313 F PDR MEMEiER MiOOLE SOUTH UTILITIES SYSTEM k

Mr. W. C. Saidle - May 31, 1983 future implementation in accordance with exemptions. We are working with the staff on the resolution of the March 28, 1983, request, but final resolution is not expected until at least late July. At that time, it may be necessary to revise the inspection procedures to reflect that resolution.

Very truly yours, k

ohn R. Marshall Manager, Licensing JRM:DLL:rd Attachment 4

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%A .t AS PC',*.En & LIGHT COVP ANY

.'a . " E G X. = ahr.*.SAS' 2 3 Xt. J 'i 4 W Maren 28, 1983 l

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ter et Nuclear Reactor Re:ulation

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• N : Mr. J. F. Stolz, Chief 0;erating Reactors Branch **.

isision of Licensing

'.e v Regu'atory Cc--ission a w ingt: . CC 2:555

^ rector af Nuclear Reactor Regulation J. ? ' N : Mr. Robert A. Clark, Chief C;erating Reacturs Branch 83

' Dis sion cf Licensing

, .. 5. L :: ear Regulatorv " --ission I aasningt:n, CC 20555 SUBJEC' Arkansas Nuclear One - Units 1 & 2 Cocket Nos. 50-313 and 50-368 License Nos. OPR-51 and NPF-6

' Apoendia R - Senedular Exemption Request m

Gentlemen:

On March 1, 1983, a meeting was held in Bethesda, Maryland between members C of the NRC Staff and representative utilities of the Nuc' ear Utility Fire Protection Group (NUFPG). It was the purpose of that meeting to discuss certain aspects of Appendix R which had been identified by NUFPG as areas of significant concern or " generic issues." These were submitted to the NRC Staff as agenda for the March 1 meeting.

In concluding that meeting, the NRC Staff suggested it would be appropriate to issue additional guidance concerning the generic issues. However, until that guidance is received, it is necessary for us to request specific action for AP&L based on our present understanding of the Staff position regarding two of those generic issues- fire barriers and suppeassion/ detection systems. The nature and consequences of these requests are discussed in detail in the following.

Section Ill.G.2.a. of Appendix R states, " Separation of cables and equipment and associated non-safety circuits of redundant trains by a fire

• barrier.

The analysis performed by AP&L, and subsequently submitted to the NRC on July 1, 1982, ensured (where necessary) that at least one fire

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• m M it t n L9n f ur ther and requires at least une redundant trair. De s

,m > r .1 ' , f1r" wal1s The difference between these i nte rp re t :st i c o As and tN tmpact on ANL's July 1 sut,nittal is empected to te pitant since each fiie Zone must be reanalyted to this new gu!dav-l med i a t e l s following the March 1 meeting, a new analysis was begun es 5 N tN %C P. Jance. At this time we are aware that some previously ident'cc twrie rs ar e na longer required, while on the other hand, credit must tw then for several new barriers. However, we will require additional tin, t.

Fe complete our assessment and then to make the necessary modifications.

these reasons, we request an exemptinn to the schedule of 10CFR50.48(c) t.

all barriers and all penetrations thereto (doors, dampers, etc.). We do not, at this tiene, anticipate any new exemptions will be required.

The analysis to determine necessary fire barriers is proceeding rapidly AM is expected to be completed by approximately the end of April. This will result in the identification of all walls for which penetration seals, doors, dampers, etc. must be procured and t u talled to effect a co.T.plete appropriately rated fire barrier in accordance with the NRC's March 1 interpretation. We then anticipate approximately 6 months will be required a s epare procurement documentat %n an'* tike delivery of all the necessary equipment. This will oc followed by approximately 6 months of install; tion efforts. Excepting where an outage is necessary in order to ccmolete a madification (such as in as of hinh radiation), we expect al' work can be completed by the end of A,..ii IW.

This represents our best estimate for time required to complete the analysis and necessary modifications. However, as we proceed, we will be aDie to provide more accurate information and will continue to revise the schedule as necessary to reflect a longer or shorter exemotion period. Furthermore.

if an outage is required to accomplish any modifications, we will prov k, justification and schedule.

The second generic issue of concern to AP&L regards the NRC Statf interpretation of suppression / detection requirements.Section III.G.2.b. AP&L's and c. states these systems must be installed ". . . in the area."

