ML20070M592

Responds to Open Items Discussed W/Fire Protection Staff at 830111 & 19 Meetings.Response Will Be Included in Amend to OL Application

ML20070M592
Person / Time
Site:	Seabrook
Issue date:	01/21/1983
From:	Devincentis J PUBLIC SERVICE CO. OF NEW HAMPSHIRE, YANKEE ATOMIC ELECTRIC CO.
To:	Knighton G Office of Nuclear Reactor Regulation
References
SBN-429, NUDOCS 8301250251
Download: ML20070M592 (24)

Text

SEABROM STAM

a., oma IPUE5LIC Companyof New SERVICE Hampshw e 1671 Worceshr Road ,

Framingham, Massachusetts 01701 (6171 - 872 - 8100 January 21, 1983 SBN- 429 T. F. B7.1.2 United States Nuclear Regulatory Commission Washington, D. C. 20555 Attention: Mr. George W. Knighton, Chief Licensing Branch No. 3 Division of Licensing

References:

(a) Construction Permits CPPR-135 and CPPR-136, Docket Nos. 50-443 and 50-444

Subject:

Open Item Responses

Dear Sir:

This letter responds to the following open items which were discussed with representatives of the NRC Fire Protection Staff in meetings conducted on January 11 and 19, 1983.

1) Containment separation of safety-related cables and equipment required for safe shutdown.

Response Information intended to close this item is submitted as Attachment A.

2) Containment fan enclosure area outside containment - separation of safety-related cables and equipment required for safe shutdown.

Response In the containment fan enclosure area, as in all areas where "barriered conduit" is mentioned, it means the conduit will be protected by a one-hour fire-rated barrier.

3) Diesel Generator Building (a) floor drainage system, (b) separation of redundant safety-related cables and equipment required for safe shutdown on Elevation 51, and (c) total automatic sprinkler coverage of the Diesel Generator Rooms.

Response) a) Fire involving fuel oil in the Diesel Generator Room will be prevented from being transmitted to the Diesel Fuel Oil Storage Tank Rooms through the Drainage Systems. The drain lines will be routed directly to the sump located at Elevation V gg)()/

(-16' - 0"). A fire water line will be routed to the sump.

The line will terminate inside the sump with a closed sprinkler head. In the event hot oil flowing to the sump should flash, the closed sprinkler head will open and discharge water to suppress the fire, f 8301250251 830121 o PDR ADOCK 05000443 F PDR

U.S. Nucitar R;gulstory Ccamicsien Page 2 Additionally, the sump will be sealed and vented with a flame arrestor, and check valves or backflow devices will be installed in the drain lines and the trench to the sump.

b) The question of separation of redundant safety-related cables and equipment required for safe shutdown on Elevation 51 of the Diesel Generator Building has been addressed in the attached analyses, Attachment B.

c) The Diesel Generator Rooms are currently protected by a detection system and Automatic Deluge Systems protecting the trenches in the floor. The following addition will be made to each Diesel Generator Room:

1. The doors into the rooms, as well as the doors between the rooms, will be supervised. The doors between the rooms will be curbed to insure that oil will not flow from one room to the other.

2. A closed head, manually-operated sprinkler system, designed and instal?ed to NEPA 13, will be added to provide area soppression in each room. The system will be

! operated by a manual valve installed outside the room.

The piping will be supervised and alarmed.

The installation of this system will ensure that if a fire does start within the room, the fire brigade leader, upon l

arrival at the scene, can manually actuate the system if needed. In the time between fire detection and the arrival of the fire brigade at the Diesel Generator Room, the fire will not have developed enough to affect the three-hour barriers around each room.

4) Primary Auxiliary Building - separation of redundant safety-related cables and equipment required for safe shutdown.

Response Information intended to close this item is submitted as Attachment C.

5) Decontamination areas - lack of fire detection systems.

Response We will install detection in both decontamination areas.

~

6) Fire Detection Systems - lack of automatic fire detection systems in areas containing safety-related equipment.

i Response a. Zone C-F-3-Z, Containment Operating Floor l

Recirculation fans 3A and 3B, are the only pieces of safety-related cable on the containment operating floor.

Detection has been installed in all other areas of containment l

U.S. Nuclser R gulatory Commission Page 3 where there are concentrations of combustibles below the operating floor. Reactor coolant pump motors are protected by seismically designed lube oil collection systems.

The containment operating floor is a huge volume. Air movement throughout the volume, the size of the volume, and the height of the containment prevent the effective placement of detection. Because of the placement of detection in areas containing concentrations of combustibles, we feel there is no need for further detection.

b. Zones MS-F-1A-Z, 2A-Z, and 3A-Z, East Main Steam and Feedwater Pipe Enclosures.

Zones MS-F-1B-Z, 2B-Z, 3B-Z, SA-Z, West Main Stream and Feedwater Pipe Enclosures.

l We will install fire detection in these zones.

c. Diesel Generator Buildiag Air Intake Areas DG-F-3E-A and 3F-A These are plenum areas, supplying intake air to the diesel generators. The two areas are redundant to each other, and are separated by a three-hour barrier. The equipment in each room consists of an intake filter and an exhaust silencer. A

transient fire, if started, would self-extinguish because of a lack of combustibles, and would not impair the function of the safety-related equipment. We feel there is no need for detection in these areas,

d. Primary Auxiliary Building PAB-F-2A-Z, 2B-Z We will install fire detection in these zones. Drawings showing detector location will be submitted for NRC review at a later date.

PAB-F-3A-Z, IJ-Z We will install fire detection around safety-related equipment in these zones. Drawings showing detector location will be submitted at a later date.

PAB-F-4-Z The only safety-related equipment in this zone is the Plant Ventilation Stack Radiation Monitor. The other equipment in the room consists of a filter and two fans, non safety-related.

U.S. Nucisar R2guletory Commiccion Page 4 The monitor is not needed to safely shutdown the plant. The-filters themselves have temperature monitors in them. The room is situated on the roof of the PAB. We feel there is no need for detection other than the filter temperature monitors.

