ML20207A632
Text
{{#Wiki_filter:/, o 'o UNITED STATES ~, 'n NUCLEAR REGULATORY COMMISSION l B .. i wAsmotow, p. c. rosse ~%.. * / OCT 2 81987 { Docket No.: 50-293 I MEMORANDUM FOR: Victoberses.ActingProjectDire ! Profect Directorate IQ ' DJfision of Reactor Proj I/II FROM: Conrad E. McCracken Acting Chief Chemical Engineering Branch Division of Engineering and Systems Technology
SUBJECT:
SAFETY EVALUATION REPORT CONCERNING LICENSEE'S REQUEST FOR EXEMPTION FROM PROVISIONS OF SECTION !!!.G.2.a OF APPENDIX R TO 10 CFR 50 IN CERTAIN AREAS OF THE PLANT - PILGRIM NUCLEAR i POWER STATION (TAC NO. 53416) Plant Name: Pilgrim Nuclear Power Station Licensee: Boston Edison Company Docket No.: 50-293 Review Basis: Exemption Requests - Section III.G of Appendix R to 10 CFR 50 Pevie > Status: Complete Our Safety Evaluation Report of the licensee's request of exemption from the technical requirements of Section I!!.G.2.a of Appendix R to 10 CFR 50 in several different areas of the plant is enclosed (Enclosure 1). Section III.G of Appendix R has to do with protection of safe shutdown capability, and Section I!!.G.2.a provides for. "Separation of cables and equipment and associated non-safety circuits of redundant trains by a fire barrier having a 3-hour rating. Structural steel forming a part of or supporting such fire barriers shall be protected to provide fire resistance equivalent to that required of the barrier." This Safety Evaluation covers three separate exemptions from Section !!!.G.2.a. The first requested exemption is for lack of 3-hour rated fire barrier separation between redundant trains of residual heat removal (RHR), automatic depressurization systems (ADS), core spray and euergency diesel generator fuel oil transfer pump cables located in Fire Zones 1.1, 1.6/1.8 and 1.30A, i respectively. The second requestei exemption is for lack of 3-hour fire proofing for structural steel in the Reactor Building Torus Compartment, Elevation - 17 feet, Fire Zone 1.30A. The third requested exemption is for lack of 3-hour fire proofing for structural steel in the Reactor Building Steam Tunnel. Evaluation 23 feet, Fire Zone 1.32, and Fire Zones 1.11 and 1.12. r ll{ $ D Y
s o i V. Nerses We have reviewed the licensee's requested exemptions and the technical information they have supplied to 3upport their requests. We agree that (1) providing three hour barriers in Fire Zones 1.1, 1.6/1.8 and 1.30A to separate redundant trains of residual heat removal, automatic depressurization systems, core spray and emergency diesel generator fuel oil transfer pump cables, and providing 3-hour fire proofing for structural steel in the (2) Reactor Building Torus Compartment, Elevation - 17 feet Fire Zone 1.30A, and (3) the Reactor Building Steam Tunnel. Elevation 23 feet, Fire Zone 1.32 and Fire Zones 1.11 and 1.12 would not significantly increase fire protection in the areas involved. We agree that the level of fire protection provided is consistent with the requirements of Section I!!.G.2.b and that these requests for exemption should be granted. Our SALP input is provided in Enclosure 2. We consider our efforts on TAC - No. 53416 to be complete. d< V & ---- Conrad E. McCracken, Acting Chief Chonical Engineering Branch Division of Engineering and Systems Technology i
Enclosures:
i (1) SER for Pilgrim Nuclear Station j (2) SALP Report l cc: L. Shao J. Richardson S. Varga B. Boger R, Wessman
Contact:
D. P. Notley, x24921 i ) I
ENCLOSURE 1 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR RESULATION RELATIVE TO APPENDIX R EXEMPTIONS REQUESTED FOR PILGRIM NUCLEAR p0WER STATION DOCKET NO. 50-293
1.0 INTRODUCTION
Cy letter dated November 16, 1983 (BEco 83-281) the licensee, Boston Edison. Company (BEco), requested four exemptions from the technied provisions of Section III.G of Appendix R to 10 CFR 50. The four exemptions requested were Nos.11 and 12 which pertained to lack of rated fire barriers between the Reactor Building Torus Compartment and the Control Rod Drive Quadrant rooms. No.13 which pertained to unprotected structural steel in the Reactor Building '- Torus Compartaent, and No.14 which pertained to unprotected structural steel in the Reactor Building Steam Tunnel. These four requested exemptions are the subject of this Safety Evaluation. (In order to simplify the review, Nos. 11 and 12 are considered together as one requested exemption in Section 2.0 below and Mos.13 and 14 are considered in Sections 3.0 and 4.0 respectively.) By letter dated December 27, 1984 BEco 84-214), July 28 (BEco 86-110) and 14, 1986 (BEco 86-176)(, and April 21 (BEco 87-062) and August 4, 1 Novemb.r (BEco 87-132), the licensee submitted additional information in support of the requests. Region I fire protection engineers visited the site on April 1, 1986 to review the fire protection modifications comitted to by the Licensee for compliance with Appendix R, and the fire areas where the exemptions from Appendix R had been requested. Infonnation furnished by the licensee and/or I gathered during the site visit was used for this evaluation. This safety evaluation is based in part on a Technical Evaluation Report (TER) generated by NRR contractor Franklin Research Center (FRC). The staff has reviewed the TER and agrees with the FRri:ofielusions'.N WL /. t s./
- i. e w
/ (RC .( gl. Section l'.l.G.1 of Appendix Er~equir'es fire protection fea'tures to be provid for structures, systems, and components important to safe shutdown and capable 4 (j " 4 of limiting fire damage so that: MLe a. One train of systems necessary to achieve and maintain hot shutdown by J% conditions from either the control roo.4 or emergency control '"d station (s) is free of fire damage; and b. Systems necessary to achieve and maintain cold shutdown from either the control room or emergency control station (s) can be repaired within 72 hours. Section !!!.G.2 of Appendix R requires that one train of cables and equipment necessary to achieve and maintain safe shutdown be maintained free of fire i damage by one of the following means: ___.o.__,__.__
. a. Separation of cables and equipment and associated nonsafety circuits of redundant trains by a fire barrier having a 3-hour rating. Structural steel forming a part of or supporting such fire barriers shall be protected to provide fire resistance equivalent to that required of the barrier. b. Separation of cables and equipment and associated nonsafety circuits of redundant trains by a horizontal distance of more than 70 feet with no intervening combustibles or fire hazards. In addition, fire detectors and an autoratic fire suppression system shall be installed in the fire area. c. Enclosure of cable and equipment and associated nonsafety circuits of one redundant train in a fin barrier having a 1-hour rating. In addition, fire detectors and an automatic fire cuppression system shall l
- s installed in the fire area.
