ML20043B170

Forwards Revised Exemption Request from 10CFR50,Section III.G.2,App R for Fire Areas a & B,Adding Description of Specific Limited Combustibles That Exist Between Redundant Safe Shutdown Components in Fire Area a

ML20043B170
Person / Time
Site:	Davis Besse
Issue date:	05/18/1990
From:	Shelton D TOLEDO EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
1809, TAC-60995, NUDOCS 9005240314
Download: ML20043B170 (16)

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I; L TOLEDO -

EDISON A CE" Lente EnSrgj Corgwiy DONALD C. SHELTON

- va wsoor DocketINumber 50-346 p'  : License Number NPF-3 Serial Number 1809 May 18, 1990 I

y EUnited States Nuclear Regulatory Commission Document Control' Desk Washington, Di C. 20555 .

i Subject Fire Protection - Revised 10CFR50 Appendix R Exemption Request for the. Containment Annulus (TAC Number 60995)

Gentlemen:

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'By letter dated April 19, 1990 (Serial 1798), Toledo Edison requested an exemption from 10CFR50 Appendix R Section III.G.2 for separation within the Containment Annulus. The exemption request. involved fire areas A and AB as described in the Fire Area Optimization' Report (FA0R). Toledo Edison is hereby revising this exemption request to add a description of specific i limited combustibles that exist between redundant safe shutdown components in  !

Fire Area A. The attached exemption request supersedes the exemption request dated April 19, 1990.

Clungestotheearlierexemptionreqhstaredesignatedbyaverticalbarat t hr. left margin and include the following:

• converts-the Compliance Assessment Report (CARP) fire area designators to -i FA0R areas by reference to the FAOR and clarifies which fire areas are 1 adjacent to the annulus.  ;

- describes combustible neutron shielding blocks near the annulus l- ventilation openings in fire areas A and AB. i

-+ . describes combustibles located between redundant pressurizer level ,

indication circuits in Fire Area A.

p The changes do not affect the description of the exemption requested or applicable special circumstances sections. I 900524o314 900518 PDR ADOCK 05000346 f

F PDC THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO, OHIO 43652 O

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@' i LIfiyou;have< any ques' tion concerning this matter, please: contact; ,

'Mr.'R. V;lSchrauder, Manager - Nuclear 1 Licensing, at.'(419)L249-2366.~

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'A'.'B.' Davis, Regional Administrator,.NRC: Region:III .

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' Serial Number 1809 Attachment '

E Page l' EXEMPTION REQUEST FOR FIRE AREAS A AND AB EXEMPTION REQUESTED An exemption is requested from Section III.G.2 of Appendix R to 10CFR50 to the 1 extent it requires the separation of redundant safe shutdown com: onents by a three-nour rated barrier. Specifically, redundant trains of'saf" shutdown circuits in the Containment Annulus are either: (1) separated within the annulus by greater than 40 feet free of intervening combustibles, (2) separated 'i within-the annulus by radiant energy shields, or (3) separated from other Auxiliary Building areas by substantial non-rated fire barriers. The separation

.provided within the annulus is adequate to meet the separation requirements of III.G.2 for noninerted containments. However, the Containment Annulus area has been analyzed with areas inside the Auxiliary Building. Vith this combination of areas, the more stringent non-containment Appendix R Section III.G.2 rules =

are being applied, and an exemption is being requested.

DISCUSSION The annulus is an approximately 4.5 foot vide space between the Shield Building and the Containment Vessel which extends completely around and above the Containment Vessel and has no internal valls. The vall between the annulus and

the Auxiliary Building is approximately 2.5. feet of concrete in thickness which is' equivalent to a three hour rated fire barrier. The Containment Vessel forms the other annulus vall and is an ASME Class III Vessel with a minimum 1-1/2 inch steel thickness on the' sides and a minimum 13/16 inch steel thickness on the dome. Cables and piping pass through the annulus on their way from the Auxiliary Building ~to equipment inside the Containment Vessel. Also, an equipment hatch, a personnel lock, an emergency lock, and two fuel transfer tubes pass through the annulus on their way from the Auxiliary Building to inside the Containment Vessel. There are four Emergency Ventilation System (EVS) flow path openings in Fire Areas A and AB to the annulus from the Auxiliary Building and their locations are depicted on the attached Figures 1 through 3.

