ML20209C442
| ML20209C442 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 09/07/1983 |
| From: | Johnston W Office of Nuclear Reactor Regulation |
| To: | Novak T Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML16340C148 | List:
|
| References | |
| FOIA-86-151 TAC-52060, NUDOCS 8309160309 | |
| Download: ML20209C442 (66) | |
Text
S u.
pa-.m\\
rA
[d UNITED STATES p,
NUCLEAR REGULATORY COMMISSION ggQ t;
a wAsHmcTom. o.c.zosos
\\,~ /
~1-2 3 gg MEMORANDUM FOR:
Thomas M. Novak, Assistant Director for Licensing Division of Licensing FROM:
William V. Johnston, Assistant Director for Materials, Chemical and Environmental Technology Division of Licensing
SUBJECT:
REQUEST FOR APPROVED DEVIATIONS FROM THE REQUIREMENTS OF APPENDIX R TO 10 CFR 50, DIABLO CANYON UNIT 1 (TAC #52060)
Facility:
Diablo Canyon Unit 1 Licensee:
Pacific Gas & Electric Company Docket'No.: 50-275 Responsible Branch:
LB #3 Project Manager:
B. Buckley CMEB Reviewer:
D. J. Kubicki Status:
Compliance with Section III.G of Appendix R to 10 CFR 50 is open.
26 approved deviation's requested:
21 Granted 5 Denied By letter dated march 2, 1983, the licensee committed to provide a report to justify deviations between existing and proposed fire protection features in the plant and the technical requirements of Sections III.G., III.J., III.L.,
and III.O. in Appendix R of 10 CFR 50.
By letter dated July 15, 1983, the licensee provided an Appendix R evaluation for the plant.
Thirty-two fire areas were determined to be in compliance with Section III.G.
Two areas will be brought into compliance following plant modi-fications.
The licensee requested approval for twenty-two deviations.
Two other deviations from Section III.G. were noted for conditior.s that were not area specific, and approval was requested for deviations from the technical requirements of Sections III.J. and III.O.
Based on our evaluation, we find that the level of fire safety in the areas listed below is equivalent to that achieved by compliance with the technical requirements of Appendix R and, therefore, the licensee's request for devia-tions in these areas should be approved.
1.
RHR Pump 1-1 and Heat Exchanger Room (Fire Area 3-B-1) 2.
RHR Pump 1-2 and Heat Exchanger Room (Fire Area 3-B-2) 3.
Centrifugal Charging Pumps Room (Fire Area 3-H-1) 4.
Reciprocal Charging Pump Room (Fire Area 3-H-2)
Contact:
D.J. Kubicki x27743 3 M N 6 6 3 d k/d N8' s
~
Thomas M. Novak 5.
Turbine Driven Auxiliary Feedwater Pump (Fire Area 3-Q-1) 6.
4.16 kV Switchgear Fan Room (Fire Area 13-E) 7.
Chemical Laboratory and Offices (Fire Area 4-A) 8.
G. Bus Compartment (Five Area 4-A-1) 9.
H Bus Compartment (Fire Area 4-A-2) 10.
Showers, Locker and Access Control (Fire Area 4-B) 11.
Hot Shutdown Panel and Non-Vital Switchgear Room (Fire Area 5-A-4) 12.
Control Room Complex (Fire Area CR-1) 13.
Electrical Area West of Battery Room (Fire Area F-A-5) 14.
Corridor Outside Diesel Generator Room (Fire Area 11-0) 15.
Component Cooling Water Heat Exchanger (Fire Area 14-E) 16.
Auxiliary Saltwater Pump 1-1 and 1-2 (Fire Areas 30-A-1/30-A-2) 17.
Diesel Fuel Oil Transfer Pump Vault (Fire Areas 35-A/35-B) 18.
Auxiliary Building and Fuel Handling Building (Fire Area AB-1)
(Two Exemptions) 19.
Diesel Generator Rooms (Fire Areas TB-1/TB-2/TB-3) 20.
Steel hatches Based on our evaluation, we also conclude that the protection provided for the areas listed below does not provide an equivalent level of safety and, therefore, the licensee's request for deviations in these areas should not be approved:
1.
Containment (Fire Area 1) 2.
Penetration Area (Fire Area 3-BB) 3.
Unlabeled Fire Doors (Generic) 4.
RCP Oil Collection System (Containment Zone 1-B) 3
'A ', W, \\
n-~
l William V. Johnston, Assistant Director for Materials, Chemical and i
l Environmental Technology Division of Engineering
(
Enclosure:
As stated cc:
R. Vollmer F. Nolan W. Johnston S. Ebneter, Region I V. Benaroya T. Conlon, Region II l
R. Ferguson C. Norelius, Region III T. Wambach G. Madsen, Region IV S. Trubatch P. Sternberg, Region V R. Eberly D. Notley S. Pawlicki W. Shields T. Sullivan D. Eisenhut O. Parr F. Rosa J. Wermiel M. Srinivasan J. Taylor G. Knighton J. Stang B. Buckley D. Kubicki N*
l
up Enclosure Chemical Engineering Branch / Fire Protection Section Request for Approved Deviations Diablo Canyon - Unit 1 Docket No. 50-275 1.0 Introduction By lettir dated March 2, 1983, the licensee committed to provide a report comparing the existing and the proposed fire protection features in the plant to the-technical requirements of Sections III.G, III.J. III.L,.and III.0 in Appendix R of 10 CFR 50.
By letter dated July 15, 1983, the licensee provided an Appendix R evaluation for the plant.
Th.irty-two fire areas were determined to be in compliance with Section III.G.
Two areas will be brought into compliance following plant modifications.
The licensee requested approval for twenty-two deviations.
Two other deviations from Section III.G were noted for conditions that were not area specific and approval was requested for deviations from the technical requirements of Sections III.J and III.O.
Section III.G.2 of Appendix R requires that one train of cables and equipment necessary to achieve and maintain safe shutdown be maintained free of fire damage by one of the following means":
Separation of cables and equipment and associated non-safe,ty circuits of a.
redundant trains by a fire barrier having a 3-hour rating.
Structural l
steel forming a part of or supporting such fire barriers shall be pro-tected to provide fire resistance equivalent to that required of the barrier; 08/25/83 1-1 DIABLO CANYON APPR DEVI SEC 1
h 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; or c.
. Enclosure of cable and equipment and associated non-safety circuits of one redundant train in a fire barrier having a 1-hour rating.
In addition, fire detectors and an automatic fire suppression system shall be installed in the fire area.
If these conditions are not met,Section III.G.3 requires an alternative shutdown capability independent of the fire area of concern.
It also requires a fixed suppression system to be installed in the fire area of concern if it contains a large concentration of cables or other combustibles.
These alternative require-ments are not deemed to be equivalent; however, they provide equivalent protec-tion for those configurations in which they are accepted.
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.
In summary,Section III.G is related to fire protection features for ensuring that systems and associated circuits used to achieve and maintain safe shutdown are free of fire damage.
Fire protection configurations must either meet the specific requirements of Section III.G or an alterative fire protection con-figuration must be justified by a fire hazard analysis.
Our general criteria for accepting an alternative fire protection configuration are the following:
08/25/83 1-2 DIABLO CANYON APPR DEVI SEC 1
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 onsite).
Fire retardant coatings are not used as fire barriers.
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.
t i
08/25/82 1-3 DIABLO CANYON APPR DEVI SEC 1 l
7-i.'
2.0 Containment (Fire Area 1) 2.1 Requested Deviation The licensee requeste'd approval for a deviation from Section III.G.2 to the extent that it requires a noncombustible radiant energy shield between redundant shutdown divisions when divisional separation is less than 20 feet.
2.2 Discussion Fire Area 1 consists of all elevations of the containment building.
It is divided into three fire zones:
the containment penetration area (zone 1-A), the reactor coolant pump area (zone 1-B), and the control rod drive area (zone 1-C).
Fire zone 1-A is an annular region within the containment between the floor of the containment at elevation 91 feet and the operating deck at elevation 140 feet.
