ML20052D656

Forwards Request for Addl Info in Support of NRC Review of Licensee Mods Required Under Section III.G.3 of App R to 10CFR50 Re Alternative Safe Shutdown.Info Re Criteria for Evaluating Exemption Requests Encl

ML20052D656
Person / Time
Site:	North Anna
Issue date:	04/21/1982
From:	Clark R Office of Nuclear Reactor Regulation
To:	Leasburg R VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
References
GL-81-12, NUDOCS 8205070052
Download: ML20052D656 (22)

Text

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3, vecket 8tus. 5 33tt and W3M Mr. R. M. Leesburg Vice President - Nucleer Operations j

Virginia (1ectric and Power Co wany Post Office Goa Pr666 i

Richusne, Virginfa 23?A1 bear Mr. Leesburg:

SUBJECit FIRE PROTECT!0m RULL - 10 CFR 50.4R(c)( - 4 Tiro.ATI.i '/!

l 544JTDOWN - SECTI0H III.t'.3 Of APPEN;>l) ' TO 10 Cl

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WORTH Ak';A POWCR STATION, UNITS NO.1 Att h2 2 ( '. " - l '.?

The fin Protection Rule (10 CF& $0.48 and Appen11, r: to 10 rr

',o' in 4 effective on February 17,19r.l. Paragraph 50.43(c)(5) require suimi t ' S '

design descriptions of modifications needed to satisfy Section III.t. 3 y Appendia R to 10 CFR 50 by March 19, 1981.

.ty letter dated May 19,1961, you sutsuitted the oesirin cescr1: ior of modificattens required to meet Section 111.0,3 of Appendix : to 10 CI- %

U for N4-47 We have reviewed your submittal and find that additional intci-metten is reedbette complete our review. The information required was

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erginally requested from you by letter dated February 20, 1981 and w s

,j presented to in draft form at a meeting in Bethesda, Maryland on f*arer I, 1962 and is a se provided in Enclosere No. I to this letter. Provide a complete response of items indicated in the enclosure within 60 days of t

l receipt of this letter. If your response is not complete at that time, i

see will be fenup in violetten of 10 CFR 50.48(c)(5).

Such violatlot.

will be a continuing one and a civil penalty may be impose.: for each a,

tha violetlen'continves. provides a rewording of the request for infomation inclu with Generic Letter 81-12. This rewording is the result of roectinss with r, wc-sentative licensees who felt that clarification of the request would help eapedits responses.

It does not include any new requests and, therefort, n'1 not adversely affect licensees' ability to respond to Generic Letter al-17. provides inforination regarding our criteria for evaluatin exemption regyests frar the requirements 'of Section !!!.r.2 of 4,v n :

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Sincerely.

Or(ina's gned by

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fobe A. Clark, G i. i Dn ADOCM 05000330 Operu inq :eactors. ranch '3

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Enclosures:

1.

Aeguest for Addittonal Infomation t.

Safe Shutdown tapability 2

-3.

Criteria for Evaluating

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e Virgiata Electric and Power Company ec:

Richard M. Foster, Esquire Mr. James Torson

% sick, williseson, $ctmeertz, 501 Leroy Leavenworth 4 Cape, P.C.

Socorro, New Meatcc 0 891 P. 6. Sea 4579 toelder, Colorade 80h06 Mrs. Marga et Dietrich Route 2, Bos 568 Nichael W. 'Aoupin, Esquire Gordonsv111e, Virginia 2204?

Nunton, Williams, E4y and Gibson P. t..tes 1535 Mr. James C. Dunstance tictmond, Virginia 23212 State Corpora:. on Comnission

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Commormeealth of Ytrginia

- ? Aldevaan Library Blandon P;ilding Ilmassertets Department Richmond, Virginia 23209 Soiversity of Virginia Charlottesville, Virginia 22901 Mrs. June Allen 1.

North Anna Enviromenta! Cosi' tion L

'.Br. tesord tube 8720 Lockmoor Circle

% seed of Sepervisors Wichita, Kansas 67207 i

Louisa County Courthouse P. O. Sea 27 U.S. Environmental Protection Agency

tesisa Virginia 23093 Region III Office L

ATTN:

Regional Radiation Representative I

Ellyn R. Weiss, Esquire Curtis Building r

_ Didon, Herman, Rotsman and Weiss 6th and Walnut Streets l

i, 1729 I Street, N.W. Suite 506 Philadelphia, Pennsylvania 19106 r

p shington, D. C.