If the above conditions are not met Section III.G.3 requires that there be alternative or dedicated shutdown capability independent of the fire area of concern. It also requires that fire detection and a fixed suppression system be installed in the fire area of concern. These alternative requirements are not deemed to be equivalent; however, they provido equivalent protection for those configurations in which they are accepted. Because it is not possible to pmdict the specific conditions under which fires may occur and propagate, design basis protective features rather than the design basis fire are specified in the rule. Plant-specific features may require protection different from the measures sp' cified in Section III.G. In e such a case, the licensee must demonstrate, by means of a detailed fire hazardt analysis, that existing protection or existing protection in conjunction with proposed modifications will provide a level of safety equivalent to the technical requinments of Section III.G of Appendix R. In sunnary, 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 damage. Fire protection configurations must meet the specific requirements of Section III.G or an alternative fire protection configuration must be justified by a fire hazards analysis. Generally, the i staff will accept an alternative fire protection configuration if: The alternative ensures that one train of equipment necessary to achieve hot shutdown from either the control room or emergency control station (s) is free of fire damage, j The alternative ensures that fire damage to at least one train of l W equipment necessary to achieve cold shutdown is limited so that it can be g repaired within a reasonable time (minor Mpairs using components stored on the site). j Fire-retardant coatings are not used as fire barriers. 4 l
.?. Modifications required to meet Section III.G would not enhance fire protection safety levels above that provided by either existing or proposed alternatives. Modifications required to meet Section III.G would be detrimental to overall f acilit,< safety. 2.0 REACTOR BUILDIM1, ELEVATION (-)17 FEiT: TORUSCOMPARTMENT(FIREZONE 1.30A), CONTROL ?.00 DRIVE QUADRANT (FIRE ZON 1.6/1.8),ANDRESIDUAL HEAT REMOYAL TRAIN A PUMP ROOM (FIRE ZONE 1.1) 2.1 Exemptions Requested Exemptions were requested from Section III.G.2.a to the extent that it requires separation of redundant trains of residual heat removal (RHR), automatic depressurization system (ADS), core spray and emergency diesel generator fusi oil transfer pump cables located in Fire Zones 1.1, 1.6/1.8, and 1.30A, resp?ctively, by 3-hour fire rated barriers. 2.2 Discussion 2.2.1 Elevation (-)17 Feet The licensee has identified the following conditions which do not meet Section III.G.2.a: redundant trains of the RHR, core spray, ALS, and emergency diesel generator fuel oil pump cables are not separated from each other by 3-hour t rated fire barrien at the boundary between Fire Zones 1.6/1 well ar at the boundary of Fire Zones 1.30A and 1 1. p g7 j,q j Each of the sur'ict fire zones is located in the reactor building. The M Y reactor build g is divided by concrete floor slabs into seven elevations MI 7 (-)17 feet, 6 inches; 2 feet, 9 inches; 23 feet; 51 feet; 74 feet, 3 inches; 6' 91 feet 3 inches; and 117 feet. It is divided into fire areas and several fire zones. The fire areas are separated from each other by fire rated barriers penetrated by 'inprotected openings. This exemption request involves.__ 3,, $ a fire zones located on or adjacent to elevation (-)17 feet. g'*1 " N Lh The reactor building elevation (-)17 feet is divided into five fire zones. Fire Zone 1.30A cwprises the majority of this elevation. It is bounded q* f, by Fire Zone 1.1 on the southeast, Fire Zone 1.2 on the northwest, Fire MI :.., Zone 1.6/1.8 on the northeast, and Fire Zone 1.5/1.7 on the southwest quadrants of this elevation. It is separated from the four zones 6 L'"j' (quadrants) by 36-inch-thick concrete walls. Penetrations in each wall M consist of an unprotected doorway and a small number of nonrated mechanical oh and electrical penetrations, / 4 +. Elevation (-)17feetisconnectedtoelevation23feetbyopenstairways 'I'" located in Fire Zones 1.6/1.8. 1.1, 1.2, and 1.5/1.7. Fire Zones 1.6/1.8 (MS and 1.1 ere open to Fire Zone 1.9 on elevation 23 feet. fire Zones 1.2 and 1.5/1.7 are op<n to Fire zone 1.10 on elevation 23 feet. i The combustible contents of Fire Zone 1.1 consist of cable insulation and lube oil. The combustible leading is approximately 12,200 Btu per square foot, which produces an equivalent fire severity of approximately 9 minutes on