PAB-F-1K-Z This zone consists of the RCA walkway and the Non-Radioactive Pipe Tunnels. The only safety-related equipment in the zone are piping and valves. The zone is cut off from the PAB by concrete walls. Because of the lack of combustibles in the area, we feel no detection is necessary.

e. Fuel Storage Building We will install detection in the Fuel Storage Building,

f. Service Water Cooling Tower, CT-F-3-0 The Cooling Tower, including its fill, is non-combustible.

This area is the top of the tower, completely open to the elements. Because the tower is non-combustible,.we feel no detection is necessary.

g. Waste Processing Building, W-F-2A-Z, 2B-Z These areas contain Safety Class 3 equipment associated with j the Waste Gas System. All electrical equipment is non-Class IE. There are no active safety-related components in the area. Zone W-F-1-Z, the Compactor and Drum Storage Area, does have detection installed. In addition, the decontamination area will have detection installed.

We feel that because there are no active safety-related components in the building, detection is not needed.

The enclosed responses will be included in a future Amendment to the OL Application.

I Very truly yours, j YANKEE ATOMIC ELECTRIC COMPANY ein 4

, John DeVincentis Project Manager f

ALL/tn Enclosure l

cc: Atomic Safety and Licensing Board Service List l

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, ASLB SERVICE LIST ~

Philip Ahrens, Esquire

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Assistant Attorney General Department of the Attorney General Augusta, ME 04333 Representative Beverly Hollingworth Coastal Chamber of Commerce 209 Winnacunnet Road Hampton, NH 03842 William S. Jordan, III, Esquire Harmon & Weiss 1725 I SP.rcet, N.W.

Suite 506 Washington, DC 20006 E. Tupper Kinder, Esquire Assistant Attorney General Office of the Attorney Cencral 208 State House Annex Concord, NH 03301 Robert A. Backus, Esquire 116 Lowell Street P.O. Box 516 Manchester, NH 03105 Edward J. McDermott, Esquire

• Sanders and McDermott Professional Association

408 Lafayette Road Hampton, NH 03842 Jo Ann Shotwell, Esquire Assistant Attorney General Environmental Protection dureau Department of the Attorney General One Ashburton Place, 19th Floor Boston, MA 02108

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ATTACRMENT A To replace Sections B.2 and C of Tabulation 3.1.4.1, Containment, in Seabrook Station Fire Protection of Safe Shutdown Capability (10CFR50, Appendix R).

2. System Analysis

a. Nuclear Instrumentation Cables for the redundant nuclear instrumentation are routed through conduit from the penetration where they enter containment to the instruments in the reactor pit. The conduits are separated by concrete floors and walls or by a minimum of 20' f rom the penetration to the reactor pit. The only intervening combustibles between the redundant conduits are cables in trays. The conduits enter the pit approximately 3' apart and again separate to run to their respective instruments, which are 16' apart. Because of high radiation, the pit is inaccessible during normal operation. Other than the cable in conduit, the fire loading in this area is zero.

The containment is a controlled entry area and the fire loading is very low. The use of transient combustibles is strictly controlled.

The minimum of 20' separation and the routing of cables in conduit provide acceptable fire protection in the general containment area.

At the entrance to the pit and inside it, the separation, routing of cables in conduit and inaccessability of the pit due to high radiation, provide acceptable protection and pr. vide protection equivalent to the technical requirements of Appendix R.

b. Pressurizer Heaters Cables for the redundant pressurizer heaters are routed through trays from the penetration where they enter containment to the heaters at the pressurizer. The trays are separated by concrete floors and walls from the penetration to a point 20' from the pressurizer except between Columns 2 and 3 where there is grating.

l l Between Columns 2 and 3, the Train B cables are routed in trays which are a minimum of 10' above floor Elevation (-) 26'-0". The Train A l

cables are routed in trays a minimum of 18' above the grating

Elevation O'-0". There is a minimum of 25' vertical separation l between the redundant trays. The only in situ combustibles at this location are the cables in the trays, in the area near the entrance to the pressurizer cubicle, the Train B l trays are 12' above floor Elevation (-) 26'-0". The Train A trays are l between 3' and 9'-7" above floor Elevation (-) 26'-0". There is a

! spatial separation of approximately 6' between the redundant trays.

The only in situ combustibles at this location are the cables in the ,

trays.

The Train A trays are 8'-4" above the floor and the Train B trays are 18'-16" above the floor at the entrance to the pressurizer cubicle.

This is a vertical separation between redundant trays of over R'.

Inside the cubicle, the cables are routed in enclosed wireways up to the point where they are routed to the individual pressurizer heater connections. The heaters are located over 20' above the floor. There are no in situ combustibles in the pressurizer heater cubicle.

The containment is a controlled entry area and the fire loading is very low. The use of transient combustibles is strictly controlled.

Where the grating exists, the cables of interest are separated vertically by 25' minimum. The lower set of cables are at least 10' off the floor. This separation and the height of the cable from the floor provide acceptable fire protection and provide protection equivalent to the technical requirement of Appendix R.

At the area near the entrance to the pressurizer cubicle, there is a spatial separation of 6' between the cables of interest. There are no in situ combustibles. Access to this area is extremely limited during power operation. The separation, lack of combustibles and limited access provide acceptable fire protection and provide protection equivalent to the technical requirements of Appendix R.

At the entrance to the pressurizer and inside, the case is the same, with the additional factor being the routing of the cables in enclosed wireways up to the point where they are routed to the individual pressurizer heater connections. The separation, lack of combustibles, limited access and routing of the cables in wireways provide acceptable fire protection and provide protection equivalent to the technical requirements of Appendix R.

c. Containment Structure Cooling Units Call-AC-1A through 1F (Fans Call-FN-1A through 1F Cables for the redundant cooling unit fans, speed changers and flow switches are routed through trays and conduits from penetration where they enter containment to the cooling units. The trays are separated by concrete floors except between Columns 2 and 4, Columns 5 and 6, Columns 7 and 8, Columns 12 and 13, Columns 14 and 15, and Columns 17 and 18 where there is grating.