The outer wall of this zone is the containment wall.
The inner wall and ceiling
.of this zone are unrated reinforced concrete shield walls.
Open steel floor gratings and open stairways provide for personnel access to various elevations within this zone.
Fire zone 1-B is a cylinder in the central part of the con-tainment.
It is separated from fire zone 1-A by the unrated reinforced con-crete shield wall which also serves as the support structure for the polar crane.
This zone is separated from fire zone 1-C above by the elevation 140 feet reinforced concrete operating deck.
Fire zone 1-C includes the reactor pit and area above the reactor to elevation 140 feet and above.
The outer wall of this zone is the steel lined reinforced concrete containment wall.
The floor of fire zone 1-C is constructed of reinforced concrete with openings for stair-ways and open floor gratings for equipment access.
The equipment and cables required for safe shutdown which are located in the fire area consist of:
v
(
08/25/82 2-1 DIABLO CANYON APPR DEVI SEC 2
~
i J
I
- a RHR pump suction valves Valves in the charging and location flow path and related cabling Reactor coolant system and steam generator instrumentation and circuitry Steam generator blowdown isolation valves and RCS temperature elements Safe shutdown circuits listed in Table 3-4 of the licensee's July 15, 1983 Appendix R report.
2 The in situ combustible fire loading in the area is approximately 26,200 BTU /ft or an equivalent severity of 19.6 minutes on the ASTM E-119 time temperature curve.
The fire load consists primarily of oil in reactor coolant pumps, cable in cable trays, grease in valve operators, oil and grease in the crane and fan cooler motors, oil and grease in cranes, and charcoal, HEPA, and roughing filters.
Fire protection for the area includes:
fire detection systems throughout zone 1-A, at each reactor coolant pump and on the operating deck in zone 1-C; a wet pipe automatic sprinkler system at each reactor coolant pump; portable fire extingushers and manual hose stations.
The licensee justifies the exemption on the bases of the low fire load, the existing fire protection, the enclosure of shutdown related cables in steel conduit, fire stopping in cable trays and the heat dissipating effects of the open areas in containment.
i 2.3 Evaluation The technical requirements of Section III.G.2 are not met in this fire area because a noncombustible radiant energy shield has not been provided between redundant divisions of reactor coolant temperature instrumentation and circuits for the pressurizer liquid level instrumentation where they are located within 20 feet of each other.
08/25/83 2-2 OIABLO CANYON APPR DEVI SEC 2 l
Our principal concern with the existing level of fire safety is the absence of any physical separation between redundant shutdown divisions.
Although the fire load is low, it is not possible to predict with any reasonable assurance the advent, location, propagating path, and resulting damage to plant systems from a fire in any unprotected area.
If a fire were to occur because of some unanticipated fire hazard, both divisions might sustain damage before the fire was detected and extinguished.
There is no automatic fire suppression capability in this area except for the reactor coolant pump areas.
The sprinkler system for the RCPs will offer no protection in the immediate area of the vulnerable shutdown systems.
A fire detection system is installed in some locations but it does not provide complete area-wide coverage.
In addition, there is an inherent time delay between the occurrence of a fire, the activation of.a detector, the marshaling of the fire brigade at the scene and eventual fire suppression.
It is during this delay period that shutdown related cable and instruments would sustain damage.
The lack of an automatic fire suppression capability could be compensated for by the provision of a radiant energy shield or separating redundant divisions by more than 20 feet without intervening combustibles.
2.4 Conclusion t
Based on the above evaluation, we conclude that the licensee's alternate fire protection configuration for these areas does not provide an acceptable level of fire protection equivalent to that provided by Section III.G.
Therefore, the licensee's request for deviation in containment should be denied.
b 08/25/83 2-3 DIABLO CANYON APPR DEVI SEC 2
. - - ~
r 3.0 RHR Pump 1-1 and Heat Exchancer Reo3 (Fire Area 3-B-1) 3.0.2 RHR Pump 1-2 and Heat Exchancer Room (Fire Area 3-B-2) 3.1 Recuested Deviation The licensee requested approval for deviattans in these areas from Sec-tion III.G.2(a) to the extent that it requirac ti'.at reoundant snutdown divisions be separated by complete 3-hour fire rated barriers.
3.2.1 Discussion (Fire Area 3-B-1)
The RHR pump 1-1 and heat exchanger room -is bounded by walls, floor and ceiling of 3-hour fire rated construction with the following exceptions:
An overflow opening in the perimeter wall at elevation 54 feet 3 duct penetrations without fire dampers and a dcor cpening with a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> fire door in the perimeter wall at elevation 64 feet An open doorway and unprotected penetrations in the perimeter wall at elevation 75 feet A duct penetration without fire dacper in the perimeter wall at elevation 104 feet These openings are in walls which form the pc.rimeter of adjoining plant locations which the licensee has designated as separate fire areas.
Safe shutdown equipment which is located in this area consists of RHR pump 1-1, RHR heat exchanger 1-1, and circuits listed in Table 3-4 of the licensee's Appendix R report.
08/25/82 3-1 DIABLO CANYON APPR DEV SEC 3 I
The in situ combustible loading in the area is approximately 862 BTU /fts with an equivalent severity of 0.6 mir.ute on the ASTM E-119 time temperature curve.
The fire load consists primarily of oil and grease evenly distributed throughout the entire 675 square foot area.
Existing fire protection includes an areawide smoke detection system, portable fire extinguishers, and manual hose stations.
3.2.2 Discussion (Fire Area 3-B-2)
The RHR pump 1-2 and hea.t exchanger room is bounded by walls, floor and ceiling of 3-hour fire rated construction with the following exceptions:
an overflow opening in the perimeter wall at elevation 54 feet 5 duct penetrations without fire dampers and a door opening with a lh hour fire door in the perimeter walls at elevation 64 feet a duct. penetration without a fire damper in the perimeter wall at elevation 85 feet a cuct penetration without a fire damper in the perimeter wall at elevation 104 feet These openings are in walls which form the perimeter of adjoining plant locations which the licensee has designated as separate fire areas.
Safe shutdown' equipment which is located in this area consists of RHR pump 1-2, RHR heat exchanger 1-2, and circuits listed in Table 3-4 of the licensee's Appendix R report.
2 with an The in situ fire loading in the area is approximately 862 BTU ft equivalent severity of 0.6 minute on the ASTM E-119 time temperature curve.
The fire consists primarily of oil and grease evenly distributed throughout the entire 675 square foot area.
08/25/82 3-2 DIABLO CANYON APPR DEV SEC 3
\\e I
Existing fire protection includes an area-wide smoke detection system, portable fire extinguishers, and manual hose stations.
The licensee justified the deviations on the basis of the 1cw fire load, the spatial separation between redundant shutdown divisicns, and the existing fire protection.
- 3. 3 Evaluation The technical requirements of Section III.G.2(a) are not met in these areas because of the unprotected penetrations and the non-3-hour fire-rated doors in t
the perimeter walls.
The requirement for a 3-hour fire-rated barrier between redundant shutdown divisions is intended to provide us with reasonable assurance that one division will remain free of damage as a result of a fire which originates on either side of the barrier. The fire hazard within these areas is minimal.
Because of the limited quantities and dispersed location of combustibles, any postulated fire would tend to propagate slowly and with initially low heat generation.
The damage producing effects of such a fire, i.e., the radiant and convective heat and other products of combustion, would to a significant extent be confined to the area of fire origin by the fire rated perimeter walls, floor and ceiling.
A small quantity of smoke and hot gases would be expected to propagate beyond the perimeter of these fire areas because of the unprotected penetrations.
However, most of them are located away from the redundant shutdown systems.
Therefore, hot gases passing through the penetra-tions would not affect components or cabling of the redundant division.
The remaining products of combusion would be so diluted by ambient air conditons and the temperature of the air mass so diminished that they would not present a threat to the redundant division.
Because these areas have been provided with an area-wide fire detection capability and because they are located in an easily accessible area within the Auxiliary Building, we have reasonable assurance that a fire would be detected and controlled before significant propagation and damage occurs.