July 1,1982, submittal ensured (where necessary) that a suppression / detection system was available in the fire zone of concern to protect the necessary redundancy and/or equIpeent. Wall-to wall coverage was not considered a requirement. A more detailed discussion of the logic leading to our position is included as Attachment 1. We request your rev w of this information. However, the interpretation stated by the NRC Staf f nr March 1 requires suppression / detection systems be installed "throughout the area." Again, the differences between these interpret.ations are obvious and, again, the impact on AP&L's July 1 analysis results is significant.

If, after your review of Attachment 1, the f4RC Staf f continues to require full area coverage for suppression / detection systems, we then request an exe+ption to the schedule of 10CFR50.48(c) for all suppression /detectinn system. This is necessary since (1) specific cGeption requests J 11 hwa to be prepared where our systems do not meet the "new" guidance and for q 'l s

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is .tited for the issue addressing barriers, a st,ppression/ detection s., s t em ina!vsi, was also begun following the March 1 meeting. Although it 25 still

> 1 m; compiled, it is probable that the results of the barrier analf5*s wti1 il m affect this analysis. In our best estimation, since these t'au 165tes tre directly related, the same schedule is req'Ji red f or uom ession/ detection as for the barriers, i.e. , end of January 1034. we

-ill continue to revise the schedule as work is completed.

truly your .

L,Ve )?. y(f.. _ .6 bohnR. Marshall Manager, Licensing 1

JEM:LVP:s1 1

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.. .t Arkansa. Power !. tiqht Company (/.P?.L) dated L<te @ cr f. 1962, the- [

l Nut irar Hegulatory Cormission (fGC) made the fullowing staterents pertainto,, l to Ar t ansas tauclear One ( ANO):

"By letter dated July 1. 1982, the licensee has also described proposed modifications to ten plant fire areas to comply with Section i!I.G of Appendix R. In several of these areas, specifically the cable spreading rooms, the licensee has i ndic ate d that alternate shutdown means will be provided, but has not indicated that a fixed fire extinguishing system will be provided as required by Section III.G.3 of Appendix R. The omission of a fixed extinguishing system does not comply with Appendix R, but could be the subject of an exemption request. In other areas only partial sprinaler system coverage of a fire area will be providec.

This does not cowply with Section Ill.G.2 of Appendix R, which requires automatic suppression to be installed throughout a fire area containing redunuant safe shutdown equipment. Those areas where pa-tial protectiva will be provided could also be the subject of exemption requests."

AP!.t does not shart - "interr-ctation" of the requirements for fire protection as set forth in Appendix R to 10CFR50 and has requested a reeting with the f4RC to appeal their position as stated above. The justificatun for AP!.L's position that Appendix R allows the licensee to choose " partial" suppres:, ion coverage without the need for exemption on a case-by-case review i< presented as follows. This justification also addresses the apparent, yet erroneous, equating by th( NRC of the terms " partial suppressinn coverage" and " partial protection."

Title 10CFR50 Appendix A section III.G.2 requires that one train of c.cles and equipment necessary to achieve and maintain safe shutdown be naintained free of fire damage by one of the following means:

A. Separation of cables and equipment and associated non-safety circuits of redundant trains by a fire barrier having a 3-hcur rating. Structural steel forming a part cf or supporting sur, fire barriers shall be protected to provide fire resistance equivalent to that required of the barrier.

S. Separation of cables and equipmert and M sociated non-safety l

circuits of redundant trains by a horizontal distance of more t*m

] 20 feet with no intervening combustible or fire hazards. "

addition, fire detectors a ..' ca, automatic fire suppression sys ter.

shall be installed in the fire area; or l

C. fnclosure of cable and equipment and associated non-safety [

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, ., L t.e r dncamontation such ..s NFPA Standards and b ranc h ' e c n t - al s ition a S-; ( E T P 9. 5- 1) are li.ted as references whic h prowice quive!): .

'r om lear po.er plant fire protection. Appendis H additionally states i n.

Oal' t: i i tti of these guidelines to indivicual nut!rar piants, as e,cil a-tt4 identification of open fire protection is5Les, is stated in the firr w t ec t ic n safoty Evaluation Report.

