ML20195D509

Safety Evaluation Supporting Util Exemption from 10CFR50, App R Requirements

ML20195D509
Person / Time
Site:	Arkansas Nuclear
Issue date:	10/26/1988
From:	Office of Nuclear Reactor Regulation
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ML20195D506	List: ML20195D502 ML20195D509
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NUDOCS 8811070034
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UNITED STATES

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION EVALUATIONOFFIREPROTECTIONEXEPPQOM FACILITY OPERATING LICENSE NO. DPR-51 ARKANSAS POWER AND LIGHT COMPANY ARKANSAS NUCLEAR ONE, UNIT NO. 1 DOCKET NO 50-313

1.0 INTRODUCTION

By letter dated August 15, 1984 Arkansas Power and Light Company, (the licensee) requested approval of exen'ptions from the technical requirenents of Sections III.G. !!!.J and III.0 of Appendix R to 10 CFR Part 50. By letter dated August 30, 1985, the licensee requested approval of additional exeniptions from Appendix R.

Supplemental infornation was provided by the licensee in letters to the staff dated October 20, 1986, April 22, and June P4, 1987. The staff's evaluation of this inforwation is contained in this report as follcws:

Secticos 2.0 through 9.0 consist of the evaluation of specific exemption requests, and Section 10.0 consists of an evaluation of the licensee's fire hazards analysis concerning non-fire-rated features in fire area boundaries.

Section III.G.2 of Appendix R requires that one train of cables and equipment necessary to achieve and maintain safe shutdown te maintained free of fire damage by one of the following ceans:

1.

Separation of cablas and equipment and associated non-safety circuits of redundant trains by a fire barrier having a 3< hour rating.

Structural steel font.ing a part of or supporting such fire barriers shall be protected to provide fire resistance equivalent to that required of the barrier; 2.

Separation of cables and equiptrent and associated ron-safety circuits of redundant trains by a horizontal distance of more than 20 feet contains no intervening combustibles or fire hazards. In addition, fire detectors and an automatic fire suppression system shall be installed in the fire area; and 3.

Enclosure of cables and equipment and associated non-safety circuits of one redundant train in a fire barrier having a 1-hour rating.

In addition, fire detectors and an automatic fire suppression system shall be installed in the fire area.

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2 If these conditions are not met Section 111.G.3 requires an alternative shutdown capability independent of the fire area of concern.

It also requires that a fired fire suppression system be insi.alled in the fire area of concern if it contains a large concentration of cables or other combustibles. These alternative requirements are not deemed to te equivalent; however, they provide equivalent prctection for those configurations in i<hich they are accepted.

Because it is not possible to predict the specific conditions under which fires may occur and propagate, the design basis protective features are specified in the rule rather than a design basi', fire. Plant specific features may require protection different from the meastres specified in Section III.G.

In such a case, the licensee must demonstrate, by fire hazards analysis, that r.xisting protection in conjunction with proposed modifications will provide a level of safety equivalent to the technical requirements of Section !!!.G of Appendix R.

In suritary,Section III.G is related to fire protection features for ensuring that systems and associated circuits used to achieve and maintain safe shutdown are free of fire darage.

Fire protection configurations must either meet the specific requirerents of Section III.G or another fire protection configuration nust be justified by a fire hazard analysis.

The staff's general criteria for accepting a different fire protection configura-tion are the following:

The alternative assures that one train of equipment necessary to achieve hot shutdown from either the control room or emergency controls stations is free of fire danage.

The alternative assures that fire darage to at least one train of ecuipront necessary to achieve cold shutdcwn will be limited suct that it can be repa4 red within a reasonable time (minor repairs with components stored onsite).

Modifications required to meet Section !!I.G would not enhance fire protection safety above that provided by either existing or proposed alternatives.

Modifications required to meet Section !!I.G would be detrimental to overall facility safety.

2.0 O!ESEL GENERATOR ROOM EXHAUST FAN OUTLETS (FIRE AREA B7An0RE5 I T AWTt) 2.1 Exemption Requested The licensee requested approval of an exemption from the technical requirements of Section !!!.G of Appendix R to 10 CFR Part 50 to the extent that it requires that redundant, shutdown-related systems be separated by a herizontal distance.

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. of at least 20 feet free of intervening corbustibles and be protected by automatic fire suppression and detection systems.

2.2 Discussion The licensee stated that the following conditions in Fire Area B do not meet the technical requirements of Sectfon III.G.2.b.

In Fire Zones 1-E and 2-E of Unit 1, redundant diesel generator exhaust fan outlets are separated from each other by less than 20 feet of horizontal distance, and a fixed automatic fire suppression system is not installed.

Fire Zones 1-E and 2-E are on elevation 386 feet of Unit 1.