08/25/82 3-3 OIABLO CANYON APPR DEV SEC 3
3.4 Conclusion Based on our evaluation, we conclude that the existing fire protection provides en acceptable level of fire safety equivalent to that provided by Sec. tion III.G.2, and therefore the licensee's request for approval fcr deviations in the RHR pump and heat exchanger rooms (Fire Areas 3-B-1 and 3-8-2) should be appeoved.
l 9
08/25/83 34 OIABLO CANYOh APPR DEV SEC 3
r
+
4.0 1 Centrifugal Charging Pumps 1-1.and 1-2 Roca (Fire Area 3-H-1) 4.0.2 Reciprocal Charging Pump Room (Fire Area 3-H-2) 4.0,3 Turbing_ Driven Aux feed Pump (Fire Area 3-Q-1) 4.0.4 4.16 kV Switchqaar Vent, Fan Room (Fire Area 13-E) 4.1 GeQuested Davistion The licensue requested sopreval foi deviations fram Section III.G.2.(a) in these areas to the extant that it requires that redundant shutdown divisions be separated by complete 3-hour fire rated barriers.
4.1.1 Ofscus Qon (Fire Area F M-1)
The centrif ugal charging pump room is bounded by walls, ficor and ceiling of 3-hour fire rated construction with the following exceptions:
An open docrway with security gate and two sets of 1\\ hour fire doors with monorail cutoucs in the perimeter walls, 4 duct penetrations without fire dampors in the perimeter Walls and a
11oor.
These openings ire in walls and floor which forp the perimeter of adjoining plant locations w.iich the licenses has designated as separate fire areas.
Safe shutdown equipment which is located in this area consists of centrifugal chargir.g puros 1-1 and 1-2, their auxiliary lute cil pumps and circuits listed in Table 3-4 of the licensee's Appandix R Report.
2 with an The in situ fire loading in the area is approximately 6980 BTU /ft equivalent severity of 5.2 minutes on the ASTM E-119 time temperature curve.
The fire lead consists primarily cf oil and grease which is evenly distributed over the entire area of 100d square feet.
03/25/82 4-1 DIABLO CANYON APPR DEVI SEC 4
Existing fire protection includes an automatic wet pipe sprinkler system over the charging pumps, an area-wide smoke detection system, manual hose stations and portable fire extinguishers.
4.1.2 Discussion (Fire Area 3-H-2)
The reciprocating charging pump room is bounded by walls, floor, and ceiling of 3-hour fire rated construction with the following exceptions:
An open doorway with security gate in the perimeter wall.
4 duct penetrations without fire dampers in the perimeter walls, floor, and ceiling.
)
These openings are in fire barriers which form the perimeter of adjoining plant locations which the licensee has designated as separate fire areas.
Safe shutdown equipment which is located in this area consists of reciprocating charging pump 1-3 and circuits listed in Table 3-4 of the licensee's Appendix R Report.
The in situ fire loading in the area is approximately 28,100 BTU /ft2 with an equivalent severity of 21 minutes on the ASTM E-119 time temperature curve.
The fire load consists primarily of oil and grease which is evenly distributed over the entire area of 235 square feet.
Existing fire protection includes an automatic, wet pipe sprinkler system over the charging pump, an area-wide smoks detection system, manual hose stations, and portable fire extinguishers.
4.1.3 Discussion (Fire Area 3-Q-1)
The turbine driven, auxiliary feed pump room is enclosed by walls, floor, and ceiling of 3-hour fire rated construction with the 'following exceptions:
4 9
08/25/83 4-2 DIABLO CANYON APPR DEVI SEC 4
+
,, e w e - -,
..--~~--*-*---e
~.
2 - 1\\ hour fire rated doors in the perimeter walls.
An unrated concrete shielding wall separates this area from an adjoining plant area.
2 ducc penetrations without fire dampers and one duct penetration with a 1\\ hour fire damper in the perimeter walls and ceiling.
Safe shutdown equipment which is located in this area consists of AFW pump 1-1 I
and circuits listed in Table 3-4 of the licensee's Appendix R Report.
2 with an The in situ fire 1cading in the area is approximately 10,700 BTU /ft cquivalent severity of 8.0 minutes on the ASTM E-119 time temperature curve.
The fire loading consists primarily of cable, oil,' and grease which is evenly distributed over the entire area of 700 square feet.
Existing fire protection consists of area-wide au;omatic fire detection and fire suppression systems, manual hose stations, and portable fire cxtinguishers.
4.2.4 Discussion (Fire Area 13-E)
The ventilation fan room is located at the north end of the Turbine Building at elevations 107 and 119 feet.
The area is bounded by walls, floor and ceiling of 3-hour fire rated construction with the following er.ceptions:
Unrated steel hatches cover persor iel and equipment openings.
Ih hour fire rated doors and danpers protect doorways and dust i
Open lowers exist in the exterior walls.
f Duct penetrations without fire dampers are in common walls with otner fire areas.
4-3 DIABLO CANYON APPR DEVI SEC 4 08/25/82 P
~
- - ~
,r-,
wn
a An unsealed diesel exhaust stack communicates with a vertically adjoining fire area.
This area contains no shutdown-related systems but communicates with other areas that contain redundant divisions via ventilation ducts without five f
dampers and unrated hatches.
The in situ fire load within this area is approximately 7EM BTU /fts with an equivalent fire severity of 0.6 minute.
It is comprised primarily of grease, filters, cable, and fan beits.
s Existing fire protection in:1udes an automatic smoke detection system and a wet pipe sprinkler system, manual hose stations, and portable fire extinguishers.
The licensee justified the deviations in these areas on the basis.cf the low fire load, the spatial separation between redundant shutdown divisions, and the existing fire prctection.
i 4.3 Evaluation The technical requirements of Section III.G.2.(a) are not met in these areas l
because of the unprotected penetrations in the 3-hour fire rated perimeter walls, flocr, and ceiling. We were concerned that because of the unprotected openings in the perimeter walls, floors, and ceilings of these areas, a fire could spread beyond-their boundaries and affect both shutdown divisions of cable and components.
i However, the fire hazards in these areas are not significant.
Because of the limited quantity and dispersed location of combustible materials, any postulated exposure fire would tend to propagate slowly and with initially low heat gen-eration.
Because of the presence of automatic fire detection systems, we expect a fire to be discovered in its early sages before serious damage occurs.
If a t
fire should generate high air temperatures, the automatic fire suppression l
systems would activate to suppress it and to protect exposed shutdown systems.
1 Catween the time the fire is detected and extinguishment occurs as a result of l
08/25/83 4-4 DIABLO CANYON APPR DEVI SEC 4
fire brigade intervention or the activation of the fire suppression system, the existing passive protection, which consists oflthe y artial fire walls and spacial separation, will provide reasonable assurance that one shutdown divisicn will remain free of fire damage.
4.4 Conclusion fased on our evaluation, we conclude that the existing fire protection pro-vides an acceptable level of fire safety equivalent to that provided by Sec-tion III.G.2 and, therefore, the licensee's request for deviations in the Reciprocal'and Centrifugal Charging Pump Rooms, the Turbine Driven Aux Feed Pump Rcon and the 4.16 KV Switchgear Ventilation Fan Room (Fire Areas 3-H-1/3-H-2/3-Q-1/13-E) should ye approves.
f 4
i
~
[
D i
i 2
(
\\
l l
's k
5 i
08/25/83 4-5 DIABLO CANYON APPR DEVI SEC 4 s
e
j :
e i
- 5
_f x
5.0 Penetration Area (Fire Area 3-BB) 5.1 Requested Deviatiion I
s Thegicensee requested approval for a deviation from Section III.G.2 in this area to the extent that it requires the separation'of redundant shutdown divisiEnsby20 feet,freeofinterveningcombustibles,andtheinstallationof area-fNdefiredetectionandsuppressionsystems.
5.2 s0'scussion i
, j' 6
Fire area 3-BB consists of three levels which comprise the area between the containment structure and the auxiliary building extending from elevation 85 feet to akvation'115 feet.
