ML20072R976
| ML20072R976 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 03/22/1983 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20072R945 | List: |
| References | |
| NUDOCS 8304060526 | |
| Download: ML20072R976 (12) | |
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UNITED STATES 7
4y 3
g NUCLEAR REGULATORY COMMISSI.ON 5
.E WASHINGTON, D. C. 20555 m
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
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~RELATED TO EXEMPTION FR0tt 10 CFR 50, APPENDIX R ARKANSAS POWER & LIGHT COMPANY ARKANSAS NUCLEAR ONE, UNIT NO. 2-DOCKET NO. 50-368 1.0 Introduction By letter dated July 1,'1982, the Arkansas Power and Light Company (the licensee) requested exemptions from the technical requirements of Section III.G of Appendix R to 10 CFR 50 for various areas in Unit 2.
. By letter dated November 11, 1982, the licensee provided new proposals and additional clarifying information regarding the previous exemption requests.
Section III.G.2 requires that one train of cables and equipment necessary to achieve and maintain safe shutdown be maintained free of fire
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damage by one of the following means:
a.
Separation of cables and equipment and associated non-safety f
circuits of redyndant trains by a fire barrier having a three-hour rating. Structural steel forming a part of or supporting such fire barriers shall be protected to provide fire resistance equivalent to that required of the barrier; b.
Separation of cables and equipment and associated non-safety circuits of redundant' trains by a horizontal distance of more than 20 feet with no intervening combustible or fire hazards'.
In' addition, fire detectors and an automatic fire suppression system shall be installed in the fire area; or c.
Enclosure of cables and equipment and associated non-safety circuits of one redundant train in a fire barrier having a one-hour
'rati n g.
In addition, fire detectors and an automatic fire supprossion system shall be installed in.the fire area.
l If these condition.s.are not met,Section III.G.3 requires alternative shutdown capability independent of the fire area of concern.
It also requires a fixed suppression system in the fire area of concern if l
it contains a large concentration of cables or other combustibles.
These~ alternative requirements are not deemed to be equivalent; however, they provide equivalent protection for those configurations in which they are accepted.
Because it is not possible to predict the specific conditions under which fires may occur and propagate, the design basis protective features are specified in the rule rather than the design basis fire.
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or Plant s'pecific features may require protection different than the measures specified in Section,III.G.
In such a case, the licensee must demonstrate, by means of. a detailed fire hazards analysis, that existing protection or existing protection in conjunction with proposed modifications will provide a level of safety equivalent to the technical requirements of Section III.G of Appendix R.
In summary,Section III.G is related to fire protection features for ensuring that systems and associated circuits used to achieve -and maintain safe shutdown are free of fire damage.
Fire protection configurations.must either meet the specific requirements of Section III.G or an alternative fire protection configuration must be justified by a fire hazards analysis.
Our general criteria for accepting an alternative ' fire protection con-figuration are the following:
- The alternative assures that one train o,f equipment necessary to achieve hot shutdown from either the control room or emergency control gtations is free of fire damage.
- The alternative assures that fire damage.to at least one train of equipment necessary to achieve cold shutdown is limited such that it can be repaired within a reasonable time (minor repairs with components
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stored on-site).
- Modifications required to meet Section III.G would not enhance fire protection safety above that provided by either existing or proposed alternatives.
- Modifications required to meet Section III.G would be detrimental to overall facility safety.
2.0
' Intake Structure 2.1.1 Discussion - Below E1. 354' l
The intake structure consists of three floor levels (i.e. below El'. 354',
l El. 354' & El. 366').
The first level is below El. 354' and contains circulating water piping, associated valves and power cables. The power cables for redundant pumps are separated by less than 20 feet.
This floor level is the pump intake bay for the service water pumps and is therefore partially filled with water.. The licensee proposes to reroute cables to provide greater than 20 feet of separation.
Portable fire extinguishers, manual hose reels, and ionization detectors are provided throughout the area.
2.1.2 Evaluation - Below El. 354' After the proposed cable rerouting, this zone will have 20' separation and automatic detection but will not have an automatic suppression system as required by Section III.G.
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n This zone consksts of the service water pump intake bays. Therefo re, the water level in the intake bays precludes the possible accumulation of transient ' combustible materials as expected in other plant areas.
