ML20101E438

Requests Approval of Addl Deviations from Listed Sections of App R to 10CFR50.Justification of Each Deviation Encl.Fee Paid

ML20101E438
Person / Time
Site:	Sequoyah
Issue date:	12/18/1984
From:	Domer J TENNESSEE VALLEY AUTHORITY
To:	Adensam E Office of Nuclear Reactor Regulation
References
NUDOCS 8412260255
Download: ML20101E438 (33)

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.- TENNESSEE mVALLEY: AUTHORITY y-44 q.. e

' CHATTANOOGA. TENNESSEE 3740'1 - '

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JDirectoh of Nuolear? Reactor Regulahlon -

? Attention:c Ms. EF Adansam, Chief.

Licansing Branch No. 4

. Division of Licensing

?U.S. Nuolear. Regulatory Commission Washington,.D.C. 20555

Dear Ms.f Adensaa:

'In'the Matter of.

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Docket Nos. 50 -327 Tennessee Valley Authority..

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50 -32 8 "In!accordance with-the requirement of the Sequoyah Nuclear Plant unit 2 1

operating license condition, 2.C.(13).o, TVA submitted a report, by the

' October' 1, ~ 1981 letter-ft'on L. M. -Mills to you, that identified compliance with Sections III.G, III.J, III.L, and III.0 of Appendix R to 10 CFR Part

50.. Enclosum.1 provides a revision to Section D of the enclosure to the.

-October 11, 1981 letter. ? Enclosum 2 provides a supplemental-response to'

' the' Appendix E evaluation for Sequoyah which identifies and requests approval' of additional' deviations to the Appendix R requirements.

' Enclosure 2 also provides a ' justification for each of the deviations.

Enclosure '3 provides clarification of TVA's position for compliance with n'

lNFPA 13-1975 in mgard to the installation of sprinkler systems at V

LSequoyah..

The additional deviations identified in Enclosure 2 are being submitted as a result of the-indepth review of TVA's compliance with Appendix R being performed in accordance with the August 10, 1984 Confirmation of Action Letter. from J.~ P. O'Reilly to H. G. Parris. We.therefore request NRC review and-approval of the deviations. In accordance with the requirements

_ of 10 CFR Part1170.21, enclosed -is the $150 application fee.

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' An Equal Opportunity Employer 3 m.p mg

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! ' Dimotor of Nuclear Reactor Regulation December. 18, 1984 If you have any questions concerning this matter, please get in touch with Jerry Wills'at FTS 858-2683

-Very truly yours, TENNESSEE VALLEY AUTHORITY l

J. A. Domer i[I Nuclear Engineer

< Sworn subsor before me 198'l

,this-day of i e

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Al Notary Publio p-

.My Commission Expires o "

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.i nclosurea E

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U.S. Ntmlear Regulatory Comalasion (Enclosures)

Rt6; ion II ~

. Attn:

Mr. James P. O'Reilly Administrator

101 Marietta Street, NW, Suite 2900

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. Atlanta, Georgia 30303 t

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, ENCLOSURE ~1 e 7

-REVISION TO SECTION D OF ENCLOSURE'TO OCTOBER 1, ' 1981 LETTER FROM L. M. MILLS -

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- D.i L SECTION III.0 REQUIREENTS h

Requimments LSection III.0 requires that the reactor coolant pumps be

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. equipped with an oil collection systemiif the containment is not inerted

'during normal ~ operation. The oil collection system shall be so designed,

-engineered,- and installed that failure will not lead to fire during normal-or design basis ' accident conditions and that there is masonable assurance 7

that - the system will Jwith-stand the Safe Shutdown Earthquake.

L Suoh collection systems shall be ' capable of collecting lube oil from all potential pressurized and unpressurized leakage sites in the reactor coolant pump lube oil-systems.- Leakage shall be collected and drained to a veted elosed container that can hold the entire lube oil system inventory. A l flame arrester is mquimd in the vent if the flash point characteristics of the oil present -the hazard of fire flashback. Leakage points to be

- protected shall include lift pump and piping, overflow lines, lube oil cooler,: oil fill and drains, lines and plugs, flanged connections on oil 14.nes, and lube oil reservoirs where such features exist on the reactor

' coolant' pumps. ~ The drain line shall be large enough to accommodate the largest potential oil leak.

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.1.

Deviation - The drain piping located between the oil collection basins 1

-(around the pump) and the contaiment floor (oil drains to the auxiliary

?mactor building sump), is designed to category I(L) requirements so the piping will not 'thil during a safe shutdown earthquake and damage nuclear g

safety-related equipment. The drain piping has not been designed to '

J amintain its pressure boundary integrity after. the event.

Justification - The reactor coolant pump (RCP) lubricating oil systems

~ are designed with. the capability for withstanding a safe shutdown earthquake. The RCP motors, the lubricating oil systems, and the containment sump are all designed to seismic category I. requirements so they will not fail during a safe shutdown earthquake (see figum I11.0.1 and III.O.2 ). Therefore, random oil leaks are not assumed to ooour

- similtaneously with a seissio event. It is TVA's position that the total system provides more than reasonable assurance that a RCP lubricating oil fim will not ccour as a result of a seissio event.

2.

Deviation - The RCP oil collection system does'not have the capacity to. hold the stire contents from all four RCP lube oil systems.

' Justification - The reactor coolant pump motors, the lubricating oil systems, and the containment sump are all designed to seismLo category I mquimments so.they will not fail during a safe shutdown earthquake (see figure III.O.1 and III.O.2).- Therefore, assuming only a single random failum,.the oil collection system would only be required to hold the oil

' moulting from the-largest spill due to such a single failure. The largest single failure -is assumed to be the rupture of the upper bearing

. oil system of one RCP,'which contains 2140 gallons of oil.

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e Since the initial design of the RCP oil collection system, modifications have been made' 42e to other commitments and safety issues.which mduced the. volume available for oil collection. As a mault, the auxiliary mactor building sump does not have adequate capacity to hold the oil ft on all four RCPs. The sump holds approximately 200 gallons anf the comecting embedded piping systems hold approximately 140 gallons for a total of 340 gallons of capacity. Annunciator maponse instructions have

been mvised and a night crder issued to mquire the operator to pump the

- samp down in the event of a RCP high/ low oil meervoir alarm in cader to ensum adequate capacity 1s'available for oil collection.

h the unlikely evet.that the sump is f\\211 of water, no more than 100

. gallons of oil would backup through floor drains. This quantity of oil m the ocntainment floor will not come in contact with hot piping e -

other igrtition-sources.

Tho' map vents do not mquire the installation of flame arresters because the high flashpoint characteristics (390 degrees F.) of the reactor coolant pump lube oil preclude the hazard of fire flashback.

TVA therefore, requests approval of the above deviations to the literal mquimments of section III.0 based upon the existing system as described above providing equivalent protection.

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' DEVIATIONS PROM APPENDIX R REQUIREMENTS v

i;1. - Deviation -;SEction III.G'.3.requims fire detection and a fixed fire suppression system,in amas, rooms, or zones for 'which alternate shutdom

- capability is provided. Contrary to this mquirement, fire detection and fixed fim suppression systems am not provided throughout the control building.-

4 Justification The' control building (CB) is a separate fire ama and is

' separated from adjacent fire amas by minforced concrete construction equivalent to 3-hour fire-rated-barriers. Fire ' detection is provided throughout. the CB, except~ for the stairs (C1 and C2), which am enclosed by11-1/2-hour equivalent fire rated barriers. Fixed-fim suppression systems 'are provided throughout the CB, except for the below listed

. rooms:

Equipment Room Name Room No.

