ML20099G699

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Forwards Clarification & Addl Info of Draft SER Open Items 74,75,77-80,82 & 84 Re Fire Protection,Per 850228 Telcon Request.Info Provided Will Be Incorporated Into Upcoming FSAR Amends
ML20099G699
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 03/08/1985
From: Bailey J
GEORGIA POWER CO.
To: Adensam E
Office of Nuclear Reactor Regulation
References
GN-552, NUDOCS 8503150060
Download: ML20099G699 (31)


Text

- - . .. _ - _ -

Georg.a Power Company Project Marugement Rout 3 2. Box 299A Waynesboro, Georgia 30830 Telephone 404 7244114 404 554 9961 Vogtle Project March 8, 1985 Director of Nuclear Reactor Regulation File: X6BB06 Attention Ms. Elinor G. Adensam, Chief Log: GN-552 Licensing Branch 94 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555 NRC DOCKET NUMBERS 50-424 AND 50-425 CONSTRUCTION PERMIT NUMBERS CPPR-108 AND CPPR-109 4

VOGTLE ELECTRIC GENERATING PLANT - UNITS 1 AND 2 DRAFT SER OPEN ITEMS 74, 75, 77 THRU 80, 82, AND 84 FIRE PROTECTION

Dear Mr. Denton:

Attached for your review are five (5) copies of information related to our draft open items 74, 75, 77 thru 80, 82, and 84 concerning the VEGP Fire Protection Program. These items were discussed in the February 28, 1985, telephone conference call with your staff. The attachment provides the clarification and additional information requested by the staff and will be incorporated into the upcoming amendments to the FSAR. The response to open items 77 and 78 in our letter dated February 22, 1985, is unchanged. It is GPC's intention to comply with the requirements of CMEB 9.5-1 Sections C.5.b and C.S.c; therefore these items should be confirmatory.

If your staff requires any additional information please do not hesitate to contact me.

Sincerely, o \*

J. A. Bailey Project Licensing Manager JAB /RLK/caa Attachment xc: D. O. Poster G. F. Trowbridge, Esquire J. E. Joiner, Esquire C. A. Stangler L. Fowler M. A. Miller L. T. Gucwa G. Bockhold, Jr.

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Open Item: 74 Fire Doors SER Section: 9.5.1, C.5.a Putc Branch CMEB (Fire Protection)

Description:

1. Door openings in. fire barriers will be protected with equivalently rated doors, frames,'and hardware except'for watertight doors (which are not fire rated by UL), pressure-retaining doors (which will have a certificate of UL label construction applied by the vendor), and security doors (which will have a certificate of UL label construction applied by the vendor). The applicant also states that only those fire doors that serve a security function are electrically supervised and monitored in the main control room. Doors designed to remain open to maintain post-accident (pipe break) pressures within design limits are normally held open and released only when smoke is detected. Other doors are kept closed. On the basis of its review, the staff will require the applicant to indicate the type of door and the method of supervision provided for each door opening in the plant that is not of a

. labeled fire door assembly. The applicant should also justify the adequacy of the special-purpose doors when used in rated fire barriers.

This information is needed for the staff to independently determine that door openings in fire barriers satisfy the guidelines of BTP CMEB 9.5-?.,

Section C.5.a(5). This is an open item.

Response

There are door openings that are required to be designed for pressure loads, bullet resistance, and the combined requirement of pressure and bullet resistance. The doors are specially designed to meet the Vogtle criteria and therefore never generically tested, as are typically fire rated hollow metal doors. Each door has been-fabricated to listed UL label procedures for a.UL 3-hour rating and the NFPA 80 and 252 standards. The construction of each door is certified by a certificate of fire label construction by the manufacturer. The manufacturer cannot affix a label to these doors and frames because they are a special design for the Vogtle project and have not-been subjected to an actual physical UL fire test. In each case the thickness of the metal used to construct the door frame, door skin, stiffeners, strike and butt reinforcements exceed the thickness of metal used in standard fire-rated doors and frames. The watertight doors used at Plant Vogtle are manufactured by the Julius Mock Company. Similar doors have been used at SNUPPS and Limerick. In addition, Baltimore Gas and Electric has tested this; type of door and received a UL rating as a special purpose door. The pressure tight doors used at Plant Vogtle are manufactured by Overly and similar doors have been installed and approved for use at Grand Gulf by the NRC Region I office.

The designated fire barriers containing unrated hatch covers will remain-designated until the safe shutdown analysis is completed in September 1985.

-When the analysis is completed, the barriers that do not separate redundant safe shutdown. equipment will be deleated. A fire propagation and effects analysis will be performed for the remaining barriers to justify the use of

'the unrated hatch covers.

In the case of the security doors, all doors that do not fall into the categories mentioned above are labeled class A fire doors.

m

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

A fire analysis of adjacent fire areas separated by the unlabeled doors and metal hatches is provided below:

Results of Fire Analysis for Unlabeled _ Doors

.A. Unrated Fire Door 105 - Auxiliary Application Watertight Fire Area Separation I-AB-LD-B & 1-AB-L1-E Fire Area Fire Area i Item 1-AB-LD-B l-AB-L1-E I

j Cable Chase Balance of Area g Fire load, Ib. 2,913 78,962 17,636 i cable insulation Fire severity, min 6.2 hrs. 73 62 t

Conclusion Should a fire spread through both fire areas, safe shutdown of the plant is l

not compromised due to the following reasons:

1. Although train A and B VCT isolation valves, of the same safety i

system, are located within fire area 1-AB-LD-B, an alternate means

' via administrative action is available such that safe shutdown is not precluded.

1 Although train A and B valves, of the same safety system located j between the boric acid tank and charging pumps are located within I

fire are 1-AB-LD-B, an alternate means via the RWST is available to {

! deliver borated water to the reactor coolant system.