Because the likelihood of an exposure fire is low, these alternative features compensate for the required suppression system and provide a level of fire protection equivalent to that reqoired by Section III.G of Appendix R, and therefore are acceptable.
2.1.3 Conclusion - Below El. 354' Based on the above evaluation, the fire protection provided below El. 354', with the proposed modifications, provides a level of fire protection equivalent to the technical ' equirements of Section III.G r
of Appendix R, and therefore, the exemption should be granted.
I 2.2.1 Discussion - El. 354 The second floor level of the Intake Structure is at El. 354' and contains redundant cables in conduits for the service water pumps and
' discharge valves. The redundant cables at this level are routed vertically and are separated by more than 20 feet. The in-situ com-bustible loading at this elevation consists primarily of cable insulation.
This fire area is provided with portable fire extinguis'hers, manual hose stations and a smoke detection syszem.
The licensee proposes to reroute all cables required for the service water pump motors to provide greater than 20 feet pf separation and to enclose one train of pump power cabling in a one-hour rated fire barrier.
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2.2.2 Evaluation - El. 354' With the proposed rerouting of cables and a one-hour barrier, this area will not comply with Section III.G. becau.se an automatic suppression system is not provided.
In the event of an exposure fire involving transient combustible materials, there will be a time lag between the ignition of the fire, detection and alarm, and the fire brigade response.
It is our opinion that the proposed configur,ation of cables and one-hour barrier will provide protection against the thermal flux of an exposure fire for a sufficient period of time to enable the fire b'rigade to respond and extinguish a fire prior to damage of both trains.
2.2.3 Conclusion - El. 354' The level of existing protection in conjunction with the proposed modifications in the Intake Structure, El. 354', provides a level of fire protection equivalent to the technical requirements of Section III.G of Appendix R; therefore, the exemption should be granted.
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2.3.1 Discussion - El. 366' The uppermost level of the intake structure is at El. 366' and contains the A and B trains and swing service water pump motors, associated valves and cables and the ventilation equipment for the intake structure. Redundant trains of safe shutdown equipment are separated by less than 20 feet. Missile barriers provided between-each pump also act as radiant energy shields..
i The in-situ combustibles at this level consist of one non-safety related cable tray and approximately 131/2 gallons of lubricating oil in each service water pump motor.
Floor drains are provided in the vicinity of l
each pump to collect and drain any potential lube oil leaks. Portable I
fire extinguishers, manual hose reels, and an ionization-type smoke detection system are provided throughout the area. The licensee pro-poses to install an automatic sprinkler system for the protection of j
the three service water pump motors.
2.3.2 Evaluation - El. 366' This zone does not have 20 feet of separation free of intervening combustibles or a complete automatic suppFession system as required in l
Section III.G.
The three service water pumps and valves are located l
at El. 366'.
The separation distance between pumps is less than 20 feet.
The partial width missile barriers do not completely enclose one train of components. Their effectiveness is therefore limited to acting as a thermal energy barrie'r to a fire exposure in a single direction. Because it is not possible to predict the conditions and locations under which exposure fires may occur, partial barriers alone do not provide reasonable assurance that both trains of redundant components will be maintained free of fire damage from any anticipated exposure fire.
Due to the' low in-situ combustible loading in th'e intake structurei it is our' opinion that the partial width missile barriers in conjuction' t
I with the proposed automatic sprinkler system will provide adequate assurance that one train of service water pumps will be maintained free of fire damage.
Y 2.3.3 Conclusion - El. 366' l
l Based on the above evaluation, th'e existing fire protection for the Intake, Structure at El. 366' provides a level of protection equivalent to the technical requirements of Section III.G of Appendix R and.
thereform, the exemption should be granted.
l 3.0 Yard Area Manholes, 2MH01E, 2MH02E, 2MH03E 3.1 Discussion This fire area consists of three manholes which are concrete bunkers approximately 7 feet by 7 feet by 8 feet, and are located remotely from the remainder of the plant. The manholes are not ventilated and can be accessed only by lifting the concrete hatches with a crane.
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or T'he licensee proposes to fill the manholes with a non-combustible material such as sand or vermiculite, 3.2 _ Eval uation The redundant service water pump cables in the manholes are neither separated by 20 feet. nor enclosed in one-hour barriers. Smoke detection, automatic suppression, and alternate shutdown capability are not provided.