e . ) the ASTM E-119 time-temperature curve. Fire protection in this zone consists { of smoke detectors and a manual hose station. The combustible contents of Fire Zcne 1.2 consist of cable insulation and lube oil. The combustible loading is approximately 12,200 Btu per square foot, which produces an equivalent fire severity of approximately 9 minutes on the i ASTM E-119 time temperature curve. Fire protect!on in this zone consists of smoke detectors, portable fire extinguishers and a manual hose station. The combustible contents of Fire Zone 1.5/1.7 consist of caole insulation and { lubc oil. The combustible loading is approximately 14,400 Btu per square i foot, which produces an equivalent fire severity of approxi'nately 11 minutes on the ASTM E-119 time-temperature curve. The fire protection in this zone t consists of smoke detectors, portable fire extinguishers and a manual hose I station. ) The combustible contents of Fire Zone 1.6/1.8 cor.sist of cable insulation and lube oil. The combustible loading is approximately 4,800 Btu per square foot, which produces an equivalent fire severity of approximately 4 minutes on the i ASTM E-119 time-temperature curve. Fire protection in this zone consists of smoke detectors in three of the ft.ur quadrants (no detectors are provided in the CRD Room) a portable fire extinguisher and a manual hose station. The ccebustible contents of Fire Zone 1.9 consist of cable insulation. The combustible loading is approximately 39,200 Btu per square foot, which 1 produces an equivalent fire severity of approximately 30 minutes on the ASTM E-119 time-temperature curve. Fire protection in this zone consists of smoke 4 detectors, portable extinguishers and manual hose stations. The combustible contents of Fire Zone 1.10 consist primarily of cable insulation. The combustible loading is approximately 30,400 Btu per square foot, which produces an equivalent fire severity of approximately 23 minutes on the ASTM E-119 time-temperature curve. Fire protection in this zone consists of smoke detectors, portable fire extinguishers and manual hose stations. j The combustible contents of Fire Zone 1.30A consist of approximately 37S pounds of cable insulation in one cable tray approximately 125 feet lona. --approximately 5,200 pounds of fire-retardant painted wood staging an 4 scaffolding) encircling the torus. (By telephnne conference cal) on August 4, 1987, the licensee advised the staff that about one-half of this sci.ffoldin M 'g'. Qas ady been removed and the remainder will be removed pr.ior to starl-up. ,The combustible losoing is approximately19T0 Btu per square foot, which ) coj.4 produces an equivalent fire severity of a~pproximately 4 minutet on the ASTM ' g W/ j ' I ' , /) E-119 time-temperature curve. No fire protection systems or equipment are
- pv1 installed in this fire zone. However, there is one hose reel and one portabl ME '
a extinguisher in each adjacent quadrant that will reach and cover this fire j' i
- zone, i
2.2.2 Fire Zone 1.30A \\ i i Fire Zone 1.30A contains,able associated with the following safe shutdown systems: ~ i m .+ w m4 4y
t,( O .c e
- { fc)./ g 5 (, I M gd<
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- k-@'.
RHR train B Core spray train B Emergency diesel generator trains A and B fuel oli transfer pumps r-Ret.ctor core isolation cooling (RCIC) y 4 Q.,g M High pressure coolant injection (HPCI) s u(, 'l s Torus water temperature. / l .The licensee has cosuiltted to reroute power cables out of Fire Zone 1.30A r that feed MCC B18 components required for train 8 of the RHR and com spray N' systems. The cables will be routed out of the reactor building throvgh the-west wall, around the exterior, and in through the east wall. The licensee has also cosuittted to reroute cables associated with torus water temperature and both trains _of fuel oil transfer pumos out of this fire zone as described) In the licensws letters aatea vune 25. IY82 and May 17, 1983. By telephone conference call on August 4,1987, the licensee advised the staff that rerouting of alltra"n 8 cables out of Fire Zone 1.30A will be completed before startup, and tnat irain A fuel oil transfer pump cables will remain in Zone 1.30A. l Upon completion of the modifications, no train A o B safe shutdown components k y cables _ (except for the train A fuel oil transfU pump caoles and train A N" s and train B Torus Instrveentation Cables) will be physically present in this /,.W ' rated boundaries from Fire Zones 1.2 and 1.10, whigqntain train ';)0[,'/firezora. a e components required for safe shutdown. This fire) zone *is also open to Fire +--- t,t,, Zone 1.6/1.8 via an open stairway.11re Zone-h5/1.8 does not contain any 'c . safe shutdown components. Therefore, Fire Zone 1.30A provides a path between 41J train A comronents located in _ Fire Zone 1.9 anLtrain B Components located in_ b^ Fire Zone 1.2 and 1.10. The minimum dists between train A and 8 components 7.3 KTong this path is at least 100 feet horizo tally (between the openings in the fire barriers separating Fire Zone 1.30A fr Fire Zones 1.2 and 1.6/1.8) and 40 feet vertically between elevations (-)17 and 23 feet. kT dwTI 4 ? l 7.2.3 Fire Zones 1.2, 1.5/1.7, and 1.10 ~ pp l. b [/. 0 i y Fire zone 1.2 contains cables and equipment associated with train B of the RHR 1 and core spray systems. Fire Zone 1.5/1.7 contains cables and equipment associated with the RCIC system. Fire Zone 1.10 contains cables and equipment associated with train 8 of the RHR, ADS, core spray, and emergency diesel generetor fuel oil transfer pump, as well as the HPCI and RCIC systems. Fire Zones 1.2,1.5/1.7, end 1.10 are separated from each other and from Fire Zone 1.30A as described above. In addition, F1-e Zones 1.10 and 1.9 are separated from each other by a sprinkler water curtain on elevation 23 feet. The separation distance between the train 8 cusponents or cables in zones 1.2 i . _ _ ~ ~ - _ _.
