ML20207J893

Safety Evaluation Granting Exemption from Technical Requirements of 10CFR50,App R,Section Iii.G for 16 Fire Areas

ML20207J893
Person / Time
Site:	Farley
Issue date:	12/29/1986
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20207J891	List: ML20207J893
References
TAC-60030, TAC-60031, NUDOCS 8701080640
Download: ML20207J893 (74)

Text

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO EXEMPTION FROM 10 CFR 50, APPENDIX R ALARAMA POWER COMPANY JOSEPH M. FARLEY NUCLEAR PLANT, UNIT NOS. 1 AND 2 00CKET NOS. 50-348 AND 50-364

1.0 INTRODUCTION

By letter dated March 13,.1985, the licensee submitted the results of their Appendix R fire hazards analysis reevaluation, dated February 1985, for review.

The licensee contends that the reevaluation was prompted by the interpretations to Appendix R promulgated in IE Notice 84-09 and Generic Lettor 83-33.

Therefore, based on the results of this reevaluation the licensee requested 49 additional exemptions from the specific provisions of Section III.G of Appendix R for fire areas in Unit 2 and fire areas shared by Units 1 and 2.

Section III.G.2 of Appendix R requires that one train of cables and equip-ment necessary to achieve and maintain safe shutdown be maintained free of i

fire damage by one of the following means:

Separation of cables and equipment and associated non-safety circuits a.

of redundant trains by a fire barrier having a three-hour rating.

Structural steel forming a part of or supporting such fire barriers i-shall be protected to provide fire resistance equivalent to that j

required of the barrier.

b.

Separation of cables and equipment and associated non-safety circuits of redundant trains by a horizontal distance of more than 20 feet with no intervening combustibles or fire hazards.

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

Enclosure of cables and equipment and associated non-safety circuits of c.

one redundant train in a fire barrier having a one-hour rating.

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

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

Fire protection configurations must either meet the specific requirements of Section III.G or an alternative fire protection configuration must be justified'by a fire hazard analysis.

If these conditions are not met.Section III.G.3 requires an alternative 2

shutdown capability independent of the fire area of concern.

It also requires that a fixed suppression system be installed in the fire area of concern if it contains a large concentration of cables or other combusti-bles.

These alternative requirements are not deemed to be equivalent; however, they provide equivalent protection for those configurations.in which they are acceptad.

3 8701030640 861229 PDR ADOCK 05000348 F

PDR i

Enclosure 2

Because it is not possible to predict the specific conditions under which fires may occur and propagate, the design basis protective features are specified in the rule rather than the design basis fire.

Plant specific features may require protection different than the measures specified in Section III.G.

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

Our general criteria for accepting an alternative fire protection configura-tion are the following:

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

The alternative assures that fire damage to at least one train of equipment necessary to achieve cold shutdown is limited such that it can be repaired within a reasonable time (minor repairs with components stored on-site).

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

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

Based on our evaluation of thelicensee's February 1985 submittal,10 CFR 50 Appendix R fire hazards analysis reevaluation and our site visit during the week of July 29,1985, we concluded that for 16 of the 49 exemption requests additional technical information was required and some additional fire protection modifications (i.e., additional safe shutdown system modifi-cations and raceway fire barrier) were necessary in order to assure that the licensee's alternative f're protection and shutdown configurations represented an equivalent level of safety to that achieved by compliance with Section III.G of Appendix R.

Therefore, the licensee committed to provide the necessary fire protection and safe shutdown system modifications and the additional technical information to support the outstanding exemption requests.

By letters dated October 18, 1985, and January 27, 1986, the licensee provided the additional technical information to substantiate the technical equivalency of these exemptions and committed to provide additional fire protection features in certain plant fire areas.

Therefore, based on our evaluation of the licensee's October 18, 1985 submittal, we conclude that the licensee's proposed fire protection and safe shutdown system modifications and their revised technical justifications pertaining to the plant's alternative ability to achieve and maintain safe

O e

Enclosure 3

shutdown conditions and the existing fire protection configurations in the following plant fire areas represent an equivalent level of safety to that achieved by compliance with Section III.G of Appendix R:

Service Water Intake Structure - fire area 72 (Exemption Request 1-3)

Unit 2 Auxiliary Building, Cable Chase Train B - fire area 2-030 (Exemption Request 1-4)

Unit 2 Auxiliary Building. Switchgear R.?om Train B - fire area 2-021 (Exemption Request 1-10)

Unit 2 Auxiliary Building, CRDM Switchgear Room - fire area 2-023 (Exemption Request 1-11)

Unit 2 Auxiliary Building to Diesel Building, Cable Tunnel Train B -

Fire Area 2-076 (Exemption Requests 1-12 and 2-26)

Unit 2 Auxiliary Building, Elevation 100 feet - 0 inches, Charging Pump Rooms and Storage Areas - fire area 2-005 (Exemption Request 2-8)

Unit 2 Auxiliary Building, Electrical Penetration Rooms Train A - Fire Area 2-035 (Exemption Request 2-9)

Unit 2 Auxiliary Building Vertical Cable Chase - fire area 2-013 (Exemption Request 2-15)

Unit 2 Auxiliary Building, Electrical Penetration Room Train B and Penetration Room Filtration System Equipment Room - fire area 2-034 (Exemption Request 2-18)

Unit 2 Auxiliary Building, Train B Inside Cable Chase - fire area 2-009 (Exemption Request 2-19)

Unit 2 Auxiliary Building Cable Chase Train A - fire area 2-031

{

(Exemption Request 2-21)

Unit 2 Auxiliary Building, Elevation 100 feet - 0 inches,121 feet -

0 inches, 127 feet - 0 inches, 139 feet - 0 inches, 155 feet - 0 inches and 175 feet - 0 inches - fire area 2-006 (Exemption Request 2-35)

Unit 2 Auxiliary Building, Elevation 83 feet - 0 inches,100 feet -

0 inches and 121 feet - 0 inches - fire area 2-001 (Exemption Request 2-36)

Unit 2 Auxiliary Building, Elevation 100 feet - 0 inches,121 feet -

0 inches, 130 feet - 0 inches, 139 feet - 0 ir.ches, 155 feet - 0 inches and 184 feet - 0 inches - fire area 2-004 (Exemption Request 2-37)

Fire areas in Unit 1 Unit 2 and Fire Areas shared by Units 1 and 2 -

Fireproofing of Structural Supporting Steel (Exemption Request 2-38)

'T

Enclosure 4

Fire Areas in Units 1 and 2 Auxiliary Building, the Diesel Generator Building and Service Water Intake Structure - Fire Door Installation Deviations (ExemptionRequest1-41)

Our evaluations of the licensee's revised alternate fire protection configu-rations and their justifications regarding the plant's alternative ability for specific redundant shutdown functions to achieve and maintain safe shutdown conditions for fire conditions which affect those fire areas documented by the above exemption requests are as follows:

2.0 SERVICE WATER INTAKE STRUCTURE - FIRE AREA 72 (EXEMPTION REQUEST 1-3) 2.1 EXEMPTION REQUESTED The licensee, in its exemption request 1-3, requested an exemption from the technical requirements of 10 CFR 50, Appendix R, Section III.G.2 to the extent that it requires one train of redundant safe shutdown cables and equipment be enclosed by a fire barrier having a one-hour fire rating and that automatic fire suppression be installed throughout the fire area.

2.2 DISCUSSION Fire Area 72 is separated from areas 73 and 74 by 3-hour fire-rated walls and is bounded by non-rated exterior walls, floors, and ceilings.

Fire area 72 is separated into five fire zones by non-rated zone barriers.

Zone 72A consists of the pump deck at elevation 188 feet - 6. inches and strainer pit at elevation 167 feet - 3 inches.

Zone 72A communicates with zone 72C and 720 through non-fire-rated doors in the zone boundary.

Zones 72C and 72D communicate with zone 72E through open doorways. Zones 72B and 72E communicate with the outside through non-rated doors.

The Unit 2 side of the pump deck contains the following Unit 2 redundant service water pump lube and cooling water pumps.

In addition, the following suction valves and suction valve local contrci stations are located under the pump deck:

EQUIPMENT FUNCTION Q2P16M002A-A Unit 2 Service Lube and Cooling Pump Train-A.

Q2P16M0028-B Unit 2 Service Water Lube and Cooling Pump Train-B.

Q2P16V719A-A Unit 2 Service Water Lube and Cooling Pump Train-A Suction Valve.

Q2P16V719B-B Unit 2 Service Water Lube and Cooling Pump Train-B Suction Valve.

Q2P16G508A-A Local Control Station for Service Water Train-A Valve Q2P16V719A-A.

Enclosure.

5 Q2P16G508B-B Local Control Station for Service Water. Train-B Valve Q2P16V719B-B.

According to the licensee's analysis, the subject pumps, valves and local control stations are used to provide lube and cooling water to the service water pump bearings, and are located in the sprinkler area of the pump deck.

The pumps are mounted in the southwest corner of the pump deck and have a' horizontal separation of 18 inches on center. The pumps are electrically driven, each having a motor rated 7.5 hp at 550 V-ac.

The pump bearings are oil lubricated with each pump casing having an oil reservoir of 4 ounces.

The valves are mounted on the west wall of the pump deck at elevation 192 feet - 6 inches and have a horizontal separation of 9 inches on center.

The local control stations are located in the southwest corner of the strainer pit at elevation 171 feet - 3 inches and have a horizontal separa-tion of 5 feet on center.

4 The Unit 2 side of the strainer pit contains the following redundant Unit 2 service water header strainer motor operated inlet valves and swing pump motor operated discharge valves:

VALVES FUNCTION Q2P16V511-A Service Water Train A Strainer Inlet Valve Q2P16V508-B Service Water Train B Strainer Inlet Valve Q2P16V507-A Service Water Swing Pump Q2P16M001C-AB Discharge to Train A Q2P16V506-B Service Water Swing Pump Q2P16M001C-AB Discharge to Train B The above strainer valves are separated horizontally by 19 feet - 6 inches on center.

In addition, the above discharge valves are separated horizon-tally by 5 feet on center.

In addition, the Unit 1 side of the strainer pit contains the following l

redundant Unit I service water header strainer motor operated inlet valves and swing pump motor operated discharge valves:

l VALVES FUNCTION

.i Q1P16V511-A Service Water Train-A Strainer Inlet Valve Q1P16V508-B Service Water Train-B Strainer Inlet Valve a

Enclosure 6

Q1P16V507-A Service Water Swing Pump Q1P16M001C-AB D.ischarge to Train A Q1P16V506-B Service Water Swing Pump Q1P16M001C-AB Discharge to Train B The above strainer and discharge valves are separated horizontally 20 feet and 6 feet-6 inches on center, respectively.

Fire area 72 Zone A contains redundant safe-shutdown service water Train-A and -B cables shared by Unit 1 and Unit 2.

Cabling associated with the following valves are routed through Fire Area 72 Zone A:

REQUIRED VALVE PRE-FIRE POST-FIRE NO.

FUNCTION POSITION POSITION QSP16V505-A Service Water Train-A Closed Closed l

Cf: charge to Wet Pit QSP16V507-A Service Water Train-A Open Open Discharge to Storage Pond Flume QSP16V506-B Service Water Train-B Discharge Closed Closed to Wet Pit QSP16V508-8 Service Water Train-B Discharge Open Open to Storage Pond Flume The licensee's analysis of the effects of f're upon the Trains-A and -B circuits located in fire area 72 Zone A shows that the subject valves could change from their pre-fire position.

Fire Area 72 Zones A and E contain redundant Unit 1 and Unit 2 service water Trains-A and -B cables. The condition exists when the swing service water pumps Q1P16M001C-AB and/or Q2P16M001C-AB are lined up to their respective B Trains.

Cabling associated with the following valves are routed through Fire Area 72 Zones A and E:

REQUIRED VALVE PRE-FIRE POST-FIRE l

NO.

FUNCTION POSITION POSITION Q1P16V507-A Service Water Pump Q1P16M001C-Closed Closed AB Discharge to Train-A Q2P16V507-A Service Water Pump Q2P16M001C-Closed Closed AB Discharge to Train-A

Enclosure 7

The licensee's analysis of the effects of the fire on the Train-A valve circuits located in Fire Area 72 Zones A and E, shows that the subject Train-A valves could change from their pre-fire position.

The pre-fire position of valves Q1P16V507-A and Q2P16V507-A is required to be maintained to insure that the service water headers are not cross-connected when only the B Train of service water pumps are operational.

In addition, Fire Area 72 Zones A and B contain redundant Unit 1 and Unit 2 service water Trains-A and -B cables. The condition exists when the swing service water pump Q1P16M001C-AB and/or Q2PIM001C-AB are lined up to their respective A Trains. The redundant Train-B cables associated with the following valves are routed through Fire Area 72 Zones A and B:

REQUIRED VALVE PRE-FIRE POST-FIRE NO.

FUNCTION POSITION POSITION Q1P16V506-B Service Water Pump Q1P16M001C-Closed Closed AB Discharge to Train-B 02P16V506-B Service Water Pump Q2P16M001C-Closed Closed AB Discharge to Train-B The licensee's analysis of the effects of the fire on the Train-B valve circuits located in Fire Area 72 Zones A and B shows that the subject Train B valves could change from their pre-fire position.

The pre-fire position of valves Q1P16V507-B and Q2P16V507-B are required to be maintained to insure that the service water headers are not cross-connected when only the A Train of service water pumps are operational.

Fire Area 72 Zones D and E contain the following redundant Unit I and Unit 2 service water swing pump cables (Th'is condition exists when the swing service water pumps Q1P16M001C-AB and/or Q2P16M001C-AB are powered from their respective B Trains):

EQUIPMENT FUNCTION Q1R18A501A-A Service Water Swing Pump Q1P16M001C-AB Train-A Disconnect Switch Q2R18A501A-A Service Water Swing Pump Q2P16M001C-AB Train-A Disconnect Switch The Train B cables enter the disconnect switch via bottom entry embedded conduit that is not exposed at any other point in Zones D and E.

The following redundant Unit 1 and Unit 2 service water swing pump cables are located in fire area 72 Zones B and C (This condition exists when the

Enclosure 8

swing service water pump Q1P16M001C-AB and/or Q2P16M001C-AB are powered from their respective A Trains):

EQUIPMENT FUNCTION Q1R18A5018-B Service Water Swing Pump Q1P16M001C-AB Train-B Disconnect Switch 1

Q2R18A5018-B Service Water Swing Pump Q2P16M001C-AB Train-B Disconnect Switch The Train-A cables enter the disconnect switch via bottom entry embedded conduit that is not exposed at any other point in Zones B and C.

Fire Area 72 Zone A also contains the following redundant safe-shutdown service water Trains-A and -B pumps for Unit 1 and Unit 2:

f EQUIPMENT FUNCTION Q1P16P001A-A Unit 1 Service Water Pump Train-A Q1P16P0018-A Unit 1 Service Water Pump Train-A Q1P16P001C-AB Unit 1 Service Water Swing Pump Q1P16P0010-B Unit 1 Service Water Pump Train-B Q1P16P001E-B Unit 1 Service Water Pump Train-B Q2P16P001A-A Unit 2 Service Water Pump Train-A Q2P16P001B-A Unit 2 Service Water Pump Train-A Q2P16P001C-AB Unit 2 Service Water Swing Pump Q2P16P001D-B Unit 2 Service Water Pump Train-B Q2P16P001E-B Unit 2 Service Water Pump Train-B The above subject pumps are separated horizontally by 5 feet on center.

The combustible materials associated with Fire Area 72 consists primarily of cable insulation and lubricating oil.

The following summarizes the fire loading associated with each of the fire zones in Fire Area 72:

MAXIMUM ROOM NUMBERS /

COMBUSTIBLE FIRE LOAD FIRE TITLES MATERIAL (BTU /FT2)

SEVERITY 1)

Fire Zone A Service Water Lubricating 6,104 Less Than Pump Room 011 30 mins.

Cable Insul.

13,330 2)

Fire Zone B Switchgear Cable Insul.

37 547 Less Than Room Train B f

30 mins.

o Enclosure g

3)

Fire Zone C Cable Insul.

255 Less Than Sky Disconnect 30 mins.

Switch Room Train-B 4)

Fire Zone D Cable Insul.

255 Less Than Disconnect 30 mins.

Switch Room Train-A 5)

Fire Zone E Cable Insul.

36 544 Less Than f

Switchgear 30 mins.

Room Train-A Fire Area 72 fire detection capabilities are provided throughout the area.

The fire detection system is designed to alarm locally and annunciate in the control room.

Manual fire hose suppression capability for Fire Area 72 is provided via the two fire hose / hydrant houses located directly outside the service water building within the security fence.

The service water pumps are protected by a preaction sprinkler system. This system utilizes fusible element type water spray nozzles installed in a directional configuration in order to provide optimum coverage to the hazard In addition. to the sprinkler protection there are steel radiant heat area.

shield walls and concrete curbs installed between the service water pumps.

Two additional preaction sprinkler systems provide coverage to the entire pump deck, the area in the strainer pit beneath the pump deck, and to safe-shutdown cabling in the upper northeast corner of the service water pump room.

In addition to the sprinkler protection in the northeast corner, one train of the redundant cabling in this area is enclosed in an equivalent one hour fire barrier.

The switchgear in Fire Zones B, C, D and E are protected by an automatic carbon dioxide suppression system which is designed to suppress a fire internal to the cabinets.

Portable fire extinguishers are located throughout Fire Zones A, B, C, D, and E.

The licensee justifies the acceptability of the exemption requested on the basis of the existing fire protection, their alternative shutdown actions and the proposed fire protection modifications associated with Fire Area 72.

Enclosure 10 2.3 EVALUATION The entire pump deck at elevation 188 feet - 6 inches is covered by preac-tion sprinkler systems, which provide coverage for pumps Q2P16M002A-A and Q2P16M002B-B, and valves Q2P16V719A-A and Q2P16V7198-B.. In addition, the service water pumps and the floor area immediately around them are provided with a preaction spray system.

The strainer pit at elevation 167 feet -

3 inches also has preaction sprinkler system coverage for local control J

stations Q2P16G508A-A and Q2P16G5088-B.

Train A of the redundant safe shutdown raceway that services the subject equipment is protected by a i

barrier. (two 1-inch thick wraps of Kaowool blanket) having a fire rating greater than that of the projected fire, which is less than 1/2 hour maximum severity.

The entire fire area is provided with detection.

Therefore, adequate fire protection features exist to ensure that a fire in Zone A will not affect both redundant trains of service water.

In order to increase the responsiveness of the preaction sprinkler system protecting the Units'1 and 2 service water pumps the licensee committed to provide. heat collector i

over each fusible element spray nozzle in the system.

In addition, the j

licensee committed to correct the sprinkler obstruction problems associated with the Unit 2 service lube oil and cooling pump area by relocating the lighting fixture above the pumps.

l The strainer pit at elevation 167 feet - 3 inches has preaction sprinkler system coverage for the redundant valves Q2P16V511-A, Q2P16V508-B, Q2P16V507-A, and Q2P16V506-8.

The raceways that service Q2P16V511-A and Q2P16V507-A are protected by a barrier (two one-inch thick wraps of Kaowool blanket) having a fire rating greater than that of the projected fire, which I

is less than 1/2 hour maximum severity.

The entire fire area is provided i

with detection.

The strainer inlet valves are separated by 19 feet -

)

6 inches on center and the swing pump discharge valves are separated by 5 feet on center. There is minimal intervening combustible material between the redundant valves consisting of cable insulation.

In addition, the l

Train-A cable in the area of these valves is wrapped with a fire resistive material (Kaowool).

In addition, the strainer pit at elevation 167 feet - 3 inches has preaction sprinkler system coverage for the redundant valves Q1P16V511-A, Q1P16V508-B, Q1P16V507-A, and Q1P16V506-B.

The raceways that service 01P16V511-A and Q1P16V507-A are protected by a barrier-(two 1-inch-thick wraps of KaoWool blanket) having a fire rating greater than that of the projected fire, which is less than 1/2. hour maximum severity.

The entire fire area is provided with detection.

The strainer inlet valves 'are separated by 20 feet on center and the swing pump discharge valves are separated by 6 feet -

i 6 inches on center.

There is minimal intervening combustible material between the redundant valves consisting of cable insulation.

In addition, the Train-A cable in the area of these valves has been wrapped with a fire l

resistive material (Kaowool).