The licensee proposes to fill the manholes with sand or vermiculite.
This will prevent a fire from occurring in the manholes and, therefore, an acceptable level of fire protection has been provided.
- 3. 3 Concl usion The level of protection for the yard area manholes 2MH01E, 2MH02E, and 2MH03E provides a level of fire protection equivalent to the technical requirements of Section III.G of Appendix R; therefore, the exemption should be granted.
4.0 General Access Area, El. 317' (Fire Zone 2006 LL)
East Pumo Area, El. 317' (Fire Zone 2007 LL) 4.1 Discussion By letter dated November 11, 1982, the licensee committed to install automatic suppression in these areas, thereby complying with Section III.G. The exemption requests are therefore withdrawn.
5.0 _ Pump Room (Fire-Zone 2024JJ) 5.T Discussion r
~ This fire area contains the steam turbine driven. emergency feedwater i
pump.
The boundary walls, floor, and ceiling assemblies are reinforced I
concrete with a three-hour rating.
Penetrations through these walls will be upgraded to a three-hour rating, with the exception of the door to the room.
Because of other safety requirements, this door is required to be a one inch thick watertight. door, and is consequently non-fire-rated.
The redundant motor-driven feedwater pump is located in an adjacent room of similar construction, with the same type of watertight access door.
The in-situ combustible loading in the steam-turbine driven pump 2
room is approximately 2200 BTV/FT, which, if totally consumed, would produce an equivalent fire severity on the ASTM E-119 standard time-t temperature curve of less than two minutes.
The in-situ combustible loading in the redundant motor-driven pump room is approximately 3100 BTV/FT2 which, if totally consumed, would produce an equivalent fire severity on the ASTM E-119 standard time-temperature l
curve of less than three minutes.
A smoke detection system is pr'ovided i
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i~n the area.
Portable fire extinguishers and manual hose stations are readily accessible in adjacent areas.
The licensee requests an exemption from providing a three-hour rated fire door for the emergency feedwater pump rooms 'on the basis of the low combustible loading in the area, the existing ability to promptly detect and manually extinguish fires, and the inherent fire resistance of the steel watertight doors.
5.2 Evaluation The licensee has provided a three-ho'ur rated fire barrier for the separation of redundant trains of emergency feedwater pumps. The watertight access door installed in this fire barrier is not an approved
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three-hour rated fire door a.nd therefore could permit the spread of fire in less than three hours.
I The combustible loading in this area is substantially lower than needed for a fire of three-hours duration. An exposure fire would therefore be of limited severity and duration.
The design of the watertight door provides a degree of inherent fire protection.
It is our experience
'that typical watertight doors provide equivalent protection as three-hour rated fire doors.
This combination.of features provides reasonable assurance that.a fire 1
in this area will be detected and extinguished before the redundant emergency feedwater pump is damaged.
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The level of existing protection for this area provides a level of fire protection equivalent to the technical requirements of S.ection III.G of. Appendix R.
Therefore, the exemption should be granted.
6.0 _C_ontainment Building (Fire Zones 2032X and 2033K) 6.1 Discussion The containment building has been subdivided into two fire areas. There is no fire barrier between the two fire areas. The separation of cables and equipment-within each fire area is such that only one division of l.
equipment is located in each fire area. With the exception of the Reactor Coolant System (RCS) pressure instrumentation, the minimum separa.
tion distance between redundant equipment in the containment building is greater than 30 feet, however there are several non-safety related cable trays which pass from one fire area to the other.
The licensee has provided fire stops in the cable trays to prevent the spread of flames among the cables.
l The fire area in the north half of the containment building contains two shutdown cooling drop line (RHR letdown) valves, in series. The licensee states that a spurious operation of both valves could cause a loss of reactor coolant.
The. spurious signal required for this action would have to be a short, phase to phase, in a specific manner involving the r_,_
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or power cables, which are routed in close proximity in this area. Both areas are protected by a partial coverage smoke detection system. Manual hose stations and an oil collection system for the reactor coolant pumps are provided.
The fire area in the south half of the containment building contains all four channels for RCS pressure indication. A junction box for each channel is situated outside the secondary shield wall near the pressurizer.
