ML20206Q050
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FRANKLIN RESEARCH CENTER OtVKH3N Of ARVIN/CALSPAN i
August 28, 1986 U.S. Nuclear Pegulatory Commission Washington, D.C.
20555 Attention:
Mr. S. Ba3wa (MS-540 )
Project Offacer Re f e re nce ttility:
Boston Ecason Company Plant Pilgrie Nuclear Power Station NRC Docket No. 50-293 NRL Contract NRC-03-81-130 TRC Project C5506 FRC Assignment No. 36 FRC Task No. 630 Sub3ect:
Evaluation of Fire Protection Exerption Recuests f rosI 10CFR50.48 and Appendix R to 10CTR50.
Dear Mr. Bajwas ne technical evaluation report (TER) for Evaluation of Fire Protection Exemption Requests f rom 10CTR50.40 and Appendix R to 10CTR50 for Boston Edison Company, Pilgria Nuclear Power Station, dated August 28, 1996 !TEF-C5506-630) is hereby forwarded.
Suhaittal of this TER represents DtC's f1,nal action on Task 630.
Very truly yours,
^
S. Pandey Project Manager
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EVALUATION OF FIRE PROTECTION EXEMPTION P2 QUESTS l
FROM 10CTR50.48 AND AFPENDIX R 7010CFR50 BOSTON EDlSON COMPANY PILCRIM NUCLEAR PCWER STATION TER-C5506-630 I
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O TECHNICAL EVALUATION REPORT N AC DOCKET NO. 50-293 FRC PROJECT C5506 SRC LICE:;SE S0. OFR-35 FRC ASSIGNMENT 36 N RC CONTR ACT NO. N RC-03-41 130 F AC TASK 630 EVALUATICN OF FIRE PROTECTION EXEMPTION REQUESTS FROM 10CTR$0.48 AND APPENDIX R TO 10CFR50 BOSTON EDISCN COMPANY PILCRIM NUCLEAR PCWER STATION TER-C5506-630 i
1 Prepar'd for Nuclear Regulatory Commission FRC Group Leader: N. Ahmed Washington, D.C. 20$55 NRC Lead Engineer:
J. stang i
August 28, 1986
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This report was prepared as an account of work sponsored by an agency of the United States Government. Neither the United States Government nor any agency tnereof, or any of their emplo,ees, makes any warranty. expressed or Imptiec, or :,4sumes any legal liability or responsibility for any third party's use, or the results of such use. of any information. appa-I ratus, product or process disclosed in this re,* ort, or represents that its use by such third party would not 14'iringe privately owned rights.
Prepared by:
Reviewed by:
Approved by:
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9 TER-C5506-630 CONTENTS Section Title Page 1
INTRODUCTION J
1.1 Purpose of Review 1
1.2 Generic Background 1
1.3 Plant-Specific Dackground 3
1.4 Review Criteria.
3 2
EVALUATION 5
i 2.A General 5
2.2 Reactor Building, Elevation (-)l7 Feett Torus Compartment (Fire Zone 1.30A), Control Rod Drive Quadrant (Fire Zone 1.6/1.8), and Residual Heat Removal Train A Pump Room (Fire Zone 1.1) 5 2.3 Reactor Building, Torus Compartment, Elevation
(-)17 Feet (Fire Zone 1.30A) 9 2.4 Reactor Building, Steam Tunnel, Elevation 23 Feet (Fire Zone 1.32) 11 3
CONCLUSIONS 13 4
REFERENCES 14 iii
i TER-C9906-630 FORE %oRD This Technical Evaluation Report was prepared by Franklin Research Center (FRC) under a contract with the U.S. Nuclear Regulatory Commission (Office of Nuclear Reactor Regulation) for technical assistance in support of NRC operating reactor licensing actions.
The technical evaluation was conducted in accordance with criteria established by the NRC.
Mr. Jacob Klevan contributed to the technical prepatation of l
this report through a subcontract with Rolf Jensen & Associates, Inc.
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TER-C9506-630 1.