~

Enclosure i Valves OSPV16V505-A, OSP16V507-A, OSP16V506-B, and OSP16V508-B - The requirement to shift service water discharce from the cire water canal to recirculate to the service water pond is a long term one, not reouired for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and can be accomplished by manually repositioning the sub.fect valves as required. Plant procedures will be written to incorporate the above action for a fire in Fire Area 72 Zone A.

Placing into service 01P16M001C-A8 or 02P16*001C-A9 swing service water pumo is required when one o# the normal train pumps is out of service for maintenance or repair. To preclude the repositioning of the subject valves, after the resnettive swing pump alignment is performed, the power will be removed from the arcropriate swing pump opposite train discharge valve, i.e., when the swino pump it 6?f Q2P1FVSV-Egned to Train-R, the Train-A service water valve (Q1P16V507-A and/or will be maintained in the closed position by administratively removine pQt>er to the valve. Plant procedures will be revised by the licensee to incorpets:P the above action.

Placing into service Q1P16M001C-AB or Q?P16M001C-AB swing service water pump is required when one of the normal train pumps is out of service for maintenance or repair. To preclude the repositioning of the subject valves, after the respective swina pump alianment is performed, the power will be removed 'from the appropriate swing pump opoosite the train discharge valve, i.e., when the swing pumps (Q1P16M001C-AB and/or 02P16M001C-AR1 are aligned to Train-A, the Train-B service water valve (01P16V506-B and/or Q2P16R506-R1 will be maintained in the closed position by administratively removing the power to the valve. Plant procedures will be revised by the licensee to incorporate the above action.

The Train-B cables enter the disconnect switch via bottom entry embedded conduit that is not exoosed at any other point in Zones D and E.

The disconnect switch and switchgear in these zones have an automatic carbon dioxide fire detection and suporession system for protection.

Zones D and E are separated from Zones A, B, and C by non-rated reinforced concrete walls. The sprinkler system in Zone A will act as a water curtain to prevent the spread of a fire from Zones A, B, and C to Zones D and E via the non-rated walls and doors in Zone A.

Therefore, adequate fire protection features exist to ensure that a fire in Zones A, R, or C will not affect both redundant trains of service water.

l w

l Enclosure 12 In addition, the Unit 1 and Unit 2 swing pump power is supplied from 4160 V switchgear Train-A, located in Zone E, and Train-B, located in Zone B.

The pump power circuit breaker is key interlocked with its associated disconnect switch.

Therefore, power from the redundant Trains-A and -B sources will not be in the disconnect switch at one time.

In addition, the redundant Trains-A and -B disconnect switches are key interlocked, preventing both switches being closed at one time.

The Train-A cables enter the disconnect switch via bottom entry embedded conduit that is not exposed at any other point in Zones B and C.

The disconnect switch and switchgear in these zones have an automatic carbon dioxide fire detection and suppression system for protection.

Zones B and C are separated from Zones A, D, and E by non-rated reinforced concrete walls.

The sprinkler system in Zone A will act as a water curtain to prevent the spread of a fire from Zones A, D, and E to Zones B and C via the non-rated walls and doors in Zone A.

Therefore, adequate fire protection features exist to ensure that a fire in Zones A, D, or E will not affect both redundant trains of service water.

The entire pump deck at elevation 188 feet - 6 inches is covered by preac-tion sprinkler systems which provide coverage for the Units 1 and 2 Train-A and -B service water pump deck area. Additionally, the pumps and the floor area immediately around them are covered by a preaction spray system.

The Unit 1 and Unit 2 service water pumps are separated by a concrete block wall which extends approximately 20 feet out from the south zone barrier unto the pump deck. The individual unit Trains-A and -B pumps are separated by curbs and partial height barriers of fire-rated construction located on either side of the swing pump.

These barriers act as radiant heat shields and prevent the spread of an oil spill from one train to the other.

The installed sprinkler and spray systems will act as a water curtain to prevent

~

a fire on the pump deck from spreading to the redundant train or opposite unit service water pumps.

The raceways servicing the Train-A service water pumps for both units have been protected by a barrier (two 1-inch thick wraps of Kaowool blanket) having a fire rating greater than that of the projected fire, which is less than 1/2 hour maximum severity.

The entire fire area is provided with detection.

Therefore, adequate fire protection features exist to ensure that a fire in Zone A will not effect both redundant trains of service water.

1 An associated circuit review indicated that adequate coordination is not provided between safe-shutdown circuits and associated nonsafe-shutdown circuits powered from 125V DC Distribution Panels IN, 2N, IM, and 2M. The safe-shutdown circuits from these distribution panels provide control power for safe-shutdown breakers. A short circuit in an associated cable from one of the distribution panels could result in a loss of power to the panel, and therefore, a loss of control power to the safe-shutdown breakers powered from the affected panel.

1 i

l

Enclosure 13 A loss of power to one of the 125V DC Distribution Panels IN, 2N, IM or 2M will result in the loss of breaker control power for the following safe-shutdown loads controlled from that panel as shown below.

Distribution Panel IN:

4 kV Breaker DLO2 to Load Center L 600 V Load Center Tie Breaker el 05 Service Water Pump 1C Service Water Pump 1D Service Water Pump IE 600V Load Center Breaker el 09 4 kV Tie Breaker DG02 Distribution Panel 2N:

Service Water Pump 2C Service Water Pump 2D Service Water Pump 2E 4 kV Breaker DLO2 to Load Center L Distribution Panel IM:

4 kV Breaker DK02 to Load Center K 600 Load Center Tie Breaker EK05 Service Water Pump 1A Service Water Pump IB Service Water Pump IC 600V Load Center Breaker EK03 Distribution Panel 2M:

Service Water Pump 2A Service Water Pump 2B Service Water Pump 2C 4 kV Breaker DK02 to Load Center K 4 kV Tie Breaker DF02 A loss of breaker control power from the single affected panel will not interrupt the operation of the load powered by the breaker.

However, electrical control of the breaker including breaker protection circuits and handswitch operation will not be functional. A loss of power to one of the subject DC distribution panels will not preclude any necessary control and operation of safe-shutdown equipment.

Should the need arise, manual operation of the affected breaker would be possible.

The licensee has initiated a design change to improve the breaker coordina-tion which will ensure that the required safe shutdown equipment is isolated from associated non-safety circuits.

This design change is scheduled to be installed prior to the end of the Unit I seventh refueling outage currently scheduled to commence during the fourth quarter of 1986.

In addition, by letter dated May 31, 1985, the licensee committed to revise the Unit 1 procedures associated with service water swing pump plant opera-tions and perform the required sprinkler system modifications associated with the service water pumps by the end of the Unit 1 seventh refueling outage. The licensee, by letters dated March 13, 1985 and October 18, 1985, also committed to revise the Unit 2 procedures associated with service water

i Enclosure 14

.)

swing pump plant operations and perform the required sprinkler system modifications associated with the service water pump and lube oil at cooling pump areas by the end of the Unit 2 refueling outage.

All other shutdown systems associated with Fire Area 72 have redundant counterparts in other fire areas or :re located in plant areas which meet the requirements of 10 CFR 50 Appendix R, Section III.G.2.

As a result, there is reasonable assurance that if a fire occurred in Fire Area 72, safe shutdown could be achieved and maintained.

2.4 CONCLUSION

Based on our evaluation, we conclude that the licensee's alternative fire protection configuration, in conjunction with its proposed modifications, will provide an acceptable level of fire protection to that required by technical requirements of 10 CFR 50 Appendix R, Section III.G.2. Therefore, the licensee's request for exemption for Fire Area 72 should be granted.

3.0 UNIT 2 AUXILIARY BUILDING, CABLE CHASE TRAIN-B - FIRE AREA 2-030 (EXEMPTION REQUEST 1-9)

UNIT 2 AUXILIARY BUILDING, SWITCHGEAR ROOM TRAIN-B - FIRE AREA 2-02, (EXEMPTION REQUEST 1-10)

UNIT 2 AUXILIARY BUILDING, CRDM SWITCHGEAR ROOM - FIRE AREA 2-023 (EXEMPTION REQUEST 1-11)

UNIT 2 AUXILIARY BUILDING TO DIESEL BUILDING CABLE TUNNEL TRAIN-B - FIRE AREA 2-076 (EXEMPTION REQUESTS 1-12 and 2-26) 3.1 EXEMPTIONS REQUESTED The licensee in its exemption requests 1-9,1-10,1-11 and 1-12 requested exemption from the technical requirements of 10 CFR 50 Appendix R, Section III.G.2 to the extent that it requires one train of redundant safe shutdown cabling to be enclosed by a fire barrier having a one-hour fire rating.

In addition, the licensee in its exemption requests 1-10,1-12 and 2-26, requested exemption from the technical requirements of 10 CFR 50 Appendix R, Section III.G.2 to the extent that it requires an automatic fire suppression system to be installed throughout fire area 2-021 and automatic fire detec-tion system to be provided throughout fire area 2-076.

3.2 DISCUSSION Fire area 2-030 consists of rooms 2249 (elevation 121 feet - 0 inches and 139 feet - 0 inches) and 2252 (elevation 127 feet - 0 inches).

All fire area boundary walls, floors, and ceilings are 3-hour fire rated except for a c.

Enclosure 15 l

non-rated bulkhead between this area and the cable tunnel (area 2-076). A UL Class A fire-rated door exists betweenrooms 2249 and 2235 (area 2-023).

The door between room 2252 and cable tunnel (area 2-076) is a non-fire-rated watertight door.

A fire-resistant coating has been applied to the water-tight door on the fire area 2-076 side.

Fire area 2-021 consists of rooms 2229 and 2233 at elevation 121 feet -

0 inches and is bounded by 3-hour fire-rated walls, ceilings, and floors.

The area boundary doors are UL Class A fire-rated.

Fire area 2-023 consists only of room 2235 at elevation 121 feet - 0 inches and is bounded by 3-hour fire-rated floors, ceilings, and walls. The area boundary doors are UL Class A fire-rated doors.

Fire area 2-076 consists of a cable tunnel running from the Unit 2 auxiliary l

building to the diesel building.

The fire area boundary walls, floor, and ceiling are 3-hour fire rated except for a non-rated bulkhead between this i

fire area and fire area 2-030. A UL Class A fire-rated door exists between

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the cable tunnel and the diesel building, and a non-fire-rated watertight door exists between the cable tunnel and the auxiliary building (area 2-030).

A fire-resistant coating has been applied to the water tight door leading into the auxiliary building.

Fire Areas 2-030, 2-021, 2-023 and 2-076 contain electrical Train-B control cables associated with the shared Diesel Generator 2C start-stop circuit.

An analysis of the effects of a fire upon these cables shows that DG-2C would fail to start and align to 4.16 kV Bus 1J.

Fire area 2-076 also contains electrical power and control cables for l

electrical Train-B distribution system.

The analysis of the potential effects of a fire in Fire Area 2-076 shows thtt the plant could lose Train-B emergency diesel backup power.

In the event of a postulated loss of offsite power along with a fire in this area, the plant could lose the total electrical Train-B system and make the following redundant safe shutdown components inoperable in the closed

'1 position.

EQUIPMENT FUNCTION N2P19HV3885-B Instrument Air to Penetration Room Q2B13HV2228-B Backup Air / Nitrogen Supply to Pressurizer PORVs Q2B31PCV0445A-A Pressurizer PORV, Train-A Q2831PCV0444B-B Pressurizer PORV, Train-B Q2E21HV8145-N Pressurizer Auxiliary Spray

(

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Enclosure 16 In addition, these Fire Areas (2-030, 2-021, 2-023 and 2 076) contain electrical Train-B control cables associated with the following safe shutdown components.

EQUIPMENT FUNCTION QSP16V506-B Service Water Train-B Emergency Recirc. to Wetpit QSP16V508-B Service Train-B Emergency Recirc. to Pond An analysis of the effects of a fire upon these cables shows that the subject valves could fail in the closed position and become inoperable.

In addition, Unit 1 service water valve Q1P16V538-B, which returns water to wetpit/ pond could fail in the normal closed position due to loss of power to MCC-1P.

The combustible materials associated with the subject fire areas consists of cable insulation and plastic panel parts.

The following summarizes the fire loading a:;sociated with these fire areas:

FIRE AREA FIRE LOAD BTU /FT2 2-030 423,898 2-023 68,002 2-021 109,062 2-076 39,000 A smoke detection system and automatic water suppression system are instal-led in fire area 2-030.

The manual fire brigade hose station located in room 2234 (area 2-020) is available for use in this area.

An area smoke detection system is installed in fire area 2-021.

In addition, in fire area 2-021, heat detectors are provided in the 4.16 kV switchgear, the 5 kV disconnect switch, and the four 600 V load centers.

These heat detectors activate the alarm horn located in the area and the total flooding carbon dioxide systems in each piece of equipment. A water hose located in room 2234 (area 2-020) outside room 2235 and a carbon dioxide hose reel located in room 2210 (area 2-020) are available to the fire brigade as backup.

In fire area 2-023, ionization smoke detectors are provided which activate total flooding Halon system, activate alarm bell in room 2234 (area 2-020),

and annunciate in the main control room.

A water hose installed in room 2234 (area 2-020) outside of room 2235 is available as a back up.

Fire area 2-076 is prptected by an automatic sprinkler suppression system.

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Enclosure 17 The licensee justifies the acceptability of the exemptions. requested in Section 3.1 on the basis of the existing fire protection and their alternative shutdown actions associated with the subject fire areas identified in Section 3.0.

3.3 EVALUATI6N During normal plant operation, the service water is lined up to discharge to the river through open valve QlP16V545-B. The requirement to shift the service water discharge from the circulating water canal to recirculate to the service water pond is'a long term one (not required for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />).

Recirculation can be accomplished by manually repositioning valves QSP16V506-B and QSP16V508-B, as required.

When service water discharge is lined up for recirculating mode to the pond (required when necessary to conserve pond inventory), the effects of a fire could cause immediate loss of Train-B service water. However, the controls of Train-B service water discharge valve Q1P16V545-B to the river are not affected by a fire in either area 2-030, 2-021, 2-0?3 or 2-076 and operator action will be taken to open the valve and reinstate Train-B service water, until recirc to the pond can be re-established by manual operation of QSP16V506-B and QSP16V508-B.

In fire area 2-076 failure of valve Q2E21HV8145-N in the closed position will disable the pressurizer auxiliary spray system which provides one method to achieve depressurization of the RCS.

Pressurizer PORVs Q2B31PCV0445A-A and Q2B31PCV04448-B provide another means of achieving RCS depressurization.

Valves N2P19HV3885-B and Q2B13HV2228-B will fail in the closed position on loss of Train B de power.

This will isolate the instrument air supply to the pressurizer PORVs Q2831PCV0445A-A and Q2831PCV04448-B.

PORV Q2B31PCV0444B-B will also be inoperable due to loss of the Train-B de power supply; however, the Train-A de supply to PORV Q2B31PCV0445A-A is not affected due to a fire in this area. Since only one of the PORVs is required for RCS depressurization, and RCS depressurization is a long term requirement, the operator has adequate time to take manual action to restore the instrument air by hand wheel operation of valve N2P19HV3885-B.

Once air is restored, PORV Q2B31PCV0445A-A will be operable to achieve RCS depressurization.

I The licensee, by letter dated March 13, 1985, committed to develop detailed procedures for Fire Areas 2-030, 2-023, 2-021 and 2-076 which will identify the manual operator actions necessary to regain normal control of the service water system and regain the control of a pressurizer PORV in the event of a fire in fire area 2-076.

Enclosure 18 These procedures will b'e fully implemented by the end of the Unit I seventh refueling outage.

In addition, the cables which are associated with the 4.16 kV Bus 1J power the river water pumps which are considered non-safe shutdown equipment. Loss-of river water pumps will not affect Unit 1 safe shutdown.

The watertight door between auxiliary building (area 2-030) and cable tunnel (area 2-076) does not comply with 3-hour fire-rated boundary requirements.

However, a fire in area 2-030 propagating into area 2-076 will not have any additional impact on Unit I safe shutdown because the same redundant safe shutdown function cables are contained in both the areas.

In addition, the fire-resistant coatings on the subject door will be placed under the licensee's fire protection surveillance program.

All other shutdown systems with the fire areas identified in Section 3.0 have redundant counterparts in other fire areas or are located in plant areas which meet the requirements of 10 CFR 50, Section III.G.2.

As a result, there is reasonable assurance that if a fire occurred in any of the subject fira areas, safe shutdown could be achieved and maintained.

3.4 CONCLUSION

Based on our evaluation, we conclude that the licensee's alternative fire protection and safe shutdown configuration will provide an acceptable level of fire protection to that required by the technical requirements of 10 CFR 50 Appendix R.Section III.G.2 and that no additional fire protection is required to satisfy the requirements of Section III.G.3. Therefore, the licensee's request for exemption for the fire areas identified in Section 3.0 above should be granted.

4.0 UNIT 2 AUXILIARY BUILDING, ELEVATION 100 FT. - 0 INCHES CHARGING PUMP ROOMS AND STORAGE AREAS - FIRE AREAS 2-005 (EXEMPTION 2-8) 4.1 EXEMPTION REQUESTED The licensee in their exemption request 2-8 requested an exemption from the requirements of 10 CFR 50, Appendix R, Section III.G. 'to the extent that it requires a three-hour fire barrier between redundant cabling and equipment.

In addition, within fire area 2-005, the licensee is requesting an exemption from the requirements of Appendix R in that it requires one train of redun-dant safe shutdown cable and equipment to be enclosed in a one-hour fire barrier and the installation of automatic suppression throughout the area.

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Enclosure 19 4.2 OISCUSSION Fire area 2-005 consists of the three charging pump rooms (2173, 2174, and 2181), and a hallway (2172). The fire area boundary walls, floors, and ceilings are 3-hour fire-rated except for the containment wall, and all fire area bourdary doors are fire rated.

Self expanding cork is installeo between the fire area boundary walls and the containment wall.

The fire area contains all three charging pumps, related valves ar.d air handling units.

Each charging pump is redundant to the other two.

The redundant charging pumps, valves, and air handling units are located in separate rooms.

The pump room walls internal to fire area 2-005 are watertight and of two feet thick reinforced concrete.

However, the water-tight penetration seals and watertight doors in the subject walls are not fire rated.

Room 2172 in fire area 2-005 contains the control cables and valves for the RWST charging pump suction (LCV115B and LCV115D), the control cables and valves for the RWMT charging pump suction and boric acid dilution injection to the VCT (FCV0113B-A and FCV01148-A). In addition, control cables for the RWM to the boric acio blender and boric acid flow control valves (FCV0114B-A and FCV0113A-A) trarrit this room.

These components provide redundant suction of makeup water from the RWMT or the RWST.

Complete fire barriers and full suppression coverage is not provided fcr the valves or cables.

The analysis of the effccts of a fire upon the subject cables in the area shows that the RWST isolation valves could become electrically inoperatise in the closed position or makeup to either the VCT or charging pump suctior, header could be isolated.

Control cables of the Train-A pressurizer power operated relief and blocking valves Q2B31PCV0445A-A and Q2B13MOV8000A-A and the reactor head vent Q2B13SV2213A-A and Q2B135V2214A-A are located in fire area 2-005.

The subject cables are associated with the control furttion from the hot shut-down panel Q2H21NBAFP2605G-A.

In addition, control cables which shif t control from the main control ooard to the hot shutdown panel via the transfer relay cabinet 02H22 LOO 2-A are in this area.

A fire induced failure having multiple hot shorte could cause the reactor inventory to letdown via the PORV, and reactor head vent paths.

Combustibles associated with fire area 2-005 primarily consist of cable insulation and lube oil.

The following summarizes the fire loading associated with the rooms bounded by fire area 2-005:

MAXIMUM ROOM NUMBERS /

FIRE LOAD FIRE TITLES (BTU /FTr)

SEVERITY Room 2173

?7,563 Less than Charging /

30 minutes Safety Injection Pamp Room

Enclosure 20 Room 2174 28,508 Less than Charging / Safety 30 minutes Injection Pump Room Room 2181 47,414 Less than Charging / Safety one hour Injection Pump Room Room 2171 31,820 Less than Combustible Area, 30 minutes Room 2172 Hallway and Room 2182 Contamination Storage Area A smoke detection system is installed throughout fire area 2-005.

Manual hose station, carbon dioxide hose reel, portable dry chemical extinguishers, portable carbon dioxide extinguishers, and portable smoke removal equipment located in the corridor just outside the fire area are available for fire brigade use for a fire in fire area 2-005.