Although train A and B valves, of the same safety system, located between the AFW pumps and the steam generators are located within fire are 1-AB-LD-B, an alternate means is available such that safe l shutdown is not precluded. There are a total of 8 train A and B valves, but only two are required to bring the plant to a safe shutdown condition.

i

, 2. The cable chase in fire area 1-AB-LD-B is equipped with automatic l sprinkler protection.

i 1

3. Each fire area has been provided with early warning detection 3,

features.

i j B. Unrated Fire Door 106 - Auxiliary

{ Application Watertight l

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, w - e - - ,,,----,,,--n- - - - - - - - - - -n v .-------n---

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1 4 I Fire Area Separation 1-AB-LD-B & 1-AB-L1-D l Fire Area Fire Area Item 1-AB-LD-B l-AB-L1-D Cable Chase Balance of Area Fire'_ load, lb 2,913 78,962 17,636 j- cable insulation Fire severity, min 6.2 hrs. 73 62 Conclusion Should a fire spread through both fire areas, safe shutdown of the plant is not compromised due to the following reasons:

1. Combining the safe shutdown equipment in both areas.does not produce any redundant safety-related trains of the same safety system.

i 2. The cable chase in fire area 1-AB-Ll-D as well as fire area l.

l-AB-L1-D is equipped with automatic sprinkler protection.

] 3. Each fire area has been provided with early warning detection

features.

C. Unrated Fire Door D36 - Auxiliary Application Watertight l

Fire Area Separation -AB-LD-B & 1-AB-LD-A Fire Area Fire Area Item 1-AB-LD-B l-AB-LD-A Balance Elect RHR Wing 4 Cable Chase of Area chase Pump Area

! Fire load, Ib 2,913 78,962 12,850 1,143 2,244 cable insulation i

Hydraulic Fluid - - - -

894 Fire Severity, min 6.2 hrs. 73 109 41 3 2

, Conclusion i Should a fire spread through both fire areas, safe shutdown of the plant

, is not compromised due to the following reasons:

-- , , - . -- - - - - -- x.. . - , - , . - - - - , .-

l l

l

1. Although train A and B VCT isolation valves, of the same safety l system, are located within fire are 1-AB-LD-B, an alternate means via administrative action is available such that safe shutdown is not precluded.

Although train A and B valves, of the same safety system, located between the boric acid tank and charging pumps are located within fire area 1-AB-LD-B, an alternate means via the RWST is available to deliver borated water to the reactor coolant system.

Although train A and B valves, of the same safety system, located between the AFW pumps and the steam generators are located within fire are 1-AB-LD-B, an alternate means is available such that safe shutdown is not precluded. There are a total of 8 train A and B valves, but only two are required to bring the plant to a safe shutdown condition.

2. The cable chase in fire area 1-4B-LD-B as well as fire area 1-AB-LD-A are equipped with automatic sprinkler protection
3. Each fire are has been provided with early warning detection features.

D. Unrated Fire Door C56 - Auxiliary Application Watertight Fire Area Separation I-AB-LC-D & 1-AB-LC-G Fire Area Fire Area Item 1-AB-LC-D l-AB-LC-G Fire Load, lb 1,189 11,811 cable insulation Fire severity, min 25 18 Conclusion Should a fire spread through both fire areas, safe shutdown of the plant is not compromised due to the following reasons:

1. Combining the safe shutdown equipment in both areas does not produce any redundant safety-related trains of the same safety system.
2. Both fire areas are equipped with automatic sprinkler protection.
3. Each fire area has been provided with early warning detection features.

E. Unrated Fire Door 123 - Auxiliary Application Watertight

Fire Area Separation 1-AB-Ll-A & 1-AB-LD-B Fire Area Fire Area Item 1-AB-L1-A 1-AB-LD-B Balance Aux Bldg Fuel Bldg Cable Chase of Area Fire load, lb 1,386 1,470 2,913 78,962 cable insulation Fire severity, min 3 1 6.2 hrs 73 Conclusion should a fire spread through both fire areas, safe shutdown of the plant is not compromised due to the following reasons:

1. Although train A and B VCT isolation valves, of the same safety system, are located within fire area 1-AB-LD-B, an alternate means via administrative action is available such that safe shutdown is not precluded.

Although train A and B valves, of the same safety system, located between the boric acid tank and charging pumps are located within fire area 1-AB-LD-B, an alternate means via the RWST is available to deliver borated water to the reactor coolant system.

Although train A and B valves, of the same safety system, located between the boric acid tank and charging pumps are located within fire area 1-AB-LD-B, an alternate means is available such that safe shutdown is not precluded. There are a total of 8 train A and B valves, but only two are required to bring the plant to a safe shutdown condition.

2. The cable chase in fire area 1-AB-LD-B is equipped with automatic sprinkler protection.
3. Each fire area has been provided with early warning detection features.

F. Unrated Fire Door D49 - Auxiliary Application Watertight Fire Area Ceparation 1-AB-LD-J & 1-AB-LD-G Fire Area Fire Area Item 1-AB-LD-J 1-AB-LD-G  !

l Fire load, Ib 14 4,042 cable insulation Fire severity, min 2 16

Conclusion Should a fire spread through both fire areas, safe shutdown of the plant is not compromised due to the following reasons:

1. Combining the safe shutdown equipment in both areas does not produce any redundant safety-related trains of the same safety system.
2. Fire area 1-AB-LD-G is equipped with automatic sprinkler protection.
3. Each fire area has been provided with early warning detection features.