Class =

' 250v Battery Board Room 1 and 2 669.0-C4 & C5 Nonsafety 24v and 48v Batt Bd and Chgr Room 669 0-C8 -

Stair C1 and C2

-Corridor 685.0-C2 Main Control Room 732.0-C12 Safety Relay Room 732.0-C13 Nonsafety

'NRC Office and Confemnce Room 732.0-C17 and C18 In addition, the CB is' provided with standpipe and hose systems and -

portable extinguishers throughout the building.

None of the above listed rooms has a fixed combustible fuel load greater than' 30,000 Btu /ft2 which equates to a fire severity of only 23 minutes. Early detection and response by the plant fire brigade provides a high degree of confidence that any fire will be extinguished quickly. The 3-hour walls that separate the CB from the auxiliary building ensures that the altemative safe shutdown capability, which is located in the Auxiliary Building will not be damaged by a fire in the control building.

It is stated in SECY 83-269 dated July 5,1983, Attachment A, section 1.2.7 that the purpose of providing fire detection and fixed fire suppression in the area under consideration is to limit 'the severity of the fire such that it' will not damage alternate safe shutdown capability. Therefore, TVA requests approval of the deviation to the requirements of section III.G.3 to provide fire detection and fixed fire suppression systems for the above listed rooms.

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Deviation - Section III.L.2.d of Appendix R requires the process monitoring function for altemative or dedicated shutdown to be capable of providing direct readings of the process variables necessary to

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iperforarand conteol a plent coold:wn. In. Attichment.1 ~of'Id Informatica P- _-Notice No?84-09' dated; February 13,1 1984,1 the NRC identified the cold leg ;

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. temperatum' (Teold)!as a componetiof the instrumentation'they consider J

L pecessey; for; alterna tivel or - ded icated. shutdown.'

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• '; 4 Toold;instrumentai. ion ~has not been provided in' the Auxiliary Control Room l(ACR)- foriuse. in safefshutdown: procedures or process monitoring.- -

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- Justification - Toold. instrumentation, ~ in' conjunction with-other system parensters, cis ' used. to ' uonitor' na tural circulation ^ in the reactor 3:

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ocolant -loop ' and : to -set the reactor cooldom rate. Both of these-

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" functions, LhoweverJean be accomplished; by using Tsat, the saturation.-

~ temperatum corresponding to the secondary side cteam guerator lpressum.

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l iThe;use'or Tsat[ instrumentation to safely coo'l down 'a PWR plant has been -

Sdemonstrated 'in startup. tests at TVA's Sequoyah Nuclear Plant Unit 1.

iThe, test ; utilized Tsat monitoring as part of the normal plant procedure. to M

perform and. control' the necessary safety functions and to bring the plant

- to safe shutdown.

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. :It has.been ~ uggested..that,Tsat cannot be relied.on to verify ' natural' s6, s

. oirculation conditions in the~ reactor coolant' loop.due to the inherent klag in' temperatum response between the primary and secondary systems.

s 7 An interruption in. natural; circulation in one' loop,.however,'can be

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detected by observation of an inomased delta-T between the hot ' leg j.7.:.

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.temperatum - (Thot). and Tsat ~in' the.other loops. It is TVA's opinion that M

no;significant, increase' in operator _ action.is mquired using this

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nonitoring' arrangement during shutdown.

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LWe therbfore requesti approval of a deviation to the requirement in.

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~ Section III.L.2.d of Appendix R'and IR Information Notice No. 84-09 that 7

Toold instrumentation-be provided. in ~ the ACR.

. 3. I Deviation - Section III.G.2.'c. mquims that one redundant train of

' equipment necessary for safe shutdown be. separated by a continuous 1-hour Ersted fim barrier. in addition to ' area protection by automatic fim :

.J detection and suppression systems.

,f The mdundant Component' Cooling Water System (CCS) Train A and B pumps are protected by automatio fim detection and suppression 'aystems ~ but am

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separated by a partial.1-hour fire rated barrier. Pmvious. fim protection submittals have incorrectly referred to these as' Component Cooling Water (CCW) pumps.

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Justification - The five CCS pumps are located - to5 ether on

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' elevation 690.0 of the Auxiliary Building. The two Train B pumps are H

separated from the ;two Train A pumps and the spare pump by a 1-hour fim-rated: barrier. which extends 3 feet above the highest point of the pumps.

The in-situ combustible load for the area is 42,050 Btu /ft2 and 2 due to the insulation on ca 1

fisLoonprised of 41,790 Btu /ft 1

3, ruming :in the' open-ladder type cable trays and 300 Btu /ftgles due to 66~ gallons of lube oil associated with the CCS pumps and tu) auxiliary feedwater pumps.

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Reedways containing1tha mdundantiaircuits.for;tha CCS pumps :

JwillE be separated by 20 cr more feet e by one-hour barriers.

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A ceiling level

proaction sprinkler system is provided for cable

tray and geeral area _ooverage.'. Automatic sprinkler coverage '

has also been provided:under ;the pipe-break barriee for! the.

g1 footor-driven auxiliary feedwater pumps and under the. mezzanine 7 q ifor all' five~-CCS pumps. Cross-zoned ionization smoke detectors

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s 1 (affecting the redundant ^ pumps. The large room volume of W

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429,000 feet and the= 23-foot-high ceilings will ' dissipate the thermal' effects of a - fire.

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" g -. fA fim &ol to' tiransient combus'tibles located near; the ' edge of

~ the. fire barrier at' A3/t:will' not. pose a' thmat to more than one

= CCS~ pump. The. 3-foot-square column at this and of the barrier willL maure that the exposum fim that could damage the CCS

. pump.1A-A will be 20 : feet.away from CCS pump 1BB. The location 6

of electrical panels and instrumentation lines ct ' Al/t which

~pmvented the barrier-fYom extending to the wall will also J

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prevent any appreciable. amounts of transient combustibles from.

being-placed near this edge 'of the barrier.. This lack of my,abustibles and. suppression system provided will prevet a fim-

' due to. transient' combustibles ' located -near the edge of the 6

barrier at Al/t from posing a thmat to more than one CCS pump.

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It.is TVA's. opinion (that lthe. fire protection in this area provides a level'or protection that;is adequate considering the

? combustibles present, the room volume, and the wall configuration. -

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J The NRC staff previously. mviewed the fim protection featums

, ; provided in the vicinity of Lthe CCS ' pumps for-compliance with

'7' guidelines set.forth in. Appedix A of BTP APCSB 9-5.1 and found those.featums to be adequate (see section IV.B. of the SNP-R

' Safety Evaluation, Report Supplement No.1 dated February 1980).

' TVAL therefore, requests approval for the deviation to the 1

Appendix R Section' III'.G.2.c mquimment for' separation of one Jmdundant' train of the safety mlated CCS pumps by a continuous 11-hour fire-rated barrier.

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4 i4. ;DeYiation 1 Appendix R guidelines-for separation of fim areas s

nquire that penetrations.in walls, floors, ani roafs forming part of a c

' ; fire, barrier be protected with seals or closum devices having a fim

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~ resistive rating equal to that of the barrier. _ The walls and floors of f'

Mthe Auxiliary Building Gas Treatment-Fan Room (ABGTS) are ' equivalent to 13-hour rated barriers, but Post-Accidet ' Sampling Facility (PAS) HVAC i > (c duct' penetrations through these barriers do not have fire dampers.