In addition, an automatic sprinkler system is installed in room 2172.

The licensee justifies the acceptability of this exemption request on the basis of the existing fire protection features and their alternative shut-down actions associated with this fire area.

4.3 EVALUATION The redundant charging pumps, valves, and air handling units are located in independent, highly segregated rooms.

Rooms 2171 and 2182 do not contain redundant safe shutdown cabling or equipment. An analysis was performed to demonstrate that a fire limited to one of the four areas identified below would not jeopardize the safe shutdown of the plants 1.

RM;2181 - Train-A Charging Pump Room 2.

RM 2174 - Swing Charging Pump Room 3.

RM 2173 - Train-8 Charging Pump Room 4.

RMs 2172, 2171, 2182 - Storage rooms and hallway The following justification is provided to show that a fire would be contained in one of the four areas listed above.

The charging pump rooms (2173, 2174, and 2181) are watertight with two feet e

thick reinforced concrete walls.

The penetrations in the pump room walls internal to fire area 2-005 are sealed to provide a watertight boundary.

The seals utilized to provide the watertight boundary are of the type (foam, welded plate, or grout) to provide an adequate barrier to inhibit the spread of fire, smoke, or gas.

The doors are watertight and are 1

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Enclosure 21 1

normally maintained closed.

Lubricating oil and cable insulation are the only combustibles present in the pump rooms.

Lubricating oil would be j

contained within the individual rooms or would drain into the sump pump servicing the room.

In addition, there is a fixed suppression system installed in room 2172 (hallway) which provides additional protection in 1

the area of the pump room doors which communicate with this hallway.

A smoke detection system is installed throughout the area including the three-4 charging pump rooms.

The maximum combustible loading in any room of this l

fire. is estimated to be, less than 48,000 Btu /fte with a maximum fire severity of less than one hour. Based upon the fire protection provided, a l

fire involving the in-situ combustibles would be contained within the plant i

area of origin.

In order to ensure that the configuration and the. fire

' protection characteristics of the charging pump rooms are maintained the licensee has committed to include the penetrations which are sealed into the surveillance program.

4 A fire barrier has been provided for raceway sections AHF15A, AH012B, AIE258, AIE128 and AIE158 in rooms 2182 and 2172 of fire area 2-005. These barriers protect cables for the boric acid flow control and the RWST to the boric acid blender valves-(FCV0113A-A and FCV01148-A) as they transit rooms 2182 and 2172 of fire area 2-005.

These :,ubject barriers also provide q

protection for the RWST charging pump sucti'-

boric acid dilution injection to the VCT cables (FCV01138-A and FCV011

.' and the redundant RWST 4

charging pump suction train-A cables (LCV0115B-A), with separation of approximately 10 feet.

Partial suppression coverage is provided for the i

subject cables and valves in this area of FCV01138-A and FCV0114A-A. There j

is approximately 15 feet of separation between the RWST charging pump suction valve and cables (FCV0113B-A) and the redundant train-B RWST suction valve and cables (FCV01138-A) and the redundant train B RWST suction valve and cables (LCV01150-B).

Again partial suppression coverage is provided in the area of FCV0113B-A and FCV0114A-A.

Detection is provided in the area of the subject components.

Due to the barriers provided, the spatial separation, detection and partial suppression coverage and the low in-situ combustible loading exposure fire would not affect both redundant I

sources of borated makeup water.

In the event of a fire in room 2181, the train-B RWST isolation valve, LCV1150-B, will be operable.

An automatic suppression system covers the raceway to be protected with the exception jl of 18 feet of raceway sections AHF15A, AHD12B and AIE158 in room 2172 and l

10 feet of AHF15A and AHD128 in room 2182.

4 In the unlikely event that a fire in this area causes a loss of these three indepandent sources of reactor makeup water, the additional fire barriers that uve been installed in Rooms 2182 and 2172 will ensure that a fire

, induced RCS letdown will not exist thus increasing the time margin available

)

to establish makeup.

Reactor decay heat will be sufficient to maintain RCS temperature and thereby prevent shrinkage of the RCS-until manual action can be taken to restore makeup water.

In addition, the reactor coolant pump i

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seal integrity can be maintained by the normal seal injection flow path from the VCT or by using component cooling water.

These flow paths will not be affected by a fire in this area; therefore, the integrity of the pump seals will not be jeopardized while makeup is being established.

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Enclosure 22 Fire indeced failures (hot shorts) in room ?l81 in the control cables for the transfer relay cabinet 02H22L002-A could cause control for the pressurizer power operated relief valves (PORV1 and block valves and the reactor head vent valves, to shift from their normal main control board alignment to the remote hot shutdown panel. Subsequent fire induced failures (hot shorts from adiacent control cables in the shared raceway) of the control cebles for 02R31PCV0445A-A, pressurizer PORV Q2R13SV2213A-A, and 02B13sv2>14A-A reactor head vent valves, could result in the valves being energized to open. The PORV block valves could become electrically inoperative in the open position.

In the unlikely event of the multiple hot shorts occurring, this condition can be mitigated by removing power from the transfer relays and manual operation (handle) of the affected relay thereby shifting control to the main control board. To remove power from the transfer relay, open breaker 9 on de distribution panel 2C (Q2R41 LOGIC-Al located in room 9312, fire area 2-004. Then go to transfer relay cabinet TRC-1 (02H22 LOO 2-Ai in fire area 2-035 room 2347 and manually shift transfer relays TRI (02R13Sv2213A-A1, TR2 (02831MOV8000A-Al placing control back to the main control beard to allow the operator to mitigate the letdown.

The licensee, by letter dated March 13, 1985, committed to develop detailed procedures specifically for this fire area covering the manual operator actions required to regain RCS n3keup and regain the control of the POPVs and reactor head vent valves. The licensee committed to have these procedures fully implemented by the end of the Unit 2 refueling outage.

All other shutdown systems associated with fire area 2-005 have redundant counterparts in other fire areas or are located in plant areas which meet the requirements of 10 CFP 50 Appendix R,Section III.G.2. As a result, there is reasonable assurance if a fire occurred in any of the rooms associated with fire area 2-005, that safe shutdown could be achieved and maintained.

4.4 CONCLUSION

Rased on our evaluation, we conclude that the licensee's alternative fire protection and shutdown configurations will provide an acceptable level of fire protection to that required by the technical requirements of 10 CFR 50 Appendix R, Section III.G.2 and that no additional fire protection is required to satisfy the requirements of Section III.G.3. Therefore, the licensee's request for exemption for fire area 2-C05 should be oranted.

5.0 UNIT 2 AUXILIARY BUILDING, ELECTRICAL PENETRATION ROOMS TRAIN-A - FTRE ADEA 2-035 (EXEMPTION RE0 VEST 2-9)

l l-Enclosure 23 5.1 EXEMPTION REQUESTED The licensee in their exemption request 2-9 requested an exemption from the technical requirements of 10 CFR 50 Appendix R, Section III.G. to the extent that it requires one train of redundant safe shutdown cables be enclosed by a fire barrier having a one-nour fire rating and that automatic fire suppression be installed throughout the area.

5.2 DISCUSSION Fire area 2-035 consists of rooms 2333 and 2347 at elevation 139 feet -

0 inches.

All fire area boundary wall, ceilings, and floors are.3-hour fire rated except for the containment wall.

Fire area boundary doors are fire rated.

This fire area contains electrical Train-A equipment, power and control cables associated with the following redundant safe shutdown and equipment:

EQUIPPENT FUNCTION Q2E21MOV8106-A Charging Pumps Miniflow Isolation Valve Q2E23M0V3764A-A MDAFW Pump Discharge Valve Q2E23MOV3764D-A MDAFW Pump Discharge Valve Q2E23MOV3764F-A MDAFW Pump Discharge Valve Q2E21MOV8131A-A Charging Pump Suction Header Isol. Valve Q2E21MOV8133A-A Charging Pump Discharge Header Isol. Valve N2B21TE413-P1 RCS Loop-1 Hot Leg Temp. Indication N2B21TE423-P1 RCS Loop-2 Hot Leg Temp. Indication N2B21TE433-P1 RCS Loop-3 Hot Leg Temp. Indication Q2E21M0V8107-A Charging Pump to RCS Isol. Valve The licensee's analysis of the potential effects of a fire upon the subject raceways and equipment indicates that the above valves could shif t position from their required safe shutdown position and become inoperative, and the plant could loose indication from the_ instrument loops affected.

In addition, fire area 2-035 contains control cables for the Train-A pressurizer power operated relief and blocking valves Q2831PCV0445A-A and Q2B13MOV8000A-A, and the reactor head vent valves Q2B135V2213A-A and Q28135V2214A-A.

The subject cables are associated with control from both the hot shutdown and main control board.

A fire induced failure having multiple hot shorts could cause the reactor inventory to letdown via the PORV and reactor head vent paths.

Fire area 2-035 contains control cables for the Train-A charging pump isolation valve Q2E21MOV8107-A.

An analysis of the effects.of a fire upon these cables shows that this valve could fail in the closed position and become inoperable. This will disable normal charging of the RCS.

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Enclosure 24 1

Combustibles in fire area 2-035 primarily consists of cable insulation material and plastic panel parts. The following summarizes the fire loading associated with the rooms bounded by fire area 2-035:

MAXIMUM ROOM NUMBERS /

FIRE LOAD FIRE TITLES (BTV/FT2)

SEVERITY Room 2333 and 83,542 Less than 2347 Electrical 1-1/2 hours Penetration Room Fire area 2-035 is provided with a smoke detection system which alarms locally and is annunciated in the main control room. The fire hose station in room 2312 (Fire Area 2-004) is available for manual fire brigade fire-fighting operations in fire area 2-035.

The licensee justifies the acceptability of this exemption request on the basis of the existing fire protection features, their proposed modifica.

tions, and their alternative shutdown actions associated with this fire area.

I 5.3 EVALUATION i

Valve Q2E21MOV8106-A is required to be maintained open to establish charging pump miniflow.

In the event this valve fails closed, miniflow will be discontinued.

According to the licensee's analysis, the charging pump can be run safely with miniflow isolated and with a minimum of 24 gal /m of seal injection flow for a period of up to I hour.

This will allow the operator time to de-energize MCC-20 and take manual action to open the valve and reestablish miniflow.

In addition, the operating charging pump flow can be increased by opening the following valves from the main control room.

EQUIPMENT FUNCTION Q2E21MOV88018-B Boron Injection Tank Outlet Isol. Valve i

Q2E21M0V8803B-B Boron Injection Inlet Isol. Valve The increased flow on charging pump will reduce heating of the pump due to miniflow isolation and allow additional time for a manual action to open i

the miniflow valve.

Letdown path is available through head vent valves Q2813SV2213B-B and Q2B135V22148-B.

Fire induced failures in control cabling could potentially result in closure of motor driven auxiliary feedwater pump discharge valves (02N23MOV3764A-A, l

Q2N23MOV3764D-A, and Q2N23M0V3764F-A).

This would limit the ability to l

provide auxiliary feedwater to a steam generator for cooldown to the turbine i

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Enclosure 25 driven auxiliary feedwater pump.

In addition, this same fire would cause the loss of the norrril ac supply to the turbine driven auxiliary feedw3ter unirterruptible power supply (UPS) 02N23L001-AB.

Upon loss of the norn.al ac supply, the UPS will ther, be supplied frcrr.

battery power.

The subject battery has a 2-hour capacity and, upon deple-tion, manual control must be taken to continue cooldown. The following is i, listing of those comporents that will require manual operation:

EQUIPMENT FUNCTION Q2N12HV3235A Steam to TDAFW from S/G B Q2N12HV3235B Steam to TDAFW from S/G C Q2N12HV3226 TDAFW Steam Admission 02N23HV3228A Feedwater to S/G A l

Q2N23HV3228B Feedwater to S/6 B Q2N23HV3228C Feedwater to S/G C The 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> provided by battery power i adequate for existing procedures for manual operation to be irrplemented.

In lieu of manual operation of the turbine driven AFW purtp system, the cotor driven AFW pump discharge valves could be manually repositicned. This would j

facilitate use of the motor driven AFW purrps.

For a fire in this area, seal injection flow will be established usirs either charging pump 2C or charging pump 2B aligned to electrical Train a power.

Valve Q2E21MOV8131A-A (suction header) and valve 02E21MOV8133A-A (discharge header) are required te be maintained in the open positier, to supply seal injection water from the RWST through charging pump 2B. Due to the effects of a fire in this area upon the. control cables for the subject valves, the valves could fail in the closed position and become inoperative.

This will cause the plant to lose seal injection water and seal integrits.

These valves cannot be locked open because they are needed for train i

separation during a LOCA event. The licensee proposes to install disconnect switches outside the electrical penetration room during the next refuelino outage.

Potential loss of all three loops of hot leg temperature indicators could result due to fire induced cable failure in this fire art.a for RTDs N2B21TE413-P1, N2B21TE423-P1, and N2B21TE433-Pl.

A review of the core exit thermocouple circ 0its shews that these cables are outside fire area 2-035 and the plant operator will have core temperature readings available at the in-core rack NGIC25010-N and plant computer, i

Enclosure 26 In addition to the core exit temperature indication availability, a design change to be installed as a result of R.G.1.97 will provide cable separation and redundant signal processing and indication for RCS hot leg temperature loop N2R21TE433. Based upon the R.G. 1.97 commitment schedule, implementa-tion of the modification is currently planned for the fourth refueling outage.

Fire induced failure (hot short) of the *ndividual control cables for power operated relief valve Q2831PCY044! t-A and for reactor head vent valves 02B1315V2213A-A and Q2B135V2214A A could result in the valves being energized to open. The PORV bloc, valve could become electrically inoperative in the open position.

In tae unlikely event of the multiple fire induced failures (hot shorts from adjacent control cables in the shared raceway) occurring, this condition can be mitigated by removing 125 V-dc power from cables in the shared raceway. This can be accomplished by opening the breaker on the 125 V-dc switchgear bus PA (Q2R42B'01A-A) for I?5 V-dc distribution panels 2A, 28, and 2C.

Failure of the valve Q2E21MOV8107-A in the closed position will cause loss of normal RCS charging. Charging pump flow to seal injection is available.

In case of uncontrolled letdown via head vents or PORVs, a manual action to open the valve Q2E21MOV8107-A will be initiated.

In addition, control room action can be taken to open the valves 02E21MOV88018-B and Q?E21MOV88038-B for charging through the Boron Injection Tank.

The licensee, by letter dated March 13, 1985, committed to develop detailed procedures specifically for this fire area covering the manual operator actions to regain charging pump miniflow, establish manual operation of the auxiliary feedwater system, regain control of the pressurizer PORVs, and initiate RCS charging through the boron injection tank.

The licensee intends to have these procedures fully implemented by the end of the Unit

? fcurth refueling outage.

All other shutdown systems associated with fire area 2-035 have redundant counterparts in other fire areas or are located in plant areas which meet the requirements of 10 CFR 50 Appendix R, Section III.G.2.

As a result, there is reasonable assurance if a fire occurred in any of the rooms associated with fire area 2-035, that upon completion of the proposed modifications safe shutdown could be achieved and maintained.

5.4 CONCLUSION

Based on our evaluation, we conclude that the licensee's alternative fire protection and shutdown configurations, in conjunction with their proposed modifications, will provide an acceptable level of fire protection to that required by the technical requirements of 10 CFR 50 Appendix R, Section III.G.2 and that no additional fire protection is required to satisfy the requirements of Section III.G.3. Therefore, the licensee's request for exenption for fire area 2-035 should be granted.

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I Enclosure 27 4.

6.0 UNIT 2 AUXILIARY BUILDING VERTICAL CABLE CHASE - FIRE AREA 2-013 (EXEMPTICf.

RE0 VEST 2-15) 6.'

EXEMPTION REQUESTED The licensee in their exemption request 2-15 requested an exemption from-the technical requirements of 10 CFR 50 Appendix R, Section III.G.2., to the

+

extent that it requires one train or redundant safe shutdown cabling to be enclosed by a fire barrier having a one-hour fire rating.

6.2 DISCUSSION Fire area 2-013 consists of rooms 2227 (elevation 128 feet - 0 inches), 2300 I

(elevation 141 feet - 0 inches), 2466 (elevation 155 feet - 0 inches) ar.d j

2500 (elevation 168 feet - 6 inches). All fire area beundary walls, floors, and ceilings are 3-hour fire rated and fire area boundary doors are fire rated.

Fire area 2-013 contains electrical Train-E power and control cables for the Train-B power distribution system and control cables for the folicwing redundant safe shutdown equipment.

EQUIPMENT FUNCTION N2P19M001A-N Service Air Compressor A N2P19M0016-N Service Air Compressor B N2P19M001C-N Service Air Compressor C i

The licensee's analysis of the potential effects of a fire upon thesE Cables l

shows that the plant could lose the entire electrical Train-B power distri-

+

bution system and the total service air system.

Due to the loss of ttE electrical Train-B distribution system and service air, the following i

redundant safe shutdown components could become inoperable in the closed position.

I EQUIPMENT FUNCTION I

I N2P19HV3885-B Instrument Air to Penetrations Room Q2B13HV2228-B Backup Air / Nitrogen Supply to PORVs Q2B31PCV0445A-A Pressurizer PORV Train-A f

Q2B31PCV0444B-B Pressurizer PORV Train-B 02E21HV8145-N Pressurizer Auxiliary Spray

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4 Enclosure 28 i

Combustible materials in fire area 2-013 primarily consists.of cable insula-tion.

The following summarizes the fire loading associated with the rooms bounded by fire area 2-013:

l ROOM NUMBERS /

FIRE LOAD FIRE TITLES (BTU /FT2)

SEVERITY Rooms 2227, 256,281 Less Than i

2300, 2466, 3-1/2 hours i

and 2500 Vertical Cable Chase Ionization smoke detection and automatic water suppression capabilities are j

provided throughout fire area 2-013.

In addition, fire extinguishers and two fire hose stations are located outside room 2300 in fire area 2-042 and are available to the fire brigade for manual fire fighting operations in fire area 2-013.

The licensee justifies the acceptability of the exemption requested in j

Section 6.1 on the basis of existing fire protection and their alternative j

shutdown actions associated with fire area 2-013.

I j

6.3 EVALUATION The only safe shutdown components which require instrument air are the pressurizer PORVs which are required to be operable for RCS depressuriza-j tion.

RCS depressurization is a long term action required to initiate RHR.

j This allows adequate time for manual action to be performed to restore instrument air / backup nitrogen to the pressurizer PORVs.

The plant has existing procedures to restore the instrument air on loss of the service i

air compressors.

Once air is restored, valve N2P19HV3885-B can be manually operated to restore air to the pressurizer PORVs.

i l

By letter dated March 13, 1985, the licensee comitted to develop a detailed j

procedure specifically for fire area 2-013 which will identify the manual operator actions required to regain the control of the pressurizer PORVs.

l All other safe shutdown systems associated with fire area 2-013 have i

redundant counterparts in other fire areas or are located in plant areas which meet the requirements of 10 CFR 50 Appendix R.Section III.G.2. As a l

result, there is reasonable assurance that if a fire occurred in fire area 2-013, safe shutdown could be achieved and maintained.

i l

l t

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l 1

I

Enclosure 29

6.4 CONCLUSION

Based on our evaluation, we conclude that the licensee's alternative fire protection and safe shutdown configurations will provide an acceptable level of fire protection to that required by the technical requirements of 10 CFR 50 Appendix R, Section III.G.2 and that no additional fire protection is required to satisfy the requirements of Section III.G.3. Therefore, the licensee's request for exemption for fire area 2-013 should be granted.

7.0 UNIT 2 AUXILIARY BUILDING, ELECTRICAL PENETRATION ROOM TRAIN-B, AND PENETRATION ROOM FILTRATION SYSTEM EQUIPMENT ROOM - FIRE AREA 2-034 (EXEMPTION REQUEST 2-18) 7.1 EXEMPTION REQUESTED The licensee, in their exemption request 2-18, requested an exemption from the technical requirements of 10 CFR 50 Appendix R, Section III.G.2, to the extent that it requires one train of redundant safe shutdown cables and equipment to be enclosed in a fire barrier having a one-hour fire rating and the installation of automatic suppression capabilities throughout the fire area.

7.2 DISCUSSION Fire area 2-034 consists of 2334 and 2317 at elevation 139 feet - 0 inches.

The walls, ceilings, and floors forming the area boundary are three-hour fire rated.