Th's fire area is, bounded on the north by the containment b'bilding wall, which 13 separated by an 8-inch seismic and vent gap at each floor level.
It is separated from the auxiliary building to the south and the f.ueF handling building to the east by concrete 3-hour rated fire walls with 1- -hour rated doors.
This fire area is separated from the turbine building to the west by a 3-hour rated fire barrier.
The floor and ceiling of this area are 3-hour-rated fire barriers.
The floors separating the three levels are concrete sicbs with numerous unsealed penetrations.
l The following exceptions exist to the 3-hour fire rated barriers in the fire area:
l 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> fire rat'ed doors -are pt;ovided in perimeter wall doorway openings at elevations 85 feet,104 feet and 115 feet.
The northwest external wall at all three elevations is provided with ventilation louvers withwt fire dampers.
P Unsealed pipe penetrations ext::t in the south ceiling at elevation 140 feet.
~
t b
l 08/25/83 5l DIABLO CANYON APPR DEVI SEC 5 l
i.
a.
u.- - -
's, Duct penetrations without fire dampers are located in perimeter walls on elevation 85 feet.
These openings are in walls and ceiling which forr. the perimeter of adjoining plant locations which the licensee has designated as separate fire areas.
Safe shutdown equipment which is located in the area includes piping and valves associated with the auxiliary feedwater system, RHR system, charging and boration system, component cooling water system and main steam system, as well as shutdown related circuits listed in Table 3-4 of the licensee's Appendix R Report.
The in situ fire load in the area, by elevation, is tabulated below and consists l
primarily of cable, grease, rubber, and hydrogen.
Elevation Combustible BTU /ft2 Equivalent Fire Severity. min.
85 feet negligible neg11ble 100 feet 9900 7.4 115 feet 9900 7.4 Existing fire protection includes a partial smoke detection system which covers the post LOCA sampling room on elevation 85 feet and approximately 75% and 60%
of the floor area on elevations 100 feet and 115 feet respectively.
Additonal protection consists of an automatic, wet pipe sprinkler system which provides area-wide coverage on e'levation 100 feet and 115 feet, manual hose stations, i
and portable fire extinguishers.
The licensee justifies the deviations on the bases of the low fire load, the existing fire protection, the fire stopping installed in cable trays, the enclosure of shutdown related cabling in steel conduit and the degree of spatial separation and/or noncombustible barriers between redundant shutdown divisions.
i l
l l
1 i
08/25/83 5-2 DIABLO CANYON APPR DEVI SEC 5 J
.s c
5.3 Discussion The technical requirements of Section III.G.2 are not met in this area because of the absence of area-wide automatic fire detection and fire suppression systems on all three elevations.
In addition,. redundant shutdown divisions are not separated by more than 20 feet free of intervening combustibles, or separated by a 1-hour fire rated barrier.
The openings in the 3-hour fire rated perimeter walls and ceiling are not protected by 3-hour rated fire doors and dampers.
Our concern with the existing level of fire safety is the absence of sufficient physical separation between redundant shutdown divisions.
Because of changing conditions over the life of the plant, it is not possible to predict with any reasonable assurance, the advent, location, and resulting damage to plant systems from a fire.
Consequently, Appendix R mandates both active fire protection (fire detectors and/or fire suppression systems) and passive protection (fire barriers or special separation).
Active fire protection in this area consists of partial smoke detection system and a sprinkler system on two elevations.
However, this protection does not cover the complete area.
In addition, there is an inherent time delay between the activation of fire detectors and the arrival of the fire brigade.
There is also a delay between the advent of a fire and the activation of a sprinkler system.
It is during this time delay that damage could be sustained by vulnerable shutdown systems.
(~
between redundant divisions or completely enclosing one shutdown train would eliminate this threat.
5.4 Conclusion l
l Based on the above evaluation, we conclude that the licensee's fire protection configuration for this area does not provide an acceptable level of fire protec-tion equivalent to that provided by Section III.G.
Therefore, the licensee's request for a deviation in the Penetration area (Fire Area 3.BB) should be denied.
08/25/82 5-3 DIABLO CANYON APPR DEVI SEC 5 l
o.
s' 6.0 Chem Lab and Offices (Fire Area 4-A) j 6.1 Requested Deviation j
The licensee requested approval for deviations from Section III.G.2(c) to the extent that it requires one shutdown division to be protected by a one-hour fire rated barrier and requires the installation of area-wide automatic fire detection and fire suppression systems.
- 6. 2 Discussion The floor and ceiling of the chemical lab and offices are 3-hour fire rated.
The perimeter walls abe 2-hour fire rated with the following exceptions:
I hour rated fire t'oor are located in the south and west perimeter walls.
Duct penetrations without fir-e dampers and penetrations with I hour fire dampers are located in the perimeter walls.
A continuous membrane drop ceiling consisting of a vermiculite plaster on metal lath with acoustical ceiling tiles adhered to the underside exists within the area at elevation 93 feet.
The fire area walls, the continuous membrane l
ceiling, and the floor form an envelope to separate the occupancy of this area from safe shutdown circuitry routed in conduit above the drop ceiling.
All ventilation. duct register penetrations in the drop ceiling have been provided with 1 -hour fire dampers.
All but one access hatch in the drop ceiling are 1 -hour fire rated.
The area above the drop ceiling contains redund.1nt shutdown circuits for the following systems:
08/25/82 6-1 DIABLO CANYON APPR DEVI SEC 6
l Auxiliary Feedwater System l
Auxiliary Saltwater System Charging and Boration System Component Cooling Water System Emergency Power System RHR-system Ventilation Equipment System These circuits are listed in Table 3-4 of the Appendix R Report.
The fire load in the ches lab is approximately 4,800 BTU /ft2 with an equivalent ~
severi,y of 3.7 minutes on the ASTM E.119 time temperature curve.
This loading includes flammable liquids and gases, clothing and ordinary Class A combustibles which is evenly distributed throughout the lab.
The fire load in the store room is approximately 49,400 BTU /ft2 with an equivalent severity of 37 minutes.
This loading is primarily flammable l
liquids mostly stored in an approved flammable liquids storage locker.
Tng l
remainder of this loading includes flammable gases, clothing,'and ordinary Class A combustibles and is evenly distributed throughout the room.
The fire load in the F bus compartment is approximately 5,160 BTU /ft2 with an equivalent severity of 4 minutes.
This loading is primarily cabling in trays.
In the remainder of this area the fire load is approximately 7,600 BTU /ft2 with an equivalent severity of 5.7 minutes.
Existing fire protection includes a partial smoke detection sysem located below the drop ceiling in the laboratory and balance rooms; an automatic, wet pipe sprinkler system throughout the area below the ceiling; manual hose stations and portable fire extinguishers.
In the July 15, 1983 Appendix R Report, the licensee committed to install a complete smoke detection system above the drop ceiling in the fire area.
08/25/83 6-2 DIABLO CANYON APPR DEVI SEC 6
6 i
The licensee justifies the deviation on the bases of the negligible fire load-ing above the ceiling, the enclosure of all safe shutdown cabling in steel con-duit, and the existing and proposed. fire protection.
6.3 Evaluation The technical requirements of Section III.G.2 are not met in this area because of absence of an automatic fire suppression" system above the drop ceiling, the lack of an area-wide fire detection system below the ceiling, and the insuffi-cient physical separation between redundant shutdown divisions.
Also, the perimeter walls of the fire area are not 3-hour rated.
We have two concerns in this area.
The first is that a fire in the room, below the ceiling, would damage cables above the ceiling.
The second is that a fire that originates above the ceiling would damage cables from redundant divisions.
If a fire should occur within the chemical lab and ancillary areas, we expect the smoke detection system to detect it in its initial stages.
This would result in early fire suppresssion by the plant fire brigade before serious damage occurs.
Although the smoke detection system does not cover the entire fire area, the rooms that are unprotected are a small fraction of the total floor arta.
The distance from any location within the fire area to a detector is slight.
So that if a fire were to occur within an unprotected room a detector located in an adjoining room would activate after a short time lag.