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.Ju'tific; tion 1-Leach ABGTS.is c fire Tont which containn safe Lstaatdowrt components and.is separated from one of the two -PAS ' rooms ~ and hfece the nitrogen storage rcom'by reinforced conomte construotion c ~ '

- l equivalent = to : 3-hour. fire-rated barriers.. The Unit 1 ABGTS has two ~ 12-ine round,?one ind round, and ' one 8-inch ' round,HVAC ducts associated n

,x, with the PAS /that pass through'it fbr a'short distance. - The Unit'2 ABGTS q

-is'sidlar except there are one 12-inch, sone.10-in&,.and one 8-inch -

round diaots passing through it (see figum 4-1). - OneL 12-inch &c t. ties

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.into each of the ABGTS filter' systems in the ' ABGTS rooms. : These & cts 1

. are construeted from. schedule' 40 carbon ateel pipe, ASTM A106, grade LB..

-The & cts are.seisically supported to 2 category I (L).requimments. Pipe

. sleeves are provided where the'& cts penetrate the barriers between{a.

' ABGTS and ' a PAS-or nitrogen storage room.. The annular space between:the

. sleeves and. the pipes' am ~ sealed with.Dow Corning RTV-3-6548 silicon foam to a depth of-12 inches. The foam was installed per annufacture's.

instructions andithe configuration is,siellar.to penetration designs that-lhave-been successfully tested to ASTM E-119 requimments.

• Two tests -

Waioh have been ' conducted by Underwriters Laboratorles (UL) ars.

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' documented under the,3-hour rated penetration firestop system numbers 13 :

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' and 31 in the 1984 UL Building Materials Directory. A sidlar penetration was'also' tested for a' 3-hour rating by Factory Mutual-(FM) 1(Test raamber'26543, OctoberL 28,.1975) for mechanical penetrations with a

minimia sealant depth.of eight inch'es.

'; The only significant. in-sitia combustibles in the PAS and nitrogen storage

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- room, which' comprise,one fire area, are two. charcoal filter units located in ;the nitrogen storage room. Each filter unit' contains six.

. trays with 35 pounds of charcoal per tray. This equates to a combustible

-loading of only 780 Btu /ft2 and is' derived by using a h t release of..

c 13,000 Btu /lb for charcoal and a room area of 3500 ft, ea 3.

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TPipes usei in' the HVAC duets and in the UL and FM tests refemnced;above-were all schedule 40. ' Since rone of the pipes in the referenced tests failed, thef ect pipes in the. ABGTS are rot expected to fail in a fire

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resulting in conditions sidlar to those. established by the - ASTM E-119 test s.

Due to. low fbel5 loading, a fire in the rooms in question would

. result in'less severe conditions than the tests. Our assertion is based on the fire severity curve A.in figure 5-9E in the NFPA Firs Protection

Handbook, 15th Edition.. ItJis, therefore, TVA's position that a failure

..of. these ' pipes is not considered to be a-credible evet.

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jThe only effect of a fire in one of the PAS rooms or in the nitrogen

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< storage room which could be expected in the ABGTS room would be radiant

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' heat 'due to ' hot gases passing through the &c ts.

The absence of fixed ocabustibles in the immediate area of the & cts provides a high degree of

f. assurance 'that this radiant heat will not be a threat to safe shutdown components : located in the ABGTS room.

- Additioruilly,.both PAS rooms arw provided with a fixed suppression m

, system, standpipe arv3 hose system, and portable extinguishers..

' It cis TVA's position that the fire protection providet is adequate for the. hazards present and that-the addition of fire rated dampers in these se

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T Iductsiwould'~not significcntly eshr.nca.tha fire pectection'in thrse treas.

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'.Therefore, TVA' requests approval of the deviation to the requimment to provide,fim rated : dampers in the:HVAC ducts penetrating the fire

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. barriers 1that separate the ABGTS from the PAS rooms and the nitrogen DX

storage room.

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' 5. n Deriation -.Section III.G.2 requires that fire detectors and '

automatic _ fim. suppression systems' be provided in amas containing :

fmdundant safe shutdown equipment that is ~ separt.ted by less than 3-hour t 4

fim-rated construction., Roone 749.0-A2 and 749.0-A15.contain redundant

vital battery inverters and &argers and the trained reactor vest 'and MOV 4

. boards-fbe units '1 ard 2 respectively. The portion of the rooms between

', - column lines A6-A8/q-r and A8-A10/q-r am ' mt.covemd by a sprinkler

' system.1

~ Ju's'tification -~ Rooms 749.0-A2 and 749.0-A15.are separated from :

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each other and other areas of the Auxiliary Building elevation 749.0 by

- reinforced concrete walls which are equivalent to at least a 1-1/2-hour barrier.z - This.is an : adequate level of separation considering the.

Ecombustible: loading of the two rooms and has previously been accepted by

.NRC in,the SER dated February 1980.

The only in-situ combustible located in the area without suppression is the insulation on the cables.inside the inverters ard &argers. A

pmaction suppression system actuated by cross-zoned ionization smoke

. detectors. covers the remainder of each room. The smoke detection system is provided throughout _ the area including the area not having

, suppression. ~ Inadvertent" operation.of a sprinkler system would cause unacceptable & mage to the-inverters and battery chargers. The cables ~in the cable ~ trays are located in the protected area. Standpipe and hose

, ' systems and portable extinguishers are also provided in the rooms.

Therefore, TVA requests approval of a deviation from the total ama

. coverage requirement of Section III.G.2 of 10CFR50 Appendix.R for roome 749.0-A2 and.749.0-A15.

_6.'. Deviation - Section III.G.2.b mquires that cables ard equipment and associated nonsafety-circuits of redundant trains be separated by:a p

' horizontal distance of.more than 20 feet with no intervening combustibles -

or fim ha::ards. ~ In. addition,. fim detectors and an automatic fim,

suppression system shall be installed-in the area. Contrary to this L

requirement ERCW valves 1 and 2 - FCV-67-146 are only 15 feet and 8 feet ~

respectively-from their redundant counterparts auxiliary power circuits.

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These' valves are located in the discharge header of the component cooling water. system heat exchangers.

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, Justification - The above listed valves are located above a L>

mezzanine in room 714.0-A1 of the Auxiliary Building. The only

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. undesirable condition that could 'msult from a transient combustible fim J in the' mezzanine area is.for the valves to spuriously close. However, the component cooling water system must only supply cooling water to a 7

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.small amount of equipment mquimd for safe shutdown & ring a fire and L

TVA has determined that these valves may maain closed for up to two 4n

' hours. This is sufficient time to manually open any of the valves which 1 -

i might have spuriously closed.

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.' This roorlisiprovided with ' fixed fire - suppression systems aotuated by :

r ionizatio'n smoke l detectors,. standpipe and. hose stations, and portable

'3 foxtinguishers. Additional sprinkler heads will; be provided under the

mezzanine.'

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' tThe. in-sittil ustible loading for this room.is' 114,500 Btu /ft,,

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'ga Insulation ; on the - cables ' routed in trays ' account. for. 113.500 Btu /ft2 i and > the. remainingl1000 Btu /ft2 is due to 3 lube oilJ in 'various water idtillers and.. pumps located. throughout the room none of which am located Junder thesel valves.L The existing ceiling level-sprinklers will provide 1

s idimot water? impingement on the valves.-

~,Therefore,- TVA. requests approval' for ther ' deviation to the, requirement of ~

section III.G.2.b to separate-these valves by more than 20 feet.

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Dediation '- SeEtion 'III.G.2.b.mquires that. fire detection and

. automatic, suppeession be ' installed in the ama. when separating cables,

. equipment,J and associated _ nonsafety circuits of redundant trains by a 1 horizontal distance.of acre than 20 feet. Contrary to this mquirement,

, cables 11PL4982B arti -1PL4985B'(normalisupply for 480v Diesel Auxiliary.

