ML20198A143
| ML20198A143 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 04/25/1986 |
| From: | Warembourg D PUBLIC SERVICE CO. OF COLORADO |
| To: | Berkow H Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20198A148 | List: |
| References | |
| RTR-NUREG-0800, RTR-NUREG-800, RTR-REGGD-01.088, RTR-REGGD-1.088 P-86069, TAC-61578, NUDOCS 8605200344 | |
| Download: ML20198A143 (7) | |
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Company of Colorado 2420 W. 26th Avenue, Suite 1000, Denver, Colorado 80211 April 25, 1986 Fort St. Vrain Unit No. 1 P-86069 Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 Attn: Mr. H.N. Berkow, Director Standardization and Special Projects Directorate Docket No. 50-267
SUBJECT:
Record Storage Center at Fort St. Vrain
REFERENCE:
PSC Letter, Warembourg to Johnson, dated 09/10/85 (P-85310)
Dear Mr. Berkow:
In the above referenced letter, Public Service Company of Colorado (PSC) informed the NRC that design was underway on a new Record Storage Center for Fort St. Vrain.
PSC also informed the NRC that a letter would be sent listing codes, standards and exception requests for the design of the new Record Storage Center at Fort St. Vrain.
As was pointed out in the above referenced letter, the new Record Storage Center will be a building separate from the present record storage building. The building will be a one-story building, and will be used solely for record storage, containing no office space.
The intent of this letter is to iaform you of the codes and standards that will provide the design basis for the new Record Storage Center, and to enumerate the exceptions that are being requested.
PSC will perform the design of the new Record Storage Center for Fort St. Vrain in accordance with the NRC Standard Review Plan (NUREG-0800)
Section 17.1.17.4 concerning the design of suitable A facilities for the storage of Quality Assurance records.
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- The records will be stored in mobile shelving units which, when contracted together, form a six-sided cabinet which totally surrounds the records.
Attachment I to this letter lists the exceptions that PSC is requesting, along with the justification for each exception requested.
PSC feels that each of the exceptions requested will not compromise the integrity or adversely affect the protection of the records within the Record Storage Center.
There are certain design parameters which, while not exception requests, do warrant notice. The fire suppression system in the Record Storage Center will be a Halon 1301 system as opposed to a water sprinkler system. The reason behind this decision is to avoid any damage to the records from water, in the event that the fire suppression system is used. The fire alarm for the Record Storage Center will sound in the plant's control room.
The security system will provide indication of entry into the Record Storage Center when record storage personnel are not present during off-shift hours.
The enclosed drawings are to assist in your review of the exception requests for the Record Storage Center.
Please note that these drawings are preliminary in nature, and minor changes may be made as the design is completed.
In Fort St. Vrain's FSAR Appendix d Section B.5.19.9, PSC has committed to the requirements of ANSI N45.2.9-1974 for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants.
PSC is now committing to the NRC Standard Review Plan (NUREG-0800) Section 17.1.17.4 for the design of the new Record Storage Center. PSC has reviewed this change in quality assurance program commitments under the provisions of 10CFR50.54(a) and considers that this change does not reduce the commitments in the program description previously accepted by the NRC. The NRC Standard Review Plan Section 17.1.17.4 specifies requirements which are as stringent as those
.specified in Fort St.
Vrain's FSAR Section B.5.19.9.
Section 17.1.17.4 of the Standard Review Plan serves as a guide for the design of the storage facilty and references ANSI N45.2.9 and NFPA 232.
PSC requests a written NRC approval of the exceptions requested in this letter.
In order to help ensure that the new Record Storage Center will meet the NRC requirements, material procurement and building construction are being held, pending NRC approval of these exception requests.
For this reason, your prompt attention to this matter would be greatly appreciated, s
,. - If you-have any questions concerning this matter, please contact Mr. M. H. Holmes at (303) 480-6960.