G. Unrated Fire Door D34 - Auxiliary Application Watertight Fire Area Separation I-AB-LD-B & 1-AB-LD-D Fire Area Fire Area Item 1-AB-LD-B l-AB-LD-D Cable Chase Balance of Area Fire load, lb 2,913 78,962 2,216

, cable insulation Fire severity,inin 6.2 hrs 73 35 Conclusion should a fire spread through both fire areas, safe shutdown of the plant is not compromised due to the following reasons:

1. Although train A and B VCT isolation valves, of the same safety system, are located within fire area 1-AB-LD-B, an alternate means via administrative action is available such that safe shutdown is not precluded.

Although train A and B valves, of the same safety system, located between the boric acid tank and charging pumps are located within fire area 1-AB-LD-B, an alternate means via the RWST is available to deliver borated water to the reactor coolant system.

Although train A and B Valves, of the same safety system located between the AFW pumps and the steam generators are located within fire area 1-AB-LD-B, an alternate means is available such that safe shutdown is not precluded. There are a total of 8 train A and B valves, but only two are required to bring the plant to a safe shutdown condition.

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2. The cable chase in fire area 1-AB-LD-B as well as fire area 1-AB-LD-D are provided with automatic sprinkler protection.
3. Each fire area has been provided with early warning detection features.

H. Unrated Fire Door D47 - Auxiliary Application Watertight Fire Area Separation I-AB-LD-I & 1-AB-LD-G

'- Fire Area Fire Area Item 1-AB-LD-I l-AB-LD-G

! Pipe & Pump i Elect. Chase Room Fire load, Ib 2,534 6,874 4,042 cable insulation Fire severity, min 5.4 hrs. 29 16 Conclusion should a fire spread through both fire areas, safe shutdown of the plant is not compromised due to the following reasons:

4

1. Although train A and B level transmitters of the same safety system are located within fire area 1-AB-LD-G, they are located in the boric acid storage tank room, which is bounded by a minimum of 3 feet of concrete, including the ceiling equipment hatch. There are no combustible materials in this room.
2. Both fire areas are equipped with automatic sprinkler protection.

3.- Each fire area has been prove.44 vith early warning detection i features.

I. Unrated Fire Door 1/? e h ol

. Application Airtight and pressure resistant Fire Area Separation 1-CB-LB-S & 1-CB-LC-B Fire Area Fire Area Item 1-C B-LB-S - 1-C B-LC-B

' Fire load, lb None. 24,959

-cable insulation Fire severity, min None 22.2 l

Conclusion should a fire spread through both fire areas, safe shutdown of the plant is not compromised due to the following reasons:

1. Combining the safe shutdown equipment in both areas does not produce any redundant safety-related trains of the same safety '

system.

2. Fire area 1-CB-LC-B is equipped with automatic sprinkler protection.

I 3. Each fire area has been provided with early warning detection features.

4. The pressure door has been certified by the manufacturer that the door's construction has been in accordance with the 3-hour U.L.

approved procedures.

J. Unrated Fire Door 253 - Control Application Airtight and pressure resistant 1

Fire Area Separation 1-CB-LB-S & 1-CB-L2-E Fire Area Fire Area Item 1-CB-LB-S 1-CB-L2-E Fire load, Ib

1. Cable insulation None 6,859
2. Cleaning fluid 67
3. Paper product 550
4. Hydrogen Small

, quantity Fire severity, min None 10.6 Conclusion 3

Should a fire spread through both fire areas, safe shutdown of the plant is not compromised due to the following reasons:

1. Combining the safe shutdown equipment in both areas does not i

produce any redundant safety-related trains of the same safety system.

2. Fire area 1-CB-L2-E is equipped with automatic sprinkler protection.
3. Each fire area has been provided with early warning detection features, l
4. 'The pressure door has been certified by the manufacturer that the door's construction has been in accordance with the 3-hour U.L. J approved procedures.

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1 K. Unrated Fire Door 104 - Diesel generator Bldg.

Application Pressure resistant Fire Area Separation 1-CB-LB-A & 1-DB-L1-A Fire Area Fire Area Item 1-CB-LB-A 1-DB-L1-A I l

Fire load, Ib

1. Cable insulation 75,670 10,030
2. oil 11,500 Fire severity, min 60.6 88 Conclusion Should a fire spread through both fire areas, safe shutdown of the plant is not compromised due to the following reasons:
1. Combining the safe shutdown equipment in both areas does not produce any redundant safety-related trains of the same safety system.
2. Fire are 1-CB-LB-A is equipped with automatic sprinkler protection.
3. Each fire area has been provided with early warning detection features.
4. The pressure door has been certified by the manufacturer that the door's construction has been in accordance with the 3-hour U.L.

approved procedures.

L. Unrated Fire Door CO2 - Fuel Application Pressure resistant l

l Pire Area Separation 1-CB-LC-A & 1-AB-LC-B Fire Area Fire Area Item 1-CB-LC-A 1-AB-LC-B Fire load, lb 33,605 18.328 l cable insulation I l

Fire severity, min 67 29 Hrs.

Conclusion j Should a fire spread through both fire areas, safe shutdown of the plant  !

is not compromised due to the following reasons:

l l

1. Combining the safe shutdown equipment in both areas does not produce any redundant safety-related trains of the same safety system.
2. Both fire areas are equipped with automatic sprinkler protection.
3. Each fire area has been provided with early warning detection features.
4. The pressure door has been certified by the manufacturer that the door's construction has been in accordance with the 3-hour U.L.

approved procedures.

M. Unrated Fire Door 333 - Control.

Application Airtight and pressure resistant Fire Area Separation 1-CB-LB-S & 1-CB-L3-K Fire Area Fire Area Item 1-CB-LB-S 1-CB-L3-K Fire load, Ib

1. Cable insulation None 13,246
2. Charcoal 967 Fire severity, min None 60 Conclusion Should a fire spread through both fire areas, safe shutdown of the plant is not compromised due to the following reasons:
1. Combining the safe shutdown equipment in both areas does not produce any redundant safety-related trains of the same safety system.
2. Fire area 1-CB-L3-K is equipped with automatic sprinkler protection.
3. Each fire area has been provided with early warning detection features.
4. The pressure door has been certified by the manufacturer that the door's construction has been in accordance with the 3-hour U.L.

approved procedures.