Boards' 1B1-B-and 1B2-B respectively) are routed in trays on the Refuel'

. Floor.(see' figure 7-1) that am' 32 feet ft om trays containing mdundant

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cables 2PL4975A and 2PL4978A (normal supply for 480v Diesel Auxiliary

,1' ' Beards 2A1-A and 2A2-A mspectively); however, there is no fixed

suppression. in this room.'

FJustification -~ The Refuel Floor -(RF) is separated from adjacent-

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Efim.' areas by minforced conomte construction equivalent to 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />' fire-

' rated: barriers.1 Itiis separated from other ' rooms.or-the auxiliary jb'uilding;by reinforced concrete equivalent to at least.1-1/2 hour fire-

. rated barriers, except. for an unprotected equipment hatch -and undampemd

' HVAC ducts through the floor slab. The RF is provided with ionization wF

. smoke -detectors, standpipe and hose systems, and portable extinguishers.

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Thelin-situ combustible load of the RF is only 5,000 Btu /ft2 of which a..

3,000 Btu /ft213-due to the insulation on cables in the cable trays.

,The remaining fixed combustible loading is due to the lube oil in the y

4

'various pumps,' air compressors,' cranes, etc., located throughout' the RF.

~

Circuit protective devices ensum that a fault on any of the cables in

thel trays.'will be cleared before the cable insulation reaches.its auto-s

. ignition temperatum. Thus with the only means of creating a fire 1 internal to;the trays eliminated, tNs only concern is with a transient combustible exposum fire on the floor.

2 Typical: transient combustibles will add a t additioral 1000 Btu /ft,

~

The only time that these quantities of transient combustibles am present is during an cutage. The RF is continually mamed during an outage and d

if the transient combustibles were to ignite, it would be detected quickly and suppression applied rapidly. Thermal effects of such a fire 2

would be dissipated by the large room area (17,500 ft ) and high ceiling (56 feet).

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y It' is TVA'o p::cititn thit a transient combu;tible fire 'will not damaga these cables. This is based on a very low fixed combustible load, large room volume aM ^high ceiling, and location of trays (513 feet above the floor). Tharefore, we request approval of the deviation to the mquirement to provide fixed autoratic suppression for the Refuel Floor.

8.: Deviation Section III.G.2 requims mdundant safe shutdown components to be separated from each other by one.of the following methods:

.a.. Separation. of cables and squipment and associated nonsafety. circuits of redundant trains by a fire barrier having a 3-hour rating.

b. : Separation of cables and equipment and associated nonsafety circuits

' of redundant trains by a horizontal distance of more than 20 feet' with no ~ intervening combustibles cr fire hazards. In addition, fire detectors and an automatic fire suppression system shall be installed in the fire area.

Enclosum of cable and equipment and' associated nonsafety circuits of c.

one mdundant train in a fim barrier having a 1-hour ratingc In addition, fire detectors and an automatic fire suppression system shall be installed in the fim area.

Power cables for both mdundant divisions of the ERCW pumps, Tim pumps, ERCW pumping station transformers, aM mlated circuits are routed in a conduit bank through a corner of the refueling water atorage tank (RWST) pipe &ase aM over the suspended ceiling in the counting room between column lines C1-A1/t-u 'on elevation 690.0 (see figura 8-1).

The Train A circuits are routed in half of the conduits aM Train B aircuits are routed in the other half of the conduits. Contrary to mquirements of section III.G.2, the conduits do not have adequate spacial or barrier separation, or complete suppression.

Justification - The RWST pipe &ase is enclosed by minforced concrete construction that is equivalent to 3-hour fire-rated barriers, except for the md that opms into the Auxiliary Building. There are to in-situ combustibles located in the pipe &ase.

Access limttations ensum that transient combustibles in the pipe &ase will be negligible. Access to the pipe &ase requires a Radiation Work Permit -(RWP) which controls access and work activities in the &ase.

Access to the chase is up a ladder and across the roof of the turbine driven auxiliary pump room.

l-The automatic sprinkler system for elevation 669.0 of the auxiliary l

building protects the strance of the &ase from an exposure fim in the Auxiliary Building.

The fire load for the Radio-Chem Lab aM Counting Room (RCL-CR) is low 2

(less than 6 1h/ft ) aM consists mostly of class A combustibles. The room are providei with preaction sprinklers actuated by cross-zoned ionization smoke detectors. In addition, a standpipe aM hose system aM portable extinguishers are provided throughout the plant. The RCL-C" is continuously mamed and any fim in this area would be detected quickly and extinguished.

7 e

However, to fhrth:r msum thIt a fire in the RCL-CR will.not damage circuits routed in these conduits, TVA will install a sprinkler system to

-cover the area above the suspeded ceiling in the CR.. The suppression system extension will be hydraulically designal for 0.16 gpm/ft2 over the area above the CR ceiling. Ionization smoke' detectors will also be addai above the' ceiling to actuate the suppmssion system. _ This part of

' the s2pression system will provide dimet. water inpingement.on the conduits and will also cool the hot gases from a fire.

It is TVA's position that the level of protection provided for the circuits in these conduits is adequate for the hazards preset.

Therefore, we request approval of the deviation to the requiremets of section III.G.2 for the circuits in the conduit bank where it passes over

' the suspmded ceiling of the CR and through a corner of the RWST pipe

. &ase.

9.

Deviation - Section III.G.2 requims mdundant safe shutdown

~

components to be separated from each other by one of the following methods:

a.

Separation of cables and equipmmt aM associated nonsafety circuits of mdundant trains by a fire barrier having a 3-hour rating.

b.

Separation of cables aM equipment aM. associated nonsafety circuits of redundant trains by a horizontal distance of more than 20 feet with no intervming combustibles or fim hazards. In addition, fire detectors and an automatic fim suppression system shall be installed in the. fire area.

c.

Enclosum of cable and equipment and associated nonsafety circuits of one mdundant train in a fire barrier having a 1-hour rating. In addition, fim detectors aM an automatic fire suppression system shall be installed in the fim area.

~ Redundant safe shutdom circuits located in the ERCW pumping station are not separated in literal-compliance with these requimments since there am unprotected openings in the interior walls and the roof is of open grating type construction.

. Justification - The ERCW pumping station is separated into three compartamts by minforced concrete constrtrtion that is equivalent to 3-hour fire-rated barriers (see Figum 9-1).

Four Train B pumps am located in the center compartmmts with te Train A pumps in each of the

.. outer compartmmts. - In situ combustibles in each of the compartments consist of 39 gallons of lubricating oil within each pump aM 3 gallons of lubricating oil within each traveling somen motor. The lubricating oil has a flashpoint of 4320F making it difficult to ignite in an unconfined spill. In addition, a standpipe and hose syatem aM portable extinguishers are installed in the pumping station.

There are tm 6-inch diameter scupper holes and one 30-inch by 20-inch

. hole for a trash sluice in each of the two interior walls that separate the redundant' pumps.

m.

m 7

y The ;floorm in the cuter compatments are ' sloped so thtt : normal drainag2 flows away from the.inneriwalls and : flammable : liquid ; from.a spill will.

idrain:into the gutters; within the respective compartments.. ' A flaamiable

-liquid spill f in the ' center compartment would ' enter the gutters and drain

to the ; sump without entering. the outer compartments.' The ' open roof -

sconfiguration would dissipate the heat from a -fire, thereby eliuLnating any significant heat transfer to' any of the adjacent compartments.

- The trash sluice is of steel construction on thme sides and covered with -

C opm grating except where the traveling somens discharge into the sluice. The sluice is enclosed on'all four sides at these locations.