INTRODUCTION 1.1 PURPOSE OF REVIEW Ihis technical evaluation report documents an independent rev12w of exemptior.s or deviations frem the fire protection reqdirements of 10CFR50.48 or Appendix R to 10CFR50 requested for Boston Edison Company's (BECo) Pilgrim Nuclear Power Station.
This evaluation was performed with the following objectives:
o To assess if each exemption request demonstrates an equivalent level of overall protection of plant safe shutdown capability following a disabling fjre event To determine the bases for acceptance or denial of each o
exemption request To recommend the minimum level of fire protection the I
o Licensee should provide to achieve an equivalent level of fire protection in case a request is denied.
1.2 GENERIC BACKGROUND l
Following a major fire at the Browns Ferry Nuclear Station in March 1975, the NRC established a Sp :ial Review Group which initiated an evaluation of the need for improving the fire protection programs at all nuclear power plants.
The group found serious design inadequacies regarding fire protection at Browns Ferry, and its report, "Recommendation Related to Browns Ferry Fire" (NUREG-0050, February 1976), contained over 50 recom-mendations regarding improvements in fire prevention and control in existing facilitiec.
The report also called for the development of specific guidance for implementing fire protection regulations, and for a comparison of that guidance with the fire protection program at each operating plant.
The NRC developed technical guidance from the technical recommendatiens in the Special Review Group's report, and issued those guidelines as Branch Technical Position (BTP) APCSB 9.$-1
[1].
This guidance did not apply to plants operating at that time, Guidance to operating plants was provided later in Appendix A to i
BTP APCSB 9.5-1 (2), which, to the extent practicable, relies on BTP APCSB 9.5-1.
The guidance in these documents was also published as Regulatory Guide 1.120 (3).
By early 1980, most operating plants had implemented nost of the guideliner in Appendix A.
However, the fire protection program has had some significant problems with implementation.
To establish a definitive resolution of thes
oblems in a manner c
- istent with the general guidelines in
,pendix A to the BTP and to assure timely compliance by licensees, the Commission issued a i
proposed fire protection rule and its Appendix R, which was descr1>.nd as setting out minimum fire protection requirements for the unresolved issues.
The fire protection features addressed l l
TER-C9906-630 included protection of safe shutdown capability, cmergency lighting, fire barriers, associated circuits, reactor coolant pump lubrication system, and alternate shutdown systems.
On February A', 1981, the final rule 10CFR50.48 (4) and Appendix R to 10CFR.LO (5) became effective, replacing the proposed rule.
Only three of the 15 items in Appendix R were of such safety significance that th(y should apply to all plants, including those j
for which alternative fire protection actions had boa.1 approved i
previously by the staff.
These items are protection of safe shutdown capability (including alternate shutdown systems),
emergency lighting, and the reactor coolant pump lubrication system.
Accordingly, the final rule required all reactors licensed to operate before January 1, 1979, to comply with these three items even if the NRC had previously approved alternative fire protection features in these areas.
However, the final rule is more flexible i
than the proposed rule because Item III.G now provides three alternative fire protection features which do not require analysis to demonstrate the protection of redundant safe shutdown equipment, and reduces the acceptable distance in the physical separation l
alternative frrm 50 feet to 20 feet.
In addition, the rule now 1
provides an exemption procedure which can be initiated by a l
licensee's assertion that any required fire protection feature will not enhance fire protection safety in the facility or that such modifications may be detrimental to overall safety.
In summary,Section III.G is related to fire protection features for ensuring that systems and associated circuits used to achieve end maintain safe shutdown are free of damage.
Either fire protection configurations must meet the rpecific requirements of Section III.G or an alternative fire protection configuration must be justified by a fire hazards analysis.
Generally, the staff will accept an alternative fire protection configuratien ift l
The alternative ensures that one train of equipment o
necessary to achieve hot shutdown from either the control room or emergency control stations is free of fire damage.
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The alternativa ensures that fire damage to at least one j
train of equipment necessary to achieve cold shutdown is l
1 limited so that it can be repaired within a reasoLiable time (minor repairs using components stored on the site).