Fire Zone 1-E is north of Fire Zone 2-E.

They are located as follows:

North of Fire Zone 112-1 (the upper north electrical penetration room) and separated from it by a fire wall.

West of Fire Zone 149-E (the sprinklered hot-tool room) and Fire Zone 120-E (boric acid additicr. tank snd pump room).

South of the Unit 1/ Unit 2 boundary fire wall.

Above Fire Zones 86-G (the Unit I north diesel generator room) and 67-H (the Unit I south diesel generator roem) from which they are separated by a rated fire barrier.

Fire Zone 1-E is separated from Fire Zone 2-E by a reinforced concrete wall, e> cept for a doorway-fire opening at the east end of this wall. Also, tha zones ce not rcofet ScTe shutdcan related equip. rent in these zor,es consists of the cutlets of toe exhu st fans fro. the diesel generator rooms below.

These zenes are protected by an autorratic fire detection system. The corbus-t,1ble loading in Fire Zones 1-E and E-E are approximately equivalent severities of 1.5 and 1.2 minutes, respectively, on the ASTM E-119 tire-tertperature curva.

Redundant exhaust fan tabling is presently routed through Fire Zone 149-E. The licensee stated that one train of +,his cabling is enclosed in a 1-hour barrier wr. ore it passes through Fire Zone 149-E. This fire zone is protected by an at.tomatic sprinkler system, a fire detection system and manual fire fighting equipment. The licensee subsequently rerouted the ccnduit for the exhaust fans associated with the north diesel generator room. The conduit was rerouted through the hot-tool room and the boric acid tank room and a 1-hour wrap was installed on the conduit in the hot-tool room.

The licensee also subsequently installed a 3-hour rated fire door in the opening of the reinforced concrete wall separating the redundant fan outlets and rerouted the power cables to the air intake louvers 50 that they are powered from vital power sources.

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.4.

The licensee.iustified the exemption request on the basis of the existing protection and the modifications made.

2.3 Evaluation The technical requirements of Section III.G of Appendix R are not met in ttis area because redundant diesel generator exhaust fan outlets are not separated by at least 20 feet free of intervening combustibles. The lack of area-wide fire detection and supprossion systems in Fire Area B does not require an exemption per the guidance issued in Generic Letter (GL) 86-10. The staff was concerned that becaust of the absence of at least 20 feet of separation between the exhaust fan outlets, a pathway exists which could allow fire to spread and damage the redundant systems. Also, the lack of fixed suppression systems and fire detectors throughout this fire area could pennit a fire to spread and result in the lots of safe shutdown capability. However, because of the light combustible loading in these fire zones, it is not expected that a fire of significant duration or magnitude will occur. There are no intervening combus-tibles between the, redundant safe shutdown systems.

If a fire were to occur in or near one of the exhaust fans, it would be expected to develop slowly with initial low heat releast and slow temperature rise. The lack of a roof over Fire Zones 1-E and 2-E would preclude any accumulation of hot gases over this equipment, it would have to spread over and down into the room below, which is not considered credible. With the licensee's connitment to install 3-hour rated fire doors between redundant trains of equipment completed, the possibility of a single fire in one of these fire zones damaging redundant equipment is extreneiy unlikely, despite the horizontal separation distance of less than 20 feet between redundant trains.

Despite the lack of 20 or more feet of horizontal separation between redundant safe shutdown systems and the lack of firc detectors and an automatic fire suppression system throughout these zonas, there is reasonable assurance that a fire will not result in the loss of safe shutdown capability. Therefore, the staff finds that separating cables and equipment of redundant exhaust fans by a horizontal distance of more than 20 feet with no intervening combustibles or fire hazards in Fire Zones 1-E, and 2-E, would not significantly increase the level of fire protection.

2.4 Conclusion Based on the above evaluation, the staff concludes that the licensee's alter-native fire protection configuration provides an equivalent level of safety to that achieved by compliance with Section III.G of Appendix R.

Therefore, the licensee's request for exemption from the requirements for 20 feet of separa-tion, free of intervening combustibles between the diesel generator exhaust fan outlets is approved. The licensee's fire hazards evaluation concerning the l

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. absence of area-wide fire detectors and a fire suppression system in Fire Area B conforms with the guidance in GL 86-10.

No exemption for this condition is there' ore required.

3.0 RACWASTE PROCESSING _ M M,fFIRE AREA C d OM 20-Y)-

3.1 E,xemption Requested The licensee requested approval of an exemption from the technical requirerents of Section III.G of Appendix R to 10 CFR Part 50 to the extent that it requires that redundant shutdown-related systems be separated by a horizontal distance of at least 20 feet free of intervening corbustibles.