If the fire propagates rapidly and room temperatures rise, the automatic sprinkler system will activate automatically to suppress the fire and limit damage.
During the time lag between the occurrence of a fire and the arrival of the fire brigade or the activation of the sprinkler system, the membrane ceiling will provide sufficient passive protection to prevent cables above the ceiling from sustaining damage.
There is no signifcant quantity of ignitable materials above the ceiling since all cables are enclosed in conduit.
08/25/82 6-3 DIABLO CANYON APPR DEVI SEC 6
Therefore, if a fire should occur it would be of limited magnitude and duration and would not produce elevated temperatures that would pose a threat to the shutdown related cables.
Because of the smoke detection system which the licensee commits to install throughout the concealed ceiling area, a fire would be detected quickly and supressed manually before serious damage occurred.
Until fire extinguishment occurred, the passive protection provided to the cables by the conduit, the heat dissipation achieved by the ventilating air flow through the ceiling, and the separation between cables of redundant divisions (which varies depending on the location in the ceiling) would provide reasonable assurance that one division would remain free of fire damage.
I 6.4 Conclusion Based on our evaluation, we conclude that the existing fire protection along with the proposed modifications provide an acceptable level of fire safety equivalent to that provided by Section III.G.2 and, therefore, the licensee's request for a deviation in the Chemical Lab and Offices (Fire Area 4-A) should be approved.
l 1
l 08/25/82 6-4 DIABLO CANYON APPR DEVI SEC 6
=. -.
~- ;_
, = - = -.
-=
. =.
7.0.1 G Bus Compartment (Fire Area 4-A-1) 7.0.2 H Bus Compartment (Fire Area 4-A-2) 7.1 Requested Deviation The licensee requested approval for deviations from Section III.G.2(a) in these areas to the extent that it requires that redundant shutdown divisions be separated by complete 3-hour fire rated barriers.
7.2.1 Discussion (Fire Area 4-A-1)
The G bus compartment is bounded by walls, floor and ceiling of 3-hour fire rated construction with the following exceptions:
The south perimeter wall is 2-hour fire rated.
A doorway in the south wall is provided with a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> fire door.
2 duct penetrations without fire dampers are located in the perimeter walls.
The openings are in walls which form the perimeter of, adjoining plant locations which the licensee has designated as separate fire areas.
i The area contains cable in conduit for various G bus safe shutdown components and equipment, which are listed in Table 3-4 of the Appendix R Report.
The fire load is negligible and consists of cable insulation within conduit.
Existing fire protection includes manual hose stations and portable fire extinguishers.
In the July 15, 1983 Appendix R Report, the licensee. committed to install a comple'.a fire detection system in the area.
08/25/82 7-1 DIABLO CANYON APPR DEVI SEC 7
=
= = ----
- - --==:=====:==-.=--------
7.2.2.
Discussion (Fire Area 4-A-2)
The H bus compartment is bounded by walls, floor and ceiling of 3-hour fire rated construction with the following exceptions:
The south perimeter wall is 2-hour fire rated A doorway in the south wall is provided with a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> fire door.
2 duct penetrations without fire dampers are located in the perimeter walls.
The openings are in walls which form the perimeter of adjoining plant fire areas.
The area contains cable in conduit for various H bus safe shutdown components and equipment, which are listed in Table 3-4 of the Appendix R Report.
2 ine fire load within this area is approximately 6800 BTU /ft with an equivalent fire severity of 5.1 minutes'on the ASTM E-119 time temperature curve.
The fire load is comprised of electric cable insulation in cable trays.
Existing fire protection includes manual hose stations and portable fire extinghuishers.
As with the G bus compartment, the licensee committed to install a complete fire detection system.
The licensee justifies the deviations in these areas on the low fire loading, the enclosure of safe shutdown cables in steel conduit, the spatial separation between redundant shutdown divisions and the existing and proposed fire protection.
- 7. 3 Evaluation The technical requirements of Section III.G.2.(a) are not met in these areas because of the 2-hour fire rating on the south perimeter wall, the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> rated fire doors and the unprotected duct penetrations in the perimeter walls.
08/25/82 7-2 DIABLO CANYON APPR DEVI SEC 7
We were concerned that a fire which might originate in either bus compartment may damage cables of the redundant division.
However, the ignitable material in these areas is negligible and because of the limited size and restricted j
access, it is not credible to postulate any significant quantity of transients.
Because the amount of material that could burn is limited, we expect any fire to be of limited magnitude and extent.
The effects of a postulated fire would, to a great extent, be confined within the area of origin by the fire rated walls and door.
Because of the lack of a fire damper in the duct penetrations of the perimeter walls, some limited quantity of smoke and hot gases may enter adjoin-ing areas.
But the products of combustion would be cooled and dissipated as they expand into these areas.
These areas are equipped with automatic smoke detection and fire suppression systems which should limit damage.
Because the bus compartments will be equipped with smoke detectors, any postu-lated fire would be detected early and suppressed by the plant fire brigade.
Until they arrive, the passive protection which includes the steel conduits, fire rated perimeter construction, spatial separation and the fire suppression systems in adjoining plant locations would provide us with reasonable assurance that only cables from one shutdown division would be damaged.
7.4 Conclusion Based on our evaluation, we conclude that the existing fire protection, with proposed modifications, will provide an acceptable level of fire safety equivalent to tha' provided by Section III.G.2 and, therefore, the licensee's request for deviations in the G and H Bus Compartments (Fire Areas 4-A-1 and 4-A-2) should be approved.
08/25/83 7-3 DIABLO CANYON APPR DEVI SEC 7 I
... ~.. _.
.y
8.0 Showers, Lockers and Access Control (Fire Area 4-8)
~ 8.1 Requested Deviation I
The licensee requested approval for a deviation from Section III.G.2(c) to the axtent that it requires the installation of an area-wide.sutomatic fire detec-tion system where one shutdown division is enclosed in a one-hcur fire barrier and the area is protected by an automatic fire suppression system.
8.2 Discussion Fire area 4-8 is the radiological control access area for Units 1 and 2.
This area contains personnel showers, lockers, restrooms, offices, and storage areas.
It is bounded by walls, floor and ceiling having a 3-hour fire rating with the following exceptions:
The north wall of this area separating it from the chemical laboratory is a 2-hour barrier with I hour rated fire doors and 1\\ hour fire dampers provided in all but four of the duct penetrations.
An unrated door provides access to stairway S-2 and a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> fire rated door provides access to stairway S-1.
There are several equipment hatches and ceiling penetrations provided with unrated steel covers.
Ventilation ducts without fire dampers penetrate the south wall of this area into the Unit 2 containment penetration area.
Safe shutdown systems located in the area consist of cables associated with the following systems:
dex. Feedwater System 08/25/83 8-1 DIABLO CANYON APPR DEVI SEC 8
i l
Aux. Saltwater System Component cooling Water System Emergency Power System Ventilation Equipment System The fire. load within this area is approximately 4590 BTU /fts with an equivalent fire severity of 3.4 minutes on the ASTM E-119 time temperature curve. The combustible loading consists primarily of wood counters, electric cable insula-tion, and anti-contamination clothing and respirators.
Existing fire protection includes an area-wide automatic sprinkler system, manual hose stations and portable fire extinguishers.
In the July 15, 1983 Appendix R Report, the licensee committed to separate redundant diesel generator and fuel transfer pump circuits by a complete one hour fire barrier.
The licensee justified the deviation on the basis of the low fire load, the existing and proposed protection and the ability to be able to maintain a safe shutdown capability after a fire.
8.3 Evaluation The technical requirements-of Section III.G.2(c) are not met in this area because of the lack of an area-wide fire detection system, and insufficient physical separation between redundant circuits of the CCW and ASW systems.
In j
addition, the perimeter walls and ceiling are not completely 3-hour fire rated.
We have two concerns in this area.
The first is that a fire within the area would damage redundant circuits of the CCW and ASW systems.
The second is that a fire might propagate beyond the perimeter of the area.
