ML20203G586

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Summary of 860617 & 18 Onsite Meetings W/Util Re Request for Exemption from Fire Protection Features in 10CFR50,App R Per 850507 Fire Hazards Analysis & 860507 Rev.Agenda Encl
ML20203G586
Person / Time
Site: Grand Gulf Entergy icon.png
Issue date: 07/18/1986
From: Kintner L
Office of Nuclear Reactor Regulation
To:
Office of Nuclear Reactor Regulation
References
NUDOCS 8608010319
Download: ML20203G586 (22)


Text

JUL 181986 Docket No. 50-416 LICENSEE: Mississippi Power & Light Company (MP&L)

FACILITY: Grand Gulf Nuclear Station, Unit 1

SUBJECT:

SUMMARY

OF JUNE 17 AND JUNE'18, 1986 MEETING REGARDING FIRE PROTECTION The purpose of the meeting was to obtain information regarding fire protection features for which an exception to Appendix R. was requested in the GGNS Fire Hazards Analysis submitted May 7, 1985 and revised May 7, 1986. Additional exceptions requested by letters dated May 18 and June 14, 1985 were also to be considered. The meeting was scheduled and noticed for June 16 and June 17, 1986, but had to be rescheduled to June 17 and 18 at the last moment so there was not time to revise the notice. Enclosure 1 is an agenda, including MP&L participants in the plant walkdown and discussions. Participants for NRC were Greg Harrison (consultant), Ward Smith and Les Kintner. Enclosure 2 is a description of the fire areas, safety related equipment and fire protection features for which exceptions were requested.

The NRC staff walked down the areas of the plant for which exceptions were requested. In addition the staff observed the area near .the primary contain-ment hatch within the secondary containment where the licensee plans to store materials needed during refueling. Licensee will install sprinklers in this area. The licensee's personnel accompanied the staff on the walkdown and provided information and answers to staff questions.

The information obtained during the walkdown will be considered by the staff in its safety evaluation of the exceptions to Appendix R as included in the GGNS Fire Hazards Analysis.

Original signed by L. L. Kintner, Project Manager BWR Project Directorate No. 4 Division of BWR Licensing

Enclosures:

As stated DISTRIBUTION cc w/ enclosures:  ; Docket File See next page NRC PDR LPDR PD#4 Rdg.

WButler LKintner M0'Brien Young, OGC Edordan PD#4/PM P #4/D BGrimes er:1b Butler ACRS (10)

LKintp/86 07/)f 07/f/86

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8608010319 860718 PDR ADOCK 05000416 F PDR I

,# a ucu,k UNITED STATES y e g NUCLEAR REGULATORY COMMISSION

%;  :. j WASHINGTON, D. C. 205S5

\..~.../ JUL 181986 Docket No. 50-416 LICENSEE: Mississippi Power & Light Company (MP&L)

FACILITY: Grand Gulf Nuclear Station, Unit 1

SUBJECT:

SUMMARY

OF JUNE 17 AND JUNE 18, 1986 MEETING REGARDING FIRE PROTECTICN The purpose of the meeting was to obtain information regarding fire protection features for which an excepticn to Appendix R. was requested in the GGNS Fire l Hazards Analysis submitted May 7, 1985 and revised May 7, 1986. Additional exceptions requested by letters dated May 18 and June 14, 1985 were also to be considered. The meeting was scheduled and noticed for June 16 and June 17, 1986, but had to be rescheduled to June 17 and 18 at the last moment so there was not time to revise the notice. Enclosure 1 is an agenda, including MP&L participants in the plant walkdown and discussions. Participants for NRC were Greg Harrison (consultant), Ward Smith and Les Kintner. Enclosure 2 is a description of the fire areas, safety related equipment and fire protection -

features for which exceptions were requested.

The NRC staff walked down the areas of the plant for which exceptions were requested. In addition the staff observed the area near the primary contain-ment hatch within the secondary containment where the licensee plans to store materials needed during refueling. . Licensee will install sprinklers in this area. The licensee's personnel accompanied the staff on the walkdown and '

y provided information and answers to staff questions.