The annulus has been divided into two fire areas (east and vest halves). Each half is combined with separate rooms in the Auxiliary Building. These combinations result in Fire Areas A and AB as described in the Fire Area Optimization Report (FA0R) Revision 1. FAOR Fire Area A consists of previous l-Compliance Assessment Report (CARP) Fire Areas A, C, DB, DJ, and DA (east half) and FA0R Fire Area AB consists of previous CARP Fire Areas AB, DC, DE, HA, Stairvell AB3 and DA (west half). In addition, the annulus is adjacent to separate Auxiliary Building Fire Areas G, V, P, K, CC, DF, X, EE, DG and DH, and the Containment, Fire Area D. Unless otherwise specified Fire Area designators are as described in the FAOR, Rev 1.

Containment (Fire Area D) is separated from the annulus by a continuous steel vessel as described above. The Containment Vessel, including the penetrating equipment listed above, is constructed of steel conforming to the requirements set forth by the ASME Boiler and Pressure Vessel Code.

_ _ _ _ - _ . . . . . _ . _ _ = _ ~ _ . . . . . .

+ ' Docket Num'ber 50-346

- ,.Licenie Number NPF-3 Serial Number 1809 Attachment

.Page 2 Table 1 lists the non-fire rated penetrations into the annulus from the-Auxiliary Building parts of Fire Areas A-and AB. In addition, Table 1 also lists the fire areas, rooms, penetration types,-the fire loading, and availability of automatic sprinkler system and/or fire detection capability.

Table 2 lists the other various fire areas which are adjacent to the annulus and are separated from the annulus by a three hour equivalent fire barrier'with non-fire rated penetrations. Table 2 also lists the fire areas, rooms, penetration types, fire loading, and availability of automatic sprinkler system and/or fire detection capability.

Table 3 lists the remaining fire areas which are adjacent to the annulus and separated from the annulus by a three hour equivalent fire barrier with no penetrations. Table.3 also lists the fire areas, rooms, fire loading, and availability of automatic sprinkler system and/or fire detection capability.

Fire' Area A (including the east half of the annulus) and Fire Area AB (including the vest half of the annulus) within the annulus are not separated from each other by a three-hour rated barrier and are not separated from certain other areas in the Auxiliary Building by a three-hour rated barrier. However, a fire vill not propagate from one area to the other because of the following:

1. The fire loading in the annulus is very lov (approximately 14,500 BTU /ft2).

Approximately 94 percent of the combustible loading in the annulus-is due to cable insulation. The cable insulation satisfies the criteria of IEEE. 383-1974 or its equivalent and vill not sustain combustion unless an external heat source is present. The ignitibility of cables at Davis-Besse was discussed in Toledo Edison letter dated February 8, 1988 (Serial Number

'1471). Additionally, the cables are protected by overcurrent devices. The remaining 6 percent of the combustible loading is small amounts of grease enclosed in the gear boxes of motor operators and incidental combustibles such as flexible pipe boot seal material. Due to the high radiation level in the annulus during plant operation, access to the annulus is restricted.

This-ensures transient combustibles are not introduced into the annulus.

-2. The fire loading in the Containment is very lov (approximately 16,000 BTU /ft2). Most of the combustible loading inside the Containment Vessel is located inside the internal shield vall which is a reinforced concrete vall approximately eighteen inches thick. This shield vall provides an additional fire barrier between the combustibles in the Containment Vessel and the annulus.

3. The mechanical penetrations as described in Tables 1 and 2 in Fire Area A are over 40 feet horizontally from the closest mechanical penetration in Fire Area AB. There are no exposed combustible materials or ignition sources in-the intervening 40 feet between mechanical penetrations. The mechanical penetrations are sealed by the use of a pipe boot seal material.