3.2 Discussion The licensee stated in the August 30, 1905 submittal that redundant borated water storage tank (BWST) outlet valves CV1407 and CY1408 are separated by less than 20 feet of horizontal distance. These valves are located at the west end of Fire Zone 20-Y cn elevation 335 feet. The corbustibles in this zone include lube oil on the south side of the zone. The combustible loading is approximately 5,784 Btu per square feet which produces an equivalent fire severity of less than 5 minutes on the ASTM E-119 tire-temperature curve.

Fire protection in the zone consists of closed-head sprinklers on a 10-foot spacing and fire detectors. The sprinklers were installed as a water curtain to protect the opening between the fire area ar.d Fire Area 8 on elevation 3Et feet.

A 1-hour rated fire barrier was installed to protect one train of conduit associated with the BWST valves. The licensee stated in the October 20, 1900 sobrittal that these valves are normally c1csed, but most be open for hot shutdown. The valves can be, rarually operated, but do not have to be opened until :-1/2 hours after a fire has started.

3.3 Evaluation The technical requirements of Section III.G are not met in this area because the redundant BWST outlet valves are not separated by more than 20 feet free of intervening combustibles. The staff was concerned that a fire of significant magnitude could damage these valves and prevent safe shutdown conditions from being achieved and maintained.

However, the corbustible loading in this area is low.

If a fire should occur, it would be detected by the existing fire detection system, and an alant vould be transmitted to the control autoratically. The fire brigade would sub-sequently be dispatched and would pst out the fire using the available ranual

fire fighting equipment. Pending arrival of the brigade, the 1-hour barrier which has been installed around the cables associated with one of the BKST valves would provide sufficient passive protection to assure that one shutdown division would be free of fire damage. Because of the low fire loading and tne nature of the valve construction, the staff would not expect the valve assembly to be affected by the elevated room temperature produced by a fire. Therefore, if the fire should damage the electric circuits, the valve could still be ranually realigned to re-establish the shutdown flowpath in sufficient tire.

On this basis, the staff finds that the lack of 70 feet of separation free of intervening corbustibles is not significant from a fire safety standpoint.

3.4 Conclusion Rased on the above evaluaticn, the staff concludes that the licensee's al-ternate fire protection configuration provides an equivalent level of safety te th6t achieved by compliar.ce with Section !!!.G of Appendix R -

Therefors, the licensee's request for exemption from the requirerent for 70 feet of separation free of intervening corbustibles, between the BVST outlet valves is granted.

4.0 EPERGEhCYFEECWATERPUPPRCCM,jFIREAREAC ZONE 38-Y) 3 4.1 Exemption Re,qu,es,ted The licensee requested approval of an exemption from the technical requirerents of Section III.G of Appencix R to 10 CFR Part 50 to the extent that it requires that redundant shutdchn-related systers be separated by at least 70 feet free 4

of intervening corbustibles, and the area be protected by an autcratic fire suppression system.

4.7 Discussiun Fire Zone 38-Y, the emergency feedwater (EFV) purp room is located on the 335-foot elevation of Unit I at the south end of Fir) Area C. This fire zone contains the following two EFW purps ar.d the ErW suction supply volves:

Purp F7A, the turbine-driven EFW purp is located on the south side of the EFW pump room.

It contains approximately 8 gallons of oil fully enclosed in heavy-gauge metal.

Pump P78, the motor-driven EFW purp is located on the north side of the room.

It contains approximately 7 gallons of oil.

The pumps are separated by a 6-foot high missile barrier, which is approx-irately the sare length as P7A. However, P7A and P78 are $1;ghtly offset in a lengthwise direction so that the west ends of both purps can "see" j

each other.

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The horizontal separation distance between the purp baseplates is 5 feet, 10 inches.

There are no intervening corbustibles in the EW pump room because the lube oil associated with the pumps is enclosed in the purps, and because skid-mounted lube oil piping and all cables in the room are in conduit. The fire hazards in the room are the lobe oil, which is associated with the turbine-driven E W punp (P7A), and transient combustibles. The combustible loading in this room is approximately 3,333 Btu per square foot, which produces an equivalent severity of 2.5 minutes on the ASTM E-119 time-terperature curve. The fire protection in this roon consists of two smoke detectors mounted on the ceiling. Manual fire fighting equipment is also available.

Suction valves associated with the service water and condensate supplies to both pumps are rounted approximately 3-1/2 feet above the floor on the north wall of this zone adjacent to P78. These valves are nortrally open and would fail open in the event that power is lost. Cabling associated with the valves and each EFV purp is routed in separate ccoduits frori each conponent to and along the ceiling of the room. Therefore, it is not credible to assure that a hot short or other fault resulting from a fire in this area would cause both valves to close.

In addition, a 1-hour fire-rated barrier was installed on the cabling associated with P7B.