5. The charcoal filtration unit is provided with a self-contained water spray system.

N. Unrated Fire Door 182 - Control Application Airtight and pressure resistant  !

l I

i . _ m - _ _ .. _ _ _ __ ... _

Fire Area Separation 1-CB-LB-S & 1-CB-L1-B Fire Area Fire Area Item 1-CB-LB-S 1-CB-L1-B Fire load, lb' material None 6,868 j cable insulation Fire severity, min None 158 Conclusion

'Should a fire. spread through both fire areas, a safe shutdown of the

plant is not compromised due to the following reasons

l 1. Combining the safe shutdown equipment in both areas does not produce any redundant safety-related trains of the same safety system.

3

2. Fire area 1-CB-Ll-B is equipped with automatic sprinkler protection.
3. Each fire area has been provided with early warning detection_

features.

! 4. The pressure door has been certified by the manufacturer that the door's construction has been in accordance with the 3-hour U.L.

approved procedures.

i O. Unrated Fire Door 'A61 - Control f

! Application Pressure resistant Fire Area Separation 1-CB-LA-N & Stairwell 43-Fire Area Fire Area Item 1-CB-LA-N N/A Fire load, Ib 31,540 None cable insulation

! Fire severity, min 54 None conclusion should a fire spread through both fire areas, safe shutdown of the plant is not compromised due to the following reasons:

! 1. Combining the safe shutdown equipment in area 1-CB-LA-N does not produce any redundant safety-related trains of the same safety j system.

1 1

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, , ,-,4 , - - - , - - - . - - -, .-,.,--,.en, .,.,-.m.,~.-+---,-r, - - - -m-

2. Fire area 1-CB-LA-N is equipped with automatic sprinkler protection.
3. Fire are 1-CB-LA-N has been approved with early warning detection features.
4. The pressure door has been certified by the manufacturer that the door's construction has been in accordance with the 3-hour U.L.

approved procedures.

P. Unrated Fire Door 101 - Diesel generator bldg.

Application Pressure resistant Fire Area Separation 1-CB-LB-D & 1-DB-L1-B Fire Area Fire Area Item 1-CB-LB-D l-D B- Ll-B Fire load, Ib 59,500 10,030 cable insulation Oil 11,500 Fire severity, min 65.4 88 Conclusion Should a fire spread through both fire areas, safe shutdown of the plant is not compromised due to the following reasons:

1. Combining the safe shutdown equipment in areas does not produce any redundant safety-related trains of the same safety system.
2. Both fire areas are equipped with automatic sprinkler protection.
3. Each fire area has been provided with early warning detection features.
4. The pressure door has been certified by the manufacturer that the door's construction has been in accordance with the 3-hour U.L.

approved procedures.

Q. Unrated Fire Door B79 - Control Application Pressure resistant Fire Area Separation 1-CB-LB-A & Stairwell #3 Fire Area Fire Area Item 1-CB-LB-A N/A Fire load, Ib 75,670 None cable insulation

Fire severity, min 60.6 None Conclusion should a fire spread through both fire areas, safe shutdown of the plant is not compromised due to the following reasons:

1. Combining the safe shutdown equipment in area 1-CB-LB-A does not produce any redundant safety-related trains of the same safety system.
2. Fire area 1-CB-LB-A is equipped with automatic sprinkler protection.
3. Fire area 1-CB-LB-A has been provided with early warning detection features.
4. The pressure door has been certified by the manufacturer that the door's construction has been in accordance with the 3-hour U.L.

approved procedures.

R. Unrated Fire Door B98 - Control Application Pressure resistant Fire Area Separation 1-CB-LC-A & 1-CB-LB-A Fire Area Fire Area Item 1-CB-LC-A l-CB-LB-A Fire load, lb 33,605 75,670 cable insulation Fire severity, min 67 60.6 Conclusion should a fire spread through both fire areas, safe shutdown of the plant is not compromised due to the following reasons:

1. Combining the safe shutdown eqaipment in areas does not produce any redundant safety-related trains of the same safety system.
2. Both fire areas are equipped with automatic sprinkler protection.
3. Each fire area has been provided with early warning detection features.
4. The pressure door has been certified by the manufacturer that the door's construction has been in accordance with the 3-hour U.L.

approved procedures.

S. Unrated Fire Door S75 - Control Application Pressure resistant 4

Fire Area Separation 1-CB-LC-A & 1-CB-LA-F Fire Area Fire Area Item 1-CB-LC-A 1-CP-LA-F

! Fire load, lb 33,605 8,250 cable insulation j

Fire severity, min 67 17 Conclusion Should a fire spread through both fire areas, safe shutdown of the plant is not compromised due to the following reasons:

~

1. Combining the safe shutdown equipment in both areas does not produce any redundant safety-related trains of the same safety system.
2. Both fire areas are equipped with automatic sp.rinkler protection.

3.