Between Columns 2 and 4, the Train B trays are a minimum of 12' above floor Elevation (-) 26'-0" and a maximum of 19' above floor Elevation

(-) 26'-0". The Train A trays are a minimum of 11' above the grating Elevation O'-0". There is a minimum of 18' of vertical separation between the redundant trays. Even if the redundant trays are affected by a fire, only two Train B and one Train A cooling unit could be affected, the other three cooling units would continue to be operable.

Between Columns 5 and 6, the Train B trays are a minimum of 14' above floor Elevation (-) 26'-0" and a maximum of 19' above floor Elevation

(-) 26'-0". The Train A trays are a minimum of 18' above the grating Elevation O'-0". There is a minimum of 24' of vertical separation between the redundant trays. Even if the redundant trays were affected by a fire, only one Train A and one Train B cooling unit could be affected; the other four cooling units would continue to be operable.

Between Columns 7 and 8, only one Train A cooling units' cables are routed. There are no Train B cooling units' cables at this location.

Between Columns 12 and 13, only one Train A and one Train B cooling units' cables are routed. The other four cooling units would continue to be operable.

Between Columns 14 and 15, the Train B trays are a minimum of 19' above floor Elevation (-) 26'-0" and a maximum of 21' above floor Elevation (-) 26'-0". The Train A trays are a minimum of 17' above the grating Elevation O'-0". There is a minimum of 22' of vertical separation between the redundant trays. Even if the redundant trays were affected by a fire, only two Train A and one Train B cooling unit could be affected. The other three cooling units would continue to be operable.

Between Columns 17 and 18, the Train B trays are a minimum of 12' above floor Elevation (-) 26'-0" and a maximum of 19' above floor Elevation (-) 26'-0" . The Train A trays are a minimum of 11' above the grating Elevation O'-0". There is a minimum of 18' of vertical separation between the redundant trays. Even if the redundant trays were affected by a fire, only two Train A and one Train B cooling units could be affected; the other three cooling units would continue to be operable.

A maximum of three Containment Structure Cooling Units (CAH) are needed to cool the containment. This can be any combination of Train A and B units. At all points discussed above where Train A and B units are run near each other without concrete floor separation, there is a minimum of 18' of vertical separation, with the Train B cables a minimum of 12' of f the floor. This vertical separation, the height of the cable from the floor and the lack of combustibles provide acceptable fire protection and provide protection equivalent to the technical requirement of Appendix R. Additionally, a fire at any of these points would affect a maximum of three out of six units, leaving three to cool containment.

d. Component Cooling Isolation Valves CC-V176, CC-V256, CC-V57, CC-V121 Cables for the redundant valves are routed through trays and conduits from the penetration where they enter containment to the valves on the west side of containment at Elevation 4'-0". The trays are separated l by a concrete floor except between Columns 17 and 18 and between Columns 14 and 15 where there is grating.

l Between Columns 17 and 18, the Train B trays are a minimum of 12' above floor Elevation (-) 26'-0" and a maximum of 19' above floor

Elevation (-) 26'-0" . The Train A trays are a minimum of 11' above l the grating Elevation O'-0". There is a minimum of 18' of vertical

! separation between the redundant trays. The only in situ combustibles at this location are the cables in the trays.

Between Columns 14 and 15, the Train B trays are a minimum of 19' above floor Elevation (-) 26'-0" and a maximum of 21' above floor

Elevation (-) 26'-0". The Train A trays are a minimum of 17' above i

I .

the grating Elevation O'-0". There is a minimum of 22' of vertical separation between the redundant trays. The only in situ combustibles at this location are the cables in the trays.

j The Train A valves CC-V57 and CC-V121 are located between Columns 14 and 15 approximately 4' above the grating Elevation O'-0". The cables for:the Train B valves CC-V176 and CC-V256 are routed in trays which are a minimum of 19' above floor Elevation -(-) 26'-0". There is a minimum of 8' vertical separation between the Train B trays and the Train A valves. The only in situ combustibles at this location are the cables in the trays.

The Train B valves CC-V176 and CC-V256 are located between Columns 12

and 13 approximately 4' above the grating Elevation O'-0". Although the cables for the redundant Train A valves are not in this location, the power cables for Train A containmant structure cooling unit CAH-AC-1E are routed.in this area such that a fire could impact four of the six cooling units. However, the cables are routed in tray 19' above the grating Elevation O'-0" and then in conduit to the cooling unit. There is a vertical separation of approximately 15' between valves CC-V176 and the Train A trays. The only in situ combustibles at this location are the cables in the tray.

One set of redundant valves is needed to provide component cooling water to one train of containment structure cooling units.

Between Columns 17 and 18, the vertical separation is 18', with the lower cables 12' of f the floor. The separation and height of cable from the floor provide acceptable fire protection and provide protection equivalent to the technical requirements of Appendix R.

Between Columns 14 and 15, there is a vertical separation of 27', with the lower cables 19' off the floor. There is a minimum separation of i 8' between the Train A valves and the Train B cables, with the Train B f cables 19' off the floor. The separation, height of cable from the.

floor and lack of in situ combustibles provide acceptable fire i protection and provide protection equivalent to the technical t

requirements of Appendix R.

l l

Between Columns 12 and 13, there is a vertical separation of 15'

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between the Train B valves and the Train A cable. The valves are 30' ,

off the floor (Elevation (-) 26'). The separation, height of the valves off the floor and lack of in situ combustibles provide l acceptable fire protection and provide protection equivalent to the technical requirements of Appendix R.

e. RHR Isolation Valves RC-V22, RC-V23, RC-V87, RC-V88 l RHR isolation valves are permanently disabled in the closed position.

! Redundant valves RC-V23 and RC-V88 are separated by 25' with no

( intervening combustibles other than cables in trays. Redundant valves RC-V22 and RC-V87 are separated by 3'. The valves are only required l to be opened for cold shutdown and this can be accomplished manually, t

if required.

t l.

Therefore, no fire protection other than the existing separation is needed, and protection equivalent to the requirements of Appendix R is provided,

f. Pressurizer Relief Valves RC-V122, RC-V124, RC-PCV-456A and RC-PCV-456B Cables for the pressurizer relief valves are routed in trays and conduits from the penetration where they enter containment to the valves on the top of the pressurizer. The trays are separated by a concrete floor except between Columns 2 and 4; between Columns 5 and 6; and between Columns 7 and 8 where there is grating.