If a fire should occur, we expect the automatic sprinkler system to activate and suppress it, while protecting vulnerable shutdown systems.
Upon activa-tion, a waterflow alarm will be annunciated in the control room which would i
08/25/83 8-2 DIABLO CANYON APPR DEVI SEC 8
I
\\
' summon the fire brigade.
If the suppression system did not activate or if the fire brigade did not arrive in sufficient time to prevent damage to both trains of the ASW system, manual operation of the system valves is available outside the fire area.
Because one of the CCW system valves is normally open and since fire damage will cause the valves to fail as is, the CCW flow path will be maintained.
The fire load in this area is low.
Consequently, we do not expect any postulated fire to generate excessive quantities of smoke and hot gases.
If it should, the sprinkler system would activate to reduce temperatures and limit damage.
The perimeter construction described above is such as to provide us with reason-able assurance that most of the effects of a fire would be confined to the area of origin.
Because of the lack,of fire dampers in some duct penetrations of the fire walls a quantity of smoke ar.d hot gases may filter out into an adjoin-ing area (Fire Area 4-A).
But the products of combustion would be cooled and dissipated as they expand into this area.
Therefore, shutdown systems would not likely be.threateled.
In addition, Fire Area 4-A is equipped with auto-matic smoke detection systems above and below the ceiling which would provide early fire warning and an automatic sprinkler system.
Also, the ceiling l
registers from the ventilation system in Fire Area 4-A have been provided with fire dampers.
Therefore, if hot gases from a fire in the. area were to propagate I
via the duct system, the fire dampers in the ceiling would close to limit damage below the ceiling.
8.4 Conclusion Based on our evaluation, we conclude that the exisitng fire protection with proposed modifications will provide an acceptable level of fire safety equivalent to that provided by Section III.G.2 and, therefore, the licensee's request for a deviation in the Showers, Lockers and Access Control Area (Fire Area 4-B) should be approved.
08/25/83 8-3 DIABLO CANYON APPR DEVI SEC 8 i
~..
3....
~ ~ - - -. -. --
- 9. 0.1 Hot Shutdown Panel & Non vital Switchgear Ro om (Fire Area 5-A-4)
- 9. 0. 2 Control Room Complex (Fire Area CR-1) 9.1 Requested Deviation The licensee requested approval for a deviati creas to the extent that it requires the installatioon from Section III.G.3 in t automatic fire suppression system in an area for n of an area-wide capability has been provided.
which an alternate shutdown 9.2.1 Discussion (Fire Area 5-A-4)
The hot shutdown panel and non vital switchge floor and ceiling of 3-hour fire rated const ar room is bounc'ed by walls, exceptions:
ruction with the following Equipment access openings with unrated steel h t h floor and ceiling.
a c es are located in the A ventilation register without a fire damper i with stairway S-1.
s located in a common wall 3-hour fire rated doors with filled metal pa perimeter walls.
nels are located in the Ventilation ducts without fire dampers or with I penetrate the perimeter walls and ceiling hour rated dampers Safo shutdown systems located in the area co and cables which are listed in Table 3-4 of the Ansist of the hot shutdown panel ppendix R Report.
08/25/82 9-1 DIABLO CANYON A?PR DEVI SEC 9
The in situ fire load in the area is approximately 25,167 BTU /ft2 or an equivalent severity of 19 minutes on the ASTM E-119 time temperature curve.
The fire load consists primarily of cable in raceways which is evenly distributed over the entire area of 2702 square feet.
Existing fire protection includes an area-wide smoke detection system, manual hose stations and portable fire extinguishers.
9.2.2 Discussion (Fire Area CR-1)
The control room complex is bounded by walls, floor and ceiling of 3-hour fire rated construction with the following exceptions:
3/4 hour and 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> fire rated doors are located in the perimeter walls Open louvers and penetrations are located in the exterior perimeter walls and ceiling.
Safe shutdown systems located in the area consist of the controls and instrufnen-tation for all safety systems from both divisions located in the control boards and consoles.
Shutdown related circuits are listed in Table 3-4 of the Appendix R Report.
Fire area CR-1 has an approximate floor area of about 7450 square feet.
The 2
in situ fire load is approximately 29,420 BTU /ft with an equivalent fire severity of 22 minutes on the ASTM E-119 time temperature curve.
The fire load is comprised primarily of electric cable insulation, paper in books, computer printouts, prints, etc. and combustible vinyl ceiling lighting diffusers.
Existing fire protection includes an area-wide smoke detection system, manual hose stat' ions and portable fire extinguishers.
In addition, an automatic wet-pipe sprinkler system is located in both control room ventilation equipment rooms and over the records storage area in the office.
08/25/82 9-2 DIABLO CANYON APPR DEVI SEC 9
~,
The licensee justified the deviations on the basis of the availability of an alternate shutdown capability, which is independent of these two fire areas, and the existing fire protection.
9.3 Evaluation The technical requirements of Section III.G.3 are not met in these areas because of the absence of area-wide fixed fire suppression systems.
The fire hazards in,these areas is low.
Because of the dispersion of the combustible materials that may ignite, a potential fire would tend to develop slowly.
Because of the smoke detection' systems and the continuous manning in the control room, a fire would be detected in its initial stages and extinguished before serious damaged occurred.
If serious damags should occur before the arrival of the plant fire brigade, an alternate shutdown capability exists which is independent of each of the rooms.
Therefore, safe shutdown could be achieved and maintained.
9.4 Conclusion Based on our evaluation, we conclude that the existing fire protection provides an acceptable level of safety equivalent to that achieved by compliance with Section III.G.2 and, therefore, the licensee's request for deviations in the control room and hot shutdown panel and switchgear room (Fire Areas CR-1 and 5-A-4) should be approved.
08/25/83 9-3 OIABLO CANYON APPR DEVI SEC 9
F s'
10.0 Electrical Area West of Battery Room (Fire Area 6-A-5) 10.1 Requested Deviation The licensee requested approval for a deviation from Section III.G.2 to the extent that it requires that redundant shutdown divisions be separated by complete 3-hour fire rated barriers.
10.2 Discussion This area is located in the northwest corner of the auxiliary building at elevation 115 feet.
The perimeter walls, floor and ceiling are 3-hour rated fire barriers with the following exceptions:
Equipment access openings, with unrated 1-inch thick steel hatches, are located in the floor and ceiling in the northwest corner of this area.
Several ventilation duct penetrations without fire dampers are located in the perimeter walls and floor.
The ducting within the area and its supports are coated with a 1-hour fire rated material.
These penetrations are in walls which form the boundaries of adjacent fire areas.
Safe shutdown systems which are located within this room are listed in Table 3-4 of the licensee's Appendix R Report.
The fire load within this area consists of electrical cable insulation and 2
small amounts of lubricating oil which equals 11,960 BTU /ft, with an equivalent fire severity of 9 minutes on the ASTM E-119 time temperature curve.
Existing fire protection includes an area-wide smoke detection system, manual hose stations and portable fire extinguishers.
08/25/83 10-1 DIABLO CANYON APPR DEVI SEC 10
+
t*
The licensee justified the exemptions on the basis of the low fire loading, the existing fire protection and the ability of the steel hatches to limit fire spread.
10.3 Evaluation The technical requirements of Section III.G.2 are not met in this' area because of the unprotected penetrations of the perimeter walls and floor and the unrated steel hatches at equipment access openings.
We were concerned that a fire might propagate beyond the area boundaries and affect redundant shutdown systems in adjoining plant locations.
However, the amount of ignitable materials is limited and widely dispersed.
As such, we would not expect a fire to be of significant magnitude or duration.
Because of the smoke detection system, which covers the entire area, a fire would be detected in its initial stages before serious, damage occurs.
The perimeter construction of this room, although not completely 3-hour fire rated, is substantial enough to confine most of the effects of a fire within the area of fire origin.
Since systems of only one shutdown division are located within the room, only one train would be damaged and, therefore, shutdown capability would remain outside of the damaged area.
Because of the lack of. fire dampers in the ventilation duct penetrations of the walls, some quantity of smoke and hot gases might flow out of the room via the ventilation system.