Each fire area has been provided with early warning detection features.

i l 4. The pressure door has been certified by the manufacturer that the j door's construction has been in accordance with the 3-hour U.L.

approved procedures.

l T. Unrated Fire Door 1990 - Technical Support Center Application Airtight and pressure resistant l

Fire Area Separation 1-CB-L1-B & 1-CB-L1-TSC Fire Area Fire Area Item 1-CB-L1-B l-CB-L1-TSC Fire load, Ib

1. Cable insulation 821 1,278
2. oil 67 0
3. Paper product 1,850 200
4. Charcoal 0 1,450 Fire severity, min 2.3 97.5 Conclusion Should a fire spread through both fire areas, safe shutdown of the plant is not compromised due to the following reasons:
1. Combining the safe shutdown equipment in both areas does not produce any redundant safety-related trains of the same safety system.
2. The fire area 1-CB-L1-B is equipped with automatic sprinkler protection. The fire area (1-CB-L1-TSC) is equipped with Halon l 1301 in computer and communication room and wet pipe sprinkler system in the balance of the area.
3. Each fire area has been provided with early warning detection features.
4. The pressure door has been certified by the manufacturer that the door's ccnstruction has been in accordance with the 3-hour U.L.

approved procedures.

5. The charcoal filtration unit is provided with a self-contained water spray system.

Results of Fire Analysis for Unlabeled Metal Hatches A. Unrated Hatch Cover Auxiliary bldg. - Level 2 (wing)

Location Col. A19 & Ag Fire Area Separation 1-AB-LD-D & 1-AB-Ll-E Fire Area Fire Area Item 1-AB-LD-D l-AB-L1-E Fire load, Ib 2,216 17,636 cable insulation Fire severity, min 35 62 conclusion Should a fire spread through both fire areas, safe shutdown of the plant is not compromised due to the following reasons:

I

1. Combining the safe shutdown equipment in areas does not produce any redundant safety-related trains of the same safety system.
2. Both fire areas are equipped with automatic sprinkler protection.
3. Each fire area has been provided with early warning detection features.

B. Unrated Hatch Cover Auxiliary bldg. - Level 1 (wing)

Location Col. A19 &AC3 I

1 l

l l

i Fire Area Separation 1-AB-L1-D & 1-AB-LA-C Fire Area Fire Area Item 1-AB-L1-D l-AB-LA-C Fire load, lb 17,636 3,576 cable insulation Fire severity, min ,

62 13 Conclusion Should a fire spread through both fire areas, safe shutdown of the plant is not compromised due to the following reasons:

1. Combining the safe shutdown equipment in areas does not produce any redundant safety-related trains of the same safety system.
2. Both fire areas are equipped with automatic sprinkler protection.
3. Each fire area has been provided with early warning detection features.

C. Unrated Hatch Cover Auxiliary bldg. - Level 1 (wing)

Location Col. A19 &AG Fire Area Separation 1-AB-L1-E & 1-AB-LA-B Fire Area Fire Area Item 1-AB-L1-E l-AB-LA-B Fire load, Ib 17,636 3,576 cable insulation Fire severity, min 62 13 Conclusion Should a fire spread through both fire areas, safe shutdown of the plant is not compromised due to the following reasons:

1. Combining the safe shutdown equipment in areas does not produce any redundant safety-related trains of the same safety system. ,

l

2. Both fire areas are equipped with automatic sprinkler protection.

l

3. Each fire area has been provided with early warning detection (

features. l 4

D. Unrated Hatch Cover Auxiliary bldg. - Level A (wing)

Location Col. A19 &Ag 1

4 y

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

Fire Area Separation I-AB-LA-B & 1-AB-LB-B Fire Area Fire Area Item 1-AB-LA-B l-AB-LB-B 1- Fire load, Ib' 3,576 3,633

l. cable insulation i

Fire severity, min 13 11 i

i Conclusion should a fire spread through both fire areas, safe shutdown of the plant

is not compromised due to the following reasons
1. Combining the safe shutdown equipment in areas does not produce any

' redundant safety-related trains of the same safety system.

2. Both fire areas are equipped with automatic sprinkler protection.
3. Each fire area has been provided'with early warning detection i

features.

E. Unrated Hatch Cover Auxiliary bldg. - Level A.(wing)

Location Col. A19 &AC3 j

Fire Area Separation 1-AB-LA-C & 1-AB-LB-B Fire Area Fire Area Item 1-AB-LA-C 1-AB-LB-B Fire load, lb 3,576 3,633 cable insulation j Fire severity, min 13 11 i

conclusion f Should a fire spread through both fire areas, safe shutdown of the plant

is not compromised due to the following reasons
-

1 l 1. Combining the safe shutdown equipment in areas.does not produce any.

] redundant safety-related trains of the same safety system.

2. Both fire areas are equipped with automatic sprinkler protection.

[ 3. Each fire area has been provided with early warning detection

. features.

i 1

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+ . . , - . . . . . _ ,,_,,.~.,.+_m,,__,.y. - , ,,y . _., _ . ..,f ...p.,,_.y..y., y , _,,, ,m

_,_%. .,%_g, , , _ _p,, y _, ,. ,e.,_.

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

. F. -Unrated Hatch Cover Auxiliary bldg. - Level B (wing)

Location Col. A19 &AC2 Fire Area Separation 1-AB-LB-B & 1-AB-LC-G Fire Area Fire Area Item 1-AB-LB-B l-AB-LC-G Fire load, lb 3,633 11,811 cable insulation Fire severity, min 11 18 Conclusion should a fire spread through both fire areas, safe shutdown of the plant is not compromised due to the following reasons:

'l. Although train A and B pressure transmitters of the same safety system are located within fire area 1-AB-LC-G, an alternate means of determining the pressure levels is available such that safe 4 shutdown is not precluded.

2. Both fire areas are equipped with automatic sprinkler protection.

f 3. Each fire area has been provided with early warning detection features.

G. Unrated Hatch Cover Auxiliary bldg. - Level 2 (wing)

. Location Col. A19 &AC3 Fire Area Separation 1-AB-L2-F & 1-AB-L1-D Fire Area Fire Area i Item 1-AB-L2-F 1-AB-L1-D l

j Fire load, lb 1,260 17,636

  • cable insulation Fire severity, min 4 62 Conclusion Should a fire spread through both fire areas, safe shutdown of the plant is not compromised due to the following reasons:
1. Combining the safe shutdown equipment in areas does not produce any l redundant safety-related trains of the same safety system.
2. Both fire areas are equipped with automatic sprinkler protection.