20006 b

Mr. Paul W. Purdom t

4tr. W. R. Cartwript Station Manager Environmental Studies Institute P. O. Sea 402 Drexel University

.fMneral, Virginia 23117 32nd and Chestnut Streets Philadelphia, Pennsylvania 19104 6 -

. Anthosty Ge4ardella 8

fice of the Attornett General

• Atomic Safety and Licensing 11 South 12th Street - Room 306 Appeal Board Panel

'tichmond, Virginia 23219 U.S. Nuclear Regulatory Commission Washington, D. C.

20555

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Besident Inspector / North Anna Regional Administrator c/o U 5.4.t.C.

Nuclear Regulatory Comission, Region !!

g Route 1, tes 78A Office of Executive Director for Operations Nineral, Virginia 23117 101 Marietta Street, Suite 3100

. Atlanta, Georgia 30303 Itr. J. N. Ferguson

~ Esecutive Vice President - Power Virginia Electric and Power Company Post Office toi 16666 Richmond, Virginia !?"'1 i

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POST F IRE SM E 5"!!iD%'* PE VIf a Pequest for Additional Inforra*2ce Based on a review of May 19, 1981 st,bmittal, and tSe SIR for %rth tr.re, tre fellowing questions (f ollowing outline of f;PC letter of Ter ruary ?6, l u l ',

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rein unanswered.

f> ' 1.

Give a description of the systens or portions tr.ereof csod t o r r o. ide

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post fire safe shutdown capability based on a sirgle pr.tulated fir e

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any area of the plant.

(Only infornation on ct.argiro p.,nas t es r ecr.

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given).

Are the pressurizer heaters required for hot shutdoan?

If

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they controlled outside of the control room?

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Wat ' systems or equipnent is used for decay heat rereval for both h0! c'id

f. i 3. ' cold shutdown? Where are the controls for these syste s out of the con-trol room? How are they isolated from the control roo.?

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4 What support systens are required (cooling *:ater, AC and DC power

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sources, lubrication etc.) for post fire safe shutdown?

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5.

Drawings submitted thdicate that a.new instrunentatitin ranel cuts:de of control room will display pressurizer pressure and level, and prii.ary

' loop teceerature. Other instrunentation that might be required (cr saf e 7

shutdown includes steam oenerator pressure and tercerature, steam 9enerator level, pump flows (auxiliary feed punos, etc.).

TFese should r

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, be available outside of the control roon although they need not all t.e in one location.

In addition, for PWRs we will require a source rir.ae flu r i

monitor, and both hot and cold leg prirary tenperatures.

Give a conplete i.

list of all instrunentation available outside of the control room.

6.

HOW do you plan to demonstrate that procedures developed for post fire 4

Safe shutdown (including procedure AP 48) are adequate for the purpose intended?

s 7.

Are the available spare fuses located conveniently to tt.e equipment in which they are r'equired?

s.

i 8.

BNL will require drawings which show nornal and alternate shutdcwn cor.-

7 trol' and power circuits, location of components, and that wiring which 1.

In the area and the wiring which is out of the area that required Lt.e i

alternate system.

9.

Denonstrate that, changes to safety systems will not decrade safetv s y '.

,tems. (e.g., new isolation switches And control switches should eeet ce sign criteria and standards in FSAR for electrical equipnent in the sy'.-

tee that the switch is to be installed; cabinets that the switches are tr; he mounted in should also meet the same criteria (FSAR) as other safety 1

4 6

rotated cabinets and panel *,; to avoid iradvert.+ t i nlo - ',

trol room, the isolation switches shnuld be k ey tock ed. er ok control room if in the

• local" or " isolated' :.csit t en; r> c r u -

• .t ould be made to verify switch is in the prc;er onsition fcr h

'e eperation; and a single transfer switch or ot er re

&vice.

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a hource for a single failure to cause inss of recurrant sa r, *, s.

teos).

10. Denonstrate that wiring, includino power' sources for the cc,nt r oi

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and equipment operation for the alternate shut do-n ret Fod, is ir '.., - w

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of equipnent wiring in the area to be avoided.

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11. fienonstrate that alternate shutdcwn power sources, ircludine all r.rr a. -

ers, have isolation devices on control circuitr, that are rnuted thre.c5 the area to be avoided, even if the breaker is to be r,merat(d rerbally.