6-and 1.10 and the closest train A-designated zone is at least 100 feet ( horizontally, cQ, / 2.2.4 Fire Zones 1.1, 1.6/1.8, and 1.9 Fire Zone 1.1 contains cables and equipment associated with train A of' the RHR and core spray systems. The closest redundant train B component f are h located in Fire Zone 1.2, approximately 150 feet from Fire Zone 1.1 which -Q'tg} ' %g@9[g centains counterpart train A components. Fire Zon .6/1.8 ntains no nafe Lhutdown cab s as 'pciated w TM~Tiese valves /_ s or equipment, ixcept RHR bj ulves_and a However, it is cpen to Fire / Zcnf l.9 on elevation 23 feet, which contains cables associated with trains A I e and 8 of the RHR, 405, core spray, and emergency ciesel generator fuel oil l trentferJumss. 3The licensee has wii.nmec to relocate caDies assOClated with 1 Ig yTab oflie abme-named' systems out of Fire Zone 1.9. Fire Zone 1.9, which g 'p is open to Fire Zone 1.6/1.8,on elevation 23 feet, contains Train A and B p safe shutdown cables and components. The 11cysea has either relocated cablet j y W-~4ated r th Train 8 out of Fire Zoie 1.94br has incorporated the required , *)a >hoperator actlii-into tne alternitive vqtdown procedure. Vg 2.3 Evaluation N The fire protection in Fire Zones 1.30A, 1.0/1.8 and 1.1 does not comply with W, the technical.1guirements of Section JII... of Appendix R because \\ 4 redundant trains of RHR, ADS, core spNy, and emergency diesel generator fuel oil transfer pump cables ure not separated by fire barriers having 3-hour ratings. l The concern was that the lack of 3-hour fire rated barriers between the redundant trains may result in a lost of redundant safe shutdown capability. However, the equivalent fire severity in any of these fire zones is less than o / 30 minutes. Therefore, a fire of significant magnitude or severity is not expected to occur. Also, the burning rate of combustibles s expected to be lioited because most combustibles (oil and lubricaes in pumps) are enclosed or treated Qite retardant-Dainted wood and fire retardant-coated cables) to reduce combustibility. C gq NT p g -{ 3 If a fire should occur in Fire Zone 1.30A, 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 roc operators. They, in turn, would alert the fire brigade to respond to the reactor building and extinguish the fire. k 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 tasons: The i separation distance is 100 feet or more between redundant safe ahetdown systems in Fire Zones 1.2 and 1.1 or 1.6/1.8 and the combustible loading in ) f Fire Zone 1.30A is limited and will prevent) fire gas temperatures from reaching the limit at which damage to cahled or equipment is expected to occur. The licensee coufimed by telephone conference call on August 4,1987 { that there are no intervening combusubl t between redundant safe shutdown y' ~ ON b ge dM3
. systems in Fire Zr.ros 1.2 and 1.1 or 1.6/1.8. In addition, the openings between elevations (-)17 feet and 23 feet would further reduce fire gas temperatures because of the mixin If a fire occurred in one of the quadrants at elevation (-)g with cooler air. 17 feet, similar results are expected. With the installed fire protection features in conjunction with the cocinitted modifications, reasuable assurance exists that a fire originating in the above-described sections of Fire Zones 1.30A, 1.2, 1.1, 1.6/1.8, or 1.5/1.7 would not prevent the plant from safely shutting cown. chdvocw 2.4 Conclusion o / n s t t c.),6* m \\ w(M. Based on the above evaluation, the staff conclades that the existing fire protection features combined with the proposed modifications to relocate train g B cables provide an acceptable level of protection for redundant trains of the ' RHR, ADS, core spray, and emergency diesel generator fuel oil transfer pumps ,M 3 on elevation (-)17 feet, rherefore, the exemptions should be granted. 3.0 REACTOR BUILDING, TORUS COMPARTMENT, ELEVATION (-)17 FEET (FIRE ZONE 1.30A)., t 3.1 Exemption Requ+sted An exemption was requ n ted from Section III.G.2.a to the extent that it requires structural *. teel forming a part of or supporting the fire barrier between redundant trains of safe shutdown components in Fire Zone 1.30A and Firt Zones 1.9 and 1.10 to be protected to provide fire resistance eq"ivalent to that required of the barrier. 