Fire-retardant coatings are not used as fire barriers.
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Modifications required to meet Section III.G would not o
enhance fire protection safety levels above those provided by either existing or proposed alternatives.
Modifications required to meet section III.G would be o
detrimental to overall facility safety.
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TER-C9506-630 Guidance to the ladustry and the NRC's position on certain requirements of Appendix R is covered by various documents, one of them being Generic Letter 83-33 (6), which has recently been superseded by Generic Letter 86-10 (7).
"The Interpretations of Appendix R" and "The Responses to Industry Questions," two sections of Reference 7, are written to facilitate industry implementation of Apper. dix R and represent the NRC's position on all issues covered.
Following the promulgation of the final rule, licensees have requested exemptions and deviations from Appendix R to 10CFR50.
The exemptions and deviations are in the form of a fire hazards analysis.
The NRC is to reviev exemption requests and associated analyses to enstee each alternative to meeting the requirements of the rule provides an equivalent level of overall protection of plant safe shutdown capability.
Franklin Research Centwr (FRC) was to provide technical assistance to the NRC within the context of the following scope of work (8):
Subtssk 1:
Review each exemption request for information deficiencies, provide Request for Information (RFI) to resolve such deficiencies.
Subtask 2:
Review and evaluate each exemption or deviation request submitted by the licensees and all additional information provided for conformance with acceptance criteria.
Prepare final Technical Evaluation Repor* (TER) with recommendations, and their basis in support of granting or denying the exemption / deviation request.
1.3 PLANT-SPECIFIC BACKGROUND By letter dated November 16, 1983, Boston Edison Company (BECo, the Licensee) requested exemptions from Section III.G of Appendix R.
By lett.ar dated December 27, 1984, the Licensee submitted additional information in support of the exemption requests.
The exemption requests are the subject of this evaluation.
The RFI required in satisfaction of Subtask 1 was transmitted to the NRC on February 5, 1986 (9) followed by a site visit on April 1, 1986.
The contents of this TER reflect the information contained in the Licensee's submittals identified above, as well as the inforra-tion provided or collected during the site visit.
The final TER also incorporates / resolves the NRC's comments received to date.
1.4 REVIEW CRITERIA i
The criteria used in reviewing the Licensee-submitted exemp-tion requests are based on the following documents: i i
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Q TER-C5906-630 1.
Fire Protection Program for operating Nuclear Power Plants, 10CTR50.48 1
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Appendix R to 10CFR50 l
3.
Standard Review Plan, NUREG-0800, Branch Technical Position (BTP), APCSB 9.5-1, "Guidelines for Fire Protection for Nuclear Power Plants" 4.
Appendix A to BTP APCSB 9.5-1 5.
Generic Letter 86-10, "Implementation of Fire Protection Requirements," dated April 24, 1986.
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TER-C9906-630 2.
EVALUATION 2.1 GENERAL
'h i.1 section presents review and evaluation of exemptions or devihtieas from 10CFR50.48 or Appendix R to 10CFR50 requested by the Licensee (Boston Edison Company, BEco) of Pilgrim Nuclear Power Station.
Evaluation of exemption requests for each fire area / zone singly or collectively follows a format suggested by the NRC and is arranged in the following subsections:
o Exemption requested o
Discussion o
Evaluation o
Conclusion.
The fire area / fire zone numbering used in this section corresponds to that used in the Lie'.nsee's subaittal.
2.2 REACTOR BUILDING, ELEVATION (-)l7 FEET:
TORUS COMPAF.TMENT (FIRE ZONE 1.30A), CONTROL ROD DRIVE QUADRt.NT (FIRL' ZONE 1.6/1.8), AND RESICUAL HEAT REMOVAL TRAIN A PUMP ROOM (FIRE ZONE 1.1) 2.2.1 Exemption Requested Exemptions were requested from the technical requirements of Section III.G.2.a to the extent that it requires separation of redundant trains of residual heat removal (RHR) and core spray systems, automatic depressurization system (ADS), and emergency diesel generator fuel oil transfer pump cables located in Fire Zones 1.1, 1.6/1.8, and 1.30A, respectively, by 3-hour fire rated barriers.