.- .. . - ~.

3. Each fire area has been provided with early warning detection 4

features.

H. Unrated Hatch Cover Auxiliary bldg. - Level B (wing) l Location Col. A19 & Ag Fire Area Separation I-AB-LB-B & 1-AB-LC-F Fire Area Fire Area Item 1-AB-LB-B l-AB-LC-F

]

Fire load, lb 3,633 11,811 cable insulation a

Fire severity, min 11 17 1

Conclusion J

Should a fire spread through both fire areas, safe shutdown of the plant is not compromised due to the following reasons:

j 1. Combining the safe shutdown equipment in areas does not produce any redundant safety-related trains of the same safety system.

1

2. Both fire areas are equipped with automatic sprinkler protection.

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3. Each fire area has been provided with early warning detection features.

I I. Unrated Hatch Cover Auxiliary bldg. - Level C (wing)

} Location Col. A19 &AC2r A19 &AG i

Fire Area Separation 1-AB-LC-G & 1-AB-LD-G Fire Area Fire Area Item 1-AB-LC-G l-AB-LD-G

! Fire load, Ib 11,811 4,042 I

cable insulation Fire severity, min 18 16 1

, Conclusion i

i Should a fire spread through both fire areas, safe shutdown of the plant

is not compromised due to the following reasons

!' 1. Although train A and B level transmittere Jf the same safety system are located within fire area 1-AB-LD-G, they are located in the boric acid storage tank room which is bounded by a minimum of 3 feet of concrete including the ceiling equipment hatch. There are no combustible materials in this room.

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i Although train A and B pressure transmitters of the same safety system are located within fire area 1-AB-LC-G, an alternate means of determining the pressure levels is available such that safe I shutdown is not precluded.

2. Both fire areas are equipped with automatic sprinkler protection.

i

3. Each fire area has been provided with early warning detection features.

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Open Item: 75 Fire Dampers i SER Section: 9.5.1, C.S.a NRC Branch CMEB (Fire Protection) *

Description:

1. Ventilation ducts that penetrate fire barriers are provided with fire dampers. The applicant states that 17 oversize fire dampers are used that do not bear a UL label. This does not comply with Section C.5.a of BTP CMEB 9.5-1. The staff will require the applicant to provide fire dampers that are tested and approved by a nationally recognized testing laboratory for all HVAC penetrations of fire barriers. This is an open item.

Response

As a result of fire barrier modifications, there are now ten (10) fire damper assemblies (Unit I and 2) installed in 3-hour barriers (6 vertically and 4 horizontally) that do not bare an approved U.L. Label as their size exceeds the manufacturer's U.L. test limitations.

Although the 3-hour barriers also make up adjacent fire area boundaries, none of the fire areas contiguous to the damper assemblies contain safety-related equipment of redundant trains that would jeopardize safe shutdown. Therefore, safe shutdown is not jeopardized should a damper assembly malfunction and fire spread throughout both fire areas. In spite of the fact that the damper assemblies are without an approved U.L. label, the manufacturer has certified

that the fire dampers have been fabricated of the same material, with the same method, and to the same design and U.L. procedures as their standard U.L.

approved 3-hour fire damper. The results of the fire hazards analysis as tabulated below, in addition to the above, is used to justify this deviation.

Upon completion of the safe shutdown analysis in September 1985, the barriers containing unrated fire dampers which do not separate redundant safe shutdown equipment will be deleated from the list of required barriers. A fire propagation and effects analysis will be performed for the remaining barriers to justify the use of the unrated fire dampers.

RESULTS OF UNIT 1 ANALYSIS A. Unrated Fire Damper A-1551-S7-612 Auxiliary Building Size, Inches 94 x 48 Fire Area Separation 1-AB-L2-A & 1-AB-L1-B Fire Area Fire Area Item 1-AB-L2-A 1-AG-L1-B l

Fire load, Ib

1. Cable insulation 3,569 6,868
2. Charcoal 21,000 Fire severity, min 59 158

conclusion should a fire spread through both fire areas, safe shutdown of the plant is not compromised due to the following reasons:

1. Combining the safe shutdown equipment in both areas does not produce any redundant safety-related trains of the same safety system.
2. Fire area 1-AB-L1-B is equipped with automatic sprinkler protection.
3. Each fire area has been provided with early warning de*.ection features.
4. The fire damper has been certified by the manufacturer that the damper construction has been in accordance with the 3-hour U.L.

approved procedures.

5. The charcoal filtration unit is provided with a self-contained water spray system.

B. Unrated Fire Damper A-1553-S7-603 Auxiliary Building Size, Inches 48 x 96 Fire Area Separation I-AB-L2-A & 1-AB-L2-B Fire Area Fire Area i

Item 1-AB-L2-A 1-AB-L2-B Fire load, Ib

1. cable insulation 3,569 420
2. Charcoal 21,000 5,000 Fire severity, min 59 121 conclusion should a fire spread through both fire areas, safe shutdown of the plant is not compromised due to the following reasons:
1. Combining the safe shutdown equipment in both areas does not produce any redundant safety-related trains of the same safety system.
2. Fire area 1-AB-L2-8 is equipped with automatic sprinkler protection.
3. Each fire area has been provided with early warning detection features.
4. The fire damper has been certified by the manufacturer that the damper construction has been in accordance with the 3-hour U.L.

approved procedures.