This pipe boot seal material represents a combustible loading of less than 300 BTU /ft2 There are no electrical penetrations between the nearest two mechanical penetrations.

t Docket Nuxb;r 50-3461 E.- ~.Licin's2 Nunb;r NPF-3' ISerial Number 1809

' Attachment Page 3

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4. The electricalfpenetrations as described in Tables 1 and 2 in-Fire Area A are'over'100. feet horizontally from the closest electrical penetration in  :

Fire Area AB. The electrical penetrations are further apart than the mechanical penetrations and there are no electrical penetrations between the mechanical penetrations. Therefore the mechanical: penetrations, which are -

separated by over 40 feet with no intervening exposed combustible material or ignition sources, constitute the most limiting separation condition. An.

exception exists for the circuits providing redundant safe shutdown functions in Fire Area A (east half of the annulus) for RC200 (Pressurizer Sample Containment Vent Header Valve), RC239A (Pressurizer Vapor Sample Valve), RC2A (Pressurizer PORV), RC4610A and B (Steam Generator 2 High Point Vent. Valve), Cl-1 (Containment Air Cooler Fan 1) and C1-2 (Containment Air Cooler Fan 2) which are protected with a radiant energy shield. The use of ,

the radiant energy shield-in the annulus is discussed in Toledo Edison Letter dated May 27, 1987 (Serial No. 1361).

5. There are two EVS flow path openings on each of the 565 foot and 585 foot ,

elevations, described in Table 1 as open doorways. Rooms 303 and 314 at the 585 foot elevation contain burated polyethylene blocks vhich are used as ,

neutron shielding to block the opening to the annulus during power operation. The closest opening in Fire Area A at the 585 foot elevation is over 85 feet from the opening in Fire Area AB.

The blocks' represent a combustible loading of 4,300 BTU /ft2 in Room 303 and 2,900 BTU /fta in Room 314. Since the openings are further apart than the mechanical penetrations, the mechanical penetrations, which are separated by over 40 feet with no-intervening exposed combustible material or ignition sources, represent the most. limiting condition. The opening in Fire Area A at the 565 foot elevation is over 170 feet from the opening in Fire Area AB and they are not-located between the openings at the-585 foot elevation. See attached figures.

6. Electrical cable penetrations in the' fire areas described in Table 2 are-made through leaktight cable seals. Flexibility of the cables is provided-across the annulus so that no damage can occur to the cables or structures-due to differential movement'between the two structures. Redundant controls, instrumentation, and power circuits are physically separated so that no redundant circuits terminate at the same penetration in the Containment Vessel.

-7. The equipment hatch as described in Table 2 is a welded steel assembly with a double gasketed, flanged and bolted cover, made to allow pressurization of the space between the double gaskets to 40 psig. The personnel lock and emergency lock are velded assemblies with provisions made to pressurize the space between the gaskets.

8. Two fuel transfer penetrations as described in Table 2 are provided to transport fuel assemblies between the refueling canal and the spent fuel pool during the refueling operations. Each penetration consists of 30 inch diameter stainless steel pipe installed inside a 42 inch sleeve and encased in concrete within the annulus. The inner pipe acts as the transfer tube.

Provisions are made to provide an allowance for dif ferential movement between structures.

' Dock 3t Nu ber~50-346 4- ,Lic:ns9 Nu;bir NPF-3 .

Serial-Number 1809

. Attachment Page 4

9. .Both the Containment Purge and the Containment Exhaust lines as described in Table 2 penetrate the Containment Vessel-with a 48 inch diameter steel pipe that is veldedL to a flued end.- The flued end is velded to the vessel and-has a flexible connection (a low pressure seal) at the annulus concrete vall to allow differential movement between the Containment Vessel and the annulus vall.

10. The penetrations in the Containment Vessel are of steel construction, tightly sealed, and provide substantial fire resistance.