These rooms communicate via two stainless steel pipes used in the penetra-tion room filtration system.

The stainless steel pipes are encased in concrete and contain no combustibles.

UL Class-A fire-rated doors exist between rooms 2334 and 2333 (area 2-034),

2334 and 2322 (area 2-004), and 2317 and 2322 (area 2-004).

Fire area 2-034 contains electrical Train-B equipment, power and control cables, electrical Train-A control, and control power supply cables associated with the following safe shutdown equipment:

EQUIPMENT FUNCTION Q2P16MOV31308-B Service Water Inlet to CCW HX-2B Q2E21MOV81308-B Charging Pump Suction Header Isolation Valve Q2E21MOV8133B-B Charging Pump Disch. Header Isolation Valve Q2E21MOV8109A-B Charging Pump 2A Minificw Valve Q2E21MOV81098-B Charging Pump 2B (Swing) Miniflow Valve Q2E21MOV8108-B Charging Pump to RCS Isol. Valve Q2P15HV3333-B RCS Hot Leg Sample Line CTMT Isolation Valve Q2P15HV3765-A RCS Hot Leg Sample Line CTMT Isolation Valve i

Enclosure 30 Q2P15HV3103-A Pressurizer Liquid Sample Line CTMT Isolation Valve Q2P15HV3332-B Pressurizer Liquid Sample Line CTMT Isolation Valve Q2N11PV3371A-A Main Steam Atmospheric Relief Valve (S.G.-2A)

Q2N11PV33718-A Main Steam Atmospheric Relief Valve (S.G.-2B)

Q2N11PV3371C-A Main Steam Atmospheric Relief Valve (S.G.-2C)

The licensee's analysis of the potential effects of a fire in this area upon the cables and equipment shows that the subject valves could shift position from their required safe shutdown position or become inoperative.

In addition, Fire area 2-034 contains control cables for the Train-B pressurizer power operated relief and blocking valves Q2B31PCV04448-B and Q2B13M0V80008-B, and reactor head vent valves Q2B13SV22138-B and Q2B13SV22148-B.

The subject cables are associated with control from both the hot shutdown and main centrol board.

A fire induced failure having multiple hot shorts could cause the reactor inventory to letdown via the PORV and reactor heat vent paths.

The fire area also contains control cables for the Train-B charging pump isolation valve Q2E21MOV8108-B and regenative heat exchanger discharge valve Q2E21HV8146-B. An analysis of the effects of a fire upon these cables shows that these valves could fail in the closed position and become inoperable.

The combustible materials associated with fire area 2-034 consists primarily of cable insulation, piping insulation, plastic panel parts and charcoal filter media. The following summarizes the fire loading associsted with the i

rooms located in fire area 2-034:

MAXIMUM ROOM NUMBERS /

FIRE LOAD FIRE TITLES (BTU /FT2)

SEVERITY Room 2234 90,995 Less than Electrical 1-1/2 hour Penetration Room Train B Room 2317 24,606 Less than Penetration 30 mins.

Room, Filtration Equipment Room Smoke detection capabilities are provided throughout rooms 2317 and 2334 in fire area 2-034.

Ir. addition, a manual fire hose station is located in rooms 2316 (Fire Area 2-004) and is available for use by the fire brigade in fire Area 2-034.

Enclosure 31 The licensee justified the acceptability of exemption request 2-18 on the basis of the existing fire protection, their alternative shutdown actior.s and their proposed modifications associated with fire area 2-034.

7.3 EVALUATION The effects of a fire in area 2-034 upon the control cables of valve Q2P16M0V31308-B could fail the valve in the closec position causing a itss of service water to CCW heat exchanger 28.

This cendition can impact safe-shutdown only when CCW heat exchanger 2B is aligned and operating ts the Train A heat exchanger.

Plant procedures will be writtin tc maintair valve Q2P16MOV3130B-B in the open pcsition by racking out the MCC breaker

{

whenever CCW exchanger 2B is aligned and operating as ttc Train-A heet exchanger.

i For a fire in this area, seal injection flow will be established using i

either charging pump 2A or charging pump 28 aligned to electrical Train-A i

header) are required to be maintained in the oper: Valve Q2E1M0 power.

injection water from the RWST through charging pump 2A or 28. position to supply sea Due to the effects of a fire in this area upon the control cables for the subject valves, the valves could fail in the closed position and become inoperative.

These valves cannot be locked open because they are needed for train i

separation during a LOCA event.

The licensee has ccmmitted to install discennect switches outside the electrical penetration room du*ing the rext refueling outage.

Valve Q2E21MOV8109A-B or Q2E21MOV8109B-B is required to be maintained the open position to establish miniflow for charging pump 2A or 2B, respec-in tively.

Due to the effects of a fire in this area upon the control cables for the subject valves, the valves could fail in the closed positior, ar.d become inoperative.

will be discontinued. In the event these valves fail closed, the miniflov.

pump can be run safely with miniflow iso? 'ted and with a. mi of seal injection flow for a period of up to one hour.

This will allow the operator time to de-energize MCC-2V and take manual action to open the miniflow valve corresponding to the operating charging i

In addition, the operating charging pump flow can be increased by pump.

l opening the following valves from the main control room:

EQUIPMENT FUNCTION i

Q2E21MOV8801A-A Boron Injection Tank Outlet Isol. Valve 02E21MOV8803A-A Boron Injection Tank Inlet Isol. Valve The increased flow on charging pump will reduce heating of the pump dut tc miniflow isolation and allow additional time for a manual action to open the miniflow valves.

Q2813SV2213A-A and Q28135V2214A-A.Letdewn path is available through head ve i

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Enclosure 32 RCS and pressurizer sample line valves Q2P15HV3332-B, HV3333-B, HV3765-A and HV3103-A are required to be maintained in the closed position to maintain RCS boundary integrity.

Due to the effects of a fire in this area upon the control cables of the subject valves, the valves could fail in the open position and become inoperative.

The open position of these valves will cllow an RCS sample to flow to the VCT through the sample coolers.

This flow is of no immediate significance for safe shutdown. An operator action will be performed to close the manual valves Q2P15V051A and Q2P15V051B to stop the flow of RCS and pressurizer liquid.

The valves Q2P15V051A and Q2P15V051B are located in the sample room 2323 outside of fire area 2-034.

Fire area 2-034 contains de control power supply cable for the main steam atmospheric relief valves Q2N11PV3371A-A, 33718-A, and 3371C-A. Due to the effect of a fire in this area upon this cable, the subject valves could fail in the closed position and become inoperable.

One of the three main steam atmospheric relief valves and its related steam generator are required to be operable to achieve steam release for cooldown.

The atmospheric relief valves are provided with hand wheels such that the 4

valves may be manually open or closed without electrical controls or air supplies.

The operator would establish manual control of the atmospheric relief valves by closing the manual air control valves to isolate the air supply and by opening the manual air vent valve to bleed off air from the diaphragm of the valve actuator.

Both the air control and air vent valves are located in the vicinity of their associated atmospheric relief valve and could be accessible despite a fire in area 2-034. The capability to control s

steam generator pressure and reactor coolant system temperature with the use of the manually controlled atmospheric relief valves was demonstrated during the Unit 2 natural circulation and cooldown startup testing. Consequently, a fire in area 2-034 would not prevent the operation of at least one redun-dant atmospheric relief valve.

Fire induced failure (aot short) of the individual control cables l

for Q2B31PCV0444B-B power operated relief valve and Q2B135V2213B-8, Q2B13SV2214B-B reactor head vent valves, could result in the valves to be j

energized to open.

The power operated relief blocking valve (MOV) could become electrically inoperable in the open position.

In the unlikely event of the multiple fire induced failures (hot shorts from adjacent control cables in the shared raceway) occurring, this conditiun can be mitigated by removing 125 V-dc power from cables in the shared raceway.

This can be accomplished by opening breaker on the 125 V-dc switchgear bus 2B (Q2R428001B-B) for 125 V-dc distribution panels, 2D, 2E, and 2F.

Failure of the valves Q2E21M0V8108-B and Q2E21HV8146-B in the closed position will cause loss of normal RCS charging.

Charging pump flow to seal injection is available.

In case of uncontrolled letdown via head vents or PORVs, a control room action can be initiated to open the valves Q2E21MOV8801A-A and Q2E21M0V8803A-A for charging through boron injection tank.

Enclosure 33 The licensee by letter dated March 13, 1985, committed to develop detai:ed procedures specifically for this fire area covering mar.ual operator actions to regain charging pump mini-flow, establish reactor coolant pump seal i nj ecti or., isolation of RCS and pressurizer sample lines, contrcl of a main steam atnospheric relief valve, regain control of pressurizer POUl and reactor head vent valves and initiating RCS charging through the borcr injection tank.

The licensee intends to have these procedures full) implemented by the end of the Unit 2 refueling outage.

All other shutdown systems associated with fire area 2-034 bave reduncant counterparts in other fire areas or are located in plant areas which meet I

the requirements of 10 CFR 50 Appendix R, Section III.G.2.

As a result, there is reasonable assurance that if a fire occurred in any of the rcy/s associated with fire area 2-034, that upon completion of the proposed -

raodifications safe shutdown could be achieved and maintained.

7.4 CONCLUSION

Based on our evaluation, we conclude thut the licensee's alternative fire protection and shutdown configurations, in conjunction with their proposed nodifications, will provide an acceptable level of fire protection to thet required by the technical requirements of 10 CFR 50 Appendix R, Sectior.

III.G.2 and no additional fire protection is required to satisfy Section III.G.3.

Therefore, the licensee's recuest for exemption for Fire area 2-034 shculd be granted.

8.0 TRAIN-B INSIDE CABLE CHASES. AUXILIARY BUILDING - FIRE AREA 2-009 (EXE:DT:0N 4

REQUEST 2-19) i UNIT 2 AUXILI ARY BUILDING TO DIESEL BUILDING CABLE TUNNEL TRAIN E - FIRE AREA 2-076 (EXEMPTION 2-26) t E.I EXEMPTIONS REQUESTED The licensee in their exemption requests 2-19 and 2-26 requested an exemp-4 tion from the technical requirements of 10 CFR 50 Appendix R, Section III.B.2, to the extent that it requires that one train of redundant safe shutdown cabling be enclosed by a fire barrier having a one hour fire rating.

In addition, the licensee in exemption request 2-26 requested an exemption from 10 CFR 50 Appendix R, Section III.G.2, to the extent that it requires the installation of fire detecticr. in fire area 2-076.

8.2 DISCUSSION I

Fire area 2-009 consists of rooms 2117, 2198, 2247, 2338, 2246 and 2344 and are separated from all plant areas by three hour fire rated fire tarriers j

constructed from reinforced concrete.

All penetratiers througn fire area 2-009 are sealed with silicene foam or Nelson Fittings.

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Enclosure 34 Airtight UL Class-A doors are located between rooms 2198 and 2185 (area 2-6) and between rooms 2338 and 2335 (area 2-41); an airtight UL Class-A door exists between rooms 2344 and 2343 (area 2-41).

Fire area 2-076 consists of a cable tunnel running from the Unit-2 auxiliary building to the diesel building.

The fire area boundary walls, floor, and ceiling are 3-hour fire rated, except for a non-rated bulkhead between this fire area and area 2-030.

A UL Class A fire-rated door exists between the cable tunnel and the diesel building and a non-fire-rated watertight door exists between the cable tunnel and the auxiliary building (area 2-030). A fire resistant coating has been applied to the watertight door.

Fire areas 2-009 and 2-076 contain electrical Train-B power and control cable raceways.

The analysis of the potential effects of a fire in this area upon cabling shows that the plant could lose the entire electrical Train-B system. Due to loss of the electrical Train-B system, the following redundant safe shutdown valves could become inoperable in the closed position.

EQUIPMENT FUNCTION N2P19HV3885-B Instrument Air to Penetration Room 02813HV2228-B Backup Air / Nitrogen Supply to Presurrizer PORVs Q2B31PCV0445A-A Pressurizer PORV, Train-A Q2831PCV04448-B Pressurizer PORV, Train-B Q2E21HV8145-N Pressurizer Auxiliary Spray N2P19HV3825-A Instrument Air to Penetration Room Fire area 2-009 contains control cables for the Train-B pressurizer power operated relief and blocking valves Q2831PCV04448-8 and Q2B13MOV8000B-B, and the reactor head vent valves Q28135V2213B-B and Q28135V22148-B. The subject cables are associated with control from both the hot shutdown and main control board.

A fire induced failure having multiple hot shorts could cause the reactor inventory to letdown via the PORV and reactor head vent paths.

In addition, a fire in fire area 2-009 could affect auxiliary feedwater isolation valves Q2N23MOV37648, Q2N23M0V3764C and Q23MOV3764E which are redundant to one another in that they isolate flow in redundant auxiliary feedwater supply lines.

Control cables associated with these valves are routed through fire area 2-009 the licensee's analysis of the potential fire effects on these cables indicates that spurious operation of the auxiliary feedwater isolation valves could occur.

Fire area 2-009 also contains a control cable for the CCW heat exchanger 2B service water discharge valve (Q2P165V3009-B).

A fire induced failure resulting in a hot short from adjacent cables in the same raceway, could energiza the solenoid and close the valve.

This condition can impact safe-shutdown only when CCW heat exchanger 28 is aligned and operating as the Train-A heat exchanger.

i Enclosure 35 The combustibles associated with fire areas 2-009 and 2-076 consist The following sum ~arizes the fire loading primarily of cable insulation.

m associated with the rooms located in these fire areas:

MAXIMUM ROOM NUMBERS /

FIRE LOAD FIRE

. TITLES (BTU /FT2)

SEVERITY Rooms 2117, 2,921,199 Less than 2198, 2247, 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> 2338 Cable Chase (Fire Area 2-009)

Rooms 2246, 180,180 Less than 2344 Cable 2-1/2 hours Chase (Fire Area 2-009)

Cable Tunnel 39,000 Less than Train-B (Fire Area 30 minutes 2-076)

A smoke detection system ar.d automatic water suppression system are provided throughout fire area 2-009.

In addition, water hoses and portable extin-guishers located in rooms'2185 (area 2-6) and 2319 (area 2-42).are available for use in the area.

Fire area 2-076 is protected by an automatic sprinkler system.

The licensee justifies the acceptability of the exemption requests identi-fied in Section 8.1 on the basis of the existing fire protection configura-tion, their alternative shutdown actions and their proposed fire protection modification associated with fire area 2-009.

8.3 EVALUATION Fire failures, caused by a fire in either Fire Area 2-009 or 2-076, will cause valve Q2E21HV8145-N to fail in the tlos'ed position and will disable i

the pressurizer auxiliary spray system which provides one method to achieve depressurization of the RCS.

Pressurizer PORVs Q2B31PCV0445A-A and i

Q2B31PCV0444B-B provide another means of achi'eving RCS depressurization.

Valves N2P19HV3885-B, N2P19HV3825-A and Q2B13HV2228-B will fail in the closed position as a result of fire damage. This will isolate the instrument air supply to the pressurizer PORVs Q2B31PCV0445A-A and Q2B31PCV0444B-B.

PORV Q2B31PCV0444B-B will also be inoperable due to loss of the Train-B de power supply. However, the Train-A de supply to PORV Q2B31PCV0445A-A is not affected due to a fire in this area. Since only one of the PORVs is required for RCS depressurization, and RCS depressurization is a long term requirement, the operator has adequate time to take manual action to restore the instrument air by hand wheel operation of valves N2P19HV3885-B and N2P19HV3825-A which are located outside of Fire Areas 2-009 and 2-076.

n Enclosure 36 Once air is restored, PORV Q2831PCV0445A-A will be operable to achieve RCS depressurization.

Fire induced failure (hot shorts) caused by a fire in Fire Area 2-009 in the individual control cables for Q2B31PCV0444B-B power operated reliet valve, and Q2B135V22138-E andQ2B135V2214B-B reactor head vent valves could cause the valves to be energized to open. The PORV block valve could become electrically inoperative in the open position.

In the unlikely event of the multiple fire induced failures (hot shorts from adjacent control cables in the shared raceway) occurring, this condition can be mitigated by removing 125-V-dc power from cables in the shared raceway.

This can be accomplished by opening a breaker on the 125 V-dc switchgear bus 2B (Q2R420001B-B) for 125 V-dc distribution panels 20, 2E, and 2F.

In Fire Area 2-009, the licensee has committed to protect the control cable associated with at least one of the auxiliary feedwater isolation valves with an equivalent one-hour fire barrier consisting of two one-inch layers of kaowool blanked with an overall layer of Zetex fabric. This modification should ensure that auxiliary feedwater will be available if a fire were to occur in Fire Area 2-009.

In addition, to preclude spurious valve movement cause by a fire in Fire Area 2-009, valve Q2P165V3009-B will be de-energized to ensure it remains in the open position whenever CCW heat exchanger 2B is aligned and operating as the Train A heat exchanger.

Therefore, by letter dated March 13, 1985, the licensee committed to protect one train of control cabling associated with the auxiliary feedwater isolation valves with a equivalent one-hour fire barrier in fire area 2-009, develop detailed procedures specifically for these fire areas with regard to regaining the control of a pressurizer PORV and isolating the Train B pressurizer PORV, reactor head vent and pressurizer block valves from a hot shot spurious signal.

The licensee intends to have the raceway fire barrier installed and the procedures necessary to satisfy the fire effects associated with fire areas 2-009 and 2-076 fully implemented by the end of the Unit 2 fourth refueling outage, The watertight door and bulkhead between auxiliary building -(area 2-030) and-cable tunnel (area 2-076) does not comply with 3-hour fire-rated boundary requirements. hunever, a fire in area 2-076 propagating into the area 2-030 will not have any additional impact on Unit 2 safe shutdown because the sarre redundant safe shutdown function cables are contained in both areas.

In addition, the fire resistant coatings on the subject door will be placed under the licensee's fire protection surveillance program.

Enclosure 37 All other safe shutdown systems associated with fire areas 2-009 or 2-076 have redundant counterparts in other fire areas or are located in other plant areas which meet the requirements of 10 CFR 50 Appendix R Section I I I. G. 2..

As a result, there is reasonable assurance that if a fire occurred in fire area 2-009, upon completion of the proposed modifications or in fire area 2-076, safe shutdown could be achieved and maintained.

8.4 CONCLUSION

P g

Based on our evaluation, we conclude that the licensee's alternative fire '

protection and shutdown configurations, in conjunction with their proposed

• modifications, will provide an acceptable level of fire protection to that required by the technical requirements of 10 CFR 50 Appendix R, Section III.G.2 and that no additional fire protection is required to satisfy the requirements of Section III.G.3. Therefore, the licensee's request for exemption for fire areas 2-009 and 2-076 should be granted.

9.0 UNIT 2 AUXILIARY BUILDING CABLE. CHASE TRAIN-A - FIRE AREA 2-031 (EXEMPTION REQUEST.2-21) 9.1 EXEMPTION REQUESTED The, licensee in their exemption request 2-21 requested an exemption from the technical requirements of 10 CFR 50 Appendix R, Section III.G.2 to the extent that it requires one train of redundant safe shutdown cabling to be enclosed in a fire barrier having a one-hour fire rating.

9.2 DISCUSSION Fire area 2-031 consist of rooms 2250 (elevation 121 feet - 0 inches and 139 feet - 0 inches) and 2251 (elevation 127 feet - 0 inches).

All area boundary walls, floors, and ceilings are 3-hour fire-rated except for a non-rated bulkhead between this fire area and the cable tunnel (area 2-075).

A non-fire-rated watertight door exists between room 2251 and cable tunnel (area 2-075), and a UL Class A fire-rated door exists between rooms 2250 and 2235 (area 2-023).

A fire-resistant coating has been applied to the watertight door on fire area 2-076 side.

~

A fire in area 2-031 could potentially result in fire damage to the electrical circuitry of both Unit I and Unit 2 Train-A diesel generators.

This condition along with an assumed loss of offsite power for Unit 2 could result in following safe shutdown equipment and instrumentation being affected:

EQUIPMENT FUNCTION i

Q2N11PV3371A-A Main Steam Atmospheric Relief Valve S.G.-2A)

Q2N11PV33718-A Main Steam Atmospheric Relief Valve S.G.-28)

Q2N11PV3371C-A Main Steam Atmospheric Relief Valve S.G.-2C)

Enclosure 38 The analysis of the potential effects of loss of power for.the main steam atmospheric relief valves has shown that the valves could become inoperable in the closed position.