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II. Provide a tab'le that lists all equipnent includico instrunentat m end Y

support, systee equipment that are required by the alternative or deft-

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cated nethod of achieving and maintain 8ng hot shutdown.

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13. For each alternative shutdown equipnent listed in !? above, provide a table that lists the essential cables (instrunentation, control and -

N power) that are locate'd in the fire area.

14

. Provide a table tht; list's safety related and ncn-safety related cables associated with the equiprent and cables constitutino the altgrnative or s e N

dedicated method of shutdown that are located in the fire area.

, if D-15.

Show that fire-induced failure, of the cables listed in 13 and 14 4tove will not pcevent operation or cause naloperation of the alternative or y

dedicated 5,hutdown rethod.

For eac' cable listed in 12 above. provide detailed electrical sche..atic

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h drawings that show how each cable is isolated f rom the fire area,.

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17. Can this plant sustain a fire in ttie shutdown looic panel?

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18.

If a fire occurs in the shutdown ' logic panel, how will the plant be shut-

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6 19.

Elch electrical support systens will be used for post fire alternatise shutdown?

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Could a fire at the new reactor coolant shutdown panel endanger safe d

shutdown by giving incorrect instrunent readings at both the new pa W 5

and at the control room? What kind of isolation is provided for j

Instruments? for c'ontrol?

21. lies the change shown on 11715-ESK SAM, SAN, SAP, and 12050-ESK $P, 'A.

I 5AP only added interlock and indicate lights for new reactor cociant e

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itering panel?

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What is the function of reley ' # J - X ' ' '

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$4ne w 6 th r.ther rot e 4 re14 v(.

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Will yDu send ($K })4F. IIAS. Il Al seri8> of I

• s**ot in,ftK-5Ah and elsomhere?

24 Print 13015-T E-309-3.

Are the !?O voit AC f.<

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.erergency diesel generators?

kTia t control for-

'on, i' ar from this panel? Wi } } you f or.-o r d pr i nt !? ten have notes for this print.

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Print IP050 FE-BAI-7.

What chancos mere i, 9a u-given; I and DCR referred to.

26.

Print I?O50 FE-??A-II.

T5ree ausiliary relay :e

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this tie into changes in new ptKP?

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e SAFE ShUTDCA CAPAh! LIT V The following discusses tN requiremer.ts for prs tecimg r r v.

alternative epipment needed for safe shstdown in it e e. e i t o f.*

requirements of Appendix R address bot shutdcwn contp +n:

I c r... : t, free of f$re damage.

The follt, wing requirements al :n app'ay to co o

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epipment M the Itcensee elects to daEonstrate that t':e equt:ren. <- :c v free of fire damage.

Appendim R oces allow repa trable dar: age t-c d c s N eenfament, Us'ing the requirements of Sections Il!.G and III.L of Appendia P.

ttc c; 4 bility to achieve hot shutdown hust exist given a fire in any arra c/ the plant in conjunction with a loss of offsite power for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

Se: t : n I.

of Appendia R provides four methods for ensuring that the hot shute -

ce.

bility is protected from fires.

The first three options as denned in ser' u -

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III.G.2 provides methods for protection from fires of equipment reedec 'or het shutdown:

1.

Redundant systems including cables, equipment, and associated cir c at * -

any be deparated by a three-hour fire iated barrier; or, 2.

Redundant systems including cables, equipment and associated circuits o e -

be separated by a horizontal distance of more than 20 feet with no inte -

vening combustibles.

In addition, fire detection and an autematic fin-suppression system are required; or.

3.

Redundant systems including cables, equipment and associated c ircuit s n.

by enclosed by a one-hour fire rated ba,rrier.

In addition, fire det.t:

and an automatic fire suppression system are required.

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The last option 4s defined by Section I!!.G.3 provides er. alterr.. is, j

capability to the redundant trains damaged by a fire.

4.

Alternative shutdown equipment must be independent of the cebles o,.

I uset and associated circuits of the redundant systcas damaged by t.

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Associated Circuits of Concern The SB110wir.g discussion provides A) a definition of associated circuit. for Appensix R consideration, B) the guidelines for protecting the safe' shutdown capability from the fire-induced failures of associated circuits and C) the in-formatten required by the staff to review associated circuits.

The definition ef assectated circuits has not changed from the February 20, 1981 generic letter.

but js merely clarified.