The infonnation obtained during the walkdown will be considered by the staff in its safety evaluation of the exceptions to Appendix R as included in the -

GGNS Fire Hazards Analysis.

c h L. L. Kintner, Project Manager BWR Project Directorate No. 4 Division of BWR Licensing

Enclosures:

l As stated cc w/ enclosures:

See next page l

l Mr. Oliver D. Kingsley, Jr. i Mississippi Power & Light Company Grand Gulf Nuclear Staiton  !

i cc:

Robert B. McGehee, Esquire The Honorable William J. Guste, Jr.

Wise, Carter, Child, Steen and Caraway Attorney General P.O. Box 651 Department of Justice Jackson, Mississippi 39205 State of Louisiana Baton Rouge, Louisiana 70804 Nicholas S. Reynolds, Esquire Bishop, Liberman, Cook, Purcell Office of the Governor and Reynolds State of Mississippi 1200 17th Street, N.W. Jackson, Mississippi 39201 Washington, D. C. 20036 Attorney General Mr. Ralph T. Lally Gartin Building Manager of Quality Assurance Jackson, Mississippi 39205 Middle South Services, Inc.

P.O. Box 61000 Mr. Jack McMillan, Director New 0: leans, Louisiana 70161 Division of Solid Waste Management Mississippi Department of Natural Mr. Larry F. Dale, Director Resources Nuclear Licensing and Safety Bureau of Pollution Control _

Mississippi Power & Light Company Post Office Box 10385 P.O. Box 23054 Jackson, Mississippi 39209 Jackson, Mississippi 39205 Alton B. Cobb, M.D.

Mr. R. W. Jackson, Project Engineer State Health Officer Bechtel Power Corporation State Board of Health 15740 Shady Grove Road P.O. Box 1700 ,~

Gaithersburg, Maryland 20877-1454 Jackson, Mississippi 39205 Mr. Ross C. Butcher President Senior Resident Inspector Claiborne County Board of Supervisors _

U.S. Nuclear Regulatory Connission Port Gibson, Mississippi 39150

' Route 2, Box 399 Port Gibson, Mississippi 39150 Mr. Ted H. Cloninger Vice President, Nuclear Engineering Regional Administrator, Region II and Support U.S. Nuclear Regulatory Commission, Mississippi Power & Light Company 101 Marietta Street, N.W., Suite 2900 Post Office Box 23054 Atlanta, Georgia 30323 Jackson, Mississippi 39205 Mr. J. E. Cross.

Grand Gulf Nuclear Station Site Director Mississippi Power & Light Company P.O. Box 756 Port Gibson, Nississippi 39150 Mr. C. R. Hutchinson

! GGNS General Manager Mississippi Power & Light Company Post Office Box 756 Port Gibson, Mississippi 39150 i

l - __ _ _

. Enclosure 1 (Revised 6/17/86)

AGENDA NRR Fire Protection Visit GGNS Energy Services Center NPE Director's Conference Room June 17-18, 1986 Tuesday, June 17, 1986 Approximate Responsibility Time Subject 1:00 P.M. Introduction J. O. Fowler Orientation and Overview -

T. E. Barnett of Plant Architectural Features Summary of Identified Appendix R Exceptions , ,

- Exceptions identified in T. E. Barnett -

the Summary Report

- Raceway Support J. H. Turner Evaluation

- Additional Exceptions T. E. Barnett .

Identified in the '

Review of Fire Area

. 25(Containment) 2:00 P.M. Security Clearances 2:15 P.M. Wal'<down of Fire T. E. Barnett/

Areas D. P. Wiles Wednesday, June 18, 1986 8:00 A.M. Question & Answer Session / S. P. Hutchins Continued Walkdown of T. E. Barnett/

Fire Areas (if necessary) D. P. Wiles 11:00 A.M. Summary & Exit J. O. Fowler l

J14PMI86051501 - 2

4

I ,. .

Enclosure 2 a

FIRE AREA 1 Fire Zone 1A101, located east of Column Line G.4, contains both Division I and Division II safe shutdown components. All Division II safe shutdown components are located more than 35 feet north of Column Line 11.0. All Division I safe shutdown components in Fire Zone 1A101, located north of  !.