3.2 Di,5cussion The cor. crete floor slab which separates Fire Zone 1.30A from Fire Zones 1.0 and 1.10 above is supported by unprotected structural steel beams. The crabustible materials in Fire Zone 1.30A are primarily located 18 feet selow the structural steel in the fom of fire-retardant painted wood staging L g\\ which will be removed by the time of startup. The other significant w P combustible material consists of cable insulation located approximately W 9 one *!oot below the steel in a 12-inch-wide cable tray. 9 ine licensee has cosmitted to rodifications described in Section 2.2. Upon completion of these modifications, Fire Zone 1.30A will contain only RCIC and W Qp ' NPCI components, which provide alternative shutdown capability for the RHR and op y ADS components contained in fire Zenes 1.9 snd 1.10 located above Fire Zone 1.30A. g y, g4g 7g 3.3 Evaluation M? l The fire protection ie. Fire Zo e 1.30A does not comply with the technical requirements of Sectior. II
- ,.2, a of Appendix R because structural steel forming a part of or supr,-Uns the fire barrier between redundant safe j
shutdown systems in Fire Zere 1.30A and Fire Zones 1.9 and 1.10 is not i protected to provide ff rc rssistance equivalent to that required of the barrier supported. I n
. /h The licensee was advised of the staff's concern and by letter dated November 14,1986 (BEco 86-176) they comitted to install covers on the cable trays { s '4 7 involved so as to prevent direct flame impingement from a potential cable M',\\* tray fire on the structural steel. By letter dated April 21,1987(BECo \\ 87-062), the licensee modified their proposal. They stated that as a result of further engineering evaluation installation of tray covers was not lV \\ practical. They further stated that engineering reanalysis demonstrated that tray covers :.re not required to protect the structural steel and, therefore, would not 'oe installed. The licensee did not submit any engineering eval": tion to support their finding. During the June 17, 1987 meeting, the s'.aff requested this information from the licensee in order to conclude the raview. Tre licensee submitted the evaluation calculations by letter dated August 4, 1987 (BECo 87-132). (Dates on the cover sheet for the calculations and reevaluation of the structural steel indicating "Prepared By, Checked By a,idApprovedBy"areall7/22/87.) The licensee utilized two separate methods to analyze the unprotected steel for ptential failure due to exposure to burning cable trays in the Torus Compartment. Both methods demonstrated an adequate margin of safety for the structural steel and indicated that additional protection for the steel, either in the fom of fire proofing applied directly to the steel or tray covers installed on the cable trays in the area, is not required. The first method considerad all of the fuel (cable insulation and jacket material) in the Torus Compartment burning and the effect of the heat released on the unprotected structural steel. The licensee calculated the average fuel loading per square foot of area in the locality of the exposed cable tray in ( t theTorusCompartmentatabout2100 Btu /sqftwithanequivalentfire p) of less than 2-minutes. _All of tur steel in the Torus Compartment was evaluated M (typeslof beams were found to be_ required to maintain the integrity And six_ of the 4 g Torus compartment ceiling as a fire area boundarf. have already shown these six beam types can survive a "Standard" fire for 14 Existing fire t l to 21 minutes before failure. Therefore, a fire lasting less than 2-minutes (, Y will not lead to failure even if all of the heat released by the burning cables is assumed to heat only the steel, +4m %f I a eiv.I de f. W5 ^,._ a 2 o 1 9 / In the second method, the cable tray is assumed to cross underbe~ structural 6 "I-)T l steel at 90' angle and about 12-inches low ther beam. The combustible 2insulationandJacketmatrrialtai e cable tray is assumed to burn completely and release 1001 of its potential heat of combustion. This heat of combustion is assumed to consist equally of radiant heat and convective heat in the fire plume. The final assumption is that 100% of the convective heat in the* T fire plume is absorbed in the steel section directly above the cable tray with l no losses into the air, surrounding concrete or axialty by conduction into the remainder of the structural steel beam. Each of these assumptions is, individually, conservative. The temperatures calculated (using those assumptions) for the six beam types (or sizes) ranged from 685'F for the heaviest beam to 970'F for the lightest, well below the critical failure temperature of 1100*F for this type of steel.