The sluice runs.from the northernmost compartment,through a 20-in& by s30-inch opening in both: interior fire rated barriers and leaves the building through ' the exterior. south wall where it discharges into a 36-

ins diameter downspout. < The traveling'somens are each capable of 1 discharging a. maximum of.three gallons of lubricating. oil into the trash sluice. - The possibility.. of the oil igniting is improbable &e to its.

high flashpoint (4320F). However, if the oil was ignited, it would be -

contained while traveling down the sluice and puld discharge into the domspout. The thermal effects of.this type of fim would be dissipated

through the. open grating roof ard would not pose an umoceptable thmat to the pumps.;

It is TVA's position that the separation between the redundant equipment

is adequate for the' hazards present.. We, therefore, request that a deviation be granted for the unprotected openings idetified above.

110.

Deviation - Section III.G.2.b requims mdundant safe shutdown components to be separated from each other by a heizontal distance of

'more than 20 feet with no intervening combustibles er fire hazards. In addition, fim detectors and an automatic fire suppression system shall be indalled in the fire area.

Floor slabs in the Auxiliary Building necessary to separate redundant

. safe shutdown componets have unprotected penetrations. Consequently,.

- some redundant safe. shutdown components that are separated by these floor slabs may rot be in literal compliance with the separation requimments l

of section III.G.2.b.

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7 Justification - The Auxiliary Building is a designated fim area

. ard is separated from adjacent fim areas by minforced concrete construction that is equivalent to 3-hour fire-rated barriers. The

. Auxiliary Building is further divided into 1-1/2-hour fire rated

' enclosures. = However, not all floor slabs within the Auxiliary Building

~

.are designated as complete fire -barriers.

?They 'are constructed of reinforced conomte that is equivalent to 3-hour fire rated barriers except for equipment hatch openings, stairwells, L

unsealed spare ~ conduit sleeves, and unprotected HVAC duct penetrations.

All other floor peetrations-have an equivalent 3-hour fire seal.

Unprotected floor penetrations in the vicinity of redundant safe shutdom components will be protected as follows:

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Sta.;irwells A water curtain designed in cocordanca with NFPA 1'3, pc

'Section 4 8.3,2 will be providet for stairvell openings located.near

column lines: 4/S and A12/S through floor slabs 690.0 and 714.0.

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- Hatches -'Pyroomte' has been installed on the equipment h'atch located

.; L

' at A13/S ' 749.0 to upgrade the hatch to a 3-hour - fire' rating. '

HVAC ducts - Redundant. safe shutdown components. located on diffemnt

. elevations near unprotected HVAC ducts will be separated in-accordance -

- with section III.G.2.

J Spare conduit sleeves - Spam conduitLsleeves are capped 1on each _end Lby thmadedL conduit plugs. 'It is. TVA's position -that neither flames nor hot: gases will-propagate. through these oapped ~ sleeves.~ All other-conduits that pass through mquired - floors are or 'will be sealed. '

- The'se modifictions will'en' sum that. in sirigle' fire can expose more thanl one train of safe. shutdom components. located on different elevations.-'

y

The rooms.containing the requimd safe

shutdown components that are t

= separated from' their redundant' counterparts by the floor slabs are protected by fire detection 'and automatic fire suppression ' systems. In

~

addition,: the_ Auxiliary Building is also provide! with standpipe ard hose

. systems and portable-extinguishers.

T Itlis TVA's' position that after the above described modifications are

complete,1 the level of protection that will be achieved by locating

+

. redundant safe : shutdown components on different ' elevations is equivalent -

to'.the separation mquirements of. section III.G.2.b.

Therefore, we mquest ' approval of the deviation to literal compliance with section

III.G.2.b.

f,

11. Deviation - Section III.G.2.c requires that cables ard equipment -

b G.

- and ' associated' nonsafety circuits of one redundant train be enclosea in a

- firw barrier having a 1-hour rating.. In addition, fire detectors and an

. automatic fire suppression system shall be installed in the fire area.

Contrary to this mquirement, Train A safe shutdom circuits are routed in trays 'that' pass through 480v shutdown board room.1B2-B, and Train B 1

. safe shutdom circuits are routed in. trays that pass through 480v-shutdown board room 2A2-A and are ' rot enclosed in a fire barrier having.a-(1-hour rating (see figure 11-1).

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-' Justification =- The Auxiliary Building is a designated fire area

'and' is-separated from adjacent fire areas by reinforced concrete construction that is equivalent to 3-hour fLre rated barriers. The 480-V

, shutdown board rooms are located on elevation 734.0 of the auxiliary -

' building and are separated -from adjacent' rooms in the Auxiliary Building p.

by reinforced concrete construction that is equivalent to 1-1/2-hour firw-rated barriers.

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m 2 Th):in-situ' combustible loading of 480v shutdown board room 1B2-B is

152,496 Btu'/ft2 and 480-V shutdown bosN room 2A2-A is 158,136 Btu /ft,.2 This is due to the insulatien on the cables in trays.

!l

' Circuit protective devices (breakers aM fuses) will be provided that will clear a' fault on a cable before the cable insulation reaches its auto-ignition temperatum. It is therefore TVA's position that an

' internally gmerated cable tray fim is not a omditable 'evet.

The. threat to the cables muld have to be from an exposure fim &e to transient combustibles. The type and quantity of transint combustibles -

allowed,through these rooms are dnidzed by the SQNP Physical Security Instruction 13

.If-transient combustibles were preset and did ignite,

. the ~ fire would be detected by the. ionization smoke detectors and

' extinguished or controlled by the fixed automatic suppression systems in

~ the rooms. However, to fbrther a sum that a transient combustible fire will not _ damage both mdundant trains of circuits, an opm head automatic.

water spray system will be providal for the protection of Train A trays located 'in 480-V_ shutdown board room 1B2-B and the Train B trays located '

in 480-V shutdown board room 2A2-A. Each system will be actuated by a line type thermal detector system. The line type thermal detectors will be located at the top and the bottom of the protected stack of trays.

. Enclosing the trays in a 1-hour fire-rated barrier would mquire major

- modifications to large HVAC ducts and their supports, fire protection piping aM supports, aM cable tray supports.. It is TVA's position that the addition of the opm head water spray systems will provide a level of

protection that will ~ adequately address the hazards present and ensure that one train of-redundant safe shutdown circuits will remain free of fim & mage. Therefore we request approval for the deviation to the separation requirement of section III.G.2.c for the Train A circuits in the 480v shutdown baord room 1B2-B and the Train B circuits in the 480v shutdown board room 2A2-A.

12.

Deviation - Section III.G.2.b requires that cables ad equipment -

and associated nonsafety circuits of redundant trains be separated by a horizontal distance of more than 20 feet with no intervming combustibles or fire hazards. In addition, fire detectors and an automatic fire suppression system shall be installed in the area. Contrary to this mquirement, the Auxiliary Building has open ladder-type cable trays located.between redundant cables that will be separated by more than 20 feet. ' The' insulation on cables in these trays is considered an intervening combustible material.

Justification - The locations in the Auxiliary Building where mdundant cables are spacially separated have no significant in-situ fim hazards present except for cable insulation in the cable trays. Fuse and breaker coordination provides or.will provide adequate protection to clear any electrical fault from a cable before its insulation reaches its auto-ignition temperature. Therefore, an internally gmerated cable tray

.fim is not considered a cmdible event. An exposum fire at the floor represents the only significant fire hazard for the redundant cables.

i.

I

q Th2 presence of the intervening cable ' trays between redundant cablOG is a concern for two masons.. First,' the exposum fire could ignite the insulation which would add to - the fire's thermal plume. Second, they could provide a path for the fim to propagate from one train of mdundant cables to.the other. ' TVA addresses both concerns by mlying on ceiling. level sprinkler system ard-supplemental sprinkler protection to compmsate for the -intervening combustibles.