However, because of the limited combustibles the 1-hour fire rated enclosure of the ducts in the room and early fire awareness and response by the fire brigade, we are of the opinion that the amount of products of combustion would not pose a threat to shutdown systems in other fire areas.
In adt:ition, compensating fire protection is available in adjoining locations to mitigate the hazard posed by damage to the ventilation duct system.
This protection includes a sprinkler system (Fire Area TB-7), enclosure of ducts in a 1-hour fire rated barrier (Fire Area 5-A-4), and fire dampers in the ceiling registers (Fire Areas 6-A-1 to 6-A-3).
l l
08/25/83 10-2 DIABLO CANYOH APPR DEV1 SEC 10
{
j i
i
10.4 Conclusion Based on our evaluation, we conclude that the existing fire protection will provide an acceptable level of safety, equivalent to that provided by Section III.G.2 and, therefore, the licensee's request for a deviation in the Electrical Area West of Battery Room (Fire Area 6-A-5) should be approved.
6 9
9 08/25/82 10-3 DIABLO CANYON APPR DEVI SEC 10
't.
11.0 Corridor Outside Diesel Generator Room (Fire Area 11-0) 11.1 Requested Deviation The licensee requested approval for a deviation from Section III.G.2.(c) to the extent that it requires the installation of a complete area-wide fire detection system.
11.2 Discussion The corridor is bounded by walls, floor and ceiling of 3-hour fire rated construction with the following exceptions:
An unrated steel hatch and metal door ara located in the perimeter wall.
A duct penetration without fire damper is located in the ceiling.
Safe shutdown systems located within the corrider consist of cables, in conduit, which are listed in Table 3-4 of the Appendix R Report.
The cables include vital bus circuitry for all three diesel generators and both diesel fuel transfer pumps.
In addition, the diesel generator emergency stop switches are located in this area.
The only fire hazard in the corridor w6uld be transient combustible material consisting of lube oil, solvent and rags.
The fire load equals 16,050 BTU /fts with an equivalent severity of 12 minutes on the ASTM E-119 time temperature curve.
Existing fire protection includes on area-wide automatic sprinkler system, manual hose stations and portable fire extinguishers.
In the July 15, 1983 Appendix R Report, the licensee committed to enclose each of the circuits for the diesel generators in a 2-hour fire rated barrier a j
2-hour barrier already encloses the circuits for the fuel transfer pump.
In 08/25/82 11-1 DIABLO CANYON APPR DEVI SEC 11 m
e' 1
addition, the licensee committed to enclose the emergency stop push button switches ror two diesel generators in a 1-hour barrier to prevent a short across the push button contact from prematurely tripping the diesel.
The licensee also committed to install isolators for diesel generator indication circuitry to prevent tripping the diesel generator due to a short circuit.
The licensee justified the deviations on the basis of the low fire loading, the existing fire protection and the proposed modifications.
11.3 Evaluation The technical requirements of Section III.G.2 are not met in the corridor because of the absence of an area-wide fire detection system.
In addition, the perimeter construction is not completely 3-hour fire rated.
We were concerned that because of the absence of a smoke detection system, a fire could damage redundant shutdown systems or propagate beyond the Joundaries of the fire area.
However, if a fire should occur we expect the automatic sprinkler system to operate and extinguish it as well as protect the vulnerable systems.
Upon activation of the sprinkler system, a waterflow alarm will annuncia*.e in the control room and summon the plant fire brigade.
Until the brigade arrived, the circuits for the diesel generators and fuel transfer pumps would be protected by the fire barriers.
Because of the limited combustibles in the corridor and the protection provided by the sprinaler system, the perimeter construction, even if not completely 3-hour fire rated, would be sufficient to confine the effects of a fire to the area of origin.
Any smoke or hot gases that filter out of the area through the ventilatio'n ducts would be dissipated and cooled so as to not pose a threat to shutdown related systems in adjoining fire areas.
11.4 Conclusion Based on our evaluation, we conclude that the existing fire protection plus proposed modifications will provide an acceptable level of fire safety 08/25/83 11-2 DIABLO CANYON APPR DEVI SEC 11 J
equivalent to that provided by Section III.G.2 and, therefore, the licensee's request for a deviation in the Corridor (Fire Area 11-0) should be approved.
k t
e 4
08/25/82 11-3 DIABLO CANYON APPR DEVI SEC 11 L
- ~.
e*
l
)
12.0 Component Cooling Water Heat Exchanger Room (Fire Area 14-E) 12.1 Requested Deviation The licensee requested approval for a deviation from Section III.G.2(c) to the extent that it requires that one train of redundant shutdown equipment be completely enclosed in a 1-hour fire rated barrier.
12.2 Discussion This room is located in the southeast ccrner er the Unit 1 turbine butiding at elevatic.n 85 feet.
It is bounded by constructicn having a 3-hour fire resistance rating with all penetration; protected.
The equipment in this zone is limited to'the two component cooling water heat exchangers and three motor operated and two tir operated valves associated with the componant cooling water system and auxiliary saltwater system for safe shutdown.
In addition, cables tssociated with the auxiliary saltwater system, CCW.ystem, and diesel generator tachometer indication a e located within the area.
A reinforced concrete missile thield separates the redunannt heat exchangers, and extends approximately 2.5 feat beyond the ends of the heat exchangers.
The in situ combustible loading in the room is approximately 16,000 BTU /f ta for an equivalent fire severity of 12 minutes.
In situ combustibles are primarily cables in trays which are evenly distributed over an area of approximately 1700 square feet.
Existing fire protection includes a smoke detection system and an automatic sprinkler system which provice complete, areamwide coverage.
Manual fire fighting equipment includes portable extinguishers and fire hase stations.
08/25/82 12-1 DIABLO CANYON APPR DEVI SEC 12 m
s
. o i
i In the Appendix R Report, the licensee committed to isolata the diesel ge,nrator tacnometer circuits to prevent te possibility of diesel generator trip.
The licer.see justified the oeviation en the basis of the low fire loading, the existing fire protection, proposed modifications, and the ability to paintain
{
i or manually restore flow paths for the CCW and auxiliary saltwater system after a fire.
12.3 Evaluation The technical requirements of Section III.G.2 are r.ot met in this area because a complete 1-hour fire barrier has not bten provided around one shutdown division.
The diesel generator 1-2 and 1-3 tachometer indication circuits are run in conduit within 5 feet of each other.
Two auxiliary saltwater valves f
and the associated conduits are located less than 10 feet apart. Two component cooling water motor operated valves and tne associated corduits are located less than 20 feet apart and the component cooling water heat exchangers are l
i less than 5 feet apart.
I f
The fire load is low.
Combustible materials that could ignite are widely scattered.
This provides us with reasonable assurance that a fire, if one should occur, would propagate slowly and with initially low heat generation.
Because of the presence of a smoke detection system, we expect the fire to be 4
detected and extinguished in its initial stages before serious damage occurs.
I If the fire propagates rapidly and room temperature rises, the automatic sprinkler system will activate, to both suppress the fire and to protect the
' vulnerable shutdown systems.
Until the time that the suppression system activates or the fire brigade arrives, the concrete shield wall and the existing spatial separation between redundant division will provide a degree of passive protection, sufficient to keep o'ne division free of damage.
If the fire should result in damage to the valve circuits to the CCW motor operated valves, the valves will fail as is.
Since one is normally open and the other normally closed, and because flow through only one CCW heat exch'nger is required, safe shutdown capability will be maintained.
08/25/82 12-2 DIABLO CAF/0N APPR DEVI SEC 12
.?
4)
If the fire should result in failure of the circuits to the auxiliary saltwater valves, time is available after fire extinguishment to manually open the valves.
12.4 Conclusion Based on our evaluation, we conclude that the existing fire protection with the proposed modifications will provide an acceptable level of fire safety equivalent to that provided by Section III.G.2 and, therefore, the if censee's request for a deviation in the Component Cooling Water Heat Exchanger Room (Fire Area 14-E) should be approved.