2.2.2 Discussion 2.2.2.1 Elevation (-)l7 Feet The Licensee han identified the following conditions which do not' meet the technical requirement of Section III.G.2.a:
redundant trains of the RHR and core npray systems, AOS, and emergency diesel generator fuel oil transfer pump cables are not separated from each other by 3-hour rated fire barriers at the boundary betwoon Fire Zones 1.6/1.8 and 1.30A, as well as ht the boundary of Firo Zones 1.30A and 1.1.
1 Each of the subject fire zones is located in the reactor building.
The reactor building is divided by concrete floor slabs i
into six elevations:
(-)l7 feet, 6 inches; 2 feet, 9 inches; 23 j
feet; 51 feet; 74 feet, 3 inches; 91 feet, 3 inches; and 117 feet.
It is divided inte 'tre areas and several fire zones.
The fire i l
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l areas are separated f.om each other by fire rated barriers with protected openings.
The fire zones are separated from each other
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by fire rated barriers penetrated by unprotected openings.
This i
exemption request involves fire zones located on or adjacent to elevation (-)l7 feet.
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The reactor building, elevation (-)l7 feet, is divided into i
five fire zones.
Fire Zone 1.30A comprises the majority of this elevation.
It is bounded by Fire Zone 1.1 in the southeast, Fire Zone 1.2 in the northwest, Fire Zone 1.6/1.8 in the northeast, and Fire Zone 1.5/1.7 in the southwest quadrants of this elevation.
It is separated from the other zones (quadrants) by 36-inch-thick j
concrete walls.
Penetrations in each wall consist of an j
1 unprotected docruay and a small amount of nonrated mechanical and j
electrical penetrations.
i Elevation (-)17 feet is connected to elevation 23 feet by open I
stairways located in Fire Zones 1.6/1.8, 1.1, 1.2, and 1.5/1.7.
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Fire Zones 1.6/1.8 and 1.1 are open to Fire Zone 1.9 on elevation l
23 feet.
Fire Zones 1.2 and 1.5/1.7 are open to Fire Zone 1.10 on j
elevation 23 feet, i
The combustible contents of Fire Zone 1.1 consist of cable insulation and lube oil.
The combustible inading is approximately 1
12,200 Btu per square foot, which produces an equivalent fire severity of 9 minutes on the ASTM E-119 time-temperature curve.
j Fire protection in this zona consists of smoke detectors and a j
manual hose station.
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The combustible contents of Fire Zone 1.2 consist of cable
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insulation and lube oil.
The combustible leading is approximately I
12,200 Btu per square foot, which produces an equivalent fire stverity of 9 minutes on the ASTM E-119 time-temperature curve.
l Fire protection in this zone consists of portable fire extin-guishers and a manual hoe? station.
The combustible contents of Fire Zone 1.5/1.7 consist of cable insulation and lube oil.
The combustible loading is approximately z
1 14,400 Btu per square foot, which produces an equivalent fire severity of 11 minutes on the ASTM E-119 time-temperature curve.
j The fire protection in this zone consists of smoke detectors, j
portable fire extinguishers, and a manual hose station.
j The combustible contents of Fit *e Zone 1.6/1.8 consist of cable insulation and lube oil.
The combustible loadity is approximately i
4,800 Btu per square foot, which produces an equivalent fire
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severity of approximately 4 minutes on the ASTM E-119 time-temper-ature curve.
Fire protection in this zone consists of a portable 4
j fire extinguisher and a manual hose station.
i The combustible contents of Fire Zone 1.9 consist of cable j
insulation.
The combustible loading is approximately 39,200 Btu per square foot, which produces an equivalent fire severity of approximately 30 minutes on the ASTM E-119 time-temperature curve.
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O TER-C9906-630 Fire protection in this zcne consists of portable extinguishers and manual hose stations.