-e " ive rev iewed these and other docurrents. We hav r- also talked with

. ,crts from various groups, including fire protection engineers and ar ultants associ ated with ANI, Rebsarnen Insurance, NFPA, and EPRI. Our conclusion is that Appendix R does not require installation of suppressico systems throughout fire areas, but instead requires adequate protection of rire areas through the use of available means, and applicable industry cu es ans standards. we offer the followino snecific discuM 4ns used to arrive at this conclusion. Attacnment I presents definitions which have been obtained primarily from the NFPA Standards, and BTP 9.5-1, for terafnology used hereir It 's of direct importance to this discussion to emphasize now the see:2ingl/

obvinus statement that 'he tern suppression system covers a wide range of I different applicatio. " u :,; . i n(ler , spray , halon, autcmatic, manual ,

l etc. These are acdressed as separate Standards within the NFPA, each l indicating the specific requirements for that application selected (there l are at least 11 different NFPA Standards for fixed suppression syste's I alcne). It is not reasonable to expect for all suppression systems to meet

• ePr 12, !or example.

Sprinkler Systems are nor ally installed within guidelines presented in hfPA lJ, which is entitled, " Standard for the Installation of Sprinkler Systems." In the " General Infornation" section of Chapter 4 of NFPA 13 (NFPA 13, Section 4-1.1.1), which is concerned with placement of sprinklers, the following statement is made:

"The basic principles for providing proper protection are namely:

(1) Sprinklers installed throughout the premises, including basements, lofts and all locations herein specified. (2) Definite maximum pratection area per sprinkler. (3) Minimum interference to disc 5arce pattern by beams, bracing, girders, trusses, piping, lighting fixtures and air conditioning ducts. (4) Correct locatio1 of au'.onatic sprinklers with re; pact .0 ceilings, or bews and wood joists to obtain schedule sensitivity." x

'fe 14th NFPA Handbook also makes the ivilowing statements reg 3rcing wrinkler Systen installation:

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. i m;1 e area because it is juWed that the h.i/ard is not sufficient to warrant t he t. a "freuentlv, building codet and ordinances require partial sprinkler protection for specific areas with the intent of providing limited protection for certain hatardous areas, and as a Out the limitations of part ial protec t {o_n life safety measure.

• often outweigh the supposed advantages they offer.

' ect io, bl.2 of Appendix A to NF PA 13 additionally states:

"When buildings or portions of buildings are of combustible construction or contain combustible material, standard fire barriers should be provided to separate the areas which are sprinkler proteued f rom adjoining unsprinklered areas. '

These statements seem to indicate that sprinklers, wisere selected as the ears of fira suppression, should be installcJ throughout the premises,On January 5, 19 though partial r0Varage is obv kusly

• onsideratior.. i t we talked witn Mr. Robert Hodnett, the Extinguishing Systems Eng nece a NFPA who is the individual responsible for interpretations of NFPA 13, and he previded us with ss al wifying information. Mr. Hodnett said i h individuals, i.e., design engineers, employed by the company select ng t e sprinkler system are responsible for determining if an area is "cornpletely sprinklered," not NFPA. He added that NFPA 13 is intended to be used to provide technical knowledge of how to install and/or select a system -- not

, to impose reautrements on the purchasing party of whereIdeally, to install that I "

l system or under what conditions to make such a selection. ... wt sprinkler protection should be installed "throughout the premises,Howev just throughout the area, premises" pertains to the performance of a case-by-case In evaluation of affected fire areas by the purchaser of the sprinkler system.

considering a room partially containing combustibles, Mr. Hodnett said coverage of that combustible material usually constitutes " complete coverage." Also, if a room enclosed by three-hour fire barriers is ee:pty, l or if it contains absolutely no combustibles, then the lack of sprink er j protection within that room does not prevent classification of the sub tct i A room which contains a limited f building as " completely sprinklered."arount of combustibles which are direc classified " completely protected," according to Mr. Hodnett.

Seeking concurrent interpretation, we discussed this subject with Mr. Paul G i ac c ar;114, a Senior Adeinistrative Engineer enployed by American Nuclear P- G:accaglia provided us with an Insurers ( ANI), en January 5, l'Jd3.fif PA 13, Section 4-1.1.1, f rom the Forrial official interpretatten of in

't ',erpretations published by the NFPA Stand)rds Inf ormation Sers ice i

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'I t i the intent of Sec t ion 4- 1.1.1 to require in.tal:aticn e' a sprin( le- head it every area including shower rooms and ttowa wi,e r e c

1 osets ostept where ex itn:cd by Section 4-4.4. 2 or e ucpt tuthorit. having juris.*iction permits oriission of the t".