O e .g. The staff agrees with the licensee's conclusion that these two methods of analysis show thct the structural steel in the Torus Compartment will not fail due to heating from a fire involving the cable trays in the compartment. Further, we agree that the licensee should not be required to install covers on the cable trays located in the Torus Compartment. 3.4 Conclusion Based on the above evaluation, the staff concludes that the existing and proposed fire protection features provides an acceptable level of protection for redundant trains of cables and equipment located in Fire Zones 1.30A,1.9 and 1.10. Therefore, the exemption should be granted. 4.0 REACTOR BUILDING, STEAM TUNNEL ELEVATION 23 FEET (FIRE ZONE 1.32) 4.1 Exception Requested l An exemption was requested from Section III.G.2.a to the extent that it requires structural steel foming 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 resistance equivalent to that required of the barrier. 4.2 Discussion The licensee has identified the following condition which do2s not meet Section III.G.2.a: 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. 1 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 i located below Fire Zones 1.11 and 1.12 on elevation 51 feet of the reactor and 1 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. 9MM i The steam tunnel (Fire Zone 1.32) contains the RCIC and HPCI systems. The v licensee has stated that the loss of these systems does not prevent safe j ^ shgry. Fire Zones 1.11 and 1.12 contain safety-related core spray and RHR valves and safety-related Cable trays and panels. 4, g The combustible contents of Fire Zone 1.32 consist of a few ex sed electrical l cables (approximately 5800 Btu per square foot which produce an equivalent M 4=r-fire severity of approximately four minutes). The majority f the cables in this fire zone are routed in conduits. There are no other combustible materials in the fire zone. Fire protection consists of a portable fire extinguisher and a manual hose station in an adjacent area, i j l _ ~. _ - - _ _
. The licensee perfomed an analysis to detennine the quantity of combustible material which would 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 Bu per square foot would be required. The licensee concluded that, since the 6 ctual combustible loading in this fire zone is negligible, the steel would not axperience a high enough temperature to fail. l 4.3 Evaluation 1 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 foming a part of or supporting the fire barrier between Fire Zone 1.32 and Fire Zones 1.11 and 1.12 is not protected to provide fire resistance j equivalent to that required of the barrier supported. The licentee's analysis indicates that the structural steel would not fail even if. instantaneously absorbed the antire heat of combustion of the combustible materials present in Fire Zone 1.32. Although the licensee's analysis does not take into account the effect of a fire p1'sne impinging directly on a structural member, because of the negligible combustible loading, it is not expected that such an exposure fire would be significant. Therefore, reasonable assurance exists that a fire originating in this fire zone will not prevent the plant from safely shutting down. 4.4 Conclusion Based on the above evaluation, the staff concludes that the existing fire protection features for the structural steel in Fire Zone 1.32, which support a the floor of Fire Zones 1.11 and 1.'2, provide an acceptable level of protection for the redundant trains of cables and eculpment located in Fire Zone 1.11 and 1.12. Therefore, the exemption shoulc be granted. 1 1 5.0 SUptuRY Based on the evaluation, the staff finds that the level of fire safety in the fire zones listed below is equivalent to that achieved by compliance with the j technical requirements of Section III.G of Appendix R and, therefore, the licensee's requt6ts for exemption in these znnes should be granted: a } 9 ; l.10 f j l= h-lO y l 1. Fire Zones 1.30A. 1.1, and 1.6/1.8 Lack of fire barriers separating redundant trains of cables and equipment, d Refer to Section 2.0 for details. 2. Fire Zone 1.32 l Lack of fire proofing of structural steel supporting or foming a part of the fire barrier between Fire Zone 1.32 and Fire Zones 1.11 and 1.12. Refer to Secti a 4.0 for details. l 1
, 3. Fire Zone 1.30A Lack of fireproofing of structural steel supporting or forming a part of the fire barrier between Fire Zone 1.30A and Fire Zones 1.9 and 1.10. Refer to Section 3.0 for details. 6.0 PRINCIPAL CONTRIBUTOR: John Stang This Safety Evaluation Report was prepared by John Stang and revised by David Notley, and is based on a Technical Evaluation Report prepared by Franklin Research Center (FRC) under a contract with the U.S. Nuclear Regslatory Consission(NRC). Dated: I t l I 4 I i j 4 l } l
\\ t's f. UNITED STATES y g NUCLEAR REGULATORY COMMISSION g l WASHING TON, D. C. 20555 %...../ October 16, 1987 Docket No. 50-293 Mr. Ralph G. senior Vice Pres.s at-Nuclear P00 Boylston Street Boston, Massachusatts 02199
SUBJECT:
FEMA MEMORANDUM ON OFFSITE EMERGENCY PLANNING FOR PILGRIN
Dear Mr. Bird:
Enclosed is a Federal Emergency Management Agency (FEMA) memorandum dated September 29, 1987 which discusses offsite emergency planning issues concerning the Pilorim Nuclear Power Station. The memorandum clarifies FEMA's position concerning the corrective actions for the major areas of corcern i identified by FEMA in its A"oust 4, 1987 finding on offsite emergency t praparedness for Pilgrim. i FEMA states that, following the submittal of revised plans by the Comonwealth for review by )EMA. the correction of sore issues will require an evaluation of plan changes while others will require demonstration of the changes in a drill or exercise. We urge you to continue your ongoing ef 4rts to assist the Connorwealth and local governments in improving their emergency plans in resonnse to the issues identified by FEHA. As previously indicated, restart of the Pi'arim plant will involvtt the censideration o' tha FEMA idantified emergency planning i sst.e s. Sincerely, 'f D Nfly y Division of Reactor cts - 1/l! Office of Nuclear Reactor Regulation _ _ _. _ cc: see next page i - - Enclosum: As Stated i g 697-M GF N O6 4& Me a ge - gg g. ' qgrw g @) 7/rf