Column Line 11.0, are protected with nominal 1-hour fire barriers.  ;

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Therefore, the minimum separation distance between Division I and Division II safe shutdown components that are not protected with barriers is 35 feet. The intervening combustible located within this separation distance consists of one ventilated cable tray containing non-safety-related IEEE-383 cable installed in accordance with the requirements of Regulatory Guide 1.75. The ventilated cable tray transverses the entire 35 foot separation zone but is' routed no closer than approximately three feet from the nearest unprotected Division I safe shutdown circuit and ten feet from the nearest unprotected Division II safe shutdown circuit. Based on the installation of fire breaks, fire barriers, separation of Division I and II safe shutdown components from intervening combustibles and each other, a postulated fire originating in Fire Zone 1A101 will not affect, or propagate to affect, more than one train of safe shutdown in Fire Zone 1A101. In addition, -

an automatic sprinkler system is also installed in the portion of Fire Zone 1A101 that is north of Column Line 10.5.

Fire Zone 1A120 does not contain any safe shutdown' components and this fire zone separates Fire Zones 1A114 and 1A117 by a distance of more than 90 feet. The intervening combustibles in this separation distance consist of two non-safety-related and three safety-related ventilated ,

trays in Fire Zone 1A120 and two non-safety-related ventilated trays in j Fire Zone 1A114. These intervening trays contain IEEE-383 cable i

installed in accordance with the requirements of Regulatory Guide 1.75.

Furthermore, the intervening trays in Fire Zone 1A120 are separated from those in Fire Zone 1A114 by approximately 16 feet of clear space. Fire propagation via 90 feet of horizontally installed tray containing IEEE-383 cable and through a 16' space free of combustibles is not credible . Therefore, a postulated fire originating in Fire Zones 1A120, 1A114, or 1A117 will not affect, or propagate to affect, more than one

train of safe shutdown in these zones.

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NELREP FIRE AREA 1

Fire Area 1 does not comply with the literal requirements set forth in III.G.2 of Appendix R. Specifically, the following exceptions exist:

1. Redundant trains of safe shutdown cable in Fire Zene 1A101 are separated by a mini =um of 35 feet vich detection and auto =stic suppression. However, this distance is not free ,of intervening combustibles. The intervening combustibles consist of one ventilated tray containing non-safety-related IEEE-383 cables installed in accordance uith Regulatory Guide 1.75. ,
2. Redundant trains of safe shutdown cable in Fire Zenes 1A114 and 1All7 are separated by a minicum of 106 feet with ioni:stion detection. However, this distance is not free of intervening combustibles and no auto =atic suppression is provided. The intervening combustibles consist of non-safety-related and safety-related. ventilated trays containing IEEE-383 cable installed in accordance with Regulatory Guide 1.75. .

The postulated fire with the greatest severity in Fire Zone IA101, lAll4, or lAll7 is less than 30 minutes. Hose stations are provided to reach all portions of Fire Area 1 with an effective hose stream. In addition, portable extinguishers are strategically located throughout the fire area.

Based on the protection provided, one train of safe shutdown equipment will remain free of fire damage in the event of a design basis fire.

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1 FIRE AREA 6 Fire Zone 1A211, which is located west of Column Line G.4, contains both Divisions I and II safe shutdown components. There are no Division I safe shutdown components located more than 30 feet west of Column Line G.4. In addition, Division II safe shutdown components are not located within 4 feet of G.4. All Division I and II safe shutdown components located within this 26-foot space are protected with nominal 1-hour fire barriers. Therefore, Division I and II safe shutdown components that are not protected with barriers in Fire ,

Zone 1A211 are separated from each other by 26 feet. Intervening combustibles located within this separation distance consist of five trays containing IEEE-383 cable installed in accordance with the requirements of Regulatory Guide 1.75. Based on the installation of fire breaks and separation between these trays and safe shutdown components without barriers, fire propagation will not affect safe shutdown components outside the 26-foot separation distance. In addition, an automatic sprinkler system is installed within this separation distance, extending west to Column Line J.5 and east into Fire Zone 1A201 to Column Line 13.0.