The combustible conten'.s of Fire Zone 1.10 consist primarily of cable insulation.
The combustible loading is approximately
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30,400 Btu per square foot, vnich produces an equivalent fire severity of 23 minutes on the ASTM E-119 time-temperature curve.
Fire protection in this zone consists of portable fire extinguishers and manual hose stations.
The comhustible contents of Fire Zone 1.30A consist of 24 pounds of cable insulation in one cable tray, which is approxi-mately 125 feet long and approximately 8,200 pounds of fire-retardant painted wood staging (scaffolding) encircling the torus.
The combustible loading is approximately 5,900 Btu per square foot, which produces an equivalent fire severity of approximately 4 minutes on the ASTM E-119 time-teaperature curve.
No fire protec-tion systems or equipment are installed in this fire zone.
However, there is one hose reel and ona portable extingulsher in cach adjacent quadrant that will reach and cover this fire zone.
i 2.2.2.2 Fire Zone 1.30A Fire Zone 1.30A contains cables associated with the following safe shutdown systemu 1
o RER train B o
Core spray train B 1
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Emergency diesel generator trains A and B fuel oil transfer pumps i
Reactor core isolation cooling (RCIC) o High pressure coolant injection (HPCI) o 1
o Torus water temperature.
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J' The Licensee has committed to reroute power cables out of Fire Zone 1.30A that feed MCC B18 components required for train D of the RHR and core spray systems.
The cables will be routed out of the reactor building through the west wall, around the Exterior, and in L
through the east vall.
The Licensee has also committod to reroute l
cables associated with torus water temperature and both trains of l
fuel oil transfer pumps out of this fire zone as described in the
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Licensee's letters dated June 25, 1982 and May 17, 1983.
l Upon completion of the nodifications, no train A or B safe shutdown components or cables will be physically present in this fire zone.
However, this fire zone is not separated by complete 3-heur fire rated boundaries from Fire Zones 1.2 and 1.10, which contain train B components required for safe shutdown.
This fire zone is also open to Fire Zone 1.6/1.8 via an open stairway.
Fire 1
O TER-CS906-630 Zone 1.6/1.8 does not contain any safe shutdown components, but it is open to Fire Zone 1.9 by an open stairwell which contains train A components required for safe shutdown.
Therefore, Fire Zone 1.30A provides a path between train A components located in Fire Zone 1.9 and train B components located in Fire Zones 1.2 and 1.10.
The minimum distance between train A and B components along this path is at least 100 feet horizontally (between the openings in the fire barriers separating Fire Zone 1.30A from Fire Zones 1.2 and 1.6/1.8} and 40 feet vertically between elevations (-)l7 and 23 feet.
2.2.2.3 Fire Zones 1.2, 1.5/1.7, and 1.10 Fire Zcne 1.2 contains cables and equipment associated with l
train B of the RHR and core spray systems.
Fire Zone 1.5/1.7 contains cables and equipment associated with the RCIC system only.
Fire Zone 1.10 contains cables and equipment associated with train B of the RHR and core spray systems, ADS, and emergency diesel generator fuel oil transfer pump, as well as the HPCI and RCIC systems.
Fire Znnes 1.2, 1.5/1.7, and 1.10 are separated from each other and from Fire Zone i.30A as described in Section 2.2.2.2.
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addition, Fire Zones 1.10 and 1.9 are separated from each other by l
a sprinkler water curtain on elevation 23 feet.
The separation distance between the train B components or cables in these zones j
and the closest train A-darignated zone is at least 100 feet horizontally, j
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2.2.2.4 Fire Zones 1.1, 1.6/1.8, and 1.9 i
f Fire Zone 1.1 contains cables and equipment associated with train A of the RHR and core spray systems.
The closest redundant train B components are located in Fire Zone 1.2, approximately 150 feet from Fire Zone 1.1, which contains counterpart train A.
a Fire Zone 1.6/1.8 contains no safe shutdown cables or equip-ment.