It is important to note that our interest is only with those circuit (cables) whose fire-induced failure could effect shutdaer..

The guidelines for protect'ing the safe shutdown capability.from the fire-indurec failures of associated circuits are not requirements.

These guidelines should be used only as guidance when needed.

The,se' guidelines do not limit the alte:

nettves available to the licensee for protecting the shutdown capability.

All proposed methods for protection of the shutdown capability from fire-indm ec failures will be evaluated by the staff for acceptability.

A.

Our concern is that circuits within the fire area.will receive fire damage

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which can affect shutdown capability and thereby prevent post-fire safe shutdown. Associated Circuits

• of Co.icern are defined as those cables (safety related, non-safety related, Class 1E, and non-Class 1E) that:

• The definition for associated circuits is not exactly the same 1

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'as the definition presented in IEEE-384-1977.

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1.

Wave a physical separation less tnan that requ' red by Section !!).Ge of Appendia R. and; y

2. Mave one of the fellowing:

p t gegnen,peuer source with the shutdown equipment (redundant or 4.

k altarmative) and the power source is not electrically protected h me circuit of concorp by coordinated breakers, fuses, or 4

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stuiler devices (see diagram as). or i

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'b' ' A'teenectice to circuits of equipment whose spurious operation usuld adversely affect the'shutdeus capability (e.g.. M /RCS L

'leeletten valves. AD$ val.es. PORVs. steam generator atmospheric L

p duop valves. testrumentation steam bypass, etc.) (see diagram 2b). or i

i c, e' commen enclosure (e.g., recomey, panel, jenction) with the shutdown

~ ebles (redundant and alternative) and.

c (1) are met electrically protected,hy circuit breakers, fuses or simi-b.'

leF devices, or

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i (2) will ellow propagatied of the fire into the commen enclosure. (see diagram 2c).

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l The area barriers shown above meet i

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f. f,3,,e ef u a.o the appropriate sub-paragraphs (a f)

Or*' & cw e c&ed of section !!!.G-2 of Appendix R.

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Diagram 2B Diagrim ?C Diagram 2A 9

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The following guidelines are for protecting the shutdown capability fror a

fire-induced failures of circuits (cables) in the fire area.

The guidance provided holes for interrupting devices applies only to new devices insta1W seprovideelectricalisolationofassociatedcircuitsofconcern,oras 4

part of the alternative or dedicated shutdown system.

The shutdown capabt12 t3 ff any he protected from the adverse effect of damage' to associated circuits j.

et eencern by the following methods:

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1. Freelde protectica between the associated circuits of concern and io

,I the shutdeus circuits as per Section III.G.2 of Appendix R, or i

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Per a casanen power source case of associated circuit:

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Provide lead fuse / breaker (interrupting devices) to feeder P

l fese/ breaker coordMtion to prevent loss of the redundant or

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alternative shut power source. To ensure that the following coordisation criteria are met the 'fofjowing snould apply:

E (1) The associated circuit of* concern interrupting devices y

,f, (breakersorfuses)timeovercurrenttripcharacteristic i

for all circuits faults should cause the interrupting

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device,te interrupt the fault current prior to initiation 6

of a trip of an upstream interrupting device which will easse a loss of. the comme'n power source.

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U D) ihe power source shall supply t'he necessary fault current i

9er sufficient time to ensure the proper coordination without loss of function of'the shutdown loads.

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5-The acceptability of a particular interrupting device is consiceree esmaastrated if the following criteria are met:

(1) The interrupting device design shall be factory tested to J

' verify everturrent protection as designed in accordance with the applicable 48.. AftSI. or IIDM standards.

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(11) Per Sew and medium voltage switchgear (480 V and above) 9 f

tiftuit breaker /pretective relay periodic testing shall I

i essenstrate that the overall coordination scheme remains within the limits specified la the design criteria. This' r

testing av be performed as a series of overlapping tests.

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(111) IIsided case circuit breakers shall peridically be manually g

enercised and taspected to insure ease of operation. On s

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a. rotattag refueltog outage basis a sample of these breakers shall be tested to determine that breaker drift is within SM alleued by the dedita c.-iteria.

Breakersshould be l

Rested la accordance with an accepted QC testing methodology l

such as IIIL STD 10 h D.

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(iv) Fases d en used as interrupting devices do not require f edic test'ing, due to,their stability. lack of drift, i

and high reliability. Administrative controls must insure

.I that replacement fuses with ratings other than those a

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selected for. proper coordinating are not accidentally used.

l' b.