j'{D"1, Federal Emergency Management Agency Washington, D.C. 20472 SEP 29 sg7 MEMORANDUM FOR: Frank J. Congel Director, Division of Radiation Protection and Energency Preparedness Office of Nuclear Reactor Regulation Nuclear Reg latory Commission FROM: a Assistant Associate Director Office of Natural and Technological Hazards Programs
SUBJECT:
Issues Concerning The Pilgrim Nuclear Power Station This is to clarify the position of the Federal Emergency Manageme (FEMA) concerning the correction of issues that were identif'*d in FEM Self-Initiated Review and Interim Finding For The Pilgrim % clear Power Station, dated August 4, 1987. As you know, FEM identified issues in six areas which formed the basis of its conclusion that the plans and prepare for the State and 1 coal governments within the plume exposure eme plarriag zone for Pilgrim are not adequate to protect the public health ency i and s Maty in the event of an accident at this plant. are submitted to FEMA for review by the Commonwealth of Massachuset the correction of the issues r.nd their subparts edil be evaluated in t categories: 1) Issues that rc{uire correction wo demonstration of the changes in a drill or an exercise 2) ~ ~ ~ corrections have been made.in a position to revise its previous assess FEMA will not be_ i ~~ e,_ If you have any questions, please feel free to contact me at 646-2871 ~ ~ " ' ' ,w .ar ie g W l pp. r
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_ _ _ _ ~. _ i, i I j Mr. Ralph G. Bird Boston Edison Company i Pilgrim Nuclear Power Station l ( I cc: "r. X. P. Roberts, Nuclea" Operations Pilgrim Nuclea' Ner Station Boston Edison Company i Boston Edise G' ATTH: Mr. Raich G. Bird .y RF0 al, Rocky Hi, Road Senior Vica President - Nuclear l i Fivmouth, Massachusetts OP160 800 Boviston Straet I Roston, Massachusetts 07109 s P*sident inspector's Office i U. S. Nuclear Regulatory Comission Mr. Richard N. Swanson, "anager Post Office Rox 867 Nuclear Engineering (,epartment j Plymouth, Massachusetts 02360 Poston Edison Company 25 Rraintree Hill Park Chairman, Roard of Salectmen Braintree, Mas achusetts 02184 3 11 t.incoln Street i 1 Plymouth, Massachusetts 02360 Ms. Elaine 0. Robinson Nuclear Information Manager i Office of the Comissioner Pilgrim Nuclear Power Station 1 Massachusetts Department of RFD #1, Rocky Hill Road ) Environmental Ouality Engineering Plymouth, Massachusetts 0?360 ' 4 One Winter Street 3 j Boston, Massachusetts 02108 Assistant Secretary Peter W. Agnes i Executive Office of Public Safety 1 Office of the Attorney General One Ashburton Place 1 Ashburton Place Room 213 19th Floor Boston, Massachusetts 02109 Eoston, Massachus*tts 0?l08 i W r. %bert M."Hallite'y, Director I Radiation Control Prooram i vassachusetts Cepartment of i Fubl idedth ___ ----- ~ 150 Trement Street, 2nd Flonc Foston, Massachusetts. 02111 Pegional Administrator, Region I U. S. Nuclear Regulatory Comission 631 Park Avenue ) } King of PrusJd.a.. Pennsylvania 19406 Mr. 1ams D. Xeyes Regulatory Affairs and Prograra Group t.eade r Boston Cdlson (ompany M Praintree Hill Park Rraintree, *sstathurct t s~ fp(84 - ~ - - - - - - - -
,8 C t g 4 ',o, UNITED STATES y j NUCLE AR REGULATORY COMMISSION a W ASHWGTON,0. C. 20555 g %-"" / nav o 219e Ms. Becky Chin. Presidert Ms. Mary St. A. Kaufran, legislative Aide Duxbury PTA Council 14 Cecar Street Duxbury, MA 02332
Dear Ms. Chin and Ms. Kaufman:
This is in respense to your letter to Sarvel Chilk, Secretary of the huclear Regulatory Comissicn (NRC), noressing ycur concerns regarding erergency pre-paredness for the Pilgrim Nuclear Pcwer Station. Ve appreciate your thought-ful letter, and we are taking your concerns seriously. Specifically, you referred to the adequacy of the evacuaticn plans for school children, the inadvisability of reducing the emergency planning rene (EPZ) frem a 10-m11e radius to 1 mile, outdated and unreviewed emergency plans for the Cerronwealth of Massachusetts and local comunities, and your concern that the safety of the citizens be considered before the Pilgrim plant is permitted to restart. The date on your letter is May 1,1987, but was not received by the NRC until after the pestmark date of September 10, 1987. As ycu may knew, the NRC and the Federal Energency Management Agency (FEMA) are the two Federal agencies assigned to evaluate tmergency preparedness at and around nuclear power plants. The NRC is responsible for assessing the adequacy of onsite emergency plans developed by the utility ard for making overall safety judgeents for operation of nuclear plants. FEMA is responsible for assessing the adequacy of offsite emergency planning and advising NRC of their findirgs and for assisting State and local governments in the preparation of emergency response plans. In September 1986 FEMA began a self-initiated review of its previous finding of adequacy regarding offsite emergency planning for the Pilgrim plant because af infomstion received from local officials, the Corrnonweelth, and other interested partier. 