, Fire Area 6 does not comply with the literal requirements set forth in III.G.2

  • of Appendix R. Specifically, the.following exception exists:
1. Redundant trains of safe shutdown cable in Fire Zone IA211 are separated by a distance of 26 feec with automatic suppression and detection. However, this distance is not free of intervening cembustibles. The intervening combustibles consist of IEEE 383 cable installed in accordance with Regulatory Guide 1.75.
  • The postulated fire with the greatest severity in the vicinity of the area above has a duration of less than 60 minutes. Hose stations are provided to reach all portions of Fire Area 6 with an effective hose stream. In addition, portable extinguishers are located thnoughout the fire area.

Based on the fire protectica features provided, one train of safe shutdown equip =ent will be free of fire da= age in the event of a design basis fire.

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FIRE AREA 11 Fire Zone 1A316, which is located west of Column Line C.4, contains both Division I and II safe shutdown ce=ponents. All Division I safe shutdown ,

components located = ore than 3 feet west of Colu=n Line C.4 and all Division 11 safe shutdown components east of Colu=n Line H are protected with nominal 1-hour fire barriers. Therefore, Division I and II safe ,

shutdown components that do not have fire barriers are separated by 25 feet. There are no Division I safe shutdown co=ponents located west of Colu=n Line H, and no Division II safe shutdown components located east of #

this 25-foot separation distance. 1

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This separation distance contains intervening combustibles, which consist of

, five non-safety-related trays and one safety-related tray containing IEEE 383 cable installed in accordance with the separation requirements of Regulatory -

Guide 1.75. ..The configuration of these intervening combustibles, in conjunction with the available fire protection, is such that a fire originating in Fire Zone 1A316 will not affect, or propagate to affect, more than one train of safe shutdown in this fire zone. In addition, an automatic sprinkler system is within this separation distance, extending west to Column Line J.5 and east into Fire Zone 1A301 to Column Line 13.0.

Fire Zone 1A322 also contains Divisica I and II safe shutdown cceponents.

All Division 1. safe shutdcun co=ponents in Fire Zone IA322 cre locatac 17 feet south of Colu=n Line 9.0. All Division II safe shutdown cEnponents are located 6 feet north of Colu=n Line 9.0. Therefore, Division I and II safe shutdown components located in 1A322 are separated by 23 feet. The only intervening co= bus'tibles located within this 23-foot separation distance consist of a total of 25 gallons of lube oil contained within three plant chilled' vater system (P71), chillers, since the two cable trays located within this separation distance are totally enclosed. In addition, fire breaks arc installed where these trays interface with the Division I safe shutdown trays in Fire Zone IA322. A postulated fire

" originating in this fire zone will not affect, or propagate to affect, ,

I more thcn one train of safe shutdown cocponents in this, fire :ene. In i addition, an automatic sprinkler system is installed throughout Fire Zone IA322. .' ~

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Fire Area 11 does not ecmply with the literal requirements set forth in III.G.2 of Appendix R. Specifically, the following exception exists:

1. Redundant trains of safe shutdcun cable in Fire Zone IA316 are separated by a minimum of 25 feet with detection and autcmatic suppression. Hewever, this d!. stance is not free of intervening combustibles. The intervening combustibles consist of IEEE 383 cable installed in accordance with the separation recuirements of Regulatory Guide 1.75. . l,,

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2. Redundant trains of safe shutdevn cable in Fire Zone IA322 are separated by a minicum of 23 feet with detection and automatic suppression. However, this distance is not free of intervening combustibles. The intervening combustibles consist only of lube oil contained in three plant chilled water system (P71) chillers. .

The postulated fire with the greatest severity in the vicinity of the area above has a duration of less chan 120 cinutes. Hose stations are provided to reach all portions of Fire Area 11 with an effective hose stream. In addition, portable extinguishers are strategically located throughout the fire area.