For circuits of equipment and/or components whose spurious operatio-would affect the capability to safely shutdown:

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. (1) provide a means in isolate the equirrent anc/r <

~p the fi re area pricr to the fi re (i.e., remove po-f r v : i.

circuit breakers); or

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(t) provide electrical isolation that prevents spurious operet;t r.

Potential isolation devices include breakers, fuses, aeri:-

fiers, control switches, current IFRS. fiber optic couplers, relays and transducers; or (3) provide a means to detect spurious operations and then proce-dures to defeat the maloperation of equipment (i.e., closure j

i of the block vilve if PORY spuriously operates, opening c f the breakers to remove spurious operation of safety injec tion';.

c.

For common enclosure cases of associated circuits:

(1) provide appropriate measures to prevent propagation of the fire; and (2) provide electrical protecticn (i.e., breakers, fuses or similardevices)

C.

We reicognite that there are different approaches which may be used to reach the'same ch M tive of determining the interaction of associated

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circuits with shutdown systems. One approach is to start with the fire area, idgettify what is in the fire area, and'deterrine the interaction l

O between uhat is in the fire area and the shutdown systems which are k

outside the fire area. We have entitled this approach, "The Fire Aree A second approach which we have named "The Systees Approact?

f would be to define the shutdown systems around a fire area and ther c, te-6 i

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these circuits that are located in the fire area that are anaia r -

with the shutdown system. We have prepared two sets of requests f cr teWormattee, ese for each approach.

The licensee may choose te resw d

to either set of requests depending on the approach selec ted by the i t.r - s e.

FIE AEA APPAQ4CH 1.

Per each fire area dwre an alternative or dedicated shutdcwn ethM.

j in accordance with Section III.G.3 of Appendix R is provided, the following taforuntion is required to deaonstrate that associated circuits will not prevent operatica or cause maloperation of the alternative or dedicated shutdown method:

a.

Provide a table that lists all the power cables in the fire area i

that connect to the same power supply of the alternative or dedicated shutdown method and the function of each power cable listed (i.e., power for WA plag).

b. ' Provide a table that lists all the cables in the fire area that were considered for possible spurious operation which would adversel.,

affect shutdown and the function of each cable listed.

c.

Provide a table that lists all the cables in the fire area that share a common enclosure with circuits of the alternative or dedicated shutdown systems and the function of each cable lista d.

bbw that fire-induced failures (hot shorts, open circuits or shorts to ground) of each of the cables listed in a; b. and c.

not prevent operation or cause caloperation of the' a'ir r :

r or dedicated shutdown method.

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1

. e.

For each cable listed in a, b and c where new electrical nolatm he heen provided or modification to existir.g electrical isolaticn us been ande, profide detailed electrical schenatic drawings the show how each cable is isolated from the fire area.

• 12 ~ phe each area dere se alternative or dedicated shutdown method, in p ',*,

escordance with Section III.E.3 of Appendix R is provided, the l.c-

' M1 swing taformation,is required to demonstrate that associated h.s sletaits an11 est pregeet aperation er cause maloperation of the e

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.etternative er dedicate ( shutdown method:

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.a.

Bescrthe the methodeley used to assess the potential of associated i;'

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cirtelt advertly affecting the alternative or dedicated shutdown.

The descripkles of the methodolog should include the t

methods

' used to identify the circuit. which share a commm power supply

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or a commen anciesure with thp alternative er dedicated shutdown

. system and t$e circuits idose spurious operation would affect shutdeun. Additteenlly, the description should include the l

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methods esed to identify if these circuits are associated circuits

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.ef concern due to their location in the fire area.

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E Provide a table that lists ali associated circuits of concern e,

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located in the ftre area.

b.*

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5 it. Show that fire-induced failurts-(hot shorts, open circuits or 4 *.,

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shorts to ground), ef each of the cables listed in b will not prevent operetten er cause maloperation of the alternatite or 3

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dedicated shutdown method.

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. i d.

For each cable listed in b where new electrical isolation ha t ce-provided, provide detailed electrical scheratic drawings that show how each cable is isolated from the fire area.

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e.

Provide a location at the site or other offices where til tne r

tables and drawings generated by this mt%$ ology approic) for the associated circuits review may be audited to verify the i

1 taformatten provided above.

>I M EMENtLINTEE%L h.