The Channel 1 and Channel 4 junction boxes are separated by 17 feet. Due to the angular shape of the wall in.this area, each junction box is
- partially shielded from a fire involving the other by a corner of the concrete barrier.
From the junction boxes, the conduits for the pressure indicators are embedded in concrete and routed to the cable penetratioh area.
6.2 Eval uation Inside non-inerted containment,Section III.G.2 requires the separation of cables and equipment and associated non-safety circuits of redundant trains by a horizontal distance of more than 20 feet with no intervening combustibles or fire ~ hazards. The arrangiment of cables and equipment inside containment does not meet this requir'ement where the non-safety related cable trays pass between divisions. The licensee has installed fire stops in these cable trays to prevent the spread of flame along the cables. Due to the restricted access to this area, the probability.of an exposure fire from the accumulation of transient combustibles and which could potentially bypass the cable tray fire stops is unlikely.
Therefore, the fire stops-installed in the intervening cable trays will provide reasonable assurance that one train will be maintained free of fire damage.
The spurious operation of the decay heat drop line valves could potentially -
cause the loss. of reactor coolant from the primary system. The licensee has analyzed the conditions under which a simultaneous spurious operation -
of both valves could occur and found that a fire involving the power cable conduits to both -valves which would cause a short, phase to phase, is necessary.
Because the amount of in-situ combustibles is low in this area-and early warning detection provided, a fire in this area which could damage both conduits is unlikely.
Further, it is unlikely that fire damage would occur in the specific manner required. This combination
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of conditions provides reasonable assurance that a spurious operation of both valves is not likely to occur.
The RCS pressure instrumentation is separated by 17 feet instea; of 20 feet. Additionally, a concrete missile barrier provides a partial radiant energy shield between the redundant instrumentation channels.
Because of the unliksly nature of significant fire occurrence inside
_ containment and the mitigating effects of the intervening missile barrier, there is reasonable assurance that one train will be maintained free of fire damage.
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- . 8-6.3 Conclusion The level of protection inside containment provides a level of fire pro-tection equivalent to the technical requirements of Section III.G of Appendix R.
Therefore, the exemption should be granted.
7.0 Tank Rooms, Pump Rooms, and Corridors, El. 355' (Fire Zone 2040JJ) 7.1 Discussion
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This area contains several pump and. tank rooms and adjacent corridors.
The redundant equipment in this area consists of the three charging
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punps and associated cables. Walls, floors, and ceiling assemblies are reinforced concrete. The ceiling height in the area is 17 feet.
The charging pumps are separated by less than 20 feet and are in
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cubicles approximately 10 feet by 16 feet. The pump cubicles are separated by partial height concrete walls, eight feet high. The i
combustible loading in this area consists of 10 gallons of lubricating oil for each pump and several cable trays in an adjacent corridor. A cable tray is also located in two of the three pump cubicles.
The combustible loading added by the cable trays has not been quantified I
by the licensee, but is described as " moderately lo.aded with a fill of -
t approximately 20%". The cables are in open cable trays and are routed 8 to 12 feet above the floor. Cables for the A and' C trains are separated by approximately 10 feet, and cables for the B and C trains are separated by approximately 12 feet. At least one pump is required for -
The licensee proposes to modify the fire protection in this area.by enclosing the cables for two of the three charging pumps in a one-hour i
barrier and enclosing one train of the corridor area cable trays in a one-hour barrier for a sufficient length to permit 20 feet of horizontal separation between unprotected' redundant cables. The con-figuration of cables in this area involves redundant cable trays in two corridors, perpendicular to each other.
In addition to the 20 feet of separation provided by the proposed barrier, the corner of the concrete wall at the intersection provides a line-of-sight radiant energy shield between redundant cables. This area *is' provided with smoke detectors, portable extinguishers and manual fire hose stations.
7.2 Evaluation l'
This area does not comply with Section III.G because an. automatic suppression is not provided.
Because of the low in-situ combustible loading in this area, proposed one-hour barriers and intervening walls, and detection systen, it is our opinion that in the event of an exposure fire, redundant cables will be protected for a sufficient period to enable the fire brigade to respond and extinguish a fire prior to damage of both trains.
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7.3 ' Conclusion The level of protection in the charging pump area in conjunction with the proposed one-hour barriers provides a level of fire protection equivalent to Section III.G; therefore, the exemption should be granted.