11. Redundant trains of pressurizer level indication are located within Fire Area A. One train (circuit for LRS-RC14) is located in the annulus and penetrates back into Fire Area DF, while the other train (circuits for LI-RC-14-1 and-3) is located in conduits along the east and south wall of Room 314 and in the' Room 314 cable chase. The annulus vall represents a substantial non-rated fire barrier. The pressurizer level indication circuits within Room 314 are located approximately 14 feet from the annulus vall at the closest location. Room 314 has full area detection and suppression with a low combustible loading (47,600 BTU /ft2). The intervening combustibles located in Room 314 are limited to piping insulation and metal-bottom cable trays with Kaovool covering. A ventilation opening (discussed above) to the annulus is over 20 feet-horizontally from the closest electrical cables in the Annulus with no ,

intervening combustibles. The redundant pressurizer level indicator circuit c

.for LRS-RC14 located in the annulus is an additional 15 feet away from the closest circuit to the Room 314 doorway, and is located one elevation above.

The combustibles associates with the electrical penetrations in this 15 foot distance represent a minimal intervening combustible. Therefore, significant separation exists between the redundant pressurizer level indication circuits located in Room 314 and the annulus.

EVALUATION Toledo Edison has evaluated the existing fire protection features for the annulus (i.e., Fire Areas A and AB) and has determined that adequate measures exist that provide a level of protection equivalent to Section III.G of 10CFR50, Appendix R. These measures are:

1. The only significant combustible in the annulus is flame retardant cable insulation amounting to a combustible loading of approximately 13,700 BTU /ft2 out of a total 14,500 BTU /ft 2 The remaining 800 BTU /ft 2 is comprised of incidental combustibles such as flexible pipe boot material and grease enclosed in the gear boxes of motor operators.

2. The cable insulation in the annulus satisfies the criteria of IEEE 383-1974 or equivalent and would not sustain combustion unless an external heat source is present. Additionally, the cables are protected by overcurrent devices.

3. The grease in the gear box of the motor operators is completely enclosed and is not considered to be a hazard.

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Docket'Numbar'50-346

.Licenia Number NPF-3

' Serial Number 1809

. Attachment Page 5

4. Due to the restricted access to the annulus during power operation, the accumulation of transient combustibles is not postulated during power operation. During other plant conditions, administrative controls require a-transient combustible permit for all transient combustible material' introduced into the annulus.

5. If a fire-were to occur in one of the four mechanical penetration rooms (ii.

Fire Area A or AB) each_of which contains an opening and non-rated penetrations to the annulus, it'is not expected to propagate into the annulus because each room has a low combustible loading and is protected by an area vide automatic sprinkler system. However, if a fire vere to propagate through the opening or the non-rated penetrations, it would not propagate from the vest half of the annulus to the east half of the annulus.

The closest mechanical penetrations are over 40 feet apart with no exposed combustible materials or ignition sources in the intervening 40 feet. The nearest opening in the vest half is separated by over-85 feet from_the.

opening in the east half. Since the openings are further apart than the mechanical penetrations, the mechanical penetrations, which are separated by over 40 feet with no intervening exposed combustible material or ignition sources, constitute the most limiting separation condition. Some heat and smoke could be dissipated upward through the open doorway into the annulus, but it vould not have a significant effect laterally.

6. The mechanical penetrations as described in Table 2 are predominantly non-combustible construction, are sealed, and provide substantial fire resistance. Several mechanical penetrations through the annulus vall do not have fire rated seals because of the need to accommodate relative building movement. However, the penetrations do not represent continuous paths of combustible material through the concrete vall and would not: result in a-

' fire propagation through the subject mechanical penetration. If a fire were to propagate through the non-rated penetrations, it would not propagate from the west half of the annulus to the east half of the annulus. The closest mechanical penetrations are over 40 feet apart with no exposed combustible materials or ignition sources in the intervening 40 feet.

7. If a fire were to occur at an electrical penetration or in the cable in the annulus, it vould not propagate from the vest half of the annulus (Fire Area AB) to the east half of the annulus (Fire Area A) or vice versa. The closest electrical penetrations or circuits in the vest half are over 100 feet from the closest electrical penetration or circuit in the east half.

Since the electrical penetrations are further apart than the mechanical penetrations and there are no electrical-penetrations between the mechanical penetrations, the mechanical penetrations constitute the most limiting separation condition. Vithin the east half of the annulus, redundant safe shutdown circuits or electrical penetrations are separated from each other by radiant energy shields which are adequate, given the very low fire loading and the restricted accessibility of the annulus.