5. The charcoal filtration unit is provided with a self-contained water spray system.

C. Unrated Fire Damper A-1553-87-602 Auxiliary Building Size, Inches 48 x 96 Fire Area Separation I-AB-L2-B & 1-EB-A l t

Fire Area Fire Area Item 1-AB-L2-B 1-EB-A Fire load, Ib

1. Cable insulation 420 0
2. Charcoal 5,000 3,553 Fire severity, min 121 29 Conclusion Should a fire spread through both fire areas, safe shutdown of the plant is not compromised due to the following reasons:
1. Combining the safe shutdown equipment in both areas does not produce any redundant safety-related trains of the same safety system.
2. Both areas are equipped with automatic sprinkler protection.
3. Each fire area has been provided with early warning detection features.
4. The fire damper has been certified by the manufacturer that the damper construction has been in accordance with the 3-hour U.L. i approved procedures.

D. Unrated Fire Damper A-1551-s7-602 Size, Inches 64 x 54 Fire Area Separation I-AB-L1-B & 1-AB-LD-B Fire Area Fire Area item 1-AB-L1-B 1-AB-LD-B Fire load, Ib cable 6,868 1. 12,850-cable insulation chase

2. 78,962 Balance of area Fire Severity, Min 158 1. 6-2 HR
2. 73 MIN

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

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t Conclusion 1

I - Should a fire spread through both fire areas, safe shutdown of the plant is not compromised due to the following reasons:

]

1. Although train A and B VCT isolation valves of the same safety i system are located within fire area 1-AB-LD-B, an alternate means i via administrative action is available such that safe shutdown is not precluded.

i Although train A and B valves of the same safety system, located j between the boric acid tank and charging pumps, are located within fire area 1-AB-LD-B, an alternate means via the RWST is available to deliver borated water to the reactor coolant system.

f Although train A and B valves, of the same safety system, located .

j between the AFW pumps'and the steam generators are located within '[

fire area 1-AB-LD-8, an alternate means is available such that safe l shutdown is not precluded. There are a total of 8 train A and B  !

s valves, but only two are required to-bring the plant to'a safe shutdown condition.

2. The cable chase in fire area 1-AB-LD-B as well as area 1-AB-L1-B I

are equipped with automatic sprinkler protection.

3 3. Each fire area has been provided with early warning detection i features. ,

4. The fire damper has been certified by the manufacturer that the i damper construction has been in accordance with the 3-hour U.L. j

! . approved procedures.

1 E. Unrated Fire Damper A-1551-s7-523 j size, Inches 52 x 44  ;

Fire Area separation 1-AB-LD-B & 1-AB-LD-A

Fire Area Fire Area t

Item 1- AB-LD-B 1-AB-LD-A 2,913 1.

Fire load, Ib cable 1. 12,850-cable insulation cable chase chase

. 2. 78,962 2. 1,143 pump room j- balance of 2,244-Wing Area [

j area and 894 lb of i

hydraulic fluid

Fire Severity, Min 1. 6.2 hr. 1. 109 1
2. 73 2. 41
3. 3 1

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conclusion should a fire spread through both fire areas, safe shutdown of the plant is not compromised due to the following reasons:

1. Although train A and B VCT isolation valves of the same safety system are located within fire area 1-AB-LD-B, an alternate means via administrative action is available such that safe shutdown is not precluded.

Although train A and B valves of the same safety system, located between the botic acid tank and charging pumps, are located within fire area 1-AB-LD-B, an alternate means via the RWST is available to deliver borated water to the reactor coolant system.

Although train A and B valves, of the same safety system, located between the AFW pumps and the steam generators are located within fire area 1-AB-LD-B, and 1-AB-LD-A, an alternate means is available such that safe shutdown is not precluded. There are a total of 8 train A and B valves, but only two are required to bring the plant to a safe shutdown condition.

2. The cable chase in fire area 1-AB-LD-A as well as area 1-AB-LD-B are equipped with automatic sprinkler protection.
3. Each fire area has been provided with early warning detection features.
4. The fire damper has been certified by the manufacturer that the damper construction has been in accordance with the 3-hour U.L.

approved procedures. 1

Open Item: 79 Power Supplies for Ventilation SER Section: 9.5.1, C.5.f NRC Branch: CMEB (Fire Protection)

Description:

1. Power supplies and controls for mechanical ventilation systems will be located outside the fire area served, where practical. This does not conform to the guidelines in Section C.E.f of BTP CMEB 9.5.1. The staff will require the applicant to demonstrate that a single fire will not disable both trains of ventilation needed for safety-related areas.

This is an open item.

Response

As part of the overall fire hazards analysis, we intend to perform a routing analysis to ensure (in part) that a single fire will not disable the ventilation systems required to be operable to support the operation of other

safe shutdown equipment. In addition, we will review all ventilation system circuits, safety-related and non safety-related in order to support smoke venting capabilities. The safe shutdown analysis to determine the separation requirements for the equipment needed to bring the plant to safe shutdown, including ventilation systems and associated power supplies, will be completed in September 1985.

Normal building exhaust ventilation systems can be utilized for smoke removal from the various plant fire areas in addition to their normal design l'

function. The control room is provided with its own independent smoke removal fan. The normal building exhaust systems can serve a combination of fire areas, building floors and, in some cases, the entire building. Exclusion of their power cable from fire areas also served by the same exhaust system is not physically possible to accomplish in most cases. However, fire damage to such cable has been minimized to the extent practical by limiting the number of fire areas through which the cable must pass. It should be noted that the j cable has been routed through areas that are equipped with early warning detection features such that imminent fire fighting activities can be

established. Should the normal exhaust system become unavailable for smoke removal operations, as in the case of loss of offsite power, portable smoke removal fans are available as an alternate means to relieve an area of smoke.