Sprinkler coverage has been providal at the ceiling in the rooms where redundant circuits are spacially separated.. These sprinklers will release large _ quantities of water in well. developed pattems at the ceiling during a fim. The' cooling effect of this water will prevent the formation of a heat plume and will control room temperatums until the fire brigade can respond and extinguish the fire. The existing sprinkler systems have been evaluated by NRC and by letter from R. C. Lewis to H.

G. Parris da ted April _28, 1981, were found to be aoceptable.

We will utilize the prinkler systems to address intervming combustibles by applying the following sprinkler system criteria.

SPRINKLER SYSTEM CRITERIA FOR RESOLVING INTERVENING COMBUSTIBLE CONCERNS 1.0 -- Objective The objective _of this criteria is to provide compensation for the

. lack of a' horizontal' distance of mcre than 20 feet hee of intervming combustibles between redundant divisions being protected

- in accordanowith.10 CFR 50 Appendix R, Section III.G.2.b.

Compmsation is providedby_ installing, in the defined. areas, supplemental sprinkler protection for floor level combustibles when adequate coverage by ceiling level sprinklers is not verified by this criteria.

2.0 Areas of Criteria Application

This_ criteria shall be applied as follows when redundant divisions are separated by horizontal space ani more than 20 continuous feet of the space is not fme of intervming combustibles.

2.1 'If the redundant divisions are greater than 30 feet apart, the criteria shall be applied to any continuous 30-foot-wide path located between the redundant divisions.

2.2 If ~ the redundant divisions are.gmater than 20 feet but less than 30 feet apart, the criteria shall be applied to the etire horizontal space between divisions.

3.0 Acceptance Criteria for Existing Sprinkler Heads 3.1 Existing sprinkler heads, which have been located to produce fully developed spray patterns at the ceiling, will provide acceptable floor coverage if there are rn intermediate e

7

.y obitruetioniin their pr.tt2rns which cm great 1;r thm 48-inch 2s r

wid e.

ifhen individual obstructions overlap or have less than a 4-inch ' flue space.between them when viewed from immediately below, they shall be considered a single obstruction for

' determining their cumulative horizontal width.. No combination of obstructions may traverse the 4-in& flue space and block more

' than -2. feet of any-8 feet of flue space.

3.2 Lateral' discharge from existing sprinkler heads may be utilized 4

-for floor coverage if the portion _of their discharge pattem that is being relied on has no significant. obstructions.' Significance shall--be evaluated considering the' typical-shape of a. sprinkler spray pattern and the obstruction guidelines of NFPA 13 3.3 : Acceptance of existing heads shall be based on visual

- observations in the plant.

4.0 Corrective Actions

~4.1 c When section 3.0 is not _ satisfied, sprinkler heads shall be

- provided under the obstructions utilizing one of. the. following options:

a., Relocate existing heads below intermediate level obstructions if adequate coverage can be mintained at the ceiling level, or.

b.

Add new heads below intermediate level obstructions. System adequacy shall be demonstrated using NFPA 13 pipe schedules -

or hydraulic calculations. If necessary, pipe sizes and supply header arrangements shall be &anged to satisfy this requirement.

n

. 4.2 The mximm floor area that can be protected by a single sprinkler head tall.be 130 square feet.

4 3 l When more than one head must be located below obstructions, the distance betwen ' heads shall not exceed 15 feet.

4.4 When hydraulic calculations are used to verify sprinkler system

' adequacy, the calculations shall be based upon the hydraulically most remote 1500 ft2 area or the area of the largest room, u

whichever is smaller. The systems shall be capable of ~

discharging a desity of 0.16 gpm/ft2 assuming all sprinkler heads in the aralyzed area are opm.

4.5 If a system designed -in moordance with the NFPA 13 pipe schedules supplies sprinkler heads in two or more rooms that are separated by 1-1/2-hour-fire-rated construction, the mximm number of L'

heads in each room must satisfy the pipe schedule limits for pipe size with each room considered separately. If this condition is satisfied, the maximm number of heads per pipe size may be exceedaf for all the rooms taken together.

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It -is TVA's pGiti n thtt cxitting tpriniclcr systins coupled with '

additional ~ sprinkler coverage resulting from the above -criteria will provide a ' level of protection that adequately compensates for.

the pmsence of = intervening combustibles' located between spacially separated redundant safe shutdom cables and that the' intent of section III.G.2.b will be satisfied.

We, therefore, request approval-of this deviation.

13 Deviation - Section III.G.2 requires that fire detectors and

' automatic fire suppression system be provided throughout areas containing redundant safe shutdown equipment which is separated by less than 3-hour fire-rated construction.

Within the Auxiliary. Building, the rooms or portions of room listed in Table 13-1 do not have the mquired detection and/or suppression system.

Justification - In the rooms with rated walls of less than three hours, the ~ fixed combustible loading will-yield a fire severity that is less than one half the rating of the room enclosums.

-In rooms without rated walls,- the construction of the walls is of reinforced masonary block which is equivalent to at least 1-1/2 hours.

These walls, however,- have pmetrations which have rot been providai' with fire-rated doors, fire dampers, or qualified fire-rated seals. These rooms contain no appreciable amounts of in-situ combustibles.

' Standpipe arri hose stations arri portable extinguishers are provided

. throughout the Auxiliary Building.

Considering-the low combustible loading arri snall size of the rooms, it is TVA's opinion that these room do not pose a significant fire exposure hazard-to redundant safe shutdown cables or equipment in the aur.iliary building. TVA, therefore, requests approval for the deviation to the

_ Appendix R Section III.G.2 requirement for fire detection and automatic

.u fim alppression throughout the fire area.

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'a TABLE.13 Coordinate

' Room Building

. Elevation Location Number Name Remarks Auxiliary.

639.5 A8/t Floor Equipment Drain Sump -

Note 1

- Auxiliary 639.5 A8/t

. Tritiated and Equipment Drain..~ Note :1 Sump Auxiliary 639.5 A8/t Elevator Shaft Note 2, Note:6 Note 11, Note 8.

Auxiliary 653.0 A5-A10/w-x 651.0-Al-Waste Holdup Tank Note 6, Note 2 Auxiliary 653.0 A10-A11/w-x.

651.0-A2 Waste Evaporator. Feed Pumps Note.6, Note 2 Auxiliary 653.0 A8/u 653.0-Al Corridor Note 3 Auxiliary 653.0 A4-A6/q-s 653.0-A2 Holdup Tank Room A

. Note 5,' Note 8 Auxiliary 653.0 A6-A10/1-s 653.0-A3' Holdup Tank Room B Note 5,aNote 8 Auriliary 653.0 A10-A12/r-s 653.0-A4 Floor Drain Collection Pump.

Note'6, Not'e 2.

and Filter Room Auxiliary 653.0 A10-A12/q-r 653.0-A4a Floor Drain Collection Tank Note 6 Note 2-Room Auxiliary 653.0 A6-A9/s-t

.653.0-A5-Gas Stripper Feed Pump' Note 6, Note 2, Note 3 Auxiliary 653.0 A5-A6/s-t 653.0-A6 Sump' Pump Room Note 6, Note 2,' Note 3 Auxiliary 653.0 A5-A6/s-t 653.0-A7 Sump Tank Room Note 6, Note 2 Auxiliary 653.0 A5-A7/t-u 653.0-A8 Containment Spray Pump IB-B Note 5, Note 12 Auxiliary 653.0 A5-A7/u 653.0-A9-Containment Spray Pump 1A-A.

Note 5, Note 32 Auxiliary 653.0 A5-A7/u-v 653.0-A10 RHR Pump Room 1B-B.

Note 5,: Note 12 Auxiliary 653.0 A5-A7/v-w 653.0-A11 RHR Pump Room 1A-A Note 5, Note'12 Auxiliary 653.0 A9-A11/v-w.