Very truly yours, 0 $ /YAA.<&
D.W. Warembourg, Ma#ager -
Nuclear Engineering Division DW/JW:pa Attachment Fort St. Vrain Records Storage Center Exceptions to Reg. Guide 1.88 and NUREG 0800 Endorsement of:
(1) flFPA 232 (1983)
Fire resistance ratings prescribed for file rooms shall Section 3-2.2 be the time that materials or assemblies have withstood a fire exposure established in accordance with the test procedure of NFPA 251, Standard Methods of Fire Tests j
of Building Construction and Materials.
PSC EXCEPTIO!!
Fire resistance ratings prescribed for file rooms shall be established in accordance with the Uniform Building Code, 1982 edition, and have a U.L.
or Factory Mutual fire rating label attached to the doors or frames.
JUSTIFICATION:
.This
- request, while providing essentially the same protection level, will allow use of a code that is commonly used, and consistent with other structures at the Fort St.
Vrain plant.
(2) NFPA 232 (1983)
Size: File rooms shall not exceed 50,000 cu. ft. (1416 m')
Section 3-3 in volume, and the height shall not exceed 12 ft. (3.7m).
PSC EXCEPTION:
File rooms shall not exceed 50,000 cu. ft. in volume, and the height shall not exceed 13 ft. from top of finished floor to bottom of roof.
JUSTIFICATIO!!:
The 13 ft. height will provide adequate roof drainage and clearances for the light fixtures and heating and ventilation equipment.
(3) NFPA 232 (1983)
Section 3-6.3 3-6.3.1 Walls of file rooms shall have no openings other than those necessary for
- access, electric
- lighting, power-limited circuits, sorinkler piping, and hot water or low pressure steam piping.
PSC EXCEPTION:
Add ducts and Halon piping to the list of wall openings.
JUSTIFICATION:
Section 17.1.17.4.5 of the NRC Standard Review Plan (NUREG-0800) allows the use of ducts with fire dampers.
3-6.3.2 Door openings shall be protected with acproved file room doors.
Doors shall not open into elevator, conveyor, or other shafts.
PSC EXCEPTION:
Door openings shall be protected with accroved fire rated doors.
Doors shall not open into elevator, conveyor, or other shafts.
O p
w JUSTIFICATION:
Fire doors with a rating of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> will be used for fire protection purposes.
NFPA 232 (1983)
Section 3-6.3 3-6.3.3 Walls shall not be pierced for ventilation.
PSC EXCEPTION: Walls shall be pierced for ventilation duct work and adequate fire rated dampers shall be installed in the wall penetrations.
JUSTIFICATION:
Same as the justification for the exception to 3-6.3.1.
(4) NFPA 232 (1983)
Section 3-7.2 In fire-resistive buildings, the roof or the floor may serve as the roof of the file room, provided it is of limited combustible or non-combustible construction throughout and complies with the following requirements:
a) Roof of file room shall be reinforced concrete or reinforced concrete on protected steel supports.
b) Roof of file room shall have fire resistance at least equal to that of the walls, and have structural strength adequate to carry the design load, greater if subject to unusual impact or if exposed to fire from outside the file room.
c) All interior supports shall have fire resistance equivalent to that of the walls.
d) Roofs of file room shall not be pierced for any purpose.
PSC EXCEPTION:
This paragraph is not applicable because the roof of the new Record Storage Center will not serve as the floor for another file room, since the new Record Storage Center will be a one-story building.
(5) NFPA 232 (1983)
Section 3-8.1 Each wall opening in the file room shall be provided with doors tested in accordance with ANSI /UL 155.
The file room door shall have a rating, in hours of fire resistance, comparable to the classification of the walls of the file room, as follows:
6-hour file room hour door 4-hour file room hour door 2-hour file room hour door 1-hour file room -
1-hour door PSC EXCEPTION:
Each wall opening in the file room shall be provided with a door or a damper certified by UL or Factory Mutual that is 2-hour fire-rated.