The licensee performed an evaluatien of potential consequences of a fire in this rcom and concluded that:

The E W suction supply valves wculd be manually operable follcwing a fire, even if their power and control cables were destroyed.

P7A could be manually operated if its control cable was destroyed. Vanual controls are located at the pump.

The heat from a fire in the room would dissipate through the open dcorway to the remainder of Firo Area C.

In case of a fire, access to the room would be possible after 2-1/2 minutes.

Ten minutes would be required for the operator to implement the manual EW pump control procedure, as compared with over 30 minutes before RCS subcooling would be lost.

i In addition, by letter dated April 20, 1987, the licensee connitted to install l

a partial, automatic sprinkler system designed to previde protection for the steam-powered purp; and by letter dated June 24,1987 the licensee comitted to protect cabling necessary to provide automatic operation of the turbine driven purp by wrapping the cable in a 1-hour rated fire barrier in Zone 38-Y.

These rodifications are scheduled for corc 4 tion during the eighth refueling outage in the Fall of 1968.

e 4.3 Evaluation The technical requirements of Section III.G are not met in this area because redundant cables and equipment required for safe shutdown are not separated by a horizontal distance of at least 20 feet free of intervening corbustible raterials. The licensee's fire hazards evaluation concerning the absence of an area-wide fire suppression system in Fire Area C confonns with the guidance in GL 86-10. Therefore, no exemption for this condition is necessary.

The staff's principal concern was that a fire of significant magnitude could damage redundant EFW trairs and prevent safe shutdown from being achieved and raintained. However, the combustible loading in this area is low.

If a fire were to occur, it would be detected by the existing fire detection system in its fenratise stages before significant room temperature rise occurred. The fire brigade would be dispatched and would put out the fire using the existing manual fire fighting equiprent.

If rapid fire propagation occurred before the arrival of the brigade, the existing and proposed cable fire barriers, missile barrier and the prtposed automatir. sprinkler system would provide reascnable assurance that one division of EFW-related systems would remain free of dairage. Therefore, the lack of Fore than 70 feet of separation between redundant divisions is not significant from a fire safety standpoint.

4.4 Conclusion Gased on the above evaluation, the staff concludes that the licensee's proposed alterr. ate fire protection configuration provides an equivalent level of safety to that achieved by compliance with Section III.G of Appendix R.

Therefore, the licensee's request for exenption from the requirerent for at least 20 feet of separation between EFW-related systems in this area is granted. The licensee's fire hazards evaluation concerning the absence of an area-wide fire suppression system in this location conforms with the guidance in GL 86-10, and therefore, no exemption for this condition is required.

5.0 p!pEAREA(FIREAREAC,, FIRE 20NE34-Y}

5.1 Ex_erption Requested The licensee requested approval of an exemption from the technical requireeents of Section III.G of Appendix R to 10 CFR Part 50 to the extent that it requires an automatic fire suppression system in an area where redundant shutdown i

related systems are separated by a 1-hour fire barrier and protected by a fire I

I detection system.

1 5.7 Discussion Fire Zone 34-Y located on elevation 335 feet is south of Fire Zone 31-Y, west and north of Fire Area C/ Fire Area P boundary wall, and east of Fire Zone 70-Y.

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The corbustible loading in Fire Zone 34-Y is 1,353 Btu per square foot, which produces an equivalent severity of 1 minute on the ASTM E-119 time-terperature curve.

Power cables to the three makeup pumps (P36A, B, and C) in Fire Zone 20-Y are routed through Fire Zone 34-Y.

The power cables for pump P36A are 19 feet, 8 inches south of the P36B power cables. The P36C power cables are 1-foot north of the P368 power cables. there are no intervening coebustibles and all cables are in conduit. The P36B power cable is enclosed in a 1-hour fire rated barrier. Existing fire protection also includes a fire detection system, portable fire extinguishers and ranual hose stations.

The licensee justifies the absence of an automatic fire suppression system on the basis of the low fire loading and the existing protection.

5.3 Evaluation The technical requirerents of Section !!!.G of Appendix B have not been ret in this location because of the lack of an automatic fire suppression system. The staff was concerned that the lack of an autoratic fire suppression system could pemit a fire in the area to spread and result in the loss of safe shutdown capability. However, because of the light corbustible loading in this location, especially near the rakeup purip power cables, it is not expected that a fire of significant duration or ragnitude would occur.

If a fire were to occur, it would develop slowly with initial low heat release and slow rise in room temperature. The If ght corbustible loading (1-minute equivalent severity) and the 1-hour fire barrier wrap on train B of the makeup purp power cables provide reasonable assurance that a fire in this area would not result in the loss of redundant trains of rakeup purps.

In addition, despite the lack of an.utomatic fire suppression system throughout the fire area, a fire should be detected by the installed fire detection systems.