<prtm lers is taken from f4FPA 13 Section 4-1..', " Partial Ih- latt( r exce; tion

'nstallations,* herein the folicwing is mentioned:

'".!hr 1 partial >prinkler instill 4 Liens are installed, ti..

raquirements of Liiis stoodar d Shain be used insofar as incy are arplicable.

According to Clearly, parti.-1 installation, are i' ed by tiTPA 13. ensurance Ns rs. Hodnett, Giaccaglia and Ivan Richardson (a fire protection cenwltant currently eeninyed by Rebsamen Insurance), if AP&t has dcctced to 311 - partial sy * *m , W" 12 s hm i d t'e u s o d to r e. .te p dance 60 ir

nstalling tnat partiai syste, As a final cc o nt on sprinkler systems we note that the app l ic ati t ! i t . of Paragraph 1- 2, " Purp o s e ,"

NFPA 1.$ g thoup not doubted) can be questioned.is to provide a reason 91e cagree state, at the purpose of this standard of protortien of life.

" Yet, in the introduction to the A'i0 ftre Protection safety Evaluatien Reports (SEth ) the following statments are m ide :

"We have reviewed the licensce's analyses and have visited the plant to examine the relationship of safety-related components, syste", and structures with both combustibles and the associatec fire detection and suppression systems. Our review has been limited to the isnects of fire nrotection ithin the PNC's jurtsoicticn, i . e. , those aspects related to the protect ion offire puolic health and safety. We have not considered aspects ofanu protection associated with lif e saf ety of onsite personnel with pronarty protection unless they impact the health and safet'.

of the puo s ic due to pot ( ntial release of raMoactive material .

Ilt'nunh se da not que!! ion the need for the guidance of stJDdards - ' a s

'J N 13, we pre ant this comparison .i. n.. mo r e n a"*p l e of *he inter it' a

'ed in rou.hioq our interpratations of the applicability of availabit' MC r * ,* stry gutde1ines and standards

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,,, . qual'y as ,alid for e, ample, *4 6 P A 15 states.

" Water spray flued syste?ls are usually applied to i,pec i a l fire prr,tect101 proble:s , since the protection can t'c spctifically designed to provide f or ef f et i t se fire control . ca t inguisteent .

pr evention, er espo:.ure protet t lon. Water spray systemt, may te it. dependent of, or supplementing to, other forms of protection."

Also:

The design of specific systens may vary consideraly, depending on the nature of the hazard and the basic purpnSes of protection.

Appendix A, paragraph A-1-$. to NFPA 15 states that effective esposure protection is accomplished by application of water spray directly to the exposed structures or equipment.

We also make brief reference to paragraph 1-5.5.3 of NFPA 12A which describes local application of Halon 9ystems. Clearly, this is but one rore reference to a partial coverage suppression system, in contacting Mr. Joseph Matte Ill (Project Manager - Fire Protection, Engineering anc Operations Department, Nuclear Pover Division) of EPRI, Messrs. Dennis Eaves and Paul Giaccaglia of ANI, Mr. Robert Hodnett of NFPA, and Mr. Ivan Richar' .. of Rebsamen Insurance, the interpretation, by each individual of the g.. .ui>>1bliity of " partial coverage" by the 14FPA codes has been affirmative.

Perhap; the most important reason for reaching our stated conclusion regarding the acceptability of partial suppression coverage is Appendix R itself. As previously stated, Appendix R directs the licensee to the issued Fire Protection Safety Evaluation Report for the licensee's plant for interpretation of the applicability of referenced guidelines to the performnce of an evaluation against Appendix R criteria.

Attachment 11 presents extracts from the ANO SERs. Note marked ite.as (1) and (2) which reference NFPA 13 and 15 and BTP 9.5-1. Obviously, we have utilized these Standards, as well as others, in the design of ANO: and we have thus far adequately addressed our position with regards to their usage and interpretation. Attachment III presents extracts from BTP 9.5-1.

Items (1) through (5) in this attachment address essentially the same information as covered above. Each item clearly addresses the acceptability of partial suppression systems for particular applications.