Between Columns 2 and 4, the Train B cables are routed in trays which are a minimum of 10' above floor Elevation (-) 26'-0". Other trays containing Train B cables are located up to 16' above floor Elevation

(-) 26'-0". The Train A cables are routed in trays a minimum of 18' above the grating Elevation O'-0" . There is a minimum of 25' vertical separation between the redundant trays. The only in sito combustibles at this location are the cables in the trays.

Between Columns 5 and 6, the Train B trays are a minimum of 14' above floor Elevation (-) 26'-0" and a maximum of 19' above floor Elevation

(-) 26'-0". The Train A trays are a minimum of 18' above the grating Elevation O'-0". There is a minimum of 24' of vertical separation between the redundant trays. The only in situ combustibles at this location are the cables in trays; three pints of oil in 15 HP RC drain tank pump motor contributing 56, 250 Btu fire load; and five pounds of grease in 3 HP containment sump pump motors contributing 90,000 Btu fire load.

Between Columns 7 and 8, the Train B trays are a minimum of 13' above floor Elevation (-) 26'-0" and a maximum of 19' above floor Elevation

(-) 26'-0". The Train A trays are a minimum of 16' above the grating Elevation O'-0" . There is a minimum of 23' of vertical separation between the redundant trays. The only in situ combustibles at this location are the cables in trays.

At the pressurizer, the cables are routed in conduit on opposite outside walls of the pressurizer enclosure with a minimum horizontal separation of approximately 15'. The Train A cables are routed in the area of reactor coolant pump C. Near the top of the pressurizer, the conduits enter the pressurizer cubicle and are routed on opposite sides of the cubicle over to the valves. The redundant valves are separated by 2' on the top of the pressurizer. There are not in situ combustibles at the top of the pressurizer.

Between Columns 2 and 4 and 7 and 8, there is a minimum vertical separation of 23' between Train A and B cables. The Train B cables are a minimum of 10' off the floor. The separation, height off the floor and lack of in situ combustibles provide acceptable fire protection and provide protection equivalent to the technical requirements of Appendix R.

t Between Columns 5 and 6, there is a vertical separation of 25' with the lower cables 14' of f the floor. The combustibles are in two motors. The separation, height off the floor, and the enclosure of combustibles in the motors provide acceptable fire protection and provides protection equivalent to the technical requirements of Appendix R.

At the pressurizer, the cables are routed in conduit on opposite sides of the pressurizer cubicle. At the top of the pressurizer where the valves are located, there is no access during operation and there are no in situ combustibles. Adequate fire protection is provided and provides protection equivalent to the technical requirements of Appendix R.

g. Accumulator Tank Outlet Isolation Valves SI-V2, SI-V32, SI-V17, SI-V47 Although valves are Train A or Train B, they are not functionally redundant for safe shutdown. These valves are not required to reach or maintain hot standby. They are required to be closed before going to cold shutdown. These valves will be manually closed, if required, prior to decreasing reactor pressure below 600 psig. Prior to this time the accumulators are prevented from injection by reactor pressure acting against a check valve.

Therefore, no fire protection other than the existing separation is needed and protection provided is equivalent to the technical requirements of Appendix R.

C. EVALUATION An exemption from the Appendix R separation requirements is requested for this area. This exemption is justified based on our assertion that additional modifications would not enhance fire protection safety which has been insured by the protective measures listed in the " General Area Analysis" and the " System Analysis".

a a i nuiru:,n i o MEMORANDUM To D. A. Maid rand LOCATION

.fa mm O' rv M14 ' 14R1 from E. A.. Sawyer l.M.3. No.wsc s i.0c.riO~

WO #6338 Subject R.T. No.

REABRODr FTRE ANAUST1- DBJECHANTcA]_VENIILATIOLAREA PROBLEM AREA: DG Building, Mechanical Ventilation Area Fire Areas DG-F-3A-Z, and 3B-Z Problem:

Ventilation to the redundant diesel rooms is provided by two fans located in this area. Will a fire in the room incapacitate both fans so that ventilation is cut of f to the rooms? The worst potential for fire is at the two places where cables penetrate the floor from the room beneath, then travel through the ventilation area.

Room

Description:

The room is 86 feet long by 37 feet wide by 26 feet high, a total floor area of approximately 3,2000 square feet, a total volume of approximately 83,000 cubic feet. The room is open to atmosphere through louvers along the two 37 foot walls. The two fans supplying the diesel room ventilation are approximately 28 feet apart. Automatic fire detection is provided in the area.

There are a total of six cable trays which run horizontally and vertically through the area. When stacked, the trays are run three high with the bottom tray being an enclosed instrumentation cable tray. There is approximately 375 f t of uncovered cable tray containing a total of approximately 80 cables, with l 750 lbs of combustibles. There are no Safe Shutdown cables in the trays. The Safe Shutdown cables for the fans and dampers are routed in conduit from the floor where they enter the area to the equipment (a distance of approximately 15 feet). The cable trays are located between 8 and 13 feet from the floor, well below the 26 foot ceiling.

Analysis:

If 5 gallons (28 lbs) of heptane were to be spilled around the cable trays, the actual spill would be less than 1/2 inch deep with an area of 16 square feet. Using Harvard Fire Code predictions, the fire duration would be less than 38 seconds. To be more conservative, we can propose a depth of one inch, with an area of 8 square feet. The fire duration will be 66 seconds, and the total Btu's released will be 560,000 (28 lbs x 20,000 Btu /lb).

Experiments and computer analyses of short duration fires (approximately 100 seconds) show that the expected temperature reached in a small room (30 feet long by 14 feet wide by 10 feet high) is about 13500F, and occurs when the fire is nearly out. For such a fire, the heat flux to cables located within l

the hot gas layer, close to the ceiling, does exceed the damage limit for IEEE 383 cables for a short time. However, in a room as large a this one, one l

l

D. A. Maidrand January 14, 1983 Page 2 would expect t ha t the hot gas layer will be far above the actual horizontal cable tray levels, and that the temperature and heat flux will be much lower due to the larger volume and the distance from the walls and ceiling to the fire, precluding much radiative feedback. Actually, a steady state burning rate will not be reached before the fire burns out.