3n August 6, 1987. FEMA issued to the NRC a repcrt on its fincings. The report listed six specific areas of concerns ir the Massachusetts emergency plans for the Pilgrim 10-mile energency planning zere, including the lack of evacuation pisns for public and private schools and day-care centers. Subsequent to that repert, I understand that extensive efforts are new under-way by the Corronwealth and the local governments within the 10-mile EPZ, with the assistance of the Bcston Edisen Company, to irrprove the offsite emergency response programs. These efforts include revision of the emergency plars of the 1ecal gevernments, revision of the Massacliusetts Civil Defense Agency Area Il plan as well as the Comonwealth's State-wide plan, the development of revised procedures, the oevelopecnt anc implementation of training prograns for officials and emergency persennel, and the upgrading of Emergency Operation Centers. In addition, Coston Edison is providing professional planners to assist the local governments and the Cormonwealth in in tir efforts to irprove the emergency preparedness program. Scre training has ceen conducted to date and training will be continued after the new training program has been develecad. l / 9, ayrc m
l 2-l l l l With regard to reducing the size of the EP't, the NRC staff is reassessing the emergency planning regulatiens; hewever, there is no proposal currently before the Comission to revise the Comission's rules on the size of the emergency planning zones for nuclear power plants. There was a recuest in an individual licensing pro:eeding involving the Seabrook nuclear power plant to reduce the size of the 10-mile emergency planning zone for Seabrook to approximately 1 mile, but that recuest is not being considered further by the Comission. NR.' will ret permit the Pilgrir plant to resume operation until we determine . at the health and safety of the public can be protected. The determinatien whether to restart the Pilgrim plant will irvelve consideration cf each of the em?rgency planning issues identified by FEttA. The ovality of offsite errergency preparedness at the Pilgrim plant will depend heavily on hcw well the Cemenwealth of Massachusetts is able to cerrect the deficiencies noted in the FEMA report. Sincerely. Original :1 :::d ty D.;;cs I. Erley Thomas E. Hurley, Director Office of Nuclear Reactor Regulation REVISED IN NRR DIRECTOR'S OFFICE 10/30/27
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Es. Chin /Hs. Kaufman Distribution: TEhurley, NRR JHSniezek, hRR FJMiraglia, NRR RWStarostecki, HRR WTRussell, RI JPMurray, OGC JLFunches, NRR JLBlaha, NRR DFMossburg, hRR - EDO 3193 CMBridgers EDO - EDO 3193 WDPaton, OGC RRBellary, RI JTWiggins, RI SECY NO: 87-1112 FJCongel, NRR DBMatthews, NRR RJBarrett, NRR LJCunningham, NRR CRVan Niel, hRR FXantor, NRR RTHogan, NRR Central Files PEPB R/F MECoons, NRR 69 (EDO 3193) RHWesstr.an, hRR WJLazarus, RI RWXrim, FEMA NRC PDR Local PDR BEco HVickers F2MA j i - - - -- J
%. x m sw NOV 0 g 19g7 Fr. David F. Malaguti Chairman, Board of Selectmen Tcwn cf P1pneuth 11 Lincoln Street P1pouth, MA 02360
Dear Mr. Malaguti:
This is in response to your Septerber 2, 1987 letter to Chairman Zech recom-merding that the Pilgrim Nuclear Power Statien net be allowed to restart until an effective radiological emergency respense plan for the Town of P1pouth is in piece. You nnted that the Radiological Emergency Response Plan (RERP) for the Town ef Plymcuth was inadequate, but is under intense revision. On August 6, 1987, the Federal Energency Management Agency (FEMA) issued tc the NRC a report on the status of effsite emergency response plans for the Pilgrim plant. The report listed six specific areas of concern in the Massachusetts emergency plans for the Pilgrim 10-mile emergency planning zere. Subsecuent to that report, I understand that the Cormonwealth of Massachusetts, local governcents within the 10-mile emergency planning zone, and the two ecomunities that have emergency reception centers, with the assistance cf the Boston Edison Company, are at present engaged in impreving their emergency preparedness programs. These improvements include revisien of the emergency plans of the local gcVernnents including the Town of Pl>routh, revision of the Massachusetts Civil Defense Agency Areas II plan as well as the Conronwealth's State-wide plan, the development of revised procedures, the developirent and implementation of training programs for officials and emergency personnel, and the upgrading of Energercy Operating Centers. In addition Boston Edison is providing prcfessional planners to assist local governments and the Cocron-wealth in upgrading their plans and in developing a new training program for offrite emergency response personnel. 3cce 1. raining has been conducted to date and will continue after the new training prcgram has been developed. NRC will not permit Pilgrim to resume operation until we determine that the health and safety of the public can be protected. The determinatien whether to restart the Pilgrim plant will involve consideration of each of the emerge' icy planning issues icentified by FEMA. The quality of offsite emergency prepar'id. ness at the Pilgrim plant will depend heavily on how well the Cormonwnith of Passachusetts is able to correct the deficiencies noted in the FEMA report. Sinterwiy, ortrim ricned t7 nm ;. Wrh7. h,fp b / Thomas E. Murley, Director Office of Nuclear Reactor Regulation Distribution: See Page 2 REVISED IN NRR DIRECTCR'S OFFICE 10/26/87 *%e attached fer previous concurrence FJ :hRR/PEPB
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f n 9 David F. Malaguti Cir+ribution: TIhurley, hRR JHSniezek, fiRR FJMirarlia, NRR RWStarw ieckt NRR WTRussell, RI JPMurray, OGC JLFunches, liRR JLBlaha, NRR DFMossburg, NRR - ED0 3192 CMBridgers. EDO - EDO 3192 WDPaton, OGC RRBellary, R! JTWiggins, RI SECY NO: 87-1111 FJCongel, hRR DBMatthews, NRR RJBarrett, NRR LJCunningham, NRR CRVan hiel, hRR FKantor, NRR RTHogan, NRK Ctntral Files PEPB R/F MEcoons, NRR 68 (EDO 3192) RHWessman, hRR WJLazarus, R1 RWKrimm FEMA HVickers, FEMA BEco .}}