The detectors' alams would annunciate in the control room and the fire brigade would be dispatched to extlaguish the fire using the existing ranual fire fighting equipment.

5.4 Conclusion Based on the above evaluation, the staff concludes that the licensee's alternate fire protection configuration provides an equivalent level of protection to that a,chieved by ccepliance with Appendix R.

Therefore, the licensee's request for exerption from the requirement for an autoratic fire suppression system in this location is approved.

. 6.0 EMERGENCY LIGHTING ON ELEVATION 317 FEET OF UNIT 1 p0RTIONS OF THE AttE5FPATR5TTRE71EWPlPDRIA WIEIVAT10FakTEIT, THE lhTAKE STRUCTUREdFTiTT5EDUIE 570AAGE7 ADIT 5--~~

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6.1 Exemption Requested The licensee requested approval of an exemption from the technical requirerents of Section !!!.J of Appendix R to 10 CFR Part 50 to the extent that it requires 8-hour battery powered emergency lighting units in areas required to be ranned for safe shutdown and in access and egress paths to these areas.

6.2 Discussion The safe shutdown related equiprent on elevation 317 feet includes the decay heat purps, associated valves, and room coolers. This equiprent is not required until cold shutdown, which is not initiated for approximately 113 hours0.00131 days <br />0.0314 hours <br />1.868386e-4 weeks <br />4.29965e-5 months <br /> folloring a fire. These areas are provided with diesel-backed ac lighting and the plant operators have flashlights which can provide sufficient illumination.

The access path to the AMO-1 steam pipe area, which is not lighted is across the start-up boiler roor roof from the turbine building, and up a set of stairs to a door at the entrance to the steam pipe area. Access to the intake struc-thres ard the diesel fuel vaults is through the yard area between the turbine buildir.g and these buildings. All of the exterior areas described above are 111oHnated by the yard lighting, which is part of the station security syster and, therefore, are provided with backup power by the security diesel generator.

The security diesel generator is initiated when there is a loss of power in the ade.inistration building. The security diesel generator is fueled by a dedicated day tank, which is refilled from the 19,000-gallon capacity start-up boiler diesel fuel day tank. The full load rating of the security diesel genertor fuel supply is 7t hcurs.

6.3 Evaluation The technical requirerents of Saction I!!.J are not met because the subject locations are not provided with fixed, 8-hour battery powered emergency lighting units.

The safe shutdown related equixent on elevation 317 feet is not required until cold shutdown, which would be 3eyond the 8-hour tire frare that battery powered lighting would be available. By the tire operators would be expected to travel through this elevation, normal lighting is expected to be restored. Therefore, the absence of 8-hour battery powered lighting units in this location is not safety significant.

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' For the remaining areas referenced above, yard lighting is av:ilable. The staff had several concerns regarding reliance upon this 111 urination method.

The first was that hand held lights would be relied upon as the sole neans of illumination. The licensee has confirmed that, while the operators will be carrying flashlights, they will only be relied on to supplement the security lighting. Further, if the flashlights become inoperable, or cannot be used while perforr.ing the safe shutdown function, the security lighting itself would supply sufficient illumination.

The second concern was that the sane fire which resulted in the need to go to i

the areas covered by the security lighting would cause the loss of this capabil-ity. Powever, the security lighting is supplied power from the security diesel and is not vulnerable to fire loss under the postulated fire scenario. The third concern was that the level of illum.ination would not he sufficent to provide reasonable assurance that the safe shutdown function could be achieved.

The licensee conducted a walkdown of the yard areas and confi ved that an adequate level of illumination has been provided. The staff was also concerr.ed that the security lighting would not be maintained. However, the licensee indicated that this lighting is inspected and raintained as part of the plant security requirements.

6.4 Conclusion Based on the above evaluation, the staff concludes that the licensee's alternete lighting arrangenent in the subject areas achievas an equivalent, Icvel of safety to that required by compliaNe with Section III.0 of Appendix F..

Therefore, the licensee's ree.uest for exemption from the requirements for 8-hour battery powered lighting units in these areas is approved.

7.0 LEVEL TRAbsk1TTERS FOR THE SAFETY-GRADE CONDENSATE STORAGE TANK tuw amre r r xg r---------""-""-

l 7.1 Derp_tionRequested o

The licensee requested approval of exemptions from the technical requirements of Section III.G.2, of Appendix R to 10 CFR Part 50 to the extent that it requires a 3-hour fire barrier between redundant safe shutdown systems.

7.7 Dit = ston The Safety-Grade Condensate Storage tank (CCST) for each unit is located in the yard approximately 142 feet west of the Auxiliary Building (to the centerline of the tank), and is surrounded by an 18 inch thick ccncrete wall approximately five feet high.