We feel the conclusion that the NRC ha: ju;.tif M the use of " partial coverage" suppression systems is obvious, and that additional examples % "

the SER will gain nothing.

As to the definition of who has the authority to make selections regarding partial versus full suppression systeas coverage, refer once again to NFPA 13

.hich st.ites this is "the authority having jurisdlClion." There can be little doubt this is AP&L Nevertheless, we offer item (3) of Attachment Il 5

, .. - 3 r i t a ; .W s f f i t. t o l l j h a '. placed thic tenwr><,1bility and !

r sat orits L;an Av!.L.

Recall *%t Ai!.L's appeal

• tatement also included the need to address the apparent equatinij by the NRC of the terms " partial suppression" and " partial pr otect ion. " We take strong exception to this comparison if it is inceed the comparisoa t:cing made. The information thus far offered presents overwhelming evidence of the acceptability of properly designed partial coverage suppression systees. Nowhere can it be inferred that " partial coverage" means " partial protection." On the contrary, Attachment IV presents a particular occurrence at ANO whereby the NRC judged a " full" coverage sprinkler system to be inadequate and suggested instead a "p3rtial" directional spray system be installed. We agree with that ruling and feel sufficiertly justified in light of that occurrence (as well as the other documentation) to continue that example by performing a case-by-case determination of the type suppression system coverage required without first receiving NRC approval to do so.

In conclusion, our appeal to the NRC is that it be stated for AP&L that

" partial" suppressian system coverage is not the basis, or possible basis, of an exemption request. We admit tt.at where " partial protection" is afforded, that does require an exemption request. Otherwise, the decision for adequacy of suppression system rests with AP&L (with a possible challenge by I&E as in all Appendix R matters).

If the NRC position cannot be changed, we request additional informathn. to our ccmplete underst- oc, regarding the definition of such teres as "p3rtial" suppressior, and " partial" protection and regarding the application of the systems in light of your interpretation of the applicability of existing incustry standards and NRC guidance documents. We would additio ully expect, because of the gross ambiguity of Appendix R in this matter, that your ruling give consideration to the additional time that will be required to meet these newly defined criteria.

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,1 i - lRt PCI! t'Is N i [ P1: ', , 'i A. from B'P 9.5-1, one finds the following d,finitto.n which a r s' corst. tent with those found in the NFFA 5tandard'.

1. fire Area - that partton of a butiding or plant that ?s separated from other areas by boundary fire barriers;

2. Ftro Barrier - those components of construction (walls, floors, and their s aports), including beams, coluons, penetration seals or closures, fire coors, and fire depers P that are rated by approving lateratories in hours of resistance to fire and are used to prevent the spread of fire;

3. Fire Zenes - the subdivisions of fire areas in which the f're suppression systems are designed to corbat the particular e

types of fires; I

k 4. Fire Soopression - control and extinguishing of fires 4 (firefighting). Manual fire suppression is the use of hoses, portable extinguishers, or manually-actuated fixed systems by pitat personnel. Automatic fire suppression is *he use of j autcmatically actuated fixed systems such as water Halco, or car " dicxide systems; j 5. Sprinkler System a network of piping connected to a reliable supply that will distribute the water throughout the f

l area protected and will discharge the water through

[ sprinklers in sufficient quantity either to extinguish the 6 fire entirely or to prevent its spread. The system, usually acti'eated by heat, includes a controlling valve ;..~ . device for actuating an alarm when the system is in cperation. The l

I h}M following categories of sprinkler systems are definec in NFPA 13. " Standard for the Installation of Sprinkler l q Systems":

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• Wet-Pipe System I

• Dry-Pipe System Preaction System I gi:

• Ocluge System

• Combined Dry-Pipe and Preaction System

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• On-Off Syste1; and, finally

6. Water Spray System - a netw;-k vi piping similar to a sprinkler sy! ten except titat it utilizes open-head spre NFPA 15. " Water Spray fixed Systems ," prov t ors i

g, netzels.

outdance on these sy>i. cms.

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ite r vry s y ' t en protec t ing t he di es e l fuel s tor irle v aul t s are i;m i l l y actJJted fi t s the Control rooms. This {s JCCeptable bcCJuse (bc i.dundant tann . are sep3 rated from each other by a three-hour fire barriev

a g, p r n c d e , loss of more than one tank.