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INSTRUMENTATI'ON FUNCTION

~

N2B21TE413 (Loop 1)

RCS Hot Leg Temperature, Indication

. N2B21TE423 (Loop 2)

RCS Hot Leg Temperature, Indication N2821TE433 (Loop 3)

RCS Hot Leg Temperature. Indication Q2C55NE0048A-A Post-Accident Neutron Flux Monitor l

N2C55NE0031-P1 Source Range Neutron Flux Monitor N2C55NE0032-P2 Source Range Neutron Flux Monitor 1

The licensee's analysis of the potential effects caused by-loss of power to the instrumentation listed above has shown that a loss of power to the j

instrument loops could result.

The combustible materials primarily associated with fire area 2-031 consists of cable insulation.

The following summarizes the fire loading associated with,the rooms located within fire area 2-031:

MAXIMUM ROOM NUMBERS /

FIRE LOAD FIRE TITLES (BTU /FT2)

SEVERITY Rooms 2250 794.491 Less than and 2251 nine hours Cable Chase Train-A Fire area 2-031 is protected by an automatic fire / smoke detection system and an automatic sprinkler system.

In addition, the fire hose station located in room 2234 (Fire area 2-020) is available for fire brigade fire fighting operations in this area.

The licensee justifies the acceptability of this exemption request or, the basis of the existing fire protection configuration, their alternatise shutdown actions and the proposed modifications associated with fire area 2-031.

9.3 EVALUATION One of the three main steam atmospheric relief valves and its related steam generator are required to be operable to achieve steam release for cooldown.

The atmospheric relief valves are provided'with hand wheels such that the valves may be manually opened or closed without electrical controls or air supplies.

The operator would establish manual control of the atmospheric relief valves by closing the manual air control valves to isolate the air supply and by opening the manual air vent valve to bleed off air from the diaphragm of the valve actuator.

Both the air control and air vent valves are located in the vicinity of their associated atmospheric relief valve and

Enclosure 39 would'be accessible despite a fire in area 2-031. The capability to control steam generator pressure and reactor coolant system temperature with the use of the manually controlled atmospheric relief valves was demonstrated during the Unit 2 natural circulation and cooldown startup testing. Consequently, a fire in area 2-031 would not prevent the operation of at least one redundant atmospheric relief valve.

Each of the RCS loop hot leg temperature instrumentation loops is powered from channelized inverter 2A.-

Inverter 2A is powered from 600 V-ac MCC 2A or 125 V-dc bus 2A.

A fire in area 2-031 could result in loss of the 600 V-ac power supply to inverter 2A; however, inverter 2A will continue to operate from 125 V-dc bus 2A and will supply power to 120 V-ac distribution panel 2J for a minimum of two hours.

If after 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> power is lost, RCS hot leg temperature is available from the core exit temperature indication in the main control room from the core exit thermocouples. Core exit tempera-ture indication will not be affected by a fire in area 2-031.

In addition to the alternate de power supply and core exit temperature indication availability, a design change will be installed as a result of R.G.1.97 to provide a redundant power supply and to provide cable separation and redundant signal processing and indication between RCS hot leg tempera-ture loops N2BlTE413, N2B21TE423, and N2B21TE433. Based upon the R.G.1.97 comitment schedule, implementation of the modification is currently planned for the fourth refueling outage. After plant implementation of this modification, a fire in area 2-031 will not affect the ability to monitor one loop of RCS hot leg temperature.

Post-accident neutron flux monitor Q2C55NE0048A-A is powered from inverter 2F.

Source range neutron flux monitors N2C55NE0031-P1 and N2C55NE0032-P2 are powered from channelized inverters 2A and 28. Inverters 2A, 2B, and 2F are all powered from 600 V-ac MCC 2A or 125 V-dc bus 2A. Therefore, neutron flux monitoring following potential fire damage in area 2-031 and the resultant loss of 600 V-ac MCC 2A will be available for a minimum of two hours.

An RCS sample can be obtained after initiation of the RHR system by using portions of the RCS sampling and RHR Hx No.1 and No. 2 sample valves 02P15HV3105-B and Q2P15HV3106-B for determination of the boron concentration and shutdown margin following a fire area 2-031.

The licensee, by' letter dated March 13, 1985, committed to develop detailed procedures specifically for, fire area 2-031 which identify the manual operator actions required to regain control of one main stream atmospheric relief valve and those actions necessary to monitor boron concentration utilizing the RCS sampling system.

The licensee intends to have these procedures fully implemented by the end of the Unit 2 fourth refueling outage.

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0 Enclosure 40 All other shutdown systems associated with fire area 2-031.have redundant counterparts in other fire areas or are located in plant areas which meet the requirements of 10 CFR 50 Appendix R Section III.G.2.

As a result, there is reasonable assurance that if a fire occurred in fire area 2-031, upon completion of the proposed modifications, safe shutdown cou'ld be achieved and maintained.

9.4 CONCLUSION

Based on our evaluation, we conclude that the licensee's alternative fire protection and safe shutdown configurations, in conjunction with their proposed modifications, will provide an acceptable level of fire protection to that required by the technical requirements of 10 CFR 50 Appendix R, i

Section III.G.2 and that no additional fire protection is required to i

satisfy the requirements of Section III.G.3.

Therefore, the licensee's l

request for exemption for fire area 2-031 should be granted.

10.0 UNIT 2 AUXILIARY BUILDING, ELEVATION 100 FEET - 0 INCHES, 121 FEET -

0 INCHES,127 FEET - 0 INCHES,139 FEET - 0 INCHES,155 FEET - 0 INCHES, AND 175 FEET - 0 INCHES - FIRE AREA 2-006 (EXEMPTION REQUEST 2-35) 10.1 EXEMPTION REQUESTED The licensee in their exemption request 2-35 requested exemption from the technical requirements of 10 CFR 50 Appendix R, Section III.G.2 to the extent that it requires one train of redundant safe shutdown cable and equipment to be enclosed by a barrier having a one-hour fire rating and the installation of automatic fire suppression systems throughout the fire.

10.2 DISCUSSION Fire area 2-006 consists of the following rooms:

Elevation 100 Feet - 0 Inches Room 2167 Combustible Storage Room Room 2185 Component Cooling Water Heat Exchanger Room Room 2189 Plant Heating Equipment Room Room 2190 Motor Control Center 2E Room Room 2191 Auxiliary Feedwater Pump Room Train-A)

Room 2192 Auxiliary Feedwater Pump Room Train-B)

Room 2193 Auxiliary Feedwater Pump Room Turbine Driven)

Room 2194 Lower Equipment Room Room 2195 Access Hatch Area Elevation 127 Feet - 0 Inches Room 2236 Duct Chase Room 2241 Main Steam and Feedwater Valve Room Room 2242 Pipe Chase Room 2243 Pipe Chase

Enclosure 41 The floors, walls, and ceilings of fire area 2-006 that form the boundary between area 2-006 and adjacent fire areas are reinforced concrete and rated for three hours with the exception of a hatchway with a steel plate cover between room 2185 (area 2-006) and room 2234 (area 2-020), and a steel bolted access plate in the duct chase room 2236 (area 2-006) and room 2346 (area 2-041) on elevation 139'-0".

All electrical and piping penetrations between adjacent fire areas are sealed for a three-hour rating. All doors between adjacent fire areas are UL Class A or Class G rated with two excep-tions.

There are non-rated doors between stairway No. 1 and room 2190 and between stairway No. I and room 2241. These doors are watertight and p'res-sure tight respectively.

The auxiliary feedwater system cables and equipment complies with 10 CFR 50 Appendix R, Section III.G.2.c throughout fire area 2-006 with the exception of the pump rooms.

The Train-A, Train-B, and turbine driven auxiliary feedwater pumps are located in rooms 2192, 2191, and 2193 respectively.

Cabling and equipment within the pump rooms are not protected by fire barriers, automatic suppression is not provided, and all three pump rooms are located in the same fire area.

Protection and/or separation of component cooling water system cables and equipment complies with 10 CFR 50 Appendix R, Section III.G.2.C throughout fire area 2-006 with the exception of the component cooling water heat exchanger room (2185).

This room contains all three component cooling water (CCW) pumps.

The CCW pumps are located on 21 feet centers and fire barriers are provided for the pump control and power cables.

However, there are small quantities of intervening combustibles consisting primarily of cable insulation between the pumps which are not provided with fire barriers.

In addition, the service water inlet valves to redundant component cooling water heat exchangers (MOV3130A-B, M0V31308-B, and MOV3130C-A) and service water discharge valves from redundant component cooling water heat exchangers (SV009A-B, SV0098-B, and SV009C-A) are located less than 20 feet apart.

Although the cables for the Train-B valves are provided with fire barriers and automatic suppression, the valves themselves are not provided with fire barriers. Automatic fire suppression is provided over the CCW pumps, CCW valves, and the other protected cables in room 2185.

However, automatic fire suppression coverage is not provided for the complete room.

Cables for the redundant main steam isolation valves traverse rooms 2185, 2189, 2190, and 2194 on elevation 100 feet - 0 inches are unprotected by fire barriers and in close proximity to one another.

In the main steam and feedwater valve room (2241) on elevation 127 feet - 0 inches, the redundant main steam isolation valves are back-to-back in each of the three main steam lines and the associated valves control cables are separated by less than 20 feet.

An automatic fire detection system is provided in room 2241, but fire barriers are not provided over the redundant main steam isolation valves and related control cabling, and an automatic fire suppression system is not provided.

Enclosure 42 Control cables for the redundant main steam atmospheric relief valves (MSARV) traverse rooms 2185, 2189, 2190, and 2194 on elevation 100 feet -

0 inches.

These cables are separated by less than 20 feet in the rooms mentioned above.

One train of the redundant MSARV control cables is not protected by a fire barrier on elevation 100 feet - 0 inches.

The local control station and related control cabling for all three MSARVs are located together in room 2189.

Fire barriers are not provided to protect the local control stations or control cabling.

On elevation 127 feet - 0 inches, the three valves and their control cabling are located in one room (2241).

Adjacent valves are within 20 feet of one another.

Fire barriers are not provided to protect' the valves or control cabling and fire suppression is not provided in room 2241.

The combustibles in fire area 2-006 primarily consists of cable insulation and pump lube oil.

The following summarizes the fire loading associated with the rooms in fire area 2-006:

MAXIMUM i

ROOM NUMBERS /

FIRE LOAD FIRE l

TITLES (BTU /FT2)

SEVERITY Room 2167 5,323 Less than j

Combustible 30 mins.

Storage Room Room 2185 Less than Component 34,775 30 mins.

Cooling Water Heat Exchanger Room Room 2191 20,107 Less than Auxiliary 30 mins.

Feedwater Pump Room Room 2192 26,411 Less than Auxiliary 30 mins.

Feedwater Pump Room Room 2189 27,634 Less than

~

Plant Heating 30 mins.

Equipment Room, Room 2190 Control Center 2E Room, Room 2194 Equipment Room, Room 2193 Auxiliary Feedwater Pump Room, and Room 2195 Access Hatch Room

Enclosure 43 Room 2236 0

0 Duct Chase

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Room 2241 3,869 Less than I

Main Steam 30 mins.

and Feedwater 1:

4 Valve Room Room 2242 1,287 Less than Pipe Chase 30 mins.

Room 2243 1,670 Less than Pipe Chase 30 mins.

A detection system covers the entire area except for rooms 2195, 2236, 2242, and 2243.

Room 2167 has a wet-pipe sprinkler system which activates a local fire alarm bell trouble horn, and annunciates in the control room.

Automatic water suppression systems are provided for rooms 2189, 2190, 2194, and a portion of room 2185.

The suppression system in room 2185 will be

-modified to provide direct, unobstructed coverage to the CCW pumps.

Heat de'tectors are provided in the 5-kV disconne'ct switch in room 2185 which

~

alarm both locally and in the control room.

The 5-kV disconnect switch cabinets are provided with a total-flooding carbon dioxide system which is activated by the heat detectors.

Two water hose stations, located in rooms 2185 and 2189, are provided.

A portable extinguisher is located in room 2185 outside of room 2167. A hose station in room 2234 (area 2-20) will be available for use in this area.

Automatic water suppression systems are provided for rooms 2185, 2189, 2190, and'2194 to protect electrical cable from exposure fires.

The licensee justifies the acceptability of this exemption on the basis of the existing fire protection, their alternative shutdown actions, and their proposed fire protection modifications associated with fire area 2-006.

10.3 EVALUATION An analysis was performed by the licensee which demonstrated that a fire limited to one of the auxiliary feedwater (AFW) pump rooms would not defeat the auxiliary feedwater system.

A fire in any one of the pump rooms would impact the AFW system only to the extent that one AFW pump and AFW flow to one steam generator could be disabled.

The AFW pump rooms are highly segregated watertight rooms with 2-feet thick reinforced concrete walls and watertight doors that are maintained closed.

Lubricating oil and cable insulation are the only combustibles present in the pump rooms.

Leaking oil would be contained within the individual rooms or would rain into the sump servicing the room. The combustible loading of l'

any one pump room is estimated to be less than 30,000 Btu /ft2 with a maximum fire severity of less than 30 minutes.

l l

1 Enclosure 44 A smoke detection system is installed in each of the three auxiliary feedwater pump rooms.

The detection system would provide early warning of a fire, allowing the fire brigade adequate time to respond. A manual hose

. station, portable carbon dioxide extinguishers, and portable smoke removal

5. %.

• equipment are available for use in the area.

The room construction coupled with a low quantity of combustible material, the presence of smoke detection systems, and the availability of equipment for use by the fire brigade substantietes the contention that a fire in one of the AFW pump rooms would be confined to the affected room. Such a fire would not prevent auxiliary feedwater flow to at least~ one steam generator.

Credit has been taken for the separation afforded. by the subject pump room boundaries.

To ensure that the as-built configuratio'n is maintained, the sealed penetrations will be placed in the licensee's fire barrier surveillance program.

A smoke detection system is installed throughout the area.

An automatic sprinkler system is installed over the CCW pumps and in' areas where cables are concentrated. The sprinkler systen will be modified in order to provide direct unobstructed impingement on the CCW pumps.

The combustible loading in the room is le'ss than 35,000 Btu /fte with a maximum fire severity of less than 30 minutes.

The detection system in the room would provide early warning of a fire allowing the fire brigade adequate time to respond.

A manual hose station, portable extinguishers, and portable smoke removal equipment are available for use in the area.

The CCW pumps are located on 21-feet centers.

Heat detectors are providad in the 5-kV CCW pump disconnect switch which alarms locally and in the control room.

The 5-kV disconnect switch cabinets are provided with a total-flooding carbon dioxide system which is activated by the heat detectors.

The CCW pump cables are wrapped with two 1-inch layers of Kaowool with the exception of the Train-A cables for the swing CCW pump which are wrapped with a single 1-inch layer.

All trains of CCW pump cables are covered by an automatic sprinkler system.

Cables for the Train-B service water inlet and discharge valves on the CCW heat exchangers are protected by the 1-inch layers of Kaowool and covered by automatic suppression.

Cables for the Train-A service water inlet and discharge valves on the CCW heat exchanger are not protected.

Although neither Train-A or Train-8 service water valves are provided with fire barriers, the nearest redundant valves are separated by a distance of approximately 10 feet.

Intervening combustibles between redundant valves are minimal, consisting primarily of cable insulation.

The licensee's fire hazards analysis has shown that a postulated fire in rooms 2185, 2189, 2190, 2194, or 2241 would potentially result in spurious operation of the main steam isolation valves.

In the event that the main steam isolation valves fail to isolate due to fire induced failures in the

Enclosure 45 valves or valve control circuitry,the main turbine stop valves would provide isolation of the main steam lines. The main turbine stop valves and related control circuitry would not be effected by a fire in area 2-006.

The main steam atmospheric reifef valves (MSARV) are located in the main steam and feedwater valve room (2241) on elevation 127 feet - 0 inches.

The backup air compressors and local control station for the atmospheric relief valves are located in the plant hearing equipment room (2189) on elevation 100 feet - 0 inches.

The combustible loading of either room is such that the maximum expected fire severity is less than 30 minutes. The main steam. and feedwater valve room is a restricted area with limited personnel access during plant operation.

A smoke detection system is installed throughout both rooms.

An automatic sprinkler system covers the plant heating equipment room.

The main steam and feedwater valve room does not have sprinkler coverage because of the high temperature piping in the room.

The detection system would provide early warning of a fire allowing the fire brigade adequate time to respond.

A manual hose station, portable extin-guishers and portable smoke removal equipment are available for use in both rooms.

' The main steam and feedwater valve room is a large room divided into three bays. The bays are separated by partial walls 14-feet in height. One main steam line lies in each bay.

fhe main steam lines and their atmospheric relief valves are on 18-feet centers and separation of the valves control cabling of redundant MSARVs is maximized between the bays. The floor of the main steam and feedwater valve room is watertight.

The only communication between the main steam and feedwater valve room is an equipment hatch. On elevation 127 feet - 0 inches the equipment hatch area is enclosed in a separate room.

.In the event of fire induced failures affecting the redundant MSARV control

. cables or the local control stationk located in rooms 2185, 2189. 2190, and 2194 on elevation 100 feet

-0 inches, the atmospheric relief valves located in room 2241 on elevation 127 feet - 0 inches are provided with hand wheels such that the valves may.be manually operated or closed without electrical controls or air supplies.

Due to the degree of separation provided between MSARVs and related control cabling in room 2241, the minimal combustible loading, the presence of an early warning smoke detection system, and the administrative controls imposed at the plant to limit access to room 2241 during plant ' operations, a credible fire in room 2241 would not result in the inability to operate the MSARV. associated with one steam generator.

By letter dated March 13 and October 18, 1985, the licensee connitted to implement the proposed fire protection sprinkler modifications in the CCW pump room, incorporate the penetration seals associated with the AFW pump rooms into the fire barrier penetration seal surveillance program and develop a procedure to regain the control of the MSARVs by the end of the Unit 2 fourth refueling outage.

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Enclosure 46 Pipe chases (rooms 2242 and 2243), duct chase (room 2236),.cnd the access hatch area (room 2195) are not provided with automatic fire detection and fire suppression systems in fire area 2-006. A non-fire-rated and checkered steel plate is located at elevation 155 feet - 0 inches at the outside exit of room 2195.

Rooms 2242, 2243, 2236, and 2195 do not contain any safe shutdown equipment or cabling, and therefore a postulated fire in these rooms will not result in the inability to achieve safe shutdown.'

All other shutdown systems associated with fire area 2-006 have redundant counterparts in other fire areas or are located in plant areas which meet the requirements of 10 CFR 50 Appendix R.Section III.G.2.

As a result, there is reasonable assurance.that if a fire occurred in any of the rooms in fire area 2-006 safe shutdown could be achieved and maintained.

10.4 CONCLUSION

Based on our evaluation, we conclude the licensee's alternative fire protec-tion and shutdown configuration, in conjunction with their proposed fire protection modification in the CCW pump room, will provide an acceptable level of fire protection to that required by the technical requirements of 10 CFR 50 Appendix R, Section III.G.2 and that no additional fire protec-tion is required to satisfy the requirements of Section !!I.G.3. Therefore, the licensee's request for exemption for the rooms associated with fire area 2-006 should be granted.

11.0 UNIT 2 AUXILIARY BUILDING, ELEVATION 83 FEET - 0 INCHES, 100 FEET -

0 INCHES, AND 121 FEET. O INCHES - FIRE AREA 2-001 (EXEMPTION REQUEST 2-36) 11.1 EXEMPTION REQUESTED

The licensee in their exemption request 2-36 requested an exemption from the technical requirements of 10 CFR 50 Appendix R, Section III.G.2 to the extent it requires one train of redundant safe shutdown cable to be enclosed by a barrier having a one-hour fire rating and automatic fire suppression.