There is a valve pit adjacent to the south side of the tank and outside the wall. The pit measures 11'6" by 12'6" and is connected to

. the Auxiliary Building by a pipe chase. The chase is separated from the Auxiliary Building by a 3-hour fire barrier. The walls of the chase and pit are reinforced concrete and below grade. The roof of the chase and a portion of the rcof of the pit is made of removable, concrete slabs. T.te remainder of the roof of the pit is reinforced concrete. Access to the pit is through an adjacent open hatchway.

At least one train of QCST level indication is required for safe shutdown in order to provide inferration to the operators so that appropriate ranual actions may be initiated to align EFW suction to an alternate water supply before the condensate inventory in the QCST is exhausted. Several hours are available before QCST level indication is required. One level transritter is located inside the pit and the other transmitter is located next to the tank, inside the wall, and under a tornado rissile shield. Cabling for the transnitter located in the pit is enclosed in conduit and is routed through the pipe chase to the Auxiliary Building.

Cabling for the other transmitter is routed in concrete-encased conduit enbedded in the ground adjacent to the pipe chase. At the tank, the conduit emerges inside the wall and under the missile shield.

At the Auxiliary Euidling it energes from the ground and is routed up the side of the building, where it penetrates the building about 75 feet above the grcund. This portion of the cenduit is enclosed by steel rissile barrier.

The valve pit, the pipe chast and the area inside the wall contain to in situ conbustibles. All cabling is enclosed in conduit.

Fire suppression capability consists cf a fire hydrant and bose house located in the irrediate vicinity at the south side of the tank.

There are not external fire hazards that could compromise the operability of both level transmitters. The warehouse and office are each located greater than 50 feet west of the tank, and each is equipped with an autcratic fire suppressien system. The em rgency Diesel fuel tanks are located in a belcw-grade vault approximately 200 feet to the north. The above-ground bulk diesel fuel storage tank is located about 300 feet to the north and is enclosed by a earthen dike sired to contain the entire volure of fuel in the tank.

The licensee justifies the exemption on the basis that there are no unmitigated fire bezards in the vicinity of the transmitters and that the physical configura-tion, as described above, is sufficient to assure that at least one transmitter and its associated cabling will remain free of fire darage.

7.3 Evaluation The technical requirerents of Section !!!.G.? are not met in the above referenced locations because redundant QCST level transmitters and their associated cabling are not completely separated by a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire-rated barrier.

. The staff was originally concerned that a fire could result in darage to the redundant components or cables. But, as described by the licensee, there are no significant unmitigated in-situ fire hazards which would represent a risk to these systems.

In addition, access to these locations is difficult, which would preclude the introduction of significant quantities of transient combustibles.

If a fire did occur under these circumstances it would be expected to be of limited regritude. The smoke and hot gases produced by the fire would tend to be dissipated in the open air, away from the subject systers.

The fire would be able to be extinguished by the plant fire brigade using the existing nornal fire fighting equipment. Pending arrival of the brigade, the physical configura-tion of the areas, including the wall and tornado missile shield, will provide sufficient protection to assure that at least one safe shutdown train will remain free of fire danage.

Therefore, the provision of additional fire protection to confortn with the criteria of Section ll!.G.2 will not significantly increase fire safety.

7.4 Conclusion Based on the above evaluation the staff concludes that the licensee's alternate fire protection configuration provides an equivalent level of safety to that achieved by compliance with Appendix R.

Therefore, the licensee's request for exerption from the requirements of Section !!!.G.2 for the QCST level transmitters and their related cabling should be granted.

8.0 REACTOR CODLANf PlWP Oil COLLECTION SYSTEM 0.1 Exemption Re_ ques,ted The licensae requested approval of exerptions from the technical requirerents of Section !!!.0 of Appendix R to 10 CFR Part 50 to the extent that it requires the reactor coolant purp (RCP) oil collection system to be sized to hold the contents of the entire lute oil system for all punps and to be designed to i

withstandasafeshutdownearthquake(SSE).

I 8.2 Discussion The RCP Oil Collection Systems at each unit contains two tanks. These tanks are each designed to hold the contents of one reactor coolant pump's lube oil inventory with margin. Oil leakage from the reraining pump in each RCS loop will be drained into the appropriate tank, until the tank capacity is reached, and then to an open curbing where it can be safely contained. The system is located above the floor of the Containrent Building.

Safe shutdown circuitry is routed approximately forty feet above that elevation outside the

-14 primary shield walls containing the reactor, RCPs, and other primary system ccc.ponents. The shield wall separates the heavy concentrations of safe shutdown circuitry in the electrical penetration areas from the RCPs and the 011 Collection System itself. Additionally, that circuitry is protected by localized autonatic fire suppression and detection capability. The Reactor Coolant Pump motor lobe oil systems are integral with the pump motors. The licensee stated in the August 15, 1984 submittal, that the lube oil systerrs are qualified to remain functional during and after a SSE.