Ot'er than for the above exceptions, the systems have been (, ,

designed in accordance with applicable standards: NFPA 13,

' Sprinkler Systems,' and NFPA 15, ' Water Spray Fixed Systems. '

We find that, subject to modification of the cable spreading room su;;pression system as described above, the cable spreadirg room fire protection will fully satisfy the objectives of Section 2.2 of this report and is, therefore, acceptable.

4 . L 1. 6 Foam The plant has available a supply of foam and a nozzle for manual fire fighting, to be used as a supplement to manual suppression means. We find that the use of foam in this manner conforms to the provisions of Appendix A to BTP 9.5-1 and is, therefore, acceptable."

Finally, from page 8-1 of the ANO-2 SER, we find:

8.0 CONCLUSION

S The applicant has pe. .omed a fire hazards analysis and has proposed certain modifications to improve the fire protection program. Additional modifications have been proposed by the applicant during the course of our review cf the fire hazards analysis and our onsite evaluation of the fire protection pregram. These proposed modifications are summarized in Section 3.1.

In surnary, significant steps have been taken to assure that safe shutdown can be accoe:plished and the plant maintained in a safe condition during and following potential fire situations. Upon implementation and NRC verification of the applicant's proposed modifications summarized in Section 3.1, we find that the requirements of General Design Criterion 3 will be fully satisfied and that the applicant's complete fire protection program shows that:

(1) Combustibles in safety-related areas are limited to the extent '

practicable; (2) Fire detection and suppression systens will minimize the effects of fire on safety-related systems and will not in themselves significas.tly irmair the capability of safety-related systems; 11-3

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.lant;

) A fire in any fire zone will not damage safety-relatea $*ructures sus'*

that they cannot perform their safety function; (j'

(5) The fire protection organization has the professional cualifications _

to implement the fire protection program, and administrative controls are adequate to maintain control of combustibles, ignit t en sources, and the fire protection crganization; and (6) A fire in any fire Zone will not cause the reiease of a-cunts of radioactive material in excess of those considered in previous safety evaluations. _

We find that the applicant's proposed modifications descrited herein are acceptable both with respect to the improvements in the fire protection program that they wf11 provide upon full co=piction of the program remaining and items witn respect to present safe coer? tion of the facti [Ly, while Llw are ccmpleted."

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..i 'u  ! at lunch Technical Po,ition 9.5-1 (biP 9.5-1):

t i e c '. r i c 31 Cable Cant.tra tion, Cabl, Travs and Cable ?.netratton (1) Only metal should tw used for cable trays. Only retallic tainq should be used for conduit. Thin wall netallir tubing shculd not t;e used Flextble tubing should only be used in short lengths to connect to autpceat. Other raceways should be made of noncombustible materl4I.

(2) Redundant safety related cable systems outside tne cable spreading rocm should be separated from each otner and from potential fire

.rxposure hazards in nonsafety-related areas by fire barriers with a mininv fire rating of three hours. These cable trays should be provided with ccntir.uous line-type heat detectors and should be accessible for manual firefighting. Cables should be designed to allow wetting down with fire suppression water without electrical faulting. Manual hose stations and portable hand er+inguishers should De provided. Safety related ecuip.cnt in the vicinity of surb cablr trays that deeh not itself require fixed Water suppression systems but is subject to unacceptable damage from water shoulc be protectec.

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5afety-related cable trays of a single division that are separated frc1 recundant divisions by a fire barrier with a minicum ratinc s' three hours an- e nornallv accessible for ~'anual fir: fighting should te trotected frcm th( :tects of a potential exposure fire by providing automatic water suppression in the area where such a fire could occur.

Automatic area protection, where provided, should consider cable tray arrarce m nts cnd possible transient combustibles to ensure adequate water I coverar;e fc- areas that could present an exposure hazard to the cable systen. Manual hose stanpipe systems may be relied upon to provide the priuary fire su::pression (in lieu of automatic water suppression systems) for safety-related cable trays of a single division that are separated from redundant safety divisions by a fire barrier with a minimum rating of three hours and are normally accessible for manual firefighting if all of the f ollowing conditions are met:

(a) The number of equivalent standard 24-inch-wide cable trays (twth saf ety-related and nonsafety-related) in a given area is six or less,

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q (b) The cabling does not provide instrumentatien, control or po-cr to systems required to achieve and maintain cold shutdown; and L

4 N (c) Smoire detectors are provided in the area of these table routinos, and continuous line-type teat detectcrs are provided in tN cable g trays J

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• protectM frc, the effects of a potential e=posure firc by pro.'ctr1 autc.itic r ater .uppression in the area where Srch a ftre could occur.