Howaver, it is open to Fire Zone 1.9 ora elevation 23 feet, which contains cables associated with trains A and B of the RHR and core spray systems, ADS, and emergency diesel generator fuel oil transfer punps.
The Licenses has committed to relocate cables assoc'ated with train B of the above-nLaed systems out of Fire Zone 1.9.
The closest train B components fra in Fire Zone 1.2, which is loc ted approximately 100 feet herito. ally across Fire Zone 1.30A from Fire Zone 1.6/1.8,'thich contains train A.
I 2.2.3 Evaluation l
The fire protection in Fire Zones 1.30A, 1.6/1.8, and 1.1 does not comply with the technical requirements of Sectica III.G.2.a of Appendix R because redundant treins of the RHR and core spray -
TEP-C5506-630 systems, ADS, and emergency diesel generator fuel oil transfer pump cables are not separated by fire barriers having 3-hour ratings.
The concern was that the lack of 3-hour fire rated barriers between the redundant trains may result in a loss of redundant safe 1
shutdown capability.
However, the equivalent fire severity in any of these fire zones is less than 30 minutes.
Therefore, a fire of significant magnitude or savority is not expected to occur.
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the burning rate of the combustibles is expected *.o be limited because most combustibles are enclosed (oil and lubricants in pumps) or treated to reduce combustibility (fire-retardant painted wood and fire-retardant coated cable).
If a fire should occur in Fire Zone 3.30A, it is expected that it would be detected by fire detectors in Fire Zones 1.5/1.7 or 1.1.
The detectors annunciate in the control room to alert the control room operators.
They, in turn, would alert the fire bri-l gade to respond to the reactor building and extinguish the fire.
i If the fire was not detected promptly, it is expected that it would not result in a loss of safe shutdown capability for the following reasons:
The separation distance is 100 feet or more between redundant safe shutdown s/ stems in Fire Zones 1.2 and 1.1 or 1.6/1.8 and the combustible loading in Fire Zone 1.30A is limited, which would not allow fire gas temperatures to exceed the limit at which damage to cables er equipment is expected to occur.
In addition, the openings between elevations (-)17 and 23 feet would further limit maximum fire gas temperatures because of the mixing with cooler air.
If a fire occurred in one of the quadrants at elevation (-)17 feet, similar results are expected.
With the installed fire protection features in conjunction with the committed modifications, reasonable assurance exists that a fire originating in the above-described sections of Fire Zones 1.30A, 1.2, 1.1, 1.6/1.8, from safely shutting down. or 1.5/1.7 would not prevent the plant 2.2.4 Conclusion Based on the above evaluation, it is concluded that the existing fire protection features combined with the proposed modifications provide an acceptable level of protection for redundant trcins of the RHR and core spray systems, ADS, and emergency diesel generator fuel oil transfer pumps on elevation l
(-)l7 feet.
Therefore, thw exemptions can be granted.
2.3 REACTOR BUILDING, TORUS COMPARTMENT, ELEVATION (-)l7 FEET (FIRE ZONE 1.30A) 2.3.1 Exemption Requested An exemption was requested from the technical requirements of Section III.G.2.a to the extent that it requires structural steel forming a part of or supporting the fire barrier between redundant 9
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O TER-C9506-630 trains of safa shutdown components in Fire Zone 1.30A and aire Zones 1.9 and 1.10 to be protected to provide fire resistance equivalent to that required of the barrier.
2.3.2 Discussion The concrete floor slab which separates Fire Zone 1.30A from Fire Zones 1.9 and L.10 above is supported by unprotected structural steel benms.
l The combustible materials in Fire Zone 1.30A are primarily located 18 feet belok the structural steel in the form of fire-retardant painteT wood staging.
The other si combustible material, including cable insulation, gnificant is located 2 feet below the steel in a li-inch-wide cable tray, i
The Licensee has comhitted to modifications described in Section 2.2.2.
Upon completion af these modifications, Fire Zone 1.30A Will contain only RCIC and HPCI components, which provide i
alternate shutdown capability for the RHR and ADS components I
contained in Fire Zones 1.9 and 1.10 located aboie Fire Zene 1.30A.