Based on the protection provided, one train of safe shutdown equip =ent -

will- remain free of fire da= age.

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FIRE AREA 19 Fire Zone IA428.contains both Division I and II safe shutdown components. All Division I safe shutdown components are located south of Column Line 6.2 and east of Colume Line N. All Division II safe shutdown components are located more than 21 f eet north of Column Line 11.0. Therefore, Division I and II safe shutdown co=ponents in Fire Zone IA428 are separated by more than 110 feet. The intervening combustibles within this separation distance consist of IEEE-383 cable in ventilated trays, installed in accordance with the requirements of ,

Regulatory Guide 1.75. Fire propagation via more than 110 feet of horizontally '

installed cable tray containing IEEE-383 cable is not likely. Therefore, a fire s originating in Fire Zone 1A428 will not affect, or propagate to affect, more than one train of safe shutdown in this zone.

Fire Zones 1A523, IA519, and 1A525 are located on Elev. 185'-0" and do not contain any safe shutdown components. These fire zones are separated from the fire zones located on Elev. 166'-0" by 3-hour rated fire barriers except for two non-rated hatchec in the floor at Elev. 185'-0". These hatches interface with fire zones IA427 and 1A428. The hatches are separated by a horizontal distance of more than 115 feet. The intervening combustibles between these ..

hatches on Elev. 185'-0" consist of IEEE-383 cable. A postulated fire originating in any fire zone on Elev. 185'-0" is not likely to propagate via the IEEE-383-cable over this 115-foot separation distance to both hatches. Therefore, a postulated fire originating in any of these fire =enes will not aff ect, or

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propagate to affect, more than one train of safe shutdown.

Fire Area 19 does not comply with the literal requirements set forth in III.G.2 of Appendix R. Specifically the following exception exists:

1. Redundant trains of safe shutdown cable in Fire Zone IA428 are separated by a mini =um distance of 110 feet and smoke detection is provided in the zone. However, this distance is not free of intervening combustibles and autematic suceression is not erevided. ,

The intervening combustibles consist of IEEE 383. cable installed in accordance with Regulatory Guide 1.75 and are located on both Elevs.

166'0" and 185'0". Cables located on Elev. 1850" are separated from safe shutdown cable on Elev. 166'0" by two nonrated hatches.

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DCP 83/0003, which will be implemented prior to the beginning of RF01,

! will provide 42 feet of automatic sprinkler coverage within this 110-foot separation distance. -

i The postulated fire with the greatest severity in the vicinity of the area l above has a duration of less than 45 minutes. Hose stations are provided

, to reach all portions of Fire Area 19 with an effective hose stream. In addition, portab.le extinguishcrs are strategically located thrcughout the fire area.

Based on the fire protection features provided, one train of safe shutdevn equip =ent will be free of fire damage in the event of a design basis fire.

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FIRE AREA 59 Fire Area 59 centains redundant Division I and Division II safe shutdown cabla and raceway. All safe shutdown cable and racavay in Fire Area 59 are located underground. The underground raceway consists of. reinforced concrete duct banks and =anholes to facilitate cable pulling. All manholes are sealed with pressure type water , gas , and steam-tight bolted lids, with rubber gaskets to prevent the entry of any potential fla==able liquid. ,

Manhole MH01 is a four-compartment manhole and is located approximately 275 feet west of the Control Building. Two compartments contain the Division I '

cables ar.d two compartments contain the Division II cables. Each compartment

, is separated by a 12-inch concrete wall with a 4-inch-diameter drainage hole, which allows the compartments to communicate.

The esble is qualified to IEEE 383 and installed in accordance with Regulatory Guide 1.75. In addition, there are no other co=bustibles present in the manhole and the sealed, pressure tight manhole covers previously described preclude the entry of any transient ce=bustibles.

Therefore, a fire originating in any compartment of Manhole }S01 will not affect or propagate to more than one train of safe shutdown.