8.0 Lower South Piping Penetration Area (Fire Zone 2055 JJ) 8.1 Discussion The piping penetration area is adjacent to the charging pump area. The fire area boundary wall separating the two areas is a concrete wall, brt does not carry a fire resistance rating. The licensee notes that this wall was previously a_ccepted, based on the low combustible loading in the area. The wall currently contains various penetrations and an open doomay. The A-train charging pump cable tray is located in the piping penetration area approximately 17 feet from the open doorway while the C-train cable tray is located in the adjacent area approxi-mately 24 feet from the doomay.
The B-train cable tray is also in this area.
The conbustible loading in the piping penetration area consists of three o~ pen cable trays.
The quantity of combustible cable insulation has not been provided, but is de' scribed as " moderate".
Smoke detection, portable extinguishers and manual hose stations are provided in both areas.
The licensee proposes to modify the fire protection in these areas by
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upgrading all ' penetrations through the boundary, wall to provide a three-hour rating, with the exception of ths doomay.
For the protec-tion of the doomay, the licensee notes that there are two doors which must be opened for passage between these areas. The first door is a fully louvered, hollow metal door. This door is equipped with a surface type intrusion alarm.swit'ch. :The second door is an air tight. door.
This door is designed such th&t it blows open with a pressure buildup in Zone 2055JJ of 0.25 psig to limit peak pressure within that zone.
This door is normally kept closed.
The licensee proposes to replace this outer metal door with a three-hour rated fire door with a modified latch in order to permit the door to open.on 0.25 psig internal pressure.
8.2 Evaluation Section III.G of Appendix R requires that individual fire areas be separated by three-hour rated fire barriers, justified fire barriers of lesser fire resistance or water curtains.
In this area, an open doorway violates the three-hour barrier and provides direct consnunication between two fire areas containing redundant trains of safe shutdown related cable. The proposed three-hour rated fire door with a modified latch is adequate for the fire hazard in these areas.
The pressures developed by a fire are typically very small.
The maximum pressures
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e expected from a fully developed fire are in the vicinity of 100 PA*,
i which is appmximately 1/1000 of atmospheric pressure, and much less than the.25 psig required to open this door.
I 8.3 Conclusion
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The protection provided for the piping penetration area provides a l
level of fire protection equivalent to the technical requirements'of Section III.G cf Appendix R.
Therefore, the exemption should be grant.ed.
9.0 Corridor, 'El. 372' (Fire Zone 2109U) s
'9.1 Discussion This corridor area is approximately 86 feet by 12 feet with a 12 foot ceiling. The floor, walls and ceiling assemblies are reinforced c
concrete with a three-hour rating. The fire area includes an access corridor to one of the diesel generator rooms.
The redundant cables and equipment in this area are the electrical distribution panels 2RS3 and 2RS4 and associated cables.
This equipment provides the power supply for safe shutdown instrumentation.
The two redundant distribution panels are wall mounted and separated by approximately
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18 feet.
Intervening combustibles between the panels include,
several ceiling level cable trays containing what the licensee l
describes as, "a large amount of cable insulation in open cable l
trays". Various transient combustibles could be introduced in this l
area during maintenance periods, including 55 gallon drums of lubricating oil.
The licensee proposes to modify the fire protection in this area by enclosing the conduits associated with one o.f the distribution panels in a one-hour rated fire barrier, and c'oating all intervening ' cables j
between the panels with a flame retardant coating.
A smo. e:de.tection system is provided throughout the corridor in k
addition 'to"1ine-typ'e heat ~ detectors in each cable tray. An automatic, open head sprinkler system, portable fire extinguishers and manual fire hose stations are also installed in the area. The licensee l
contends that the proposed modifications, combined with the existing fire protection, will maintain one train of distribution panels and cables free of fire damage.
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- Butcher, E.G., & Parnell, A.C., " Smoke Control in Fire Safety Design",
E&F.ft. Spon, London, 1979, page 34.
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s AU0-2 11-9.2 Evaluation The redundant components in this area are'not separated by one-hour rated fire barriers or 20 feet free of intervening contdstibles.