The Licensee has performed an analysis of the effect of j
instantaneous complete combustion of the entire combustible load of this fire zone on the structural steel.
The analysis assumed that all of the heat : rom the fire was immediately absorbed by only the I
stegl, and that the steel would fail if it reached a temperature of i
650 F.
The Licensee?s analysis indicated that based on the total combustible loading, the sgeel would not experience mora ghan an average temperature of 326 F, which is well below the 650 F assumed to fail the structural steel.
2.3.3 Evaluation l
The fire protection in Fire Zone 1.30A does not comply with the technical requirements of Section III.G.2.a of Appendix R l
because structural steel forming a part of or supporting the fire barrier between redundant safe shutdown systems in Fire Zone 1.30A 4
and Fire Zones 1.9 and 1.10 is not protected to provide fire resistanca equivalent co that required of the barrier eupported, i
The Licensee's analysis indicates that the structural steel would not fail even if it instantaneously absorbed the entire heat of combustion of the combustible materials in Fire Zone 1.30A.
However, the Licensee's analysis does not take into account the effect on the steel of a fire plume impinging directly on a structural steel member.
Because the cable tray is located approximately 2 feet belot< the structural stgel, a fire in the tray might create air temperatures as high as 650 F at the lower flange of the steel.
Therefore, there is not reasonable assurance that a fire in this zone would not jeopardize the structural steel, creating a situation which will impair the safe shutdown capability.
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TER-C9506-630 2.3.4 conclusion Based on the above evaluation, it is concluded that the existing fire protection features do not provide an acceptable level of protection for rodundant trains of cables and equipment located in Fire Zones 1.9 and 1.10.
Therefore, the exemption should not be granted.
2.4 REACTOR BUILDING, STEAM TUNNEL, ELEVATION 23 FEET (FIRE ZO'iE 1. 3 2 )
2.4.1 Exemption Requested An exemption was requested from the technical requirements of Section III.G.2.a to the extent that it requires structural steel forming a part of or supporting the fire barrier between Fire Zone 1.32 and Fire Zones 1.11 and 1.12 to be protected to provide fire resistanco equivalent to that required of ths barrier.
2.4.2 piscussion Tht Licensee has identified the following condition which does not mean the technical requirements of Section III.G.2.at The structural steel beam supporting the floor slab separating Fire Zone 1.32 from Fire Zones 1.11 and 1.12 is not protected to provide fire resistance equivalent to that required of the barrier.
Fire Zone 1.32 is located on elevation 23 feet.
It adjoins the containment to the north, Fire Zone 1.9 to the east, and Fire Zone 1.10 to the west.
It is located below Fire Zones 1.11 and 1.12 on elevation 51 feet of the reactor and turbine buildings.
Fire Zone 1.32 is separated from Fire Zones 1.11 and 1.12 by a concrete floor slab supported by one structural steel beam.
Fire Zones 1.11 and 1.12 contain redundant safe shutdown systems.
The combustible contents of Fire Zone 1.32 consist of a few exposed electrical cables.
The majority of the cables in this fire zone are routed in conduits.
There are no other combustible materials in tr a fire zone.
i Fire protection consists of a portable fire extinguisher and a manual hose station in an adjacent area, t
The steam tunnel (Fire Zone 1.32) contains the RCIC and HPCI systems. The Licensee has stated that the loss of these systems does not prevent safe shutdown.
Fire Zones 1.11 and 1.12 contain safety-related core spray and RHR valves and safety-related cable trays and panels.
The Licensee performed an analysis to determine the quantity of combustible material which vguld be required to raise the temperature of the steel to 650 F, above which it would fail to support the floor.
The analysis indicated that a combustible loading of 21,500 Btu per square foot would be required.
The t
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Licensee concluded that, since the actual cembustible loading in this fire zone is negligible, the steel would not experience high temperature to fail.