The closest in situ combustibles to Manhole FE01 are the Unic 2 diesel fuel tanks, located approxi=ately 25 feet from Manhole MH01, and the Unit 1 diesel fuel tank, located approximately 35 feet away. All tanks are buri_ed-approximately 10 feet below grade and are provided with an oil collection sump to collect and contain any potentially spilled oil. Refueling activities are supervised by operations personnel, and further prctection is afforded by a yard hydrant, which is located approximately 50 feet north of MH01.

Based on the location, installationlind configuration of the nanhole, separation from the nearest yard fire ha:ard, and precautions taken during refueling activity, a fire at the ofi collection sump or tank will not affect or propagate to either train of safe shutdown.

Fire Area 59 does not eo= ply with the literal requirements set forth in Section III.G.2 of Appendix R. Specifically, the folicwing .expection exists:

1. Redundant trains of safe shutdown cable located in Manhole MH01 are not separated by 3-hour barriers. Separation is provided by walls .

containing a minimum of 12 inches of concrete with 4 inch drain holes.

The manhole is divided into 4 compartments, 2 containing Division I cable and 2 containing Divisior. II cable.

Cable and PVC conduit represent the in situ combustibles. The cable is qualified to IEEE 383 and installed in accordance v'ith Regulaccry Guide 1.75. The sealed manhole covers prevent the introduction of transient combustibles and air infiltration required to sustain co=bustion. Also, access is provided to yard hydrant (s).

Based on the configuration of Manhole MH01, one train of safe shutdown equipnent will re=ain f ree of fire demage in the event of a fire.

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FIRE AREA 25 MP&L (GGNS Unit 1) requested an exception to the literal requirements of 10CFR50, Appendix R, Section III.G.2 in Fire Area 25 until the end of the first refueling outage via AECM 85/0129, dated May 07, 1985. The basis for this exception i

is limited accessibility to Fire Area 25 (Containment and Drywell), and a commitment s by MP&L to complete the analysis, document any additional exceptions, and perform any s codifications determined to be prudent.

MP&L has completed the analysis to determine compliance of Fire Area 25 to Section III.G.2. of Appendix R. This analysis is contained within AECM 86/0123 dated 05/07/86. In consideration of this analysis, MP&L requests an exception to the literal requirements of Section III.G.2 of Appendix R, and proposes certain codifications to support the analysis for Fire Area 25. Note that this exception and completion of modifications are scheduled to be in effect following the end of the first refueling outage, as the exception requested via AECM 85/0129 is in effect during the interim period.

As previously stated, GGNS Unit 1, Fire Area 25 does not comply with the literal requirements set forth in III.G.2 of Appendix R. Specifically, the following cxception exists: _

Redundant trains of safe shutdown equipment in Fire Zone 1A112 are separated by less than 20 feet horizontally, and no automatic suppression nor radiant energy chields have been provided. The circuits are components involved are related to safety relief valves that are required for safe shutdown.

The following discussion describes the physical configuration and features for the circuits and components identified in the proposed exception:

In Fire Zone 1A112, four of the six safe shutdown ADS / safety relief valves are located between azi=uth 270* and azimuth 330* at Elev. 154'. All of the cables to _

these valves, and within 14 feet horizontally of the valves, are installed in totally onclosed raceway systems in accordance with the separation requirements of Reg. Guide 1.75. The nearest in situ combustible loading to this group of valves consists of t.

the 59.5 gallons of lubrication oil in the B reactor recirculation pump located at czimuth 325* at Elev. 120' which is 34 feet below two (Q1B21F051D and F047D on Elev.

154') of the four ADS and relief valves discussed above. However, as stated below the NRC has concluded that the lube oil is adequately confined; therefore, a lube oil cxposure fire is not considered a credible event. The only other in situ combustible loading close to these four valves is the Division II IEEE-383 cable in cable trays 1CBTMN04, 05, and 06 located between azimuth 258* and azimuth 325* at Elev. 168' 6".

These cable trays are located more than 9 feet horizontally from the nearest valve Q1B21F051B and its associated Division I raceway.

The remaining two safe shutdown ADS / safety relief valves (Q1B21F051A and Q1B21F047G) are located between azimuth 50* and azimuth 85* at approximate Elev.