We normally would assume that the cables in the vertical trays directly exposed to the flame would be damaged, and might even be exposed long enough for them to ignite. However, being IEEE 383 cables, and with very few in each tray, they would be expected to self-extinguish when the exposure fire burns

! out. The ref o re, they would provide no danger to the fans in the room.

However, to satisfy the NRC, we must assume an exposure fire that burns for fif teen minutes around the cable trays. If this were to happen, there is still some question, given the air flow in the room and the height of the ceiling, whether the cables away from the immediate fire area would be affected. For this analysis, we shall assume they are, and that they burn completely. We shall also assume that the total number of cables installed is doubled, to avoid having to redo this analysis every time a change is made.

The total amount of in-situ combustible, therefore, is 1500 lbs.

Using 20,000 Btu /lb for plastic, the Btu load from the cable is 30,000,000.

The total load for cable and heptane is 30,560,000 Btu. The combustible loading will be 9550 Btu /ft2 in the room. This is equal to about 0.5 lb/ft2 Using Ingberg's conversion to relate fire load to length of fire, this gives us a three minute fire, which really does not tell us much.

If we try to look at a concentrated load in the trays, and use 375 feet of 2 foot wide tray as a base, we come up with a concentrated load of 40,750 Btu /ft2, or approximately 4 lbs/ft2 Again using Ingberg's conversion factors, this would provide us a 24 minute fire.

Conclusion:

If we evaluate the above analysis for fire load and length of fire, along with the size of the room (particularly the height of the ceiling) and the use of IEEE 383 rated cable, we can predict that a fire in that room would not burn up all the cable and would self extinguish. Because of the air flow from the louvers, the transient fire would burn more rapidly than the assumed 15 minutes. If it were to burn for 15 minutes, the high ceiling and air flow would prevent the build up of high heat flux at the level of the cable trays, so with the exception of those cables directly in the fire _ plume, the cables would not burn. Even if we assume the cables were to totally burn, the fan motors and cable in conduit to the motors would not be affected. The fan motors are separated from each other by a distance of approximately 25 feet plus the fan enclosure itself. The height of the room and the open louvers on the walls preclude the buildup of any stratification which would effect the fan motors located approximately three feet off the floor or the conduits to the fan motors, wrapped in a one-hour fire-rated barrier and located at floor level.

D. A. Maidrand January 14, 1983 Page 3 Therefore, I feel that the protection af forded by the existing automated fire detection system and the manual application of suppressant by the fire brigade is sufficient for this area. No further protection is required.

J' 9

/ / /

E. A.' S#awyer Fire Protec on Coordinator Yankee Nuclear Services Division EAS/tn cc: J. DeVincentis J. J. Lance I

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ATTACHMENT C To replace Sections B and C of Tabulation 3.1.4.37, Primary Auxiliary Building, in Seabrook Station Fire Protection of Safe Shutdown Capability (10CFR, Appendix R).

B. ANALYSIS

1. General Area Analysis

a. The PAB is a Class 1 concrete structure which contains the above listed equipment and cable required for safe shutdown. The PAB has been divided into several zones for fire protection analysis, with intervening walls, floors and ceilings of poured concrete.

b. The significant in situ combustibles consist of 0.25 gallons of oil in each of the two boron injection pumps; 1.0 gallons of oil in the monorail crane hoists; one gallon of oil in each of the two chiller pumps; 0.25 gallon of oil in each of the two reactor makeup water pumps; one pound of grease in each of the two boric acid transfer pumps; one gallon of oil in each of the four primary component cooling pumps; 0.5 gallons of oil in each of the two flash tank distillate pumps; and 19,000 pounds of insulation for cables in trays. The analysis of the in situ fire load provided by the cable in trays is contained in the " System Analysis". An analysis of the Design Basis Fires for the remaining combustibles is contained in the " Fire Protection Program Evaluation and Comparison to Branch Technical Position APCSB 9.5-1, Appendix A" and is summarized as follows:

1) Elevation 7'-0" and Below a) Fire Zone PAB-F-1A-Z Total combuctibles for 2.5 gallons of oil is 375,000 Btu (chiller pumps CS-P-7A, and CS-P-78 and reactor makeup water pumps RMWP-16A and 16B).

b) Fire Zone PAB-F-1B-Z No combustibles.

c) Fire Zone PAB-F-lJ-Z No combustibles.

d) Fire Zone PAB-F-lK-Z No combustibles.

2) Elevation 25'-0" a) Fire Zone PAB-F-2A-Z No combustibles.

- .- - .. , - . - = . . - - . . -. . . .

b) Fire Zone PAB-F-25-Z

. Total combustibles for two pounds of grease is 36,000 Btu (boric acid transfer pumps CS-P-3A.and'38).

l c)' Fire Zone PAB-F-2C-Z

! Total combustibles for 5.25 gallons of oil la 787,500 Btu (PCCW pumps CC-P-11A,11B,11C and 11D; 3-1/2 ton monorail i crane hoist CS-CR-13; 4-1/2 ton monorail crane hoist -

CS-CR-5; boron injection pumps SI-P-4A and 4B).

i

3) Elevation 53'-0" and 81'-0" l

! a) Fire Zone PAB-F-3A-Z Total combustibles for one gallon of oil is 150,000 Btu

(flash tank distillate pumps SB-P-171A and 171B).

. c. Only the Train A safe shutdown cables are routed in trays. The Train B safe shutdown cables are routed in barriered conduits with a fire rating of one hour.

2. System Analysis

a. Fire Zone PAB-F-1A-Z

1) Primary Component Cooling Water (CC) System'

]

i This zone contains cables routed in barriered conduits for pumps CC-P-11B and CC-P-llD and valves CC-TV-2271-1, CC-TV-2272-2, CC-V122 and CC-V168. This equipment is all Train B. There is no redundant Train A CC System equipment or

cables in this fire zone.