08/25/82 12-3 OIABLO CANYON APPR DEVI SEC 12
13.0 Auxiliary Saltwater Pumps 1-1 and 1-2 (Fire Areas 30-A-1 and 30-A-2) 13.1 Requested Deviation The licensee requested arproval for deviation's from Section III.G.2 to the axtent that it requires that redundant shutdown divisions be separated by complete 3-hour fire rated barriers.
13.2 Discussion Fire area 30-A-1 housas auxiliary saltwater pump 1-1, located in the intake structure.
(The area description and exemption request for fire area 30-A-1 are identical to that of fire area 30-A-2, which houses the redundant auxiliary saltwater pump 1-2.
Conditions described in this section apply to both fire areas.)
The area is bounded by 3-hour fire barriers, including a common wall to fire area 30-A-2, and has an unrated-steel watertight door facing southwest to an adjoining fire area.
This door is equipped with a security alarm in the control room to ensure the door is closed.
The ceiling of this area is penetrated by an open metal ventilation stack to the outside and a 3-hour
. rated concrete plug to the outside.
I I
The power supply to the auxiliary saltwater pump and its associated exhaust fan is separated from the redundant train by the 3-hour rated fire barriers and the watertight doors.
Each unit has two auxiliary saltwater pumps, only one of which per unit is required for safe shutdown, and the auxiliary
(
saltwater systems can be cross-connected between units.
The in-situ fire load in these areas consists primarily of lube oil and a l
rubber boot on the pump discharge which equals about 1700 BTU /fts with an j
equivalent severity or 1.2 minutes on the ASTM E-119 time temperature curve.
1 i
08/25/82 13-1 DIABLO CANYON APPR DEVI SEC 13 j
i l
1 l
J l
l
?
Existing fire protection in each of the rooms includes smoke detectors immediately outside the entrance to these areas, portable fire extinguishers and manual hose stations.
The licensee justified the deviations on the bases of the low fire loading, the ability of the watertight doors to limit fire spread and the existing fire 4
protection.
13.3 Evaluation The technical requirements of Section III.G.2 are not met in these areas because the watertight doors are not 3-hour _ fire rated.
We were concerned that the steel, watertight door would not prevent the passage of smoke and heat through the doorway.
The fire load within the pump room and on the Iltake Structure side of the door is negligible.
Combustible materials are widely dispersed.
Consequently any postulated fire would not produce a temperature rise of sufficient magnitude to affect the stability of the door.
The effects of a fire in the Intake Structure would also be dissipated throughout the area and not concentrated near the doorway.
Because of the smoke detection system, a fire, if one should occur, would be detected in its initial stages and suppressed by the fire brigade before significant damage occurred.
During the time delay between the advent of a j
fire and'its eventual extinguishment, the door,.because of its substantial steel construction and watertight nature, would be able to confire smoke and hot gases to one side of the barrier and, thus, provide reasonable assurance that one shutdown division would remain free of damage.
13.4 Conclusion Based on our evaluation, we conclude that the existing fire protection will i
provide an acceptable level of fire safety equivalent to that provided by Section III.G.2 and, therefore, the licensee's request for deviations for the j
auxiliary saltwater Pump Rooms (Fire Areas 30-A-1 and 30-A-2) should be approved.
08/25/82 13-2 DIABLO CANYON APPR DEVI SEC 13
14.0 Diesel Fuel Oil Transfer Pump Vaults (Fire Areas 35-A and 35-B) 14.1 Requested Deviation The licensee requested approval for deviations from Section III.G.2 to the extent that it requires that redundant shutdown divisions be separated by complete 3-hour fire rated barriers.
14.2 Discussion These areas house diesel fuel oil transfer pumps 0-1 (Fire area 35-A) and 0-2 (Fire area 35-8), associatea fuel oil piping, and power control circuitry.
These areas lie ur. der the turbine building seismic buttress support below elevation 85 feet, which houses the condensate polishing system.
Conditions described in this section apply to both fire areas.
Each fire area is bounded by minimum 3-hour rated barriers with the following exceptions:
A curbed personnel hatch in the ceiling of each area communicates with the buttress area above.
A 3/8-inch thick, locked steel cover protects these openings.
Concrete hatches provide restricted access to the areas for equipment removal.
Caulked gaps of approximately 1/4 inch in width may exist between the concrete hatch pieces.
Each fire area communicates with the associated fuel oil piping trench through an open p-ipeway (less than 30 square inch area).
The pipe trench associated with pump 0-1 is separated from the pipe trench for pump 0-2 hy a 6 inch reinforced concrete vertical barrier.
A single pipe penetra-tion in this barrier is sealed.
Each pipe trench is provided with concrete trench covers.
08/25/82 14-1 DIABLO CANYON APPP DEVI SEC 14
i 4
4 Each area encompasses an approximate floor area of 110 fts.
In situ combustible loading is approximately 141,370 BTU /fts with an equivalent severity of 106 min-utes on the ASTM E-119 time temperature curve and is comprised of fuel oil in the pump, piping, strainers, and filter.
Existing fire protection includes manual hose stations and portable fire extinguishers.
The licensee justified the deviations on the basis of the ability of the existing construction to withstand a postulated fire exposure, the potential for early fire detection by personnel in the area or by secuirty cameras, and the existing fire protection.
14.3 Evaluation C
The technical requirements of Section III.G.2 are not met because the personnel and equipment hatches providing access to the vaults are not 3-hour fire rated.
Although the fire load within the vaults represents a potentially severe fire exposure if combustible material were ignited, the air supply necessary to support vigorous burning is limited.
Consequently, the restricted air supply would act to limit the fire and produce large quantities of s'mo'ke due to incomplete combustion.
The smoke would be detected either by security cameras which survey the area or operating personnel.
During the time delay between the advent of a fire and its eventual extinguishment, the reinforced concrete construction of the vault and trench, along with the steel hatches, would provide sufficient passive fire protection to assure that one division would be free of fire damage.
Another credible fire scenario would be a flammable liquid spill on elevation 85 feet with ignition.
However, because of the curbing around the personnel hatch, the caulking for the equipment, hatch pieces and the 25 foot separation with intervening buttress wall between the hatch covers, a fire of this nature under worst-case assumptions would only cause damage to one shutdown division.
08/25/82 14-2 DIABLO CANYON APPR DEVI SEC 14 l
. ~
6 14.4 Conclusion Based on our evaluation, we conclude that the existing fire protection will provide an acceptable level of safety, equivalent to that provided by Section III.G.2 and, therefore, the licensee's request for a deviation in the Diesel Fuel Oil Transfer Pump Vaults (Fire Areas 35-A and 35-B) should be approved.
e 08/25/82 14-3 DIABLO CANYON APPR DEVI SEC 14
-s 4
15.0 Aux. Buildina and Fuel Handlina Buildina (Fire Area AB-1) 15.1 Requested Deviation The licensee requested approval for two deviations from Section III.G.2(c) in this fire area to the extent that it requires the installation of complete, area-wide automatic fire suppression systems.
15.2 Discussion This area encompasses the main portion of the auxiliary building from eleva-tion 54 to 140 feet and fuel pool and machine shop areas of the fuel handling building from elevation 99 to 140 feet.
For purposes of analyses, the licensee divided the area into numerous zones.
However, because the boundaries of these zones contain a significant number of unprotected vents, equipment hatches, manways, ducts, pipeways, electrical raceways and other diverse openings, we consider this portion of the plant as a single fire area.
Within this large area the licensee identified two locations where the technical requirements.of Section III.G.2 are not met.
1.
On elevation 75 feet of the Auxiliary Building, circuitry for diesel i
generator fuel transfer pumps 0-1 and 0-2 are located in the Drain Recovery and Gas Decay Tanks area (Fire Zone 3-C) and the Unit 1 Component Cooling Water Pump 1-1 area (Fire Zone 3-J-1).
They are separated by a distance of 15 feet.
The conduits containing the circuits for fuel transfer pump 0-1 (zone 3-J-1) are completely enclosed in a 2-hour fire rated barrier.
The fire load in zone 3-C consists primarily of