154'. All cables related to these valves, within 4 feet horizontally and 14 feet vertically of the valves, are installed in a totally enclosed raceway system in accordance with the separation requirements of Reg. Guide 1.75. The nearest in situ combustible loading to this group of valves and related raceway consists of Division I IEEE-383 cable in cable trays ATMNO3 and ATMN04, located between azimuth 50* and NELREP 86/041 ,

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s azimuth 90* at Elev. 168' 6". These cable trays are located more than 14 feet above the valves and more than 9 feet above the closest Division II conduit containing .

circuits routed to these valves. The only other in situ combustible loading close to these two valves is the 59.5 gallons of lubrication oil in the "A" reactor recirculation pump located at azimuth 145* and Elev. 120', which is more than 32 feet horizontally and 34 feet vertically below the two valves. However, as stated below, the NRC has concluded that the lube oil is adequately confined; therefore, a lube oil cxposure fire is not considered a credible event. I-The maximum fire duration in the drywell from in situ combustibles is less than 15 minutes for Fire Zone 1A112 and less than 45 minutes for Fire Zone 1A113 (Ref.

Calculation 7.3.105-N). There are only two types of in situ combustibles found in the drywell: 1) the lubricating oil contained within the two reactor recirculation pump motors'and 2) the electrical cable in the drywell. The NRC concluded in the SER, Section 9.5.4.3, that "... an engineered oil leak collection system or.

cdditional fire protection for the (recirculation) pumps is not required." Since the recirculation pump lube oil is confined within the metsi motor housing with no external parts, an exposure fire due to the ignition ef the recirculation pump lubricating oil is not postulated to occur.

All electrical cables in Fire Zone IA112 are IEEE-383 qualified and are installed in accordance with the separation requirements of Reg. Guide 1.75. All cable insulation used in the drywell is of the nonflame propagating type. Except for _

the two Division I and Division II ventilated tray systems, which are separated by a minimum of 45 feet horizontally and located above Elev.112' 2", all other safety-related cables in Fire Zone 1All2 are installed in totally enclosed raceway cystems. All electrical cables in Fire Zone IA113, which is inside the reactor vessel pedestal, are IEEE-383 qualified. Fire Zone IA113 does not contain any safe chutdova components.

If a fire were to occur in the drywell, it wouId be detected by the dual thermocouples that are provided to monitor the drywell ambient air temperature (System M51) . These thermocouples alarm when the temperature in the drywell reaches  !

145 F, which.is 10 F above the normal ambient air temperature of 135 F. Two of these _

thermocouples are mounted on Elev.182' 8" and the third is mounted at approximately Elev. 110' 0" (Ref. Drawings M-1101, M-1471, and M-1474).

The drywell (Fire Zones 1A112 and 1All3) is separated from the balance of the containment by a 5-foot-thick concrete wall with vault type doors. Therefore, based on the construction of the wall, a fire breaching the drywell wall is not postulated.

l The drywell is inaccessible during plant operation; therefore, no transient combustibles are postulated.

t The proposed modifications in Fire Area 25 are as follows:

i l 1) Provision of radiant energy shields for Safe Shutdown Nuclear Boiler System (B21) pressure switches and raceways containing these circuits in Fire Zone -

l 1A110D3, and raceway ICARNP14 from Fire Zone 1A110D3 to azimuth 19' in Fire Zone i

1A411. These modifications will achieve more than a 20' horizontal separation j distance between redundant safe shutdown circuits relating to these componenes i in Fire Area 25.

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2) Provision of radiant energy shields for all Division II Safe Shutdown Suppression Pool Te=perature Monitoring Circuits (Systen M71) in Fire Area 25. _

These circuits are only redundant to the Division I M71 System circuitry.

Therefore, at least one train of safe shutdown suppression pool temperature monitoring circuits will protected from the effects of a design basis fire .

in Fire Area 25, Therefore, the. fire protection provided for Fire Area 25, as described in the- ' .

Fire Hazards Analysis, the above discussed exception, and proposed modifications will s~

insure that at least one train of safe shutdown components will remain free of fire damage following a design basis fire in Fire Area 25.

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