11.2 DISCUSSION Fire area 2-001 consists of the following rooms:

Elevation 83 Feet 0 Inches Room 2101 Waste Decay Tank Room Room 2102 Valve Compartment Room Room 2103 Corridor Room 2104 Passageway to Unit 1 Room 2105 Catalytic Hydrogen Recombiner A Room Room 2106 Catalytic Hydrogen Recombiner B Room Room 2108 Waste Monitor Tank Room Room 2109 Waste Monitor Tank Pump Room i

r

o Enclosure 47 Room 2110 Monitor Control Panelevation Room Room 2111 Containment Spray Pump Room A Room 2112 Access tc Tendon Access Gallery Room 2113 Valve Encapsulation Room 2114 Pipe Chase Room 2115 Hallway Room 2118 Floor Drain Tank Room Room 2119 Waste Holdup Tank Room Room 2120 Corridor Room 2121 Floor Drain Tank Pump Room Room 2122 Waste Evaporator Feed Pump Room Room 2123 Pipe Chase Room 2124 Valve Encapsulation Room 2125 Containment Spray Pump Room B Room 2126 Pipe Chase Room 2127 Pipe Chase Room 2128 RHR heat Exchanger Room Room 2129 RHR Low head Pump Room B Room 2130 Pipe Chase Room 2131 RHR Low Head Pump Room A Elevation 100 Feet. - 0 Inches Room 2183 Tendon Access Gallery Entrance Room 2184 Piping Penetration Room t'

Room 2169 Pipe and Duct Chase Room 2196 Tendon Access Gallery Elevation 121 Feet - 0 Inches Room 2223 Piping Penetration Room All of the fire area boundary walls, floors, and ceilings are rated as 3-hour fire barriers except for a non-rated steel hatch cover between the ceiling of room 2103 and the floor of room 2163 (area 2-4).

All electrical and piping penetrations sealed for a three-hour rating.

All doors in the boundary walls are UL Class A or Class B rated.

A fire induced failure in the control cable for instrument air isolation valve 02P19HV3611 in fire area 2-001 may cause the valve to fail closed. A loss of instrument air causes the normal charging line isolation valve 02E21HV8146 and the alternate charging line isolation valve Q2E21HV8147 to fail open.

It may be necessary to close these valves during the course of shutdown to isolate charging flow.

A fire induced failure in the control cable for the pressurizer PORV backup air / nitrogen supply valve Q2B13HV2228-B and N2P19HV3825-A may cause the valve to fail closed.

If instrument air isolation valve Q2P19HV3611 or N2P19HV3825-A and the pressurizer PORV backup air / nitrogen supply valve l

1 Enclosure 48 i

Q2813HV2228-8 fail, closed, the pressurizer PORVs will be inoperable. in the l

closed position.

Operation of the pressurizer PORVs may be required to achieve depressurization of the RCS.

1 In addition, control cables associated with the three redundant atmospheric

[

relief valves are routed through fire area 2-001. An analysis of potential effects of a fire upon these cables has shown that the subject valve could i

l become inoperable in the closed position.

j Power and control cables associated 'with chargthg pump miniflow isolation valve MOV8106-A are also routed through fire area 2-001. An analysis of the potential effects of a fire upon these cables has shown that MOV8106-A could close and isolate the charging pump miniflow line.

Control cables for the Train A pressurizer power operated relief and I

blocking valves 02B31PCV0445A-A and 02B13MOV8000A-A, and the reactor head i

vent valves Q2813SV2213A-A and Q2B135V2214A-A are located in fire area j

2-001. The subject cables are associated with the control function from the hot shutdown panel Q2H21NBAFP2605G-A.

In addition, control cables which j

shift control from the main control board to the hot shutdown panel via the transfer relay cabinet Q2H22L002-A are in this area. A fire induced failure 1

i having multiple hot shorts could cause the reactor inventory to letdown via the PORV, and reactor head vent paths.

l y

1 The combustible materials associitted with the rooms in fire area 2-001 primarily consist of cable insulation, lube oil, plastic panel parts and charcoal filter media.

Based on the licensee's fire loading calculations, 1

it was determined that the maximum fire severity expected if a fire were to occur in any of the rooms in fire area 2-001 would be less than 30 minutes.

A detection system covers the majority of the area.

Exceptions to this l

coverage are rooms 2112, 2114, 2115, 2123, 2126, 2127, 2130, 2169, and 2196.

The western half of the piping penetration room on elevation 121 feet -

1 0 inches is the only part of fire area 2-001 covered by automatic suppres-t sion.

l 4

Portable extinguishers, smoke removal equipment, and water hose cabinets are located throughout the fire area for use by the fire brigade.

4 The licensee justifies this exemption on the tasis of the existing fire l

protection features and their alternative shutdown actions associated with l

fire area 2-001.

l 11.3 EVALUATION Instrument air isolation valves Q2P19HV3611 and N2P19HV3825-A are equipped with a handwheel to facilitate manual operation.

In the event the valve 1

fails closed an operator can manually open them.

This action will restore i

instrument air to the charging line isolation valves and the pressurizer l

PORVs.

Consequently action would not have to be taken on the pressurizer i

PORV backup air / nitrogen supply valve Q2B13HV2228-B.

1 i

)

i

e Enclosure 49 One of the. three main steam atmospheric relief valves and its related steam -

!)enerator are required to be operable to achieve steam release for cooldown.

}

"he atmospheric relief valves are provided with hand wheels such that the i

valves may be manually opened or c'osed without electrical controls or air i

supplies.

The operator would establish manual control of the atmospheric i

relief valves by closing the manual air control valves to isolate the air supply and by opening the manual air gent valve to bleed off air from the' diaphragm of the valve actuator.

Both the air control and air vent valves j

are located in the vicinity of their associated atmospheric relief valve and i

j would be accessible despite a fire in area 2-001.

j The capability to control

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steam generator pressure and reactor coolant system temperature with the use 1

of the manually controlled atmospheric relief valves was demonstrated during the Unit 2 natural circulation and ccoldown startup testing.

a fire in area 2-001 would not prevent the operation of at least oneConsequently, i

redundant atmospheric relief valve.

1 i

Valve Q2E21M0V8106-A is required to be maintained open to establish charging j

pump miniflow. In the event this valve fails closed, miniflow will be j

discontinued.

The charging pump can be run safely with miniflow isolated l

and with a minimum of 24 gpm of seal injection flow for a period of up to one hour.

the valve and re-establish miniflow.This will allow the operator time to take action to open i

r can be established.

In the interim, normal charging flow will reduce heating of the pump and allow additional time for a ma i

j action to open the miniflow valve.

Fire relayinduced failures (hot shorts) to the control cables for the transfer cabinet Q2H22L002-A could cause control for the and blocking valves and the reaction head vent valves, power operated relief to shift from their normal main control board alignment to the remote hot shutdown panel.

Sub' sequent fire induced failures (hot shorts for adjacent control cables in the shared raceway of the control cables for Q2831PCV0445A-A, power operated relief valve,) Q28135V2213A-A, and 28135V2214A-Ai valves could result in the valves being energized to open. The power relief i

blocking valve (MOV) could become electrically inoperative in the open position.

In the unlikely event of the multiple hot shots occurring, this condition can be mitigated by removing power from the transfer relay and manual operation (handle) of the effected relay, thereby shifting control to j

the main control board.

To remove power from the transfer relay open breaker 9 on de distribution panel 2C (Q2R41L001C-A), located in room 2312, i

fire area 2-004.

Then go to transfer relay cabinet TRC-1 i

j in Fire area 2-035 room 2347 and manually shift transfer (relays TR1Q2H22 i

i (Q28135V2213A-A), TR2 (Q28135V2214A-A). TR3, (Q2831PCV0445A-A) and TR5 I

{

(Q2831M0V8000A-A) placing control back to the main control board to allow i

the operator to mitigate the letdown.

By letter datei March 13, 1985, the licensee connitted to develop detailed procedures to regain control of the instrument air system, one of the three mainstream atmospheric relief valves, charging pump mintflow and the pressuriser P0RVs and block valves and have them fuily implemented by the

)

and of the Unit 2 fourth refueling outage.

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Enclosure 50

'The rooms in fire area 2-001 without detection -(2112 2114, 2115, 2123, 2126, 2127, 2130, 2169, and 2196) contain little or no, combustible material cad contain no safe shutdown cable or equipment.

The western half of the piping penetration room on elevation 121 feet - 0 inches is the only part of the fire area 2-001 covered by an automatic suppression system. This is the only part of the fire area 2-001 that has cables or equipment that are i

associated with redundant hot shutdown. systems.

One train of redundant cables are provided with fire barriers. consisting of two 1-inch. layers of knowool blanket with overall layer of Zetex cloth with this area.

All other shutdown systems associated' with fire area 2-001 have redundant" counterparts in other fire areas or are located in plant areas which meet the requirements of 10 CFR 50 Appendix R, Section III.G.2.

As a resuTt P

there is reasonable assurance that if a fire occurred in fire area 2-001 safe shutdown could be achieved and maintained.

11.4 CONCLUSION

Based on our evaluation, we conclude the licensee's alternative fire protec-tion and shutdown configuration will provide an acceptable level of fire i

protection to that required by the technical requirements of 10 CFR 50 Appendix R.Section III.G.2 and that no additional fire protection is required to satisfy the requirements of Section III.G.3.

licensee's request for exemption for the rooms associated with fire areaTherefore, the i

2-001 should be granted.

l 12.0 UNIT 2 AUXILIARY BUILDING, ELEVATION 100 FEET - 0 INCHES 121 FEET -

AND 184 FEET - 0 INCHES - FIRE AREA 2-004 (EXEMPTI 12.1 EXEMPTION REQUESTED The licensee in their exemption request 2-37 requested an exemption from the technical requirements of 10 CFR 50 Appendix R, Section III.G.2.

extent that it requires one train of redundant safe shutdown cable and to the equipment to be enclosed by a barrier having a 1-hour fire rating, the instal-installed throughout the fire area.lation of automatic fire suppression sys 12.2 DISCUSSION Fire area 2-004 consist of the following rooms:

Elevation 100 Feet. - 0 Inches Room 2151 Waste Gas Decay Tank Rooms Room 2152 Valve Compartment Room Room 2153 Waste Gas Compressor Room Room 2154 Weste Evaporator Steam Generator Room Room 2155 Passageway to Unit 1

i,'

o Enclosure 51 Room 2156 Holdup Tank Room Room 2157 Holdup Tank Room

. Room 2158 Holdup T'ar.k Room Room 2159 Recycle Evaporator Feed Pump Room 3

Room 2160 Hatch Area Room 2161 Corridor Room 2162 Hallway i

Room 2163 WDS Control Panel Room

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' Room.2164 Storage Room Room 2165 Waste Gas Decay Tank Room Room 2166 Waste Gas Decay Tank Room Room 2168 Chemical and Laundry Drain Tank Room Room 2170 Letdown Heat Exchanger Room 4-Room 2175 Hallway Room 2176 Secondary Spent Resin Storage Tank Room Room 2177 Pump Room Room 2178 Filter Room I

Room 2179 Valve Room / Combustible Storage Room 2180 Recycle Evaporator Steam Generator Room Room 2186 Boric Acid Area

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Room 2187 Hydro Test Pump Room j

Room 2188 Boric Acid Tank Area

)

Elevation 121 Feet - 0 Inches Room 2203 Waste Condenser Tanks and Pump Room Room 2204 Waste Evaporator Package Room Room 2205 Passage to Unit 1 j

Room 2206 Heat Exchanger Room i

Room 2207 Hatch Area Room 2208 Corridor i

Room 2209 Hallway Room 2215 Duct and Pipe Chase Room 2216 Valve Compartment Area Room 2217 Volume Control Tank Room Room 2218 Chiller Unit Room l

Room 2219 Pipe Chase Room 2220 Valve Compartment Room Room 2221 Primary Spent Resin Storage Tank Room Room 2222 Corridor Room 2230 Recycle Evaporator Pa'ckage Room i

Room 2231 Spent Resin Pump Room Room 2232 Spent Resin Filter Room 1

Room 2237 Corridor j

Room 2238 Cask Storage Area Room 2239 Transfer Canal j

Room 2240 Spent Fuel Pool Room Room 2253 Valve Compartment i

i b -.-. -- _. ---,- -- -,,. - - -

Enclosure 52 Elevation 130 Feet - 0 Inches Room 2601 Drumming Area Room 2602 Passageway Room 2603-Drum Storage Area Room 2604 Passage Room 2605 Blowdown ' Pumps and Sur,ge Tank Room Room 2606 Filter. Room Room 2607 Filter Room Room 2608 Blowdown Heat Exchanger Room Room 2609 Storage Room Room 2610 Valve Compartment Room Elevation 139 Feet - 0 Inches Room 2301 Seal Water Filter Room Room 2302 Recycle Evaporator Feed Filter Room Room 2303 Reactor Coolant Filter Room Room 2304 Waste Monitor Tank Filter Room Room 2305 Seal Injection Filter Room Room 2306 Recycle Evaporator Feed Demineralizer Room Room 2307 Valve Compartment Room Room 2308 Waste Condensate and Monitor Tank Demineralizer Room Room 2309 Hatch Area Room 2310 Valve Compartment Room Room 2311 Recycle Evaporator Concentrates Filter Room Room 2312 Corridor Room 2313 Floor Drain and Laundry Tank Filter Room Room 2314 Waste Evaporate Feed Filter Room Room 2315 Recycle Waste Condenser Filter Room Room 2316 Passage to Unit 1 Room 2321 Sample Panel Room Room 2322 Hallway Room 2323 Sample Room Room 2324 High Activity Radioactive Lab Room 2325 Counting Room Room 2326 Gas Analyzer Room Room 2327 Valve Access Area Room 2328 BTR Demineralizer Room Room 2329 Pipe Tunnel Room 2330 Chiller Surge Tank Pump Room Room 2331 Valve Access Area Room 2332 MCC.2A Area Room 2340 Demineralizer Compartment Room 2341 Pipe Chase Room 2342 Spend Fuel Pool Pump Room Room 2447 Cask Wash Storage Area / Combustible Storage Room 2348 Case Wash Area

Enclosure 53 Elevation 155 Feet - 0 Inches Room -2402 Passage to Uqit 1 Room 2403 New Resi.n Storage Room 2404 Filter Hatches Room / Combustible Storage Room 2405 Hatch Room l

~

Room 2408 Hallway Room 2409 Hallway Room 2410A 600-VLoadCenter(StationServiceTransformerRoom)

Room 2410B Clean Storage Rcom Room 2418 Auxiliary Building and Containment Purge Vent Equipment Room Room 2419 Demineralizer Hatch Area Room 2422 Corridor Room 2423 Valve Compartment Room 2424 Demineralizer Compartment Room 2425 Demineralizer Compartment Room 2426 Demineralizer Compartment Room 2427 Demineralizer Compartment Room 2429 Containment Purge Air Equipment Room Room 2445 Spent Fuel Pool Heat Exchanger Room Room 2446 Hallway Room 2448 SFPC Pump Room Room 2449 Demineralizer Roon Room 2450 Valve Compartment Room 2451 Filter Room Room 2467 SFP Heat Exchanger Room Room 2478 Motor Control Center Room Elevation 148 Feet - 0 Inches Room 2504 Stair No. 6 Room 2505 Spent Fuel Pool Vent Equipment Room Room 2506 Component Cooling Water Surge Tank Room All of the fire area boundary walls are rated as a three-hour fire barrier with all electrical and piping penetrations sealed for a three-hour rating.

Self-expanding cork is installed in portions of the area boundary along the containment wall.

A steel bolted access plate is installed in the duct chase room 2215 (area 2-004) and room 2317 (area 2-034) on elevation 139'-0".

All doors that are part of the fire area boundary are UL Class-A doors except for Class-B doors to stdirwells used for access and egress and for doors in the fire area boundary leading to the outside which are not j

rated.

The floors and ceilings of fire area 2-004 which bound other fire ereas are rated for three-hour.

All internal floors of fire area 2-004 are reinforced concrete, and exposed structural steel has been protected by fire proofing.

To ensure that the as-built configuration is maintained, those sealed penetrations for which credit has been taken will be placed in the licensee's fire barrier surveillance program.

l 0

Enclosure 54 Fire area 2-004 contains redundant safety-related MCCs (2A). Q2R17B001A-A, (2B)- Q2R17B0018-B,' (2CC) Q2R179098-A and (2DD) Q2R17B099-B which power for various Train-A and Train-B safe shutdown components.

Power supply cabling and subject motor control centers are not protected by fire, barriers, full 4

coverage automatic suppression is not provided.

j In addition, this fire area contains redundant safety related DC distribu.

tion panels (2C) Q2R41L001C-A and (2F) QR41 LOO 1F-B.

Train-A and Train-B cabling for redundant condensate water storage tank level indication Q2P11LT515-A and Q2P11LT516-B are routed through this fire area.

The cabling for the subject safe-shutdown components are not 4

protected by fire barriers and full area automatic suppression coverage.

4 i

Fire area 2-004 contains redundant instrument air system de power and control cabling).,which serve N2P195V 3825-A (instrument penetration room isolation valve Q2P195V3611-A (instrument air containment isolation valve) i Train-A and Q2B135V2228-B (power relief valve backup air supply) Train-B.

The de power and control cabling for the subject safe shutdown components are not protected by barriers, and full coverage automatic suppression is not provided.

i 1

i Redundant pump (AFW) power and t.ontrol cables of both motor driven auxiliary feedwater j

room coolers, associated feedwater valves, the turbine driven AFW pump, associated steam admission valves and associated feedwater valves are routed through this area.

The subject power and control cabling is not protected by fire barriers, and full coverage automatic fixed suppression is not provided.

I I~n addition Fire Area 2-004 contains redundant power and control cabling of battery charging room coolers Q2E16M006A-A and Q2E16M006B-B (Trains-A and -B, i

respectively), and battery room exhaust fans and. exhaust dampers QH47C012A-A, Q2V47C0128-B, Q2V47MOV3644-A, and Q2V47MOV3643-B (Trains-A and -B, respec-l tively). The subject power and control cabling is not protected by barriers, and full coverage automatic fixed suppression is not provided.

i DC distribution panel (2C) Q2R41L001C-A which supplies solenoid power for i

atmospheric relief valves Q2N11PV3371A, Q2N11PV33718, and Q2N11PV3371C are located in fire crea 2-004.

Subject de distribution panel is not protected by barriers, f

Fire area 2-004 also contains redundant power and control cabling, MCCs Q2R178098A, Q2R17B0998, and terminal boxes A2TB025, 82TB025, and service water valves Q2P16V539-A Q2P16V546-A, Q2P16V538 8, and Q2P16V545-B Trains-A and -B, respectively. The subject cabling and equipment is not protected by barriers, and automatic fixed suppression is not provided.

I l

l

o Enclosure

• 55 Redundant instrumentation. cabling and equipment Q2C55fM0048-A of neutron flux monitoring Q2C55NE0048A-A (post accident neutron flux monitor),

N2C55NE0031-P1, and N2C55NE0032-P2, (source range neutron flux monitors) are located in the subject ' fire area.

The subject instrumentation cabling and

.* equfpment is not, protected by' barriers, and automatic fixed suppression is not prov,ided.

Flow from the charging pumps is required for reactor coolant boration and makeup, reactor coolant system depressurization, and reactor coolant pump seal integrity. The following independent conditions concern cables related to'the charging pumps, charging pump room coolers and charging system valves:

Fire area 2-004 contains redundant charging pump Trains-A and -B power o

cables. One tr'ain of redundant power cables is not provided with a fire-rated barrier for its entire route in the fire area nor is full suppression coverage provided for both redundant trains throughout their entire routes in the fire area.

Fire area 2-004 contains the Train-B charging pump room cooler, Q2E16M001C-B, power cables which are required for continued operation of the Train-B charging pump Q2E21M001C-B.

The Train-B charging pump room cooler power cable, redundant power and control cabling, and power disconnect switches, Q2R18A001A-A and Q2R18A001B-B, required for operation of the swing charging pump Q2E21M0018-AB, from Train-A power are located in close proximity on elevation 100 feet - 0 inches of fire area 2-004.

Fire barriers have not been provided to protect the Train-B charging pump room cooler power cable or the redundant power and control cabling and power disconnect switches required for Train-A operation of the swing charging pump.

In addition, a portion of the Train-B charging pump room cooler power cable is routed on elevation 121 feet - 0 inches above the power and control cabling and disconnect switches required for Train-A operation of the swing charging pump. An unsealed penetration exists in the floor slab of elevation 121 feet -

0 inches, which separates the charging pump room cooler power cable on elevation 121 feet - 0 inches from the redundant power cabling and power disconnect switches. required for Train-A operation of the swing charging pump located on elevation 100 feet - 0 inches.

During normal plant operation and during the early stages of shutdown the charging pumps take suction from the volume control tank (VCT).