Per either approach chosen tk fo1'10 wing concern dealing with high-low c

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pressure laterface should be addressed.

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2. The residual heat, removal system is generally a low pressure system I(

that interfaces with the high pressure primary coolant system. To

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, preclude a LOCA,through this interface, we require compliance with f

the recommendations of Branch Technical Position R58 5-1.

Thus, the E,

laterface most ilkely commists of two redundant and independent motor eperated valves. These two motor operated valves and their associdted f

cables may be subject to a single fire hazard.

It is our concern that i

L this single fire could cause the two valves to open resulting in a fire initiated LOCA through the high-low pressure systee s

laterface. To assure that this interface and other high-low I

pressure interfaces are adequately protected from the effects of a single fire, we require the fo11erl.ng infomation:

):

e.

Identify each high-low pressure interface that uses redundant

3..

electrically controlled dev' ices' (such as two series motor operatec

,I f volves) to isolate or preclude rupture of any primary cool' ant Lt.

L,-

i.t D.Jo E r u.> 7, 10 b. Fo each set of redundant valves identified in a., ver:fy tre redundant cabling (power and control) have adequate peysice; separation as required by Section !!!.G.2 of Appendia R. i f' For each case dere adequate sagration is ec: revi je. s : t 'r, c. i fire induced failures (hot short, open circuits o-short to ground ],. of the cables will not cause us1 operation and result in a tota. f, F. r, l q l Q. l l l 1 e Y o ir f" e Y t 3 t >g ? 2 e }. i )!. (. CRITERIAF0PEVA(UAilNG EXEMPTIONS TO SECTION I!! G OF Ari r,,,. Or 10 CFR PADT SC faragraph 50.43 Fire Protection of 10 CFR Part 50 recoires to t s i ,muclear power plants licensed prior to January 1,1979 satisG i.

• requiremer.ts of,Section III.G of Appendix R to 10 CF R Part 50.

alt also requires that alternative fire protection configuratica.s, t yreviously approved by an SER be reexamined for compliance wi th the requirements of Section III.G. Section III.G is related to fire j ection features for ensuring that systems and associated circot ts to achieve and maintain safe shutdown are free of fire damage. jftre protection configurations must either meet the specific require ' sents of Section III.G or an alternative fire protection cor.figuratic r. g,(; oust be justified by a fire hazard analysis.

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'i%e general criteria for accepting an alternative fire protectior. c ; c'- ~ {: g,'ations are the following: C The alternative assures that one train of equipment necessary te i echieve hot shutdown from either t5e control roem or emergena w- ~ d stations is free of fire damage. p ? The alternative assures that fire damage to at least one trair. c-8 equipment necessary to achieve cold shutdown is limited such that 4, it can be repaired within a reasonable time (minor repairs with 1 compongnts stored on-site). 4h