2) Chemical and Volume Control (CS) System This zone contains cables routed in barriered conduits for l pump CS-P-2B and for valves CS-V66 and CS-V143.--This equipment is all Train B. There is no redundant Train A CS System equipment or cables in this fire zone.

3) Containment Enclosure Air Handling (EAH) System This zone contains cables routed in barriered conduits for fans EAH-FN-5B and EAH-FN-31B. This equipment is all Train ,

B. There is no redundant Train A EAH System equipment or.

cables in this fire zone.

4) Electrical Distribution - Emergency (EDE) System This zone contains only Train B cables routed in barriered conduits for the EDE System.

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

5) PAB Air Handling (PAH) System This zone contains cables routed in barriered conduits for fan PAH-FN-42B and dampers PAH-DP-43B and PAH-DP-44B. This equipment is Train B. There is no redundant Train A PAH System equipment or cables in this fire zone.

6) Service Water (SW) System This zone contains cables routed in barriered conduits for Train B valves SW-V5, SW-V17, SW-V18, SW-Vl9, SW-V23 and SW-V25. Train A valve SW-V54, which is redundant to valve SW-V25 is routed in tray that is 9' above floor Elevation 7'-0" except at the entrance to the duct bank'to the cooling towtes where it is 3'-6" above floor Elevation 7'-0". There

! is approximately 8' of horizontal separation between the Train B barriered conduit and the Train A tray. The only in situ-combustibles in the vicinity of the cables for the redundant valves SW-V54 and SW-V25 are cables in open trays with a total '

fire loading of 6,000 Btu's per square foot of floor area.

7) Summary 1

For systems 1) through 5) .above, the Train B cables are routed in conduit with a one-honr, fire-rated barrier. There is_no redundant Train A equipment or cables in the zone. The provision of a one-hour, fire-rated barrier and the lack of Train A equipment and cables provide acceptable fire protection and provide protection equivalent to the technical requirements of Appendix R.

For system 6) above, Train B conduits are routed in one-hour, fire-rated barriers. The 8' of separation between the Train A tray and the Train B conduit, the one-hour, fire-rated barrier

on the conduit; and considering the low combustibles loading in the zone, provide acceptable fire protection and provide protection equivalent to the technical requirements of Appendix R.

b. Fire Zone PAB-F-1B-Z

1) Primary Component Cooling Water-(CC) System This zone contains cables routed in tray for the Train A valves CC-V175 and CC-V257. The tray is a minimum of 10'

above floor Elevation (-) 26'0", only 6 lineal feet of the tray is in the zone. The only in situ combustibles in the zone are cables in open trays with a total fire loading of 500 Btu's per square foot of floor area. The redundant Train B cables are routed in barriered conduit above floor Elevation

(-) 8'-0" in fire zone PAB-F-1A-Z, which is approximately 18' horizontally above the Train A cables with an intervening concrete floor, l

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. _ . _ . _ - _ - _ _ _ . . _ _ _ . . _ . - - _ ~,_

The spatial separation, the low fire load and the routing of the Train B cables in a one-hour, fire-rated conduit in another fire zone, provide protection equivalent to the technical requirements of Appendix R.

c. Fire Zone PAB-F-lJ-Z There are no safe shutdown equipment or cables in this fire zone.

Therefore, no protection is necessary.

d. Fire Zone PAB-F-1K-Z

1) Service Water (SW) System This zone contains cables routed in conduit for Train A valve SW-V4. The Train B cables for its redundant counterpart valve SW-V5 are routed in barriered conduit in the zone. There is 8' horizontal separation between the barriered conduit and the valve. There is 16' horizontal separation between the redundant valves. The valves are located approximately 15' above floor Elevation 53'-0" and 3' above platform Elevation 65'-0". The zone contains no cable in tray or other in situ combustibles.

All cable is in conduit. The horizontal separation of 8' between conduit and valve and 16' between the valves themselves, the height of the valves from the floor, the routing of the Train B cables in one-hour fire barriered conduit, and the absence of in situ combustibles provide acceptable fire protection and provide protection equivalent to the technical requirements of Appendix R.

e. Fire Zone PAB-F-2A-Z

1) Containment Enclosure Air Handling (EAH) System This zone contains cable routed in barriered conduit for the Train B fan EAH-FN-5B. The cables for the redundant Train A l fan EAH-FN-5A are routed in trays in fire zone PAB-F-2C-Z.

l There is approximately 16' horizontal separation between the barriered conduit and the redundant tray. The only in situ

, combustibles in the zone are cables in open trays with a total fire loading of 20,000 Btu's per. square foot of floor area.

I 2) PAB Air Handling (PAH) System i

! This zone contains cables routed in tray for the Train A fan PAH-FN-42A and damper PAH-DP-44A. The cables for the l

redundant Train B fan PAH-FN-42B and PAH-DP-44B are routed in l

barriered conduit in fire zone PAB-F-2C-Z. There is greater l

than 50' of horizontal separation between the tray and the redundant barriered conduit. Thc only in situ combustible in the zone are cables in open trays with a total fire loading of' l 20,000 Btu's per square foot of floor area.

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3) Service Water (SW) System This zone contains cable routed in tray for the Train A valve SW-V54. The cable for the redundant Train B valve SW-V25 is routed in a barriered conduit in fire zone PAB-F-1A-Z. There is approximately 25' of horizontal separation between the tray and the redundant barriered conduit. The only in situ combustibles in the zone are cables in open trays with a fire loading of 20,000 Btu's per square foot of floor area.

4) Summary A fire load of 20,000 Btu / square feet is classed Ts a low fire load. For each of the systems discussed above, the Train B cables are routed in one-hour, fire-rated barriered conduit.

There is a horizontal separation of 16, 25 and 50',

respectively. The separation, fire rated barriers and low fire load in the zone provide acceptable fire protection and provide protection equivalent to the technical requirements of Appendix R.

f. Fire Zone PAB-F-2B-Z

1) Chemical and Volume Control (CS) System Valves CS-V423, CS-V424, CS-V430, CS-V431, CS-V437, CS-V439 and CS-V442 are manual valves required for gravity feed from the boric acid tank to the charging pumps. These valves are not required to be operated until boric acid is required for shutdown reactivity. This would be after a minimum of three hours and the valves would then be accessible for manual operation.