The capacity of the VCT is such that the letdown line must be open in order to replenish the tank as long as the charging pumps are taking suction from it. During the shutdown process the charging pump suction is switched from the VCT to the refueling water storage tank (RWST).

Fire area 2-004 contains power and control cables for the redundant RWST to charging (pump suction valves (LCV1158 and LCV1150),' VCTL isolation valves cables.

.The subject power and control cables and valves are not protected by fire barriers and full automatic fire suppression is not provided.

1 Enclosure 56 i

r Fire area 2-004 also contains redundant Trains-A and -B charging pump i

room coolers power and control cables.

One train of redundant power and control cabi'es is not provided a fire-rated barrier for its entire route in the fire area, nor is full suppression coverage.provided for both redundant trains throughout the entire route in the fire area.

)

' The combustible materials associated with the rooms in fire area 2-004 l

primarily consists of cable insulation,' lube ' oil, pipe insulation and plastic panel parts.

Based on the licensee's fire loading calculations, it was determined that the maximum fire severity expected if a fire were to occur in any of the rooms in fire area 2e004 would be less than one hour.

i L

Smoke detection systems are installed in all rooms containing safe-shutdown equipment (except room 2341) or applicable combustible material. -Automatic,

j suppression is provided in the following rooms 2160, 2161, 2162, 2163, 2175, 2179, 2205 (partial), 2207, 2208, 2209, 2312 (partial), 2316, 2322, 2402, i

2403, 2404, and 2447.

Heat collectors will be installed on all sidewall mounted sprinkler / spray nozzles in room 2161 to increase their responsive-ness to a fire condition.

The 5-kV disconnect switches in room 2161 have I

an automatic heat-actuated carbon dioxide suppression system. Hose stations are installed throughout the fire area and are spaced in accordance with requirements of NFPA 14. Portable carbon dioxide extinguishers and portable j

smoke removal equipment are provided on each elevation.

i Room 2341 (pipe tunnel) has one train of safe-shutdown control and instru-nientation cabling which passes through it and smoke detection is not l

• provided, f

The licensee justifies this exemption on the basis of the existing fire l

protection features, their proposed fire protection modifications and their

}

alternative shutdown actions associated with the rooms bounded by fire area j

2-004.

i 12.3 EVALUATION.

An analysis was performed by the licensee to demonstrate that a fire would be limited to one MCC and/or its associated power feed and would not effect i

the redundant KCC and/or its associated power feed.

Therefore, based on l

our evaluation of the licensee's analysis, only one train of redundant l

electrical distribution could be lost due to a credible fire in area 2-004.

i MCC 2A is located in room 2332 elevation 139 feet - 0 inches having its i

power feed continue through room 2312 thence up to elevation 155 feet -

{

0 inches.

MCC 28 is located in room 2209 elevation 121 feet - 0 inches

' having its power feed exit this room into an adjacent fire area.

The j

redundant MCCs are separated by a 2-feet thick reinforced concrete floor I

at elevation 139 feet - 0 inches.

Unsealed penetrations located in the subject floor have been reviewed and will not effect the separation afforded by the concrete floor.

The minimum horizontal separation between redundant t

components is approximately 66 feet between MCC 2B (elevation 121 feet - 0 inches)

I i

~. - - -..,. - - - -.

- - - -, _. - - - - _ -. - =

Enclosure -

57 and MCC 2A power feed (elevation 155 feet - 0 inches).

This 66 feet of horizontal separation has complete automatic suppression coverage on eleva-tion 121 feet - 0 inches.

A smoke detection system is installed in all rooms containing the. subject equipment and cables. The detection system would provide early warning of a fire, allowing the fire brigade adequate time to respond.

Manual hose stations, portable carbon dioxide extinguishers, and portable smoke removal equipment are available for use on the subject elevations.

In addition, our evaluation of de power distribution panels 2C and 2F demonstrate that a fire would be limited to one de distribbtion panel and/or its associated power feed and would not effect the redundant de distribution panel and/or its associated power feed.

Therefor *e, only one train of redundant de distribution panels could be lost.

Dc distribution panel 2C is located in room 2312 elevation 139 feet -

0 inches and de distribution panel 2F is located in room 2209 elevation 121 feet - 0 inches.

The redundant de distribution panels are separated by a 2-feet-thick reinforced concrete floor at elevation 139 feet -

0 inches.

Unsealed penetrations located in the subject floor have been reviewed and will not effect the separation afforded by the concrete floor.

The minimum horizontal separation between these redundant panels is approximately 55 feet and has complete automatic suppression coverage on elevation 121 feet - 0 inches.

' A smoke detection system is installed in all rooms containing the subject equipment.

The detection system would provide early warning of a fire, allowing the fire brigade adequate time to respond.

Manual hose stations, portable carbon dioxide extinguishers, and portable smoke removal equipment are available for use on the subject elevations.

Loss of de distribution panel 2C would render the main steam atmospheric relief valves electrically inoperable.

One of the three main steam atmospheric relief valves and related steam generator is required to be operable to achieve steam release for cooldown.

The atmospheric relief valves are provided with hand wheels such that the valves may be manually opened or closed without electrical controls or air supplies. The operator would establish manual control of the atmospheric relief valves by closing the manual air vent valve to bleed off air from the diaphragm of the valve actuator.

Both the air control and air vent valves are located.in the vicinity of their associated atmospheric relief valve and would be acces sible despite a fire in area 2-004.

The capability to control steam generator pressure and reactor coolant system temperature with the use of the manually controlled atmospheric relief valves was demonstrated during the Unit 2 natural circulation and cooldown startup testing. Consequently, a fire in area 2-004 would not prevent the operation of at least one redundant atmospheric relief valve.

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Enclosure 58 Condensate water storage tank level indication Train-A ' cabling is located in rooms 2402, 241C A, 2409, 2405, 2419, and 2478, on elevation 155 feet -

0 inches.. Train-B cabling is located in rooms 2209, 2208, 2222, 2230, and -

2231, elevation 121 feet - 0 inches, and rooms 2605, 2609, and 2608, eleva-tion 130 feet - 0 inches.

The redundant cables are separated by two, 2-feet-thick reinforced concrete floors at elevation 139 feet - 0 inche's and 155 feet - 0 inches.

Unsealed penetrations located in the subject floors have been reviewed and will not affect the separation afforded by the concrete floor.

The Train-B cabling at elevation 121 feet - 0 inches.

is provided with automatic find suppression over 95 percent of its route.

A smoke detection system is installed in all rooms containing condensate water storage tank level indication cabling.

The detection system would provide early warning of a fire, allowing the fire brigade adequate time to respond.

Manual hose stations, portable carbon dioxide extinguishers, and portable smoke removal equipment are available for use on the subject elevations.

In addition, Train-A instrument air cabling is located in rooms 2168, 2163 and 2162 elevation 100 feet - 0 inches, and room 2321, elevation 139 feet -

0 inches.

Train-B cabling is located in rooms 2209, 2208, and 2218, elevation 121 feet - 0 inches.

The redundant cables are separated by two 2-feet-thick reinforced concrete floors. at elevation 121 feet - 0 inches and 139 feet - 0 inches.

Unsealed penetration in the subject floors have been reviewed and will not effect the separation afforded by the concrete a floors.

The Train-A cables have full suppression coverage on elevation 100 feet - 0 inches, and Train-B cables full suppression coverage on eleva-tion 121 feet - 0 inches.

Based on our evaluation, it appears that a fire would be limited to one train of redundant PORV instrument air header isolation valve cabling.

A smoke detection system is installed in all rooms containing the instrument air cabling.

The detection system would provide early warning of a fire, allowing the fire brigade adequate time to respond.

Manual hose stations, portable carbon dioxide extirguishers and portable smoke removal equipment are available for use on the subject elevations.

Fire induced failures in control and power cabling could potentially result in the loss of redundant motor driven auxiliary feedwater pump room coolers and feedwater regulation valves.

This would limit the ability to provide auxiliary feedwater to a steam generator for cooldown to the turbine driven auxiliary feedwater pump.

In addition this same fire would cause the loss of the normal ac supply to the turbine driven auxiliary feed water uninter-ruptible power supply (UPS) Q2N23L001-AB.

l l

1

Enclosure 59 Upon lo,ss of the normal ac supply, the UPS will then be supplied from battery power.

The subject battery has a two-hour capacity and upon deple-tion manual control must be taken, to continue cooldown.

The following is a listing of those components that will require manual operation:

EQUIPMENT FUNCTION Q2N12HV3235A Steam to TDAFW'from S/G IB Q2N12HV3235B Steam to TDAFW from S/G IC Q2N12HV3226 TDAFW Steam Admission Q2N23HV3228A Feedwater to S/G 1A Q2N23HV3228B Feedwater to S/G 1B Q2N23HV3228C Feedwater to S/G IC The two hours provided by battery power is adequate for existing procedures for manual operation to be implemented.

Plant procedures will be revised to include the above action for a fire in area 2-004.

Fire induced failures in control and power cables could potentially result in the loss of ventilation in both the redundant Trains-A and -B battery and battery charger rooms.

A failure of the ventilation systems will not result in failure of the redundant Train-A or-B 125 V-dc battery systems.

Therefore, the potential fire induced failure of the power and control cable for the redundant battery and battery charger room ventilation fans and dampers will not result in the loss of systems necessary to achieve and maintain hot shutdown conditions. The safe shutdown requirement for battery and battery charger room ventilation is a long term requirement.

If venti-lation is lost due to a fire in area 2-004, either portable ventilation,

equipment will be installed in the effected room or the damaged ventila-tion system will be repaired within 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> of post-fire hot shutdown initiation to insure that battery room hydrogen concentration do not exceed acceptable limits.

An exposure fire in area 2-004 could cause a loss of Train-A service water flow.

The effects of the fire upon the control cable for valve Q2P16V546-A could close and cause the loss of Train-A service water flow.

Train-B service water is available.

In addition the effects of a fire upon the power and control cables for valves Q2P10V539-A, Q2P16V538-B, and Q2P16V545-B could cause them to become electrically inoperative.

A long

' term requirement (greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) is to shift the service water discharge from the river and recirc. to the service water pond.

Manual operation of the subject valves is required to perform the line up of service water to pond recirc.

In addition, aligning Train-A to recirc. to pond by manual operation, service water Train-A will be restored to service.

Plant procedures will be revised to include the above actions for a fire in area 2-004.

Instrumentation cables for the source range neutron flux monitors N2C55NE0031-P1 and N2C55NE0032-P2 traverse fire area 2-004 through conduit l

embedded in the floor slab at elevation 155 feet - 0 inches, and are acces-sible through embedded pullboxes on this elevation.

The instrumentation I

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g 4

Enclosure 60 cables for the neutron flux monitor Q2C55NE0048A-A are routed through fire area 2' 004 on elevation 100 feet. - 0 inches,121 feet - 0 inches, and 139 feet - 0 inches.

The amplifier Q2C55NM0048-A for neutron flux monitor is located on elevation 139 feet - 0 inches.

The redundant cables are separated by a 2-feet-thiqk reinforced concrete floor at elevation 155 feet

.- 0 inches.

Uniealed penetrations in the subject. floor slab have been reviewed and will not effect the separation afforded by the concrete floor

therefore, a credible frife in area 2-004 would not cause the loss of redundant neutron flux monitoring.

Train-A' charging pump power cabling is located in rooms 2161, 2162, 2163, and 2168. Train-B cabling is located in rooms 2175, 2160, 2159, 2158, 2157, 2156, 2155, 2154, 2153, 2152, 2165, and 2166.

The redundant power cables are provided with a fire-rated barrier in the following rooms of fire area 2-004:

Train-A'in rooms 2161, 2162, 2163, and 2168, Train B in rooms 2175, 2160, and 2159.

Full fixed suppression coverage is provided in rooms 2163, 2162, 2161, 2160, and 2175.

Heat collectors will be installed on all sidewall sprinkler heads in room 2161 to increase their responsiveness to a fire condition.

In addition, the redundant power cables are separated at a minimum with a 2-feet-thick reinforced concrete wall bounding rooms 2159, 2158, 2157, 2156, 2155, 2154, 2153, 2152, 2151, 2165, and 2166, with the exception of room 2155 where there is approximately 24 feet of separation with no intervening combustibles.

Unsealed penetrations in the subject walls have been reviewed and the walls are considered.to afford adequate

~

separation.

Therefore, based on our evaluation which was perfnrmed based on a one hour fire rated barrier being installed for Train-A power cable raceway ADDIC

. ADD 18A and ADD 21 A throughout fire area 2-004, it would appear that a fire would be limited to one train of redundant charging pump power cabling.

A smoke detection system is installeil in all rooms containing the charging pump power cabling.

The detection system would provide early warning of a fire, allowing the fire brigade adequate time to respond.

Manual hose stations, portable carbon dioxide extinguishers, and portable smoke removal equipment are available for use on this elevation.

Raceways BFD028. BFD03B, and BFD06B carry the Train-B charging pump room cooler power cable through the portions of fire area 2-004 on elevation 100 feet - 0 inches where this cable is in close proximity to redundant Train-A cables has been wrapped with two 1-inch layers of Kaowool and an overall layer of Zetex fabric.

An automatic fire suppression system presently covers the area.

In addition, the blockout located 11 feet -

0 inches east of Col,M. 2 feet - 4 inches south of Col. 20 which communi-cates between elevation 100 feet - 0 inches and 121 feet - 0 inches will be sealed.

Based on the implementation of this modification one train of the redundant charging pump room cooler power and control cables are protected by a fire rated barrier and has a 40-feet horizontal separation from the opposite train cables.

Automatic suppression and smoke detection systems provide coverage for the subject Train-B power and control cables and the intervening 40 feet of separation on elevation 100 feet - 0 inches.

l

Enclosure 61 Elevation 121 feet - 0 inches contains the same redundant cables.which have a minimum horizontal separation of 40 feet.

The Train-B power and control l

cables are provided automatic suppression and detection coverage for the entire route on this elevation.

I In addition, redundant Trains-A and -B charging pump room cooler power and control cables are separated by a 2-feet-thick re'inforced~ concrete slab floor at elevation 121 feet - 0 inches.

Unsealed penetrations in the floor slab at elevation 121 feet-0 inches have been reviewed and are considered not to effect the separation afforded.by the floor.

In conclusion a credible fire in fire area 2-004 could not effect both trains of redu;ndant charging pump room cooler power and control cables.

In order to ensure that the RWST is available for RCS makeup, 6ne raceway associated with the required RWST function will be provided with a fire barrier of a rating greater than the maximum fire severity of less than 30 minutes in the Boric Acid Area (RM 2186).

This should to ensure that a source of borated makeup water is available from the RWST and will not require any manual operator action.

In the boric acid area (RM 2186) automatic fire suppression is not provided.

However, the raceway fire barrier and the area fire detection system in conjunction with fire brigade's fir'efighting capabilities provide an adequate level of fire protection boric acid area.

Those raceways to the protected are BFD2GD, BF021B, BHF457 and BHF42.

The licensee's analysis of the potential effects of a fire in fire area '

2-004 on the power and control cables for VCT isolation valves LCV115C and LCV115E, and in the power and control cables for RWST to charging pump 4

suction isolation valves LCV115B and LCV115D has shown that the valve will fail in their pre-fire positions and became electrically inoperable.

The normal operating (pre-fire) position of valves LCV115C and LCV115E is open, i

and the normal operating (pre-fire) position of valves (LCV115B and LCV115D) is closed.- The cabling for LCV115D has been protected by the fire barrier i

instalied in the proposed modification above and will not fail in the closed position.

In addition, in fire area 2-004 fire induced failures (hot shorts) to the control cables for the transfer relay cabinet Q2H22 LOO 2-A could cause control for the reactor head vent valves to shift from their normal main control board alig(nment to the remote hot shutdown panel.

Subsequent fire induced failures hot shorts from adjacent control cables in the shared raceway) of the control cables for Q2813SV2213A-A and Q2B135V2214A-A reactor head vent valves would result in the valves being energized to open.

In the unlikely event of the multiple hot shorts occurring, this condition can be mitigated by removing power from the transfer relays and manual operation (handle) of the effected relay thereby shifting control to the main control board.

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g Enclosure 62 s

To remove power from the transfer relay open breaker 9 on de distribution panel 2C (Q2R41L001C-A) located in room 2312 fire area 2-004. Then go to transfer relay cabinet TRC-1 (Q2H22 LOO 2-A) in fire area 2-035 room 2347 and manually shift transfer relays TR1 (Q2B13SV2213A-A), TR2 (Q2B13SV2214A-A), TR3 (Q2831PCV0445A-A), and TR5 (Q2831MOV8000A-A) placing control back to the main control board to allow the operator to mitigate the letdown.

If it is found that the sampling line isolation valves have not had spurious action as described below then power isolation for the transfer relay may be accomplished by opening breaker 0 on de distribution panel 2C (Q2R41L001C-A) fire area 2-004. room 2132 An analysis of the effects of fire upon subject redundant RCS and pressuri-zer sampling line isolation valves shows that it would take multiple hot shorts to energize the solenoid to open all the valves.

In the unlikely event of the multiple hot shorts (induced from adjacent control cables in the shared raceway) occurring, the condition can be mitigated for the Train-A powered valves Q2P15HV3765-A and Q2P15HV3103-A by removing power from all cables in the shared raceway. This can be accomplished by opening the supply breaker on the 125 V-dc switchgear 2A (Q2R428001A-A) in fire area 2-018 room 2224 for 125 V-dc distribution panel 2C (Q2R41L001C-A).

By letter dated March 13, 1985, the licensee committed to develop detailed procedures specifically for this fire area covering the manual operator actions required to regain control of the transfer relays associated with the PORVs and the reactor head vent valves, restoration of the battery room ventilation system, manual control of the TDAFW pump, manual control of one main steam atmospheric relief valve, manual service water valve line up to the service water pond, and the isolation or RCS and pressurizer sampling line isolation valves.

These procedures will be implemented by the end of the Unit 2 fourth refueling outag6.

In addition, the licensee has also committed to install heat collectors on the sidewall mounted sprinkler / spray nozzles in room 2161 seal a floor slab blockout on elevation 121 feet -

f 0 inches and install a raceway fire barrier in the boric acid room 2186 by the end of the Unit 2 refueling cutage.

Room 2341 (pipe chase) contains safe-shutdown cabling.

All cabling in this pipe chase including the subject safe shutdown cabling is enclosed in conduit.

The pipe chase is considered to have no in situ combustible. The pipe chase exits the auxiliary building at elevation 139 feet - 0 inches which is below grade.

This transition from room 2608 to room 2341 has a concrete wall with all penetration considered watertight.

As there is no redundant safe-shutdown cabling in room 2341.

Due to the low in situ combustible loading and the very low probability of a transient combustible being introduced, the installation of a smoke detection system is not required.

Enclosure 63 All other shutdown systems associated with fire area 2-004.have redundant counterparts in other fire areas or are located in plant areas which meet the requirements of 10 CFR 50 Appendix R, Section III.G.2.

As a result, upon completion of the licensee's fire protection modifications there is reasonable assurance if a fire were to occur in any of the rooms identified in Section 12.2 safe shutdown could be achieved and maintained.

12.4 CONCLUSION

Based on our evaluation, we conclude that the licensee's alternative fire protection and shutdown configuration, in conjunction with their proposed fire protection modifications, will provide an acceptable level of fire protection to thatalbequir'ed' by the technical requirements of 10 CFR 50 Appendix R, Section III.G.2 and that no additional fire protection is required to satisfy the requirements of Section III.G.3.

Therefore, the licensee's request for exemption for the Unit 2 auxiliary building elevation 100 feet 0 inches,121 feet - 0 inches,130 feet - 0 inches,139 feet -

0 inches,155 feet - 0 inches,175 feet - 0 inches, and 184 feet - 0 inches (fire area 2-004) should be granted.

13.0 FIRE AREAS IN UNIT 1, UNIT 2, AND FIRE AREAS SHARED BY UNITS 1 AND 2 - FIRE PROOFING OF STRUCTURAL SUPPORTING STEEL (EXEMPTION REQUEST 2-38) 13.1 EXEMPTION REQUESTED The licensee in their exemption request 2-38. requested an exemption from

.t the technical requirements of 10 CFR 50 Appendix R, Section III.G.2 to the extent that it requires the structu~ral steel supporting raceway fire barrier assembl'ies to be protected by a fireproofing material having a fire rating of one' hour.