In sucti plant areas as primary and ser oncary containeent or other areas where it may riot be possible bcCause of other overriding cesign features necessary for reasons of nuclear safety to separate redundant saf ety-related cable systems by three-hour-rated fire barriers, cable trays st auld be protected by an automatic water system with open-head deluge or open directional spray nozzels Such arranged cablesotrays that should adequate alsowater coverage is be protected provided for each cable tray.frca the effects of a potential lhe exposure CaDabIIityfireto by providing aut suppression in the area where such a fire could h cur.

actiieve and maintain safe shutdown considering the ef fects of a fire involving fixed and potential transient combustibles should be evaluated with and without actuation of the automatic suppression system and should be justified on a suitably defined basis.

(3) Cable and cable tray penetration of fire barriers (vertical and horizontal) should be scaled to ginn protection et least equivalent to that required of the fire barrier. The design of fire barrier penetrations The for horizontal and vertical cable trays sheuld be qualified by tests.

penetration qualification terts sbaul1 use the tir e-tereparature exposure cu*ve specified by ASTH E-119, Vire Test of Building Construction and Materials." Openings inside conduit larger than four inches in diameter fire carrier penetration; these seals should be should t'e sealed at Openings inside conduit four incnes qualified by tests om described above.

or less in diameter should be sealed at the fire barrier ano shculd be qualified by tests as described above unless the conduit e or at the fire barrier with noncombustible material to prevent the passage of smoke and hot gases.

Fire carrier penetrations that caust maintain envircnmental isolation or pressure dif ferentials should be qualif'd by test to maintain the barrier integrity under the conditions specified acove..

(4) Fire steps should be installed every 20 feet along horizontal cable routings in areas that are not protected by autcaatic water systems.

Veritical cable routings should have fire stops installed at each floor / ceiling level. Between levels or in vertical cable bases, fire steps should be installed at the midheight if the vertical run is 20 feet er more but less then 30 feet or at 15-foot intervals in vertical runs of 30 feet or  !

more unless such vertical cabic routir.gs are protected by autenatic water  !

Individual fire stop cesigns should systems directed on the cable trays. "

prevent the prepagation of a fire

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it; cf.le, that enter the cs atrol rotm ,houi1 terminite in e o 'n it 3; is, no cablir.) shuuld tm simply rout.J tr-c W t*e tsttr i Cable', in the control r o o'1 shculd Or tral ro na from ore area to another.

, rt t, mininom necessary fcr plant operation i

rabh s in uncerflec r and ceiling spacesAir-handling should meetfunctions.

the

.eparation criteria givan in Regulatory Guide 1.75. spaces; 1. e . , if cl.bles should be ducted separately from cable runs in suchin underfloor or ceiling spa are routed Fully enclosed as air plenums for sentilation of the control room.

electrical raceways in such underfloor and ceiling spaces, if over one in cross-sectienal area, should have automatic fire s@pression scuare foot (3) inside. Area automatic fire supp ession shoulo oe provided for underfloor i anc ceiling spaces if usec for cable runs unless all cable is run in 4- nch or smaller steel concuit or the cables are in fully enclosed raceways internally protected by automatic fire suppression.

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c. Cable Screadirq Room i

l The primary fire supprossio.. in the cable spreading room should be an autenatic water systen such as closed-head Deluge sprinklers, open-head deluge and open spray f system, nr open directional water spray system.

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systees should have provistens fe- -anual operation at a remote station; hwever, there should be provisions to preclude inadvertent oper* tion.

Ineation of sorinkler heads or spray nozzles should consider cable tray adequate water

) ,r rangments and ; ihle t u ntient combustibles to ensura coverage 1or areas snat could present exposure hazards to the caole system.

g}l Ca',les shculd te designed to allow s.etting down with water supplied by the i

fire suppression system withcut electrical faulting.

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Open-head deluge and open directional spray systens should be q]W zones.

A The use of foam is acceptable.

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' Automatic gas systems (Italon or CO 2 ) may be used for primary fire l suppression if they are backed up by a fixed water spray syste:n.