8.3 Evaluation The technical requirerents of Section !!!.0 of Appendix R have not been ret because the oil collecticn system for the RCPs has not been sized to hold the oil from all of the. pumps and is not seismically designed.

Generic letter 86-10 states:

"Where the RCP lube oil syster is capable of withstanding the safe shutdown earthquake (SSE), the analysis should assune that only random oil Icaks from the jcints could occur during tre lifetine of the plant. The oil collection system, therefore, should be designed to safely channel the quantity of oil froni one purp to a ver.ted closed container. Under this set cf circuristances, the oil collecticn system would not have to be seismically designed.'

Cn the basis t. tat the late oil syster at ANO-1 is capable of withstanding the SSE without rupture and that the existing oil collection system will channel random leaks to a vented and closed container, t,he existing design conforms i

with the above staff guidance.

C.4 Cenclusion Based on the above evaluation, the licens(c's altern1te design of the oil collection syster provides an equivalent level of safety to that achieved by ccepliance with Section III.0 of Appendix R.

Tnerefore, the licensee's request for exerption is approved.

9.0 AUXILIARY BUILDING ELEVATION 335 FEE 1 M RE AREA C,_ ZONES 70-L AND 34-Y) 9.1 Egmption Requested The licensee requested approval of an exemption from the technical requirenents of Section !!!.G of Appendix R to 10 CFR Part 50 to the extent that it requires an autoratic fire suppression system be installed in an area to protect redundant shutdown systems which are separated by twenty feet and protected by a fire detection system.

. 9.2 Discussion Fire Zones 20-Y and 24-Y are located on elevation 335 feet of the auxiliary building. The corbustible loading in these locations is 656 and 1,353 BTV's per square foot, respectively. This is equivalent to a fire severity of about I minute as determined from the ASTM E-119 time-terperature curve. The licensee has stated that power cabling for the electric driven EFW purp is in the corridor in Zone 34-Y.

The control cabling for the turbine driven purp is located in Zone 20-Y. The cabling is separated by at least 26 feet with the only in-situ corbustible consisting of a nonorail with an isolated cable run to a srall electric motor.

Existing fire protection includes an area-wide fire detection system, and nanual fire fighting equipment.

The licensee justifies the exemption on the basis of the limited hazard and the existing protection, g.3 Evaluation The technical requirerents of Section !!!.G. are not met in this location because of the lack of an autoratic fire suppression system in the ares.

The staff was concerned that a fire of significar.t nagnitudc would occur and denage the redundant EFW punp cables. Fewever, the fire Itading in these lccations is negligible and consists prinarily of cables in tra.ys.

If d fi>:e would occur it would be characterized, initially, by low heat release ar d lir.ited flame propagation. The ext 9 ting snoke detection syster would be espected to actuate and transmit an alarm autoratically to the control room.

The plant fire brigade would be dispatched and would be capable of putting cut the firo using the existing war.ual file fighting equipment, Pending arrival of the brig 6de, the existing spatial separation wculd provide reasonable assurance that at least one shutdown division would remain free of fire damage. Therefore, the lack of an autcratic fire suppression system is not safety sitnificant.

9.4 Conclusion Based on the above evaluation, the licenste's existing fire protection provides an equivalent level of safety to that achieved by compliance with Appendix R.

Therefore, the licensee's request for exemption from the requirement for an autor4. tic fire suppression system in the subject locations is approved.

5 f

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. 10.0 RADWASTE PROCESSING AREA FIRE BARRIER OPENING (FIRE AREA C FIRE ZONE 20-Y)

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10.1ExemptionsRequesM The licensee requested approval of exerptions from the technical requirements of Section !!!.G of Appendix R to 10 CFR Part 50 to the extent it requires that redundant shutdown-related systems be separated by a 3-hour fire-rated barrier.

10.2 Discussion Radwaste ProceshArea The licensee stated in the August 15, 1984 submittal that an opening in the fire barrier separating Fire Area C from Fire Area B is not a fire rated construction.

Fire Zone 20-Y is on elevation 335 feet.

It contains the three makeup /HPI pup >ps and the BWST valves. The pueps are in cubicles on the south side cf the fire zone. The valves are in a roce on the west side of the zone and are connected to Fire by fire detectors. A line of closed-head sprinklers on a 10-foot spacing was installed in the valve area to serve as a water curtain separating the two fire areas. The corbustible loading in this fire area is approximately 5.600 Btu per square foot, which produces an equivalert fire severity of atout 4 minutes on the ASTP E-119 tire-terperature curve.