The early warning detection system and automatic water deluge system will ensure that any fires are promptly detected and suppressed. The intervening combustibles between the redundant panels are located above the panels at the ceiling level.. The coating o'f all intervening cables with a flame retardant coating, which is not equivalent to a one-hour barrier, but which will retard the propagation of flame, and '
enclosing one train of conduits for the distribution panels, which rise vertically to the ceiling level,.in a one-hour fire rated barrier will provide enhanced protection for the distribution panels and will reduce the probability of damage to both trains prior to activation of the corridor detection and suppression system.- The proposed modifica-tions in conjunction with the existing detection and automatic deluge system will provide an alternative protection system that gives reasonable assurance that one train of distribution panels will be maintained free of fire damage.
9.3 Conclusion The existing protection for this area in conjunction with the proposed one-hour fire rated barrier and flame retardant coating of intervening cable trays provides a level of fire protection equivalent to the technical requirements of Section III.G of Appendix R.
Therefore the exemption should be granted.
10.0 Fixed Fire Suppression for Eiaht Areas 10.1 Discussion The licensee has provided al' ternate shutdown capability for the following areas in Unit'2:
a) Upper North Piping Penetration Area (Fire Zone 2081HH) b) lbtor Control Center (Fire Zone 2096M) c) Electrical Equipment Room El. 368' (Fire Zone 2091BB) d) -Corridor Area (Fire Zone 2107N) e) Pipeway & Equipment Access Way (Fire Zone 2223KK) f) Pump Room (Fire Zone 2106R) g) Core Protection ' Calculator Panel (Fire Zone 2150C) h) Health Physics Area (Fire Zone 2136I)
The combustible loading in these zones is negligible.
The redundant
. equipment in these areas is primarily one system, the diesel fuel transfer pumps. The licensee requests an exemption from pmviding fixed extinguishing systems in these areas and detection for fire zones 2081HH and 2136I.
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- n 10.2 Evaluation All of the fire zones for which exemptions have been requested repre-sent a similar configuration, i.e., combustible loading is light, them is alternate shutdown capability, and manual fire suppression equipment is available. The low combustible loading in these areas ensures that safety related equipment in adjacent areas will not be threatened.
The installation of a fixed fire suppression system in all these areas and detection for fire zones 2081HH and 21361 will not significantly increase' the level of fire protection in these areas.
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10.3 Concl usion Based on our evaluation, we find that the existing fire protection in conjunction with alternate shutdown capability in the areas for which an exemption has been requested provides a level of fire protection
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equivalent to the technical requirements of Section III.G.3 of Appendix R and, themfore, the exemptions should be granted.
Sumary - Unit 2
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Based on our evaluation, we find that the protection provided for the following areas provides a level of fire protection equivalent to the technical requirements of Section III.G of Appendix R and exemptions should therefore be granted:
2.1 Inthke Structure', Below El. 354' 2.2 Intake Structure, El. 354' 2.3 Intake Structure, El. 366' 3.0 Yard Area Manholes, 2MH0lE, 2MH02E,' 2MH03E 5.0 Pump Room (Fire Zone 2024JJ)
,6. 0 Containment Building (Fire Zones 2032K and 2033K) 7.0 Tank Rooms, Rump. Rooms, and Corridors E1. 355' (Fire Zone 2040JJ) 8.0 Lower South Piping Penetration Area (Fire Zone 2055JJ) 9.0 Corridor, El. 372' (Fire Zone 2109U) 10.0 Fixed Fire Suppression for Eight Areas:
a)
Upper North Piping Penetration Area (Fire Zone 2081HH) b) Motor Control Center-(Fire Zone 2096M) c) Electrical Equipment Room, El. 368' (Fire Zone 2091BB) d) Corridor Area (Fire Zone 2107N) e) Pipeway and Equipment Access Way (Fire Zdne 2223KK) f)
ump Room (Fire Zone 2106R) n g)
Core Protection Calculator Panel (Fire Zone 2150C) h) Health Physics Area (Fire Zone 21361)
The exempt. ion requests for the following areas were withdrawn when the licensee committed to install automatic suppression in them to comply with Section III.G:
a)
General Access Area, El. 317' (Fire Zone 2006LL) b)
East Pump Area, El. 317' (Fire Zone 2007LL).
Dated: March 22,1983 Principal Contributors:
R. Eberly, C. Vissing, O. D. T. Lynch, Jr.
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