2) PAB Air Handling (PAH) System This zone contains cables routed in tray and conduit for the Train A fan PAH-FN-42A and damper PAH-DP-44A. The cables for the redundant Train B fan PSH-FN-42B and damper PAH-DP-44B are routed in barriered conduit in fire zone PAB-F-2C-Z. There is 4' horizontal separation between the Train A raceways and the Train B equipment and barriered conduit. The Train A trays are a minimum of 8' above floor Elevation 25'-0". A total of 3 trays exist in the stack with the bottom tray and enclosed instrument level tray containing no safe shutdown cables. The Train B damper PAH-DP-44B is located approximately 18' above floor Elevation 25'-0". The in situ combustibles in this zone consists of cables in open trays with a fire loading of 6,000 Btu's per square foot of floor area and the boric acid transfer pumps CS-P-3A and CS-P-3B containing two pounds of grease for a fire loading of 36,000 Btu's.

3) Summary For system 1) above (CS), the valves are manual and are not required for a minimum of three hours. Therefore, Appe". dix R is met and no further protection is necessary.

For system 2) above (PAH), there is a 4' horizontal separation between Train A and B with the Train B cable routed in conduit with a one-hour, fire-rated barrier. The trays are a minimum of 8' off the floor. The separation, height above floor, barriered conduit and very low fire load provide acceptable fire protection and provide protection equivalent to'the technical requirements of Appendix R.

g. Fire Zone PAB-F-2C-Z

1) General Zone Analysis This zone at Elevation 25'-0" of the PAB is bounded by concrete floors, ceilings and walls (North, East and West) and is contiguous to fire zones PAB-F-2A-Z and PAB-F-2B-Z to the South. The southern boundary consists of full height partitions, full and partial height concrete walls and an 11' wide access passage. The zone is approximately 100' long by.

75' wide by 26' high with a floor area of 7,200 square feet and a volume of 187,000 cubic feet.

The trays installed at Elevation 25'-0" are in stacks five and six high by four wide, as a worst case, with a minimum of 4' between the Train A and Train B stacks. There are several areas where the trays have vertical drops through the floor.

With a limited number of exceptions, the trays are a minimum of 10' above the floor. Metal covers are provided around the vertical trays near column lines 2 and C. A 3-hour rated penetration seal is provided where these trays penetrate both floor and ceiling in this zone.

Detectors are provided in the zone.

The in situ combustibles are limited to cables in open trays which provide a fire load of 16,000 P.u's per square foot of floor area; the boron injection pumps which contain .25 gallons of oil are a fire loading of 37,500 Btu's; the primary component cooling water pumps CC-P-134, llB, llc and 11D containing a total of four gallons of oil for a fire loading of 600,000 Btu's; 4-1/2 ton monorail crane hoist CS-CR-5 containing 0.5 gallons of oil for a fire loading of 75,000 Btu's; and 3-1/2 ton monorail crane hoist CS-CR-13 containing 0.5 gallons of oil for a fire loading of 75,000 Btu's.

The concentrated fire load in this zone is 30,000 Btu's per square foot of tray. Because of the concentrated fire load, we have installed sprinklers to control transient fires in the area of the trays.

To protect the FCCW pumps against a fire from a transient l combustible, we will add an additional system over the pumps and the surrounding area. This will be a pre-action system, using high temperature heads. Spray shields will be installed over the PCCW pump motors. A drawing showing the extent of this system will be submitted for NRC review and approval in the near future.

I

2) Primary Component Cooling Water (CS) System The redundant Primary Component Cooling Water (PCCW) pumps are located in the same fire area. The CC System is configured such that there are two 100% capacity PCCW pumps in each train either of which can be utilized for safe shutdown. The spatial separation between Train A pump CC-P-11A and Train B pump CC-P-llD is in excess of 20' with a metal partition between them. The spatial separation between Train A pump CC-P-llc and Train B pump CC-P-11B is in excess of 20' with a metal partition between them. The cables to the Train B pumps are routed in barriered conduit from the point they enter the PAB to the pump motors. The conduits are barriered in the vicinity of the Train B pumps. The Train B pumps have a spatial separation of 25' from the Train A trays and 15' from the Train B trays.

The redundant PCdW heat exchanger valves CC-TV-2171-1, 2 and CC-TV-2271-1, 2 and their associated solenoids are located in the same fire area. The redundant valves are within 2'.

These valves are air-operated and upon loss of air or electrical power the outlet valve fails open and the bypass valve fails closed. This is an acceptable safe shutdown position. The Train B valves CC-TV-2271-1 and CC-TV-2272-2 cables are routed in barriered conduits.

The spatial separation, the metal partition, the routing of Train B cables in one-hour, fire-rated conduit, and the additional sprinkler system provide acceptable fire protection and provide protection equivalent to the technical requirements of Appendix R.

3) Chemical and Volume Control (CS) System This zone contains cable routed in tray and conduit for the Train A charging pump CS-P-2A, The cable for the redundant Train B pump CS-P-2B is not routed in this zone.

The redundant boron injection tank inlet isolation valves CS-V65 and CS-V66 are located in prcrimity. These valves are normally closed and remain closed for safe shutdown. The operators will prevent spurious operatiin by tripping the power supply breakers for these. valves at the Train A and Train B Switchgear Rooms (Fire Areas: CB-F-1A-A and CB-F-1B-A).

Cables for only the Train B charging pump discharge to RCS isolation valve CS-V143 are routed in this area.

The separation between the Train A and Train B charging pump cables provides acceptable fire protection. Operator action in tripping supply breakers for the redundant boron injection tank isolation valves obviatua the need for fire protection for them and meets Appendix R.

, __ _ _ __ . . - = _ _ _

4) Containment Enclosure Air Handling (EAH) System t

The cables for the redundant fans EAH-FN-5A and EAH-FN-5B, and EAH-FN-31A and EAH-FN-31B are routed in the same area. The Train B fan cables are routed in barriered conduits.