Lower North Pjpjng, Penetration Recm The licensee stated in the August 15, 1984 and the August 30, 19P5 submittals ttat the structural steel supporting the fire barrier between Fire Area C on elevation 335 feet and Fire Ares B on elevation 360 feet is not protected to provide a 3-hour fire resistance rating.

Fire Zone 53-Y contains no in-situ corbustibles.

Fire Area C has a corbustible loading of approxirately 5.600 Ptu per square foot, which produces an equivalent fire severity of about 4 minutes on the ASTP E-119 time-terperature curve.

j.oyerNorth_ElectricalPenetrationRoom The licensee stated in the August 15. 198/ and the August 30. 19F5 subeittals that the structural steel supporting the fire barrier between Fire Zones 112-1 and 98-J of Fire Area I (on elevations 372 and 373 feet. 6 inches, respectively) and Fire Zone 129-F of Fire Area G (on elevation 386 feet) is not protected to provide a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire resistance rating. The corbustible contents of Fire Area ! are corprised of electrical cable insulation. The corbustible loading

. in the fire area is appror. irately 72,000 Btu per square foot, which produces an equivalent fire severity of about 55 minutes on the ASTM E-119 time-temperature curve.

Fire zone 98-J is protected by a deluge sprinkler system, which is actuated by ceiling-rounted smoke detectors and line-type heat detectors installed in the cable trays. Fire Zone 112-1 is protected by a preaction sprinkler system, which is activated by ceiling-rounted smoke detectors.

10.3 Evaluation The above-referenced features exist in the boundary construction of individual fire areas and, as such, come within the guidance issued in GL 86-10.

No exerptions for these conditions are therefore necessary. The staff considers the licensee's submittals as constituting the required fire hazards analysis.

The staff's principal concern was that a fire of significant nagnitude would prcragate from the area of fire origin into the adjoining fire area and darage redundant systers required for safe shutdown.

If a fire were to occur in the subject locaticns, it would be detected in its forrative stages by the existing fire detection systems. The fire brigade would be dispatched and would suppress the fire before significant damage occurred. Pending arrival of the brigade, the existing construction is adequate to confine the effects of the fire to the i

nea of origin. Therefore, the lack cf a corplete fire-rated barrier et these lor.atior.s is not significant from a fire-safety standpoint.

1 10.4 Conclusj,on o

The licensee's analysis of the non-fire-rated features in the perireter of the subject fire areas confonns with the guidance in GL 86-10 and is, therefore.

acceptable.

11.0 ENVIRONPENTAL C0hSIDERAT10h5 The NRC staff has previously concluded, pursuant to 10 CFR 51J2, that the issuance of these exeeptions will not have a significant irpact on the quality i

of the human environment (53 FR 27091, July 18, 1988).

4 12.0 StM4ARY Based on its evaluation, the staff concludes that the licensee's alternate fire protection configuration in the identified areas provides an equivalent level of safety to that achieved by compliance with Appendix R.

Therefore, the licenste's request for exerption for the following conditions is approved:

1.

Lack of 20 feet of separation free of intervening corbustible roterials between redundant shutdcwn related systees in the diesel exhaustfanoutletsarea(FireAreaB. Zones 1-Eand2-E)generatorrecm

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18-2.

Lack of 20 feet of separation free of intervening corrbustibles, between the borated water storage tank outlet valves in the radwaste processing are (Fire Area C Zone 20-Y).

3.

Lack of 20 feet separation free of intervening corbustible materials between redundant shutdown-related systems in the erergency feedwater purp room (Fire Area C, Zone 38-Y).

4 Lack of an autoratic fire suppression system to protect redundant shutdcwn-related systems in the pipe area (Fire Area C, Zone 34-Y).

5.

Lack of 8-hour battery powered emergency lighting units on elevation 317 feet of Unit I and portions of the access path to the steam pipe area on elevation 404 feet, the intake structure, and diesel fuel storage vaults.

6.

Lack of a coeplete 3-hour fire-rated barrier between redundant level transmitters for the safety grade condensate storage tank (Yard Area t

Unit I and 2).

7.

Lack of a reactor coolant purp oil collection system that is designed to withstand a safe shutcown earthquake and that is sized to hold the oil from all reactor coolant pumps.

l S.

Lack of an autoratic fire suppressio9 systen to protect redundant erergency feedwater punp cables in tre aufliery butiding on elevation 335 feet (Fire Area C, Zones 34-Y and 20-Y).

d In addition, based on its evaluation of the licensee's submittals, the staff I

concludes that the licensee's analysis of the partial fire detection and suppression systers in Fire Arva B, the partial sprinkler system in the EfW Purp Room, and the non-fire-:sted features in certcin fire avea boundaries, ss described above, conform with the g'sidarice issued in GL EC-10 and are, therefore, acceptable.

Principal Contributor:

D. Kubicki Dated: October 26, 1988