8. The electrical cables as described in Table 2 and blockouts for the electrical cable penetrations are sealed.

- Dock 2t Numb;r 50-346

/( .Licensa Numbsr NPF-3'

' Serial Number 1809 Attachment Page 6

9. Localized fire detection as described in the Fire Hazards Analysis Report (FHAR)Ris provided within the annulus. Manual suppression capability in the form of portable fire extinguishers and hose stations are available in the fire areas with the open doorways to the annulus.

10. The fire areas listed in Table 3 contain no penetrations into the annulus and are separated by the 2.5 foot thick concrete vall which provides the equivalent of a three hour barrier.

11. The. containment Vessel vall is not a fire rated barrier, but'it provides adequate fire resistance for the fire hazards involved.

12. If a fire vere to occur in Room 314 or in the annulus, it would not affect the redundant trains of the pressurizer level indication since there is significant separation. Although there are soma limited intervening combustibles between the redundant trains, separation is provided by:

suppression within' Room 314

- a substantial non-fire rated barrier (the annulus vall), and

- a total horizontal distance between the ventilation opening in the annulus vall and the redundant pressurizer level indication circuit in the annulus of over 35 feet. Of this 35 feet, 20 feet is free of intervening combustibles and the remaining 15 feet has minimal intervering combustibles associated only with containment penetrations.

Consequently, Toledo Edison has determined that the existing fire protection features provided for the Davis-Besse annulus (i.e., Fire Areas A and AB) would ensure that at least one train of systems necessary to achieve and maintain hot standby is-free of fire damage and, thereby, provide an equivalent level of fire protection as required by Section III.G of Appendix R. Additionally, the imposition of additional modifications only to satisfy the non-containment methods specified by Appendix R of 10CFR50 would not significantly enhance the level of fire protection currently provided for the annulus.

APPLICABLE SPECIAL CIRCUMSTANCES JToledo Edison has determined that the requested exemption conforms to the applicable exemption criteria of 10CFR50.12(a). There are no prohibitions of law to preclude the activities that vould be authorized by the requested exemption, and the requested exemption, if granted, would have no impact on the common defense and security. Additionally, the requested exemption does not present an undue risk to the public health and safety since an equivalent level of fire protection as that required by Section III.G of Appendix R is provided as described above.

Special circumstances are applicable to the requested exemption in accordance with 10CFR50.12(a)(2)(ii) in that application of the regulation for these particular circumstances is not necessary to achieve the underlying purpose of the rule.Section III.G of 10CFR50, Appendix R specifies methods to ensure one

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age.: The. underlying purpose of the-rule.is satisfied by the requested 4' Axemption'since'the existing. fire protection features described above provide an

. equivalent level.of fire protection as required by Section III.G of Appendix R, 9;~ and the completion of modifications only to satisfy the methods specified by Appendix R is not necessary.

Additional special circumstances are applicable to the requested exemption in~

accordance with-10CFR50.12(a)(2)(iii) in that the application of the regulation

.vould represent an unwarranted burden on Toledo Edison resources. Any modifi-O cation of the current annulus fire protection features;vould result.in.

U l considerable expenditure of engineering, construction, and plant staff resources

> - for its installation, mainterance and surveillanc'e. The associated cost vould include:

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' Engineering the-design and installation of the fire protection features such as erecting fire rated barriers between the two fire areas or installing a fire' suppression system in the annulus.

Implementation of increased surveillance and maintenance requirements for l M the fire protection features.

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Impracticality of-design and installation associated with a three-hour fire rated enclosure around the circuits in the annulus because the cables need to expand or: contract.

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t Impracticality of design and installation associated with a three hour 9 fire barrier over the ventilation openings to the annulus because it conflicts with Emergency Ventilation System design requirements to function following a Loss-of-Coolant Accident, i Impracticality of the design and installation associated with the addition of-a sprinkler system to the annulus because of the height and configuration of the annulus being open around the top of the a ntainment Vessel.