653.0-A12 RHR Pump Room 2A-A' Note 5, Note 12 Note 5, Note 12 Auxiliary 653.0 A9-A11/u-v 653.0-A13-RHR. Pump Room 2B-B Note 5, Note 12 Auxiliary 653.0 A9-A11/u 653.0-A14 Containment Spray Pump 2A-A Auxiliary 653.0 A9-A11/t-u 653.0-A15 Containment Spray Pump 2B-B.

Note 5,~ Note 12-Auxiliary 653.0 A4-A5/s-w 653.0-A16 Pipe Gallery Note 6, Note 2 Auxiliary 653.0 A11-A12/s-w 653.0-A17 Pipe Gallery Note 6, Note 2-Auxiliary 653.0

'A6-A8/v-w A Room in 651.0-Al Note 6, Note 2 Auxiliary 669.0 A2-A4/S 669.0-A2 Valve Gallery.

Note 6, Note 2 Auxiliary 669.0 A3-A4/q-s.

669.0-A3 Gas Decay Tank Room.

Note 5 Auxiliary 669.0 A2-A3/q-s 669.0-A5 Gas Decay Tank Room Note 5-d

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. Build'ing '

Elevation' Location' '

Room.

'. Coordinate Number "Name'>

' Remarks' h-.

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Auxiliary, 669.0 A3-A5/u-w~

• f669.0-A82 i Pipe Gallery and,Chasei Note 15s iNote 4, Note 51-s Auxiliary 669.0

.A3-A4/t-u

~669.0-A9

/ Charging Pump;1A-A"

Note 4,; Note 5 Auxiliary 669.0 A4-AS/t-u,

.669.0-A10-. Charging Pump.1B-B.

n Auxiliary 669.0.-

A5-A6/t-u.

l669.0-A11

' Charging Pump.1C?

tNote 4,; Note 5; Auxiliary 669.0 A8-A10/w 669.0-A17 Waste. Evaporator Package _~

Note'6,LNote.2, Note.10:

-Auxiliary 669.0 A9-A11/x 669.0-A16; Valve Gallery /

1 Note 4, Note 5 f

l-Auxiliary' 669.0 A10-A11/w.

669.0-A18- ' Auxiliary Waste Evaporator.

1 Note.4,' Note:5' Package.

l Charging. Pump 2C:

. Note 4, Note 5~

j Auxiliary 669.0

-A10-A11/t-u-

.669.0-A21 Auxiliary 669.0 A11-A12/t-u.

669.0-A22 Charging Pump 2B-B

Note.4,' Note 5' H

4 Auxiliary 669.0 A12-A13/t-u 692.0-A23 Charging Pump 2A-A, _

Note 4, Note 5-l Auxiliary 669.0 A11-A13/u-x 669.0-A24.

Pipe Gallery and Chase Note'5 j

Auxiliary 669.0 A14-A15/q-r 669.0-A27 Concentrate Filter Note:2, Note'6:

Auxiliary 669.0-A13-A14/q-s 669.0-A29 Boric Acid Evaporator Package Note.2, Note.67-

[

Room B i

Auxiliary 669.0 A12-A13/q-s-669.0-A30' Boric Acid Evaporator Package. ' Note 2, Note.6I Room A Auxiliary 669.0 A10-A12/q-s 669'0-A31 Spare Room Note:2, Note'6

^

Reactor Cavity Refueling Water Note 5 l

Auxiliary 669.0 AS/v-w 1

Pumps and Filters Auxiliary 690.0 A4-A5/u-v 690.0-A7-Volume Control Tank Room

' Note 4,l Note 5 l

Auxiliary 690.0 C1/v 690.0-A8 Reactor Building Access Room Note'5 Auxiliary 690.0 A3-A4/t-u 690.0-A9 Valve: Gallery, Demineralizers ~ Note 2, Note 6' and Filter' Enclosures-Auxiliary 690.0 A6/u 690.0-10_

Seal Water Hx 1AL Note 5

)

Auxiliary 690.0 A5-A7/u-v 690.0-A11 Heat Exchanger IB.

Note 5, Note 8 l

Auxiliary 690.0 A5-A7/v-w 690.0-A12-Heat Exchanger IA.

Note 5, Note 8 Auxiliary 690.0 A9-A11/v-w 690.0-A15 Heat Exchanger 2A

. Note 5,. Note 8.

j Auxiliary 690.0 A9-A11/u-v 690.0-A16 Heat Exchanger 2B.

' Note 5, Note 8 l

Auxiliary 690.0 A10/u 690.0-A17. -Scal Water Hx 2A Note'5 Auxiliary 690.0 A12-A13/t-u 690.0-A18 Valve Gallery, Demineralizers Note 2

l and Filter Enclosures Auxiliary 690.0

.A11-A13/u-v 690.0-A20 Volume Control Tank Room.

Note.4, Note 5;

.=.

Coordinate Room Building Elevation Location Number Name Remarks Auxilia ry 690.0 C13/v 690.0-A21 Reactor Building Access Room Note 5 Auxiliary 690.0 A6-A10/s 690.0-A22 Valve Gallery Note 2, Note 6 Auxiliary 690.0 A10-A12/r 690.0-A23 CVCS Valve Gallery Note 2, Note 6 Auxiliary 690.0 AS-Alor 690.0-A23a CVCS Valve Gallery Note 2, Note 6 Auxiliary 690.0 A3-A4/r 690.0-A24 VGC Valve Gallery Note 5 Auxiliary 690.0 A4/q 690.0-A25 Waste Gas Compressor B Note 5 Auxiliary 690.0 A3/q 690.0-A26 Waste Gas Compressor A Note 5 Auxiliary 690.0 A4-A8/u to 690.0-A28 Pipe Chase Note 5 R.B.

Auxilia ry 690.0 A8-A12/u to 690.0-A29 Pipe Chase Note 5 R.B.

Auxiliary 690.0 A1/s 690.0-A30 Air Lock Note 5 Auxiliary 690.0 A8-A9/w to 690.0-A31 Waste Gas Analyzer Note 2, Note 6 R.B.

Auxiliary 690.0 A14-A15/q-r AFW Valve Room Note 2, Note 6 Auxiliary 714.0 Al-A3/u-v 706.0-Al Main Steam Valve Room Note 5, Note 8 Auxiliary 714.0 A13-A15/u-v 706.0-A11 Main Steam Valve Room Note 5, Note 8 Auxiliary 714.0 A3/u 714.0-A4 Air Lock Note'2, Note 5 Auxiliary 714.0 A2-A3/u-v 714.0-A6 Air Lock Note 5 Auxiliary 714.0 A5-A7/u 714.0-A7 Let Down Heat Exchanger Note 5 Auxiliary 714.0 A9-A11/u 714.0-A8 Let Down Heat Exchanger Note 5 Auxiliary 740.0 A13-A14/u-v 714.0-A10 Air Lock Note 5 Auxiliary 714.0 A13/u 714.-A11 Air Lock Note 2, Note 5 Auxiliary 714.0 A11-A12/w 714.0-A15 Fuel Detector Room Note 2, Note 6 Auxiliary 714.0 A4-A5/w 714.0-A16 Fuel Detector Room Note 2, Note 6 Auxiliary 714.0 A4-AS/u-w Pipe Shaft Note 5 Auxiliary 714.0 A11-A12/u-w Pipe Shaft Note 5 Auxiliary 714.0 A2-x 706.0-A2 Main Steam Valve Room Note 7, Note 8 Auxilia ry 714.0 A14/x 706.0-A10 Main Steam Valve Room Note 7, Note 8 Auxiliary 714.0 A5-A11/RB Fuel Handling Area Note 5 to Z Auxiliary 734.0 Al-A3/s 734.0-A2 69KV Shutdown Board Room A Note 2, Note 5 (Corridor Only)

Auxilary 734.0 AS-All/t-y 734.0-A13 Refueling Room Note 5, Note 8, Note 14

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' Charger III.