The Train B cables are separated from the Train A cables by a minimum of 20' with the exception of the area where the cables for fan EAH-FN-31B must cross the Train A trays to enter the containment enclosure ventilation area. At this location there. is suppression and a one-hour, fire-rated barrier around the conduit.

The separation of 20', the routing of the Train B cables in conduits with a one-hour, fire-rated barrier and the area sprinkler system provided where the Train B conduit crosses the Train A trays provide acceptable fire protection and provide protection equivalent to the technical requirements of Appendix R.

5) PAB Air Handling (PAH) System The redundant PAH fans and dampers are in proximity. The fans and dampers are inside separate metal enclosures located approximately 15' above the floor. The Train B fan and damper I

cables are routed in barriered conduits. There are no cable i trays in the vicinity of the fans and dampers. The only in situ combustibles in the vicinity are the PCCW pumps which are separated from the fans and dampers by greater than 20' horizontally and the monorail crane hoist.

These fans are not needed unless the main ventilation system is lost due to a loss of off-site power or unless the

temperature in the immediate area exceeds 400C (1040F).

The height of the fans off the floor, the lack of combustibles in the area, the fact that a fire in this area could not cause a loss of off-site power and the routing of the Train B cables in conduits protected by a one-hour fire barrier provide acceptable fire protection and provide protection equivalent to the technical requirements of Appendix R.

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6) Service Water (SW) System 4

The cables for redundant valves SW-V4 and SW-V5 are located in the same fire zone. These valves may be required to l reposition to isolate secondary component cooling water. The Train B valve SW-V5 cables are routed in barriered conduits

and are separated from the Train A cables by greater than 30' horizontally. There are no cable trays or other in situ combustibles in the vicinity of Train B conduits.

Redundant valves, SW-Vl9, SW-V20, SWOV23 and SW-V34 are located in the same fire zone. Operators for valves SW-V34 and SW-V23 are approximately 5' above floor Elevation 25'-0" and operators for valves SW-V20 and SW-Vl9 are approximately l

, . . . , _ . _ _ _ _ . , . , . _- , ,.,v_._ r , - ,3., . . _ . _ , . . , _ - , ,m ,-m. s_.y

J 10' above floor Elevation 25'-0". The redundant valves are

, separated by approximately 16' horizontally. There are no j cable trays in the vicinity of the valves. The only in situ

! combustibles in the vicinity are the PCCW pumps which are separated from the Train A valves by greater than 16' horizontally. The valves are in safe. shutdown position. The

operators will prevent spurious operation by tripping the I power supply breakers at the Train A and Train B Switchgear Rooms (Fire Areas: CB-F-1A-A and CB-F-1B-A).

t

. The cables for redundant diesel generator jacket water heat g exchanger valves SW-V16 and SW-V18 are locate in the same fire j area. The Train B valve SW-V18 cables are routed in barriered conduits and are separated from the Train A valve cables by greater than 30' horizontally. There are no cable trays or other in situ combustibles in the vicinity of the Train B conduits. The valves are normally closed and are required to open for operation of the diesel generators. De-energizing

the solenoids will open the valves. The operators will trip

the power supply breakers at the Train A and Train B i Switchgear Rooms (Fire Areas

CB-F-1A-A and CB-F-1B-A).

For valves SW-V4 and SW-V5, the 30' horizontal separation and l the routing of the Train B cables in conduit which is i protected by a one-hour, fire-rated barrier provide acceptable fire protection and provide protection equivalent to the i technical requirements of Appendix R.

For valves SW-V19, 20, 23 and 34, the 5' vertical separation 1 and 16' horizontal separation, the lack of in situ

combustibles in the vicinity of the valves and the fact that the operator will trip the power to the valves in the event of a fire, obviate the need for further fire protection and provide protection equivalent to the technical requirements of Appendix R.

For valves SW-V16 and 18, the 30' horizontal separation, the routing of the Train B cable in conduit protected by a one-hour, fire-rated barrier, the lack of in situ combustibles in the vicinity of the Train.B conduits, and the fact that the j operators will trip the power supply to the valves in the event of a fire, obviate the need for further fire protection and provide protection equivalent to the technical requirements of Appendix R.

h. Fire Zone PAB-F-3A-Z l 1) Service Water (SW) System This zone contains Train A valves SW-V15 and'SW-V16 and cables for Train A valve SW-V4. Also contained in this zone are the redundant Train B valves SW-V17 and SW-V18 and cables for valve SW-V5.

i 6

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-~. . . . . .. . - -. .. -..

Redundant valves SW-V15 and SW-V17 are in the safe shutdown position. The operators will prevent spurious operation by tripping the power supply breakers at the Train A and Train B Switchgear Rooms (Fire Areas: CB-F-1A-A and CB-F-1B-A).

Redundant diesel generator jacket water heat exchanger valves i

SW-V16 and SW-V18 are normally closed and are required to open for operation of the diesel generators. De-energizing the solenoids will open the valves. The operators will trip the power supply breakers at the Train A and Train B Switchgear Rooms (Fire Areas: CB-F-1A-A and CB-F-1B-A).

The Train A cables for valve SW-V4 are routed in trays and j conduit. The trays and conduit are a minimum of 10' above floor Elevation 53'-0". The Train B cables for valve SW-V5 are routed in barriered conduits. The Train A and Train B raceways are separated by greater than 25'. The in situ combustibles in this zone consist of cables in open trays for a fire loading of 3,000 Btu's per square foot of floor area and the flash tank distilate pumps SB-P-171A and SB-P-171B containing one gallon of oil for a fire loading of 150,000 Btu's.

i For valves SW-V4 and V5, the125' horizontal separation, the

routing of the Train B cables in conduit protected by a

! one-hour, fire-rated barrier, and the low fire load provide acceptable fire protection and provide protection equivalent to the technical requirements of Appendix R.

For valves SW-V15, 16, 17 and 18, the operator will trip the power supply to the valve, obviating the need for fire protection and meeting Appendix R.

C. EVALUATION An exemption from the Appendix R separation requirements is requested for this area. The exemption is justified based on our assertion that i additional modifications would not enhance fire protection safety which has been insured by the protective measures discussed in the " Analysis",

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