2.4.3 Evaluation The fire protection in Fire Zone 1.32 does not comply with the technical requirements of Section III.G.2.a of Appendix R because structural steel forming a part of or supporting the fire barrier between Fire Zone 1.32 and Fire Zones 1.11 and 1.12 is not j
protected to provide fire resistance equivalent to that required of the barrier supported.
i The Licensee's analysis indicates that the structural steel 1
would not fail even if it instantaneously absorbed the entire heat of ecmbustion of the combustible materials present in Fire 3one 3
j 1.32.
Although the Licensee's analysis does not take into account i
the effect of a fire plume impinging directly on a structural member, it is not expected that such an exposure fire would be significant because of the negligible combustible loading.
Therefore, reasonable assurance exists that a fire originating in i
this fire zone will not prevent the plant from safely shutting down.
2.4.4 Conclusion Based on the above evaluation, it is concluded that the 1
existing fire protection f?atures for the structural steel in Fire i
L Zone 1.32, which support the floor of Fire Zones 1.11 and 1.12, j
provide an acceptable level of protection for the redundant trains 3
of cables and equipment located in Fire Zones 1.11 cnd 1.12.
Therefore, the exemption can be granted.
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TER-C5506-630 3.
CONCLUSIONS This section is provided to consolidate the results of the evaluation contained in Section 2 concerning the exemptions requested by the Licensee from the requirements of Section III.G of Appendix R to 10CFR50 for Pilgrim Nuclear Power Station.
It is not meant as a substitute for the specific conclusions reached in the various subsections of Section 2 for which the reader is referred to specific subse tions.
l Based on the evaluation, the level of fire safety in the fire zones listed below is equivalent to that achieved by compliance i
with the technical requirements of Section III.G of Appendix R and, thereforo, the Licensee's requests for exemptions in the following areas can be granted.
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Fire Zones 1.30A, 1.1, and 1.6/1.8.
Lack of fire barriers separating redundant trains of cables and equpiment.
Refer to Section 2.2 for details.
2.
Fire Zone 1.32.
1 Lack of fireproofing of structural steel supporting or forming a part of the fire barrier between Fire Zone 1.32 and Fire Zones 1.11 and 1.12.
Refer to Section 2.4 for details.
i Based on the evaluation, it is found that the level of fire safety in the zone listed below has not been shown to be in compliance with the technical requirements of Section III.G of Appendix R and, therefore, the Licensee's request for exemption should not be i
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granted:
1.
Fire Zone 1.30A.
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Lack of fireproofing of structural steel supporting or l
i forming a part of the fire barrier between Fire Zone 1.30A and Fire Zones 1.9 and 1.10.
Refer to Section 2.3 for i
i details.
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TER-C5906-630
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REFERENCES 1.
BTP APCSS 9.5-3 "Fire Protection Program," July 1981 (Standard I
Review Plan, NUREG-0800) 2.
Appendix A to BTP APCSB 9.5-1, "Guiitelines for Fire Protection for Ntclear Power Plants Docketed PMicr to July 1, 1975,"
August 23, 1976 i
3.
Regulatory Guide 1.120, "Fire Protettion Gaidelines for I
Nuclear Power Plants," November 197*
l 4.
10CFR50, "Fire Protection Program for Operating Nuclear Power i
Plants," November 19, 1980 5.
A)pendix R to 10CTR50, "Fire Protection rrogram for Nuclear l
Pcwer Facilitied Operating Prior to January 1, 1979," November i
19, 1980 6.
Generic Letter 83-33, "NRC Position on Certain Requirements of Appendix R to 10CFR50," October 19, 1983 r
i 7.
Generic Letter 86-10, "Implementation of Fire Protection l
Requirements," April 24, 1986 8.
Final Work Assignment No. 36, transmitted by M. Carrington l
(NRC) to Dr. S. Pandey (FRC) on July 17, 1985 l
9.
Request for Information (RFI), transmitted by N. Ahmed (FRC) to l
l J. Stang (NRC) on February 5, 1986.
I Dated August 28, 1986 1
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