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Fire retardant coatings are not used as fire barriers, fj. k Modifications required to meet Section III'.G would not enhance k fire protection safety above that provided by either existing or p proposed alternatives, ky. Modifications required to meet Section 111.G would be detrimental to overall facility safety. p \\ Because of the broad spectrum of potential confiourations for wni r ~ j, exemptiors may be requested, specific criteria that account for all o' 4' the parameters that are ignportant to firt! protection and consistent witr safety requirements of all plant-unique configurations have not tseen i developed. However, our evaluations' of deviations from these require-e sents is our previous reviews and in the requests for 111.G cxennm. received to date have identified scme recurring configurations for wne .'., specific criteria have been develcaed. r h 't I 4 m ~ ~w , Section 111.G.2 accepts three meth5ds of fire protec tion. A passise 3-hour fire barrier should be used where possible. Where a fixe 6 tarric cannet be installed, an automatic suppression systen in com.bination wi tt 4 fire barrier or a separation distance free of combustibles is used if the configurations of systems to be protected and in-situ co-bustibles e - such that there is reasonable assurance that the r otected system.s wil' survive. If this latter condition is not met, alternative shutdown cap-bility is required and a fixed suppressiort system installed in the ' ire bree of concern, if it contains a large concentration of cables. It is essential to remember that these alternative requirements are not deemed to be equivalent. However, they provide adequate protection for those configurations in which they are accepted. When the fire protection features of each fire area are evaluated, the whole system of such features must be kept in perspective. The defense-in-depth principle of fire protection programs is aitned at achieving er. adequate balance between the different features. Strengthening any cr.c can compensate in some measure for weaknesses, known or unknoen iri ethe rt The adequacy of fire protectioi. for any particular plant safety systec or area is determined by analysis of the effects of pos*.ulated fire relatir to maintaiding the ability to safely shutdown the plant and minimize ra: active relettes to the envirornent in the event of a fire. During the ' evaluations it is necessary to consider the two-edged nature of fire ' protection features recognized in General Design Criterton 3 na ely, f1o protection should be provided consistent with other safety consider 6 tie An evaluation must be made for each fire area for which an exemption ' is requested. During these evaluations, the staff considers &a folicer: parameters: A., Area Description walls, floor, and ceiling construction ceiling height room volume ventilation congestion B. Safe Shutdown Capability number of redundant systems in area whether or not system or equiment is required for hci st a type of equipn.ent/ cables involved repair time for cold shutdown.equipent within this ar n separation between redundant component s and in-site concentration of combustibles alternative shutdown 'ccpability J-C'M1.W'Ml9E.'tREC AW m 3-C. Fire Nazard Analysis type and configuration of combustibles in area 4eantity of combustibles f ease of ignition and propagation j beat release rate potential transient and instc11ed combustibles suppression damage to equipment ) whether the area is continuously manned 1 traffic through the area accessibility of the area D.' Fire Protection Existing or Committed fire detection systees t fire extinguishing systems hoge station / extinguisher radiant heat shields A specific description of the fire protection features of the configuration is required to justify the compensating features of the alternative. Low i. fire leading is not a sufficient basis for grtnting an exemption in areas e ere there are cables. If necessary, a team of. experts, including a fire protection engineer, ,~ will visit the site to determine the extsting, circumstances. This visual inspection is also considered in the review process. g The majority of the.III.G exemption requests received to date are being denied'because they lack specificity. Licensees have not identified the extent of the exemption requested, have not provided a technical basis For the request and/or have not provided a specific description of the alternettve. We expect 'to receive requests for exemption of the followinc . nature:

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Fix'ed fire barriers less than 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rating. 2. Fire barrier without an automatic. fire suppression system. ~ 3. Less than 20 feet separation of cables with fire propagation retardants (e.g., coatings, blankets, covered trays) and an automatic suppression system. ' \\ '4. For large open areas with few comp'on'ents to be protected and fe. n o u combustibles, no automatic suppression system with separation a: 3 above. 5. No fixed suppression in the control t'oom. 1 ~-. 1 4-l 6. We fixed suppre:.sion in areas without a large contentrwen er c .e. m which alternative shutdown capability has been providig. Our fire research test program is conducting tests to provide i.for m that will be useful to determine the boundary of acceptable condition:, f:.- fire protection configurations which do not include a fire rated barrie-Based on deviations recently approved, specific criteria for certain recurring configurations are as follows: Fire terrier less than Three Hours This barrier is a wall, floor, ceiling or an enclosure which separates one fire area from another. ' 'Enemptions may be granted for a lower rating (e.g., one hour or two houra,) uhere the fire loading is no core than 1/2 of the barrier rating. The fire rating of the barrier shall t'e no less than one hour. Esemptions may be granted for a fixed barrier with a lower fix rating supplemented by a water curtain. Aa Astematic Supprestiton System With Either One Hour Fire Barrie.r or N-Foot 5eparation This' barrier is an enclosure which separates those portions of one division which are within 20 feet of the redundant division. The suppressant mry be water or gas. o Exemptions may be granted for configurations of redundant systems whict "have compensating features. For, example: A. Separatfor. distances less than 20 feet may be deemed acceptable where: 1. Fire propagation retardants (i.e., cable coatings, covered trays, conduits, or mineral wool blankett) assure that fire propagation through in-situ combustibles will not occur or will be delayed sufficiently to ensure adequa.te time for detection and suppression. 2. Distance above a floor level exposure firt and below ceiling assures that redundant systems will not be staultaneoasly subject to 4n un4CCeP able temperature or heat flux. t S. The onmission of an automatic suppr'ession system may be dee ed accept eble where: 1. Distance above a floor level exposure fire anc be;e cei'ing as. that redundant systems will not be simultaneously subject te e unacceptable temperature or heat flur. C i, 5-I t. TM fire area is required to be manned continuously by the r c. 4 3"', in the Technical Spectfications. 0 O e O s e e 4 4 3 e 9 9 e e 4 hO 4 e e i I 9 M -m

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