The costs associated with modifications to the annulus fire protection-features vould represent an unwarranted burden on Toledo Edison resources, considering i the resulting negligible increase in safety benefit and the alternative means of j fire. protection described above.

In conclusion, Toledo Edison considers that special circumstances in accordance with 10CFR50.12(a)(2)(ii) and 50.12(a)(2)(iii) justify the requested exemption, j The completion of additional modifications simply to satisfy the methods i specified by Appendix R of 10CFR50 is not necessary to satisfy the underlying  !

purpose of the rule since the existing fire protection features provided for the i Davis-Besse annulus would ensure one train of systems necessary to achieve and }l maintain hot standby is free of fire damage and, thereby, provide an equivalent j level of fire protection as required by Section III.G of Appendix R. j Considering the resulting negligible safety benefit, the completion cf  ;

additional modifications only to satisfy the methods specified by Appendix R of l 10CFR50 represents an unwarranted burden on Toledo Edison resources.

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FIRE PENETRATION PENETRATION ELOOR (BTU /SO. FT.) SUPPRESSION DETECTION

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LOCATION TYPE ELEVATION. AUX BLDG / ANNULUS AUX BLDG / ANNULUS AUX BLDG / ANNULUS AREA No. 1 Hechanical a. Mechanical '565 5,800/14,500 Tes/No Yes/Yes AB Penetration Room (208) b. Open doorway into Annulus (127)

A No. 2 Hechanical a. Mechanical 565 15,900/14,500 Tes/No .Tes/Yes Penetration Room Q36) b. Open doorway into Annulus (127)

No. 3 Hechanical a. Mechanical 585 11,000/14,500 Tes/No Yes/Yes AB Penetration Room (303) b. Open doorway-into Annulus (127) c. Electrical No. 4 Hechanical a. 'Hechanical 585 47,600/14,500 Tes/No Yes/Yes A

Penetration Room (314) b. Open doorway into Annulus c. Electrical

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ELEVATION (BTU /SO. FT.) 8 4. b.

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Mechanical 603 63,100 Tes Yes -

DG 402 No. 1 Electrical a.

Penetration Room b. Electrical Nechanical 603 61,200 Tes Yes DF 427 No. 2 Electrical a.

Fenetration Room b. Electrical

c. Containment Purge Exhaust Containment- 643 .600 No Tes DH 600 Furge Inlet Room Ferge Supply Main Steam 643 2,800 No Yes DH 601 Main Steam Line Room Line Main Steam 643 3,600 No Yes DH 602 Main Steam Line Room Line Fuel Transfer 365 3,400 No No V 222 Fuel Transfer Tube Room Tubes:

Equipment 603 67,200 No Yes V 400 Corridor Hatch Personnel 603 5,500 No No CC 426 Fersonnel Lock Area . Lock Mechanical 603 400 No No CC 422B . Ladder Space 585 400 No No None 317A Emergency Emergency-Lock Enclosure Lock

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ELEVATION (BTU /50. FT.) SUPPRESSION DETECTION $ Q d, AREA A l LOCATION PENETRATION L&

AB 225 Makeup Pump Mechanical 565 18,600 No Tes Purge Exhaust Room Containment Purge 623 54,300 No Tes l EE 515 Exhaust Mechanical 585 7 7,5t'X) Yes Yes lK 318 Diesel Generator Room 221 Top /Transtube Electrical 565 8,500 No Tes G

Shield Room

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G 209 . Corridor 565- 27,700 Tes Yes V 304 Corridor -585' 72,300 Tes Yes V 404 Corridor 623 52,500 No Yes V 405 Storage- 603 26,100 Tes Yes V 406 Hot Instrument Shop 603 36,000 No Tes P 321 Charge Roos 585 3,300 No Yes P 322 Passage 585 51,'700 No 'Tes X 428 low Voltage Switchgear Roos 603 52,700 No Yes X 4288 No. 1 Electric Isolation Room 603- 4,400 No No EE 500 Radvaste/ Fuel Handling Area : 623. 2,000 No Yes EE 501 Radvaste Exhaust Fan Room 623 6,400 Tes Yes m-A

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Docket Numbar 50-346  !

License Numbar NPF-3

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