13.2 DISCUSSION The following raceway have been protected by a fire barrier enclosure having a one-hour fire rating:

RACEWAY NO.

ROOM FIRE AREA AEN007 0072A 72A AEN008 0072A 72A AHP193 0072A 72A AHS126 0072A 72A AHS127 0072A 72A AHT033 0072A 72A BON 129 0072A 72A BON 132 0072A 72A BHP 093 0072A 72A BHP 094 0072A 72A BHQ108 0072A 72A l

BHR42C 0072A 72A 1

l

Enclosure 64 BHR45C 0072A 72A BHR48C 0072A 72A BHRC42 0072A 72A BHRC43 0072A 72A BHRC48 0072A 72A BHS063 0072A 72A BHS268 0972 72A BHT 061 0072A 72A BHT 130 0072A 72A CDN002 0072A 728 BON 198 00728 1-001 AEF-4B 0223 AEF016 0223 1-001 21E044 0462 1-004 21E045 0462 1-004 21E047 0462 1-004 21E048 0462 1-004 31E017 0462 1-004 31E018 0462 1-004 31E020 0462 1-004 31E021 0462 1-004 41E016 0462 1-004 41E017 0462 1-004 41E019 0462 1-004 41E020 0462 1-004 ADDA09 0161 1-004 ADDA15 0162 1-004 ADDA15 0161 1-004 ADDA18 0163 1-004 ADDA18 0162 1-004 ADDA21 0168 ADDA21 0163 1-004 1-004 BDE-09 0175 1-004 BDE-09 0160 1-004 BDE-0A 0175 1-004 BDE-12 0160 1-004 BDE-15 0160 1-004 BFD803-0160 1-004 BFD803 0175 1-004 BFD806 0175 1-004 BFD812 0175 1-004 BFD815 0175 1-004 BFD821 0175 1-004 BFD821 0180 1-004 BFD821 0186 1-004 BFD82G 0186 1-004 BHF-21 0160 1-004 BHF-24 0160 1-004 BHF-24 0175 1-004 BHF-27 0175 1-004

Enclosure 65 BHF-33 0175 1-004 BHF-36 0175 1-004 BHF-41 0175 1-004 BHF-42 0175 1-004 BHF-42 0180 1-004 BHF-42 0186 1-004 BHF025 0186 1-004 BHFA03 0160 1-004 AEF028 0172 1-005 AFD-30 0172 1-005 AHDB12 0182 1-005 AHDB12 0172 1-005 AHF031 0172 1-005 AHFA15 0172 1-005 BFDB2G 0172 1-005 AHE-03 0190 1-006 AHE-06 0190 1-006

~

BDDA03 0190 1-006 BDDA06 0190 1-006 BDDA06 0189 1-006.

BDDA09 0189 1-006 BDDA09 0185 1-006 BDDA0A 0190 1-006 I

BODA12 0185 1-006 BDDA1A 0185 1-006 BDDA1B 0185 1-006 BEE 016 0194 1-006 BFDDOM 0194 1-006 BHD100 0185 1-006 BHDE06 0185 1-006 BHDE09 0185 1-006 BHE-12 0185 1-006 BHE010 0185 1-006 BHE011 0185 1-006 BHF032 0185 1-006 CDD003 0185 1-0 06 CDD004 0185 1-006 BHD-12 0117 1-009 BHMZ09 0117 1-009 21E044 0500 1-013 21E044 0466 1-013 21E044 0300 1-013 AEM085 0300 1-013 AEM085 0227 1-013 AHE139 0227 1-013 AHE133 0300 1-013 AHJ029 0227 1-013 AHJ029 0300 1-013 AID 175 0227 1-013

s.,

Enclosure 66 I

s AHD102 0244 1-020 AHD102 0210 1-020 4

AHD102 0245 1-020 AHE072 0210 1-020 AHE133 0211 020 AHJ029 0211 1-020 21E044 0319 1-042 31E021 0319 1-042 41E020 0319 1-042 BEE-0A 0319 1-042 BEE 010 0319 1-042 BHD-51 0319 1-042 BHD-63 0319 1-042

~

BHF-C33 0319 1-042 BH8Z27 0319 1-042 BHH-60 0319 1-042-BHH161 0319 1-042 BHJX63 0319 1-042 BHJX64 0319 1-042 BHJZ33 0319 1-042 BHLZ45 0319 1-042 B1J-33 0319 1-042 21E044 0455 1-043 21E044 0444 1-043 31E021 0455 1-043 31E021 0444 1-043 41E020 0455 1-043 41E020 0444 1-043 AHD130 1-502 1-S02 AHE071 1-502 1-S02 BHJ511 1-S02 1-S02 BHJV18 1-S02 1-S02 BHJW12 1-S02 1-S02 BHKZ18 1-S02 1-502 ADN390 0072A 72A ADN391 0072A 72A AEN251 0072A 72A AEN252 0072A 72A AEP310 0072A 72A AEP320 0072A 72A AHP193 0072A 72A AHP443 0072A 72A AHP850 0072A 72A AHS376 0072A 72A AHS419 0072A 72A AHS421 0072A 72A AHT033 0072A 72A AHZ281 0072A 72A BDN379 0072A 72A BHQ108 0072A 72A

. i.

Enclosure 67 BHR42C 0072A 72A BHR45C OG72A 72A BHR48C 0072A 72A BHRC42 0072A 72A BHRC45 0072A 72A BHRC48 0072A 72A BHS063 0072A 72A BHS268 0072A 72A BHS358 0072A 72A CDN252 0072A 72A

~

BHJ251

'2223 2-001

]

BHM03S 2223 2-001 1

BHM06S 2223 2-001 BH 9S 2223 2-001 AD@D18A 2163 2-004

)

1 ADD 18A 2162 2-004' ADDIC-2161 2-004 j

ADD 1C-2162 2-004 ADD 21A 2168 2-004 ADD 21A 2163 2-004 AED454 2209 2-004 AED454 2316 2-004 AED454 2312 2-004 AEM302 2312 2-004 AEM302 2322 2-004 AEM302 2209 2-004 AFD0AE 2175 2-004 AFD12G 2175 2-004 AFD36-2175 2-004 AFD3B-2175 2-004 AHD18B 2175 2-004 AHD360 2175 2-004 AHF21A 2175 2-004 AID 21B 2175 2-004 BDE06-2175 2-004 BDE09-2175 2-004 BDE09-2160 2-004 BDE12-2160 2-004 BDE15-2159 2-004 BDE15-2160 2-004 BFD02B 2160 2-004 BFD03B 2160 2-004 BFD038 2175 2-004

~

BFD06B 2175 2-004 BFD128 2175 2-004 BFD218 2186 2-004 BFD2GB 2186 2-004 BHF03A 2160 2-004 BHF21-2160 2-004 l'

. s.

Enclosure

'68 BHF21-2159 2-004 BHF24-2175 2-004 BHF24-2160 2- 0 04 BHF27-2175 2-004 BHF33-2175 2-004 BHF42 2186 2-004 BHF457 2186 2-004 AHD12B 2182 2-005 AHD12B 2172 2-005 AHF15A 2182 2-005 AHF15A 2172 2-005 AID 12B 2172 2-005 A10158 2172 2-005 Ald258 2172 2-005 CDD255 2172 2-005 ADD 12-2185 2-006 Add 1A-2185 2-006 j

ADDIB-2185 2-006 AHD365 2185 2-006 BDD03A 2190 2-006 BDD06A 2189 2-006 BDD06A 2190 2-006 BDD09A 2185 2-006 BDD0AA 2190 2-006 BDD12A 2185 2-006 BDDIAA 2185 2-006 BDDIBA 2185' 2-006 BF003D 2190 2-006 BFD06D 2189 2-006 BFD06D 2190 2-006 BFD09D 2185 2-006 4

BFDOLJ 2185 2-006 BFDOMJ 2185

'2-006 BFDOSJ 2185 2-006 BFD12D 2185 2-006 i

BHD03C 2190 2-006 BHD06E 2185 2-006 BHD09E 2185 2-006 BHD15C 2185 2-006 BHD314 2185 2-006 BHD349 2185 2-006 i

BHD35D 2185 2-006 BHE12-2185 2-006 BHE260 2185 2-006 BHE261 2185 2-006 CDD253 2185 2-006 CDD254 2185 2-006 BHM09Z 2338 2-009 i

~

. i o i

Enclosure 69 1

21E294 2300 2-013 21E294 2466 2-013 21E294 2500 2-013 AHM291 2201 2-014 AHE322 2210 2-020 AHF463 2245 2-020 AHF485 2210 2-020 4

AHF486 2210 2-020 AHF487 2210 2-020 AID 305 2211 2-020 AID 305 2244 2-020 AID 305 2210 2-020 21E294 2319 2-042 3EE251 2319 2-042 31E271 2319 2-042 4EE251 2319 2-042 41E270 2319 2-042 BEE 0A-2319 2-042 BHD57-2319 2-042

• 2-042 BHF33C 2319 BHF443 2319 2-042 BHG27Z 2319 2-042 BHH60 2319 T-042 BHJ33Z 2319 2-042 B1003D 2319 2-042 B1J33-2319 2-042 21E294 2452 2-043 21E294 2462 2-043 21E295 2462 2-043 21E296 2462 2-043 31E268 2462 2-043 31E269 2462 2-043 31E270 2462 2-043 31E271 2452 2-043 31E271 2462 2-043 2462 2-043 41E266 41E270 2462 2-043 41E270 2452 2-043 AHE321 t2-S02 2-502 BHJ12W 2-502 2-S02 BHJ18V 2-502 2-S02 BHJ21V

'2-S02 2-502 BHK18Z 12-502 2-S02 BHK21Z 2-502 2-S02 The strutt; ural steel members which support the above protected raceway have not been protected by a fireproofing material with a one hour fire rating.

I

):

e,.

Enclosure 70 13.3 EVALUATION All safety-related tray and conduit supports which support raceways that are protected by a fire barrier have been evaluated by the licensee to determine the effects of a one hour ASTM E-119 exposure fire on the subject supports.

The assumptions utilized by the licensee's analysis were as follows:

Maximum temperature attained in the area of fire influence is 1700 F for approximately one hour.

The maximum area of fire influence is equal to that of a fire with a base of 20 feet in diameter.

The weld strength is equivalent to that of the structural supporting steel material.

A seismic event is not postulated to occur concurrently with the fire.

Therefore, based on our evaluation of the licensee's analysis, it was determined utilizing the properties of steel at elevated temperatures as given in the American Iron and Steel Institutes " Fire-Resistance Steel Frame Construction," second edition June 1974, that the structural steel supports affected by the area of fire influence were of adequate strength to ensure that the raceway identified in Section 13.2 will retain their integrity for the required one hour fire duration.

13.4 CONCLUSION

Based on our evaluation, we conclude that the licensee's Appendix R raceway structural steel analysis demonstrated that its load carrying characteris-tics of the steel would be adequate to maintain the raceway fire barrier integrity after an exposure to a fire having a -one hour fire severity.

Ther~efore, the licensee's recuest for exemption should be granted.

14.0 FIRE AREAS IN UNIT 1 AND UNIT 2 AUXILIARY BUILDING, THE DIESEL GENERATOR BUILDING AND SERVICE WATER ~ INTAKE STRUCTURE - FIRE DOOR INSTALLATION DEVIATIONS (EXEMPTION REQUEST 1-41)~

^

14.1 EXEMPTION REQUESTED The licensee in their exemption request 1-41 requested an exemption from the technical requirements of 10 CFR 50 Appendix R, Section III.G to the extent that the fire door installations deviate from the requirements of National Fire Protection Association (NFPA) Standard No. 80.

... o Enclosure 71 14.2 DISCUSSION NFPA Standard for Fire Doors and Windows (NFPA 80) specifies the maximum clearance between the bottom of a fire-rated door and its sill or the floor. Deviations in these clearances could result in the doors potentially having a rating of less than three hours.

NFPA 80.3-6.1 states that the noncombustible clearance between the bottom of flush mounted doors and a raised noncombustible sill shall not exceed 3/8-inch, or where there is no sill, the maximum clearance between the bottom of the door and the floor shall not exceed 3/4-inch.

The following fire doors deviates slightly from this standard:

000R 4

NO.

BETWEEN ROOMS LOCATION DESCRIPTION ELEVATION 101 104 & Unit 2 Hallway to Unit 2 - WS 83' 150 155 & Unit 2 Hallway to Unit 2 - WS 100' 163 183 & 162 Hallway E of Spray Add Tank 100

155 172 & 161 Corridor to Chg Pump Area 100' 102 103 & 107 Corridor to Storage Room 83'

• 105 Str. #2 & 115 Stairwell - WS to Spray Pumps 77' 165 116 & 185 Entry to Cable Chase - CCW 100' 169 Str. #1 & 185 Stairwell to CCW 100' 201 254 & Unit 2

'HSP Room to Unit 2 121' 207 202 & 210 Communications Room 121' 202 205 & Unit 2 Hallway to Unit 2 - C 121'

• 205 208 & Str. #8 Stairwell - ES 121' 203 207 & Unit 2 Corridor to Unit 2 - ES 121' 210 212 & 213 Battery Room IB 121' 217 226 & 225 SWGR 1B to Charger Room 121' 216 213 & 225 Charger Room to Corridor 121' 211 213 & 214 Corridor to Battery Room A 121' 219 228 & 229 Corridor to SWGR Room - N 121' 223 234 & 235 Corridor to CRDM Room - N 121' 224 234 & 235 Corridor to CRDM Room - S 121' 225 234 & Str. #1 Stairwell - WS 121' 227 233 & 235 CRDM to SWGR Room 121' 240 250 & 235 Half Door to Cable Chase - E 121' 301 319 & Unit 2 Corridor to Unit 2 - WS 139' 302 316 & Unit 2 Corridor to Unit 2 - C 139' 304 309 & Unit 2 Big Door to Unit 2 - ES 139' 318 333 & 334 Room between Elect. Pen Rms - W 139' 311 317 & 322 Pen Filt Room 139' 312 318 & 319 Corridor to Cable Spr Room - N 139' 324 335 & 338 SWGR Room to Cable Chase - M 139' 322 343 & 339 Corridor to SWGR Room - S 139'

• This door has automatic smoke / heat detection on one side only.

m.

o

~

Enclosure 72

,t D0OR NO.

BETWEEN ROOMS LOCATION DESCRIPTION ELEVATION 447 429 & Str. #2 Stairwell to Radwaste Vent Room 155' i

402 405 & Unit 2 Double Doors Corridor to 2 - ES 155' 411 409 & Str. #2 Stairwell - WS 155'

• 333 604 & Str. #10 Hallway to Stairwell 130' DIESEL BUILDING D00R X

BETWEEN ROOMS LOCATION DESCRIPTION ELEVATION

• 732 56C & Cable Tunnel SWGR Room to West Tunnel 155' 734 56A & 56B Center Foyer to E SWGR 155' i

715 56A & 61 SWGR to 1-2A Diesel Room 155' i

716 56A & 60

-SWGR to IC Diesel Room 155'

~

717 56B & 59 Foyer to 2B Diesel Room 155' 718 56C & 58 SWGR to IB Diesel Room 155' 719 56C & 57 SWGR to 2C Diesel Room 155 l

701 71 & 61 South Hallway to 1-2A Diesel 155' 1

704 71 & 60 South Hallway to IC Diesel Room 155' 707 71 & 59 South Hallway to 2B' Diesel' Room 155' 710 71 & 58 South Hallway to IB Diesel Room 155' 713 71 & 57 South Hallway to 2C Diesel Room 155' 700 71 & 66 Hallway to 1-2A Day Tank Room 155' 703 71 & 65 Hallway to IC Day Tank Room 155' 706 71 & 64 Hallway to 2B Day Tank Room 155' 709 71 & 63 Hallway to IB Day Tank Room 155' 4

712 71 & 62 Hallway to 2C Day Tank Room 155'

• 731 56A & Cable Tunnel SWGR Room to East Tunnel Unit II 155'

• 733 56C & Cable Tunnel SWGR Room to West Tunnel Unit II 155' l

SERVICE WATER BUILDING I

D00R j

"WD-

_BETWEEN ROOMS LOCATION DESCRIPTION ELEVATION 851 72C & 73 Foyer to IB Battery Room 155' 853 72D & 74 Foyer to IA Battery Room 155" UNIT 2 l

D0OR l

NU-BETWEEN ROOMS LOCATION DESCRIPTION ELEVATION

• 2105 Str. #2 & 2115 Stair No. 2 77'

• 2154 Str. #8 & 2160 Stair No. 8 100" 2155 2172 & 2161 Corridor 100" 2159 Str. #2 & 2162 Hallway 100' l

2163 2183 & 2162 Hallway 100' 2165 2197 & 2185 CCW HX Room 100' i

-. ~. -, -

,.. o Enclosure 73 DOOR N0.

BETWEEN ROOMS LOCATION DESCRIPTION ELEVATION 2167 2198 & 218 CCW HX Room 100' 2169 Str. #1 & 2185 Stair No. 1 100'

• 2205 Str. #1 & 2185 Hatch Area 121' 2207 2202 & 2210 Corridor 121' 2212 Str. #2 & 2209 Hallway 121' 2215 2224 & 2225 Battery Charger Room 121' 2216 2225 & 2213 Battery Service Room 121' 2217 2226 & 2225 Battery Charger Room 121' 2222 2233 & 2228 Corridor 121' 2223 2235 & 2234 Hallway 121' 2224 2235 & 2234 Hallway 121' 2225 2234 & Str. #1 Stair No. 1 121' 2227 2235 & 2233 Switchgear Room 121' 2214 2249 & 2235 Control Sys. Cab. Room 121'

• 2305 Str. #8 & 2309 Hatch Area 139' 2312 2318 & 2319 Corridor 139' 2317 2334 & 2322 Hallway 139' 2318 2333 & 2334 Elec. Pene. Room 139' 2319 2337 & 2335 Load Center Room 139' 2322 2343 & 2339 Corridor 139' 2324 2338 &'2335 Load Center Room 139' 2329 2604 & 2602 Blow Down Panel Room 130'

• 2333 2604 & Str. #10 Stair No. 10 130'

• 2335 2609 & Str. #10 Stair No. 10 130' 2403 2405 & 406 Decon Room 155' 2404 2408 & 407 Hot Machine Shop 155' 2406 2405 & 407 Hot Machine Shop 155'

• 2407 2405 & Str. #8 Stair No. 8 155'

• 2431 2422 & Str. #10 Stair No. 10 155' 2439 2452 & Str. #1 Stair No. 1 155' 2447 2429 & Str. #2 Stair No. 2 155' 2327 2339 & 2346 MG Set Room 139'

• This door has automatic smoke / heat detection on one side only.

14.3 EVALUATION The fire-doors identified in Section 14.2 above, exceed NFPA 80 gap specifications.

In a majority of the fire door installations, the NFPA criteria is exceeded by less than 3/4 of an i'nch.

Most of the excessive clearances result from an unintentional unevenness of or slope in the concrete floors.

o.. e Enclosure 74 Smoke or heat detection systems are installed on both sides of the affected doors except as noted.

There are fourteen fire door exceptions categories.

Eleven of these exceptions involve stairwells; nine instances wherein the stairwell does not have detection, and two instances where small unprotected vestibules (Rooms 115 and 2115) are adjacent to protected stairwells.

The remaining three exceptions involve doors between the diesel generator building switchgear rooms and the diesel generator-auxiliary building cable tunnels.

These doors all have smoke detection on their diesel generator o building side and automatic water suppression systems on their tunnel side.

The in-situ combustible loading in the vicinity of the bottom of the doors is minimal.

Transient loads are unlikely to be located near the doors because access to fire doors is routinely kept clear.

Since the excessive gaps are located at the bottom of the doors, passage of smoke and heat is minimized in the event of a fire. The results of a liquid spill near a door with excessive clearance would not differ significantly from one near a door with prescribed clearance since a flow path exists under both doors. There-fore, the existence of the gaps at the bottom of the fire doors greater than those recommended in the NFPA 80 does not prevent each door from performing its intended function.

14.4 CONCLUSION

Based on our evaluation, we conclude that the licensee's alternative fire door configurations for those doors identified in Section 14.2 above, will provide an acceptable of fire protection to that required by the technical requirements of 10 CFR 50 Appendix R, Section III.G.2.

Therefore, the licensee's request for exemption should be granted.

Dated: December 29, 1986 Principal Contributor:

P. fladden e

2