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Fan. Room

' Note 2,1 Note 6 Auxiliary 763.0 A8/t 763.0-A2 Roof Access Air Lock-

' Note,2, Note 6 Room to Right of 763.0-A2-Note 2, Note 6 Auxiliary 763.0 A7/t

_ Room to Left of 763.0-A2 Note 2',' Note 6-

' Auxiliary 763.0 A8'A10/t Notes Note 1: This room is an enclosed sump and.contains no fixed combustibles.

Note 2: 'No appreciable in-situ combustibles are. located in this room.

Note 3: A fire detection system is provided-for this room.

Note 4: This room is provided with a detection and sprinkler system except in the entrance' labyrinth of each room.

Note 5: Compartmentation for this room is adequate for.the hazards present as approved by the SER,.

February 1980.

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Coordinate Room Building Elevation Location Number Name Remarks Note 6: This room is enclosed by reinforced concrete construction which may have unprotected openings.

Note 7: This fire area is completely separated from other buildings and other fire areas by reinforced concrete construction equivalent to a 3-hour fire rated barrier.

Note 8: This room appears on more than one elevation.

Note 9: Aside from the referenced inverter / charger area, the remainder of this room is protected by a preaction suppression system actuated by cross-zoned ionization smoke detectors.

Note 10: This room is protected by an automatic suppression system.

Note 11: This is an elevator shai

h 1-1/2-hour fire rated doors.

l Note 12: This room has detection except in the labyrinth.

Note 13: This room is provided with a detection and sprinkler system everywhere except stairway number 3, which extends from elevation 669.0 to 734.0.

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1 ENCLOSURE 3

> QMPLIANCE WITH NFPA '13-1975' IN REGARD TO THE' INSTALLATION OF WRINKLER SYSTEMS AT SEQUOYAH NUCLEAR PLANT-WPA 13-1975." Standard for the Installation.of Sprinkler Systems" is a standard which has been written to provide ' guidance for the installation of sprinkler systems. fbr a wide range of' industrial and comnercial properties. NRC also issues guidelines for

= the provision of fire protection 'in nuclear power plants. Some portions of NRC

~ guidelines modify the requiremets contained in NFPA 13-1975.. NRC guidelines take precedence over portions of'NFPA 13-1975 when NRC guidelines modify.those particular portions of NFPA '-13-1975..-

l Other: publications aM standards are referenced in NFPA 13-1975. Compliance with

.the referenced publications and standards is not inplied when NFPA 13-1975 is used as a design basis. document. Any commitment to comply with a particular publication e istandard in' whole or in part has been stated as a specific comunitment.

Therefore, NFPA-13-1975 is the ~ design basis document 'for the sprinkler systems at

- Sequoyah Nuclear Plant except for _ specific portions which have been modified or deleted in lieu of NRC guidelines er which are rot applicable in the nuclear power plant evironment, or idlich have been modified' or deleted in lieu of established TVA procedures.. The specific portions of NFPA 13-1975 which have been deleted or modified are listed below.

NFPA 13-1975 TVA Position Section 1-5.2 Maintenance and operation of installed systems

. Maintenance is performed in accordance with plant operating and maintenance proced7res.

Section 1-9 Plans are prepared, reviewed and approved in

~ Working Plans accordance with TVA design, construction aM modification procedures.

Section 1-10 Approval of sprinkler systene is performed in Approval of accordance with TVA design, construction aM Sprinkler Systems.

modification procedures.

Section-1-11 System tests are performed in accordance with

Acceptance ~ Tests -

TVA design, construction, ard modification procedu re s.

~

Section 1-12 Material ard test documentation are prepared Contractor's Material and maintained in accordance with TVA design, and Test Certificate construction ard modification procedures.

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• "NFPA 13-1971

-TVA Pnition j

Section 2-7 Fire department pumper connnections are rot of

- Fire Department significant benefit in a nuclear power plant Connections

- environment and are rot provided.

'Section 3-7.3 Flushing connections are rot of significant

. Provision ' for benefit in a nuclear power plant myironment aM

' Flushing System are tot provided. Strainers are provided in the.

supply to each preaction sprinkler system.

'Section 3-9.3' NRC guidelines and other appropriate staMards for Protection of support of piping is used in lieu of the

' Piping Against guidelines contained in this section.

Damage Where-Subject to

- Earthquakes

Section 3-10.3 4 -

Auxiliary ' drains' for trapped sections of pipe am Auxiliary Drains providei but the drains are rot installed in the exact configuration specified in section 3-10 3.4.

However, the drains, as installed, will perform the required function.

Section 3-11.2 Installation of welded piping is performed in Weldei Piping-accordance with TVA design, construction, modification and operatioral procedures. These procedums allow field welding. on sprinkler system installations ani modifications. All such welding is controlled by the appropriate safety procedu re s.

Sections 3-12.1 '.5 Due to other factors affecting the design of Fittings on Risers sprinkler system in a nuclear power plant environment, flange joints am rnt used on the riser at each floor level.

Secton 3-13 3 -

Valve idmtification is accomplished in accordance

~ Idetification of with TVA design, construction, modification, ard

> Valves operationa1 procedures.

Section 3-14 NRC guidelines ani other appropriate stardards am Hangers used for support of piping in lieu of the guidelines contained in this section.

Section 3-15.7 TVA procedures for the procumment and storage of

' Stock of Spare spare parts are used-in lieu of the guidelines set Sprinklers forth in this section.

Section 4-4.8.

Only those openings specifically documented in Elevators, Stairs previous consnitments to NRC are protected in

.and, Shafts accordance with the guidelines contained in this section.

Y Y

f' 1 NFPA 13-1975-TVA Position; Section 5-3 5 2-Sprinkler p'iping supervision is not included in -

~

f Supervision:

the design criteria for all' systems with more than

'20 : sprinklers on the. system. Sequoyah FSAR.

figums 9.5-1 through 9.5-36 as submitted in i

amendment 61, dated May 25, 1979, idestify the sprinkler systems which are and are rot

_ supervised. The provision of cross-zoned detector logic and pressum switches downstream of each

. preaction valve is adequate protection against inadvertent application of water from preaction sprinkler systems in areas which do not contain

. delicate, water-sensitive electrical equipment.

This position has been reviewed by NRC-NRR and has.

been found to be acceptable.

1 The Sequoyah Nuclear Plant Technical Specifications reflect the requimment fbe six-month testing of detection circuits from the local panel to the actuated devices, i.e., rim dampers, fim door holders, ventilation equipment x-preaction valves as agreed in the resolution of opas item 7.a during a meeting en February 12, 1979 with NRC-NRR. This commitment is included in Revision 4 of TVA Responses 9

to NRC fim protection questions submitted by letter from L.~M.

Mills to L. S. Rubenstein &ted October 23,

.1979. These responses have been reviewed by NRC-NRR and have been found to bc acceptable.

Chapter 7.

~

TVA design and documentation procedums are used Hydraulically Designed in lieu of the guidelines set forth in this chapter.

' Sprinkler Systems Any other sinor' deviation to requimments contained in applicable portions of NFPA ' 13-1975 which have not been listed above will be arnlyzed in accordance with 10 CFR 50.59. Any such deviation which does not adversely affect safety will be documented in accordance with established plant

- procedums.. Corrective action will be initiated for any such deviation

^

which could adversely affect safe operation of the plant.

_.