Cable spreading econs shculd have:

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1. 4 At least twa remote and separate entrances for access by fire (1) f i

' brigade personnel; 1

(2)

An aisle sepration between tray stacks at least three feet side and eight high; (3) Hose stations and pcrts',1c extingu. hers insta!Io1 i "

' ~cdiately outside the roon.

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(1) Sprinkler systecs and manual hose station standpipes 5 % .

ta,e tonnecticos to the plant underground watcr rs& t n so that no single active failure or crack in a ecderate energy lirm can impair both the pr t.T.ary and backup f ire suppress ion systems. Alternatively, beacers fed from each end are permitted inside buildings to supply both sprinkler and standpipe systems provided steel piping and fittings meeting the requirements of ANSI B31.1, " Power Piping," are used f or the headers up to a r.d including the first valve supplying the sprinkler systems where suc's headers are part of the seismically analyzed hose standpipe system. When provided, such headers are considered an extension of the yard main systet Hose standpipe and automatic water suppression systeres serving a single fir e area should have independent connections to the yard main systems. Each sprinkler and standpipe system should be equipped with OS&Y (outside screw and yoke) gate valve or other approved shutof f valve and waterflow alarn Safety-related equipment that does not itself require sprinkler water fire prctection but is subject to unacceptable damage if wet by sprinkler water discharge should be protected by water shields or baffici. i (2) Control ano sectionalizing valves in the fire water systems should be electrically supervised or administratively controlled. The electrical supervision signal should indicate in the control room. All valves in tha fire protection sy:,aa should be periodically checked to v=rify position (see NFPA 26, " Supervision of Valves").

(3) Fix e r m tinguishing systems should, as a minimun, ccaform to requirements of appropriate standards such as NFPA 13, " Standard for tne Installation of Sprinkler Systems." and NFPA 15. " Standard f or Water Spray Fixed Systems."

(4) Interior manual hsoe installation should be able to reach any location that contains, or could present a fire exposure ha:ard ta.

safety-related equipment with at least one ef fective hose stream. To acccmplish this, standpipes with hose connections equipped with a maximun cf 100 feet of 1-1/2-inch voven-jacket, lined fire hose and suitable nozzles should be provided in all buildings on all floors. Individual standpipes should be at least four inches in diameter for multiple hose connections anc

' 2-1/2 inches in diameter for single hose connections. These systems should follow the requirements of NFPA 14 " Standpipe and Hose Systems," for sizing, spacing, and pipe support requirements.

Hose stations should be located as dictated by the fire hazard analysis to facilitate access and use for firefighting operations.

Alternative hose stations should be provided for an area if the fire hazart could block access to a single hose station ser*. ...g that area.

Provisions should be made to supply water at least to standpoints and hose connections for anual firefighting in areas containi v 4 equip-ent required f or safe plant shutdown in the event of a safe shutdown M carthquake. The piping system serving such hose .."

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n ' ~, )!$ $ 5 kda$$Nbbb AT T AC}NEN T IV SWNARY Of HISTORY OF M40-1 SER ITD1 J. 7 I, SER item 3.7 concerning the ANO-1 Cable Spreading Room, a deluge systen a, installed in accordance with hFPA 15. It is important to note that this Water Jeluge system was not a sprinkler system, but a water spray system.

spray systems are designed to protect a local hazard, i.e., cable trays, and not to protect an entire area. The original suppression system installed in the M40-1 Cable Spreading Room was a wet pipe sprinkler system with ceiling level :prinkler heads and one intermediate layer of sprinkler heads, as described in cur September 17, 1976, letter to Mr. Victor Stello, Jr. This systes provided complete coverage of the Cable Spreading Room. Mcwever, because of disbelief by the NRC that this system teuld safely extinguish f f res in the lower cable trays, either an analysis demcnstrating the adequacy of the system or prcposed system modifications was requested by the NRC on February 22, 1977. As of January 18, 1978, a deluge water spray system actuated by head and smoke detectors with directional nozzels to insure impingement on cables trays was proposed and was installed per NFPA 15 requirements, and the pre-existing wet-pipe sprinkler system was rer.oved. The new system provides " partial protection" ectording to the apparent NRC definition regarding " partial" systems, but " complete coverage" according to the NFPA.

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