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Open Item:- 80 Fire Detection l

SER Section: 9.5.1, C.6.a I NRC Branch: CNEB (Fire Protection) j Descriptions i

1. A backup power supply exists for the fire detection system with access.

i to the class lE diesel, switching manually, and a 4-hr battery backup power supply for the suppression actuation system with no access to the i Class IE diesels.

1 3

The applicant did not provide enough information for the staff to verify l that this is in accordance with staff guidelines. The staff will 4

require the applicant to confirm that primary and secondary power supplies for the fire detection system and for electrically operated

] control valves for automatig suppression systems conform to the guidelines of BTP CMEB 9.5-1, section C.6.a(6). This is an open item.

2. The applicant states that it will be guided by NFPA Std. 72E for selecting fire detectors and installing them in the plant, but does not  ;

indicate how the detectors might deviate from NFPA Std., 72E. The staff will require the applicant to confirm that the fire detectors meet the ,

l guidelines of BTP CMEB 9.5-1, section C.6.a(3).

1 Response:  ;

1. The VBGP complies with NFPA 72D, 1975, Section 2220 in the following

] manner:

i a. Fire detection system - Power, via battery charges, is supplied I from at least one Class lE diesel generator with isolation provided

! per R.G. 1.75. A second Non-Class lE diesel generator provides l primary power to an inverter which provides uninterruptible power

]

to the detection system. An inverter secondary power source'is

! provided from a two-hour battery system deriving power from the l

above indicated battery charges.

4

! Alternately, fire detection panels located remotely from the above

! power system are provided with 24-hour backup batteries. The above

backup power sources.are provided in addition to normal system '

i power which is derived from offsite sources. ,

a b. Fire suppression system and fire alarm signaling systems - these j systems are powered f rom normal power sources and are provided with '

4 24-hour battery backup. '

l j 2. The detector supplier will locate and install detectors in accordance i with NFPA 725. Where it is physically impossible to do this, the detector locations will be. evaluated and accepted by Georgia Power Company using the services of a registered professional fire protection ,

engineer..

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Open Item: 82 Sprinkler Systems SER Section: 9.5.1, C.6.c NRC Branch: CMEB (Fire Protection)

==

Description:==

1. The applicant states that NFPA Stds. 13 and 15 have been used as guidance in the design of wet pipe sprinkler systems, deluge systems, and pre-action systems, but has not indicated how these systems might vary from the applicable standards. The staff will require that the applicant conform to NFPA Stds. 13 and 15 or identify and justify any deviations from Section C.6.c of staff guidelines. This is an open item.

Response

Except for the following chapters, sections, subsections, and their applicable appendix items, VEGP compliance with NFPA 13-1983 " Sprinkler Systems" and NFPA 15-1982 " Water Spray Fixed Systems" is assured during the design process through compliance with approved design criteria and procedures.

NFPA 13-1983 Subsections C-11.1, ' Flushing of Underground Connections,' the underground main and lead-in piping will not be flushed before connection is made to the sprinkler piping. However, measures will be taken and controlled via the flush procedure to prohibit the introduction of foreign material into the sprinkler piping during main and lead-in flushing.

Subsection 1-11-2.5, " Test Blanks," Test blanks will not be painted or numbered, however, they will be strictly controlled by procedure which requires removal verification.

Subsection 2-2.1.2.4, ' Water Supply Requirements Tables," water allowance for outside hose not added to sprinkler and inside hose requirements for all buildings since some buildings are not accessible for outside hose usage, i.e., Auxiliary control Fuel Handling &

Containment buildings. However, the design at Plant Vogtle is such that no given system plus hose stream will exceed the requirements of CMEB 9.5-1 section C.6.b.

Subsection 2-6, " Pressure Tanks," is not applicable because pressure tanks are not used at VEGP.

Subsection 2-7, " Fire Department Connections," are not provided at VEGP. The local fire department will be used for additional fire brigade members only. The plant fire protection systems consist of redundant fire water pump and water supply, and the yard network is a loop providing water supply even if any one section is out of service.

In addition, each fire hydrant at VEGP is equipped with a pumper connection.

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i subsection 3-14.2.7, " Valves Controlling Sprinkler Systems," is not applicable because a city connection is not provided at.VEGP.

Subsection 4-4.17, " Fur Vaults," is not applicable because vaults are not provide at VEGP.

Subsection 4-4.21, " Theater stages," is not applicable because theater staged not provided at VEGP.

Subsection 5-5, " Antifreeze Systems," is not applicable due to heat tracing of piping subject to freezing.

Chapter 8, "High-Rise Buildings," not applicable to VEGP because none provided at VEGP.

NFPA 15-1982 Subsection 2-12, " Fire Department Connections," is not applicable because fire department connections are not provided at VEGP as licensed in NFPA 13 Subsection 2-7 above.

Subsection 3.3.2, " Fire Department Connections," is not applicable as stated above.

Subsection 4-4.3.5, " Belt Conveyors," is not applicable because none provided at VEGP.

Subsection G-ll, " General Periodic Testing and Maintenance," the testing and maintenance of water spray systems will be under the control of VEGP and will be done by qualified VEGP testing personnel.

Open Item: 84 Halon 1301 Systems SER Section: 9.5.1, C.6.d NRC Branch: CMEB (Fire Protection)

==

Description:==

1. The applicant states that the use of Halon systems is guided by NFPA Std. 12A, but has not indicated how it might vary from NFPA Std. 12A.

The staff will require the applicant to comply with NFPA Std. 12A or to identify and justify any deviations from section C.6d of BTP CMEB 9.5-1. This is an open item.

Response

VBGP intends to comply with the requirements of NFPA 12A. The suppression system contractor will install the system inaccordance with the code to the maximum extent possible. If any deviations due to physical limitations are identified by the contractor, they will be evaluated for acceptability by Georgia Power Company through the services of a registered professional fire protection engineer.