JUSTIFICATION:
The dampers were added since the Standard Review Plan (NUREG-0800) allows the use of ducts, as long as dampers are included at wall penetrations.
The 2-hour fire rating was specified because that is the rating that the Standard Review Plan allows.
- 6) ANSI N45.2.9-1974 Section 5.6 Facility:
Permanent and temporary record storage facilities shall be so constructed or located so as to protect contents from possible destruction by causes such as fire, flooding, tornados, etc.
PSC EXCEPTION: The word " tornado" shall be changed to " winds", and the Uniform Building Code, 1982, shall be used to determine the wind speed for the area.
JUSTIFICATION:
The wind design criteria for structures not directly associated with safe shutdown or operation of the reactor is 100 mph (90 mph + 10% allowance for gusts).
This design criteria is referenced in FSAR Section 1.4.5.2 and Reference Design Criteria DC 70, Section 3.2.1.
7)
NFPA 232 Section 3-10.2 The wiring shall provide as many fixed lamps as needed for adequate illumination.
There shall be no pendant lamps or extension cord used within a file room.
Fixed lighting shall be adequate for all portions of the file room to preclude the use of matches or other hazardous lighting.
PSC EXCEPTION: The wiring shall provide as many fixed fixtures as needed for adequate. illumination.
Pendant mounted fixtures will be used, supported by rigid galvanized steel conduit.
JUSTIFICATION:
Pendant mounted fixtures are needed to facilitate mounting the fixtures at mounting height for adequate lighting.
8)
NFPA 232 Section 3-10.3 Necessary lighting shall be limited to vapor-proof or explosion-proof lamps controlled by a 2-pole switch equipped with a pilot light outside of the file room.
No other electrical devices or appliances, other than power-limited circuits, shall be permitted within the file room.
PSC EXCEPTION: Necessary lighting shall be limited to totally enclosed steel chassis fluorescent fixtures controlled by 3-way switches inside the file room adjacent to the doors.
A minimum number of duplex receptacles shall be permitted within the file room.
JUSTIFICATION: The 3-way switches will allow the lighting to be controlled from either access door in accordance with NFPA 70, 1983, National Electrical Code, Article 380-8 (a).
The duplex receptacles will allow for adequate house cleaning.
I
- 9)
NFPA 232 Section 3-11 3-11.1 Heating shall be by hot water or steam... Piping shall be placed overhead.
Where the pipe is carried through the wall, the holes shall be made as small as practicable...
PSC EXCEPTION: Heating shall be by hot water, steam or forced conditioned air... Piping or ducting shall be placed overhead.
Where the pipe or duct is carried through the wall, the holes shall be made as small as practicable...
JUSTIFICATION: The Standard Review Plan (NUREG-0800, Section 17.1.17.4.5) allows the use of ducting.
3-11.2 Ventilation of the interior shall be through a door opening.
PSC EXCEPTION: Ventilation of the interior shall be through ducting that contains dampers that have a 2-hour fire rating whare the ducts penetrate the walls.
JUSTIFICATION: The Standard Review Plan (NUREG-0800) allows the use of ducting, with fire dampers at wall penetrations.
10)
NFPA 232 Section 3-12.4 File rooms shall not be used as working spaces.
No work stations shall be permitted.
Persons other than those authorized to handle records shall not be permitted in the file rooms.
PSC EXCEPTION: The file room shall not be used as an office;
- however, a staging area shall be permitted in the file room solely for the purpose of arranging records prior to their filing and separating records prior to their reproduction.
There shall be no record reproduction, film developing, or other activities not directly associated with record storage or retrieval permitted in the file room.
JUSTIFICATION:
The separation and rearranging of records is more safely done in the file room, which has c 2-hour rating, than in an office area.
The staging area, while not an office area, may have personnel working in it, but this work will be limited to activities. directly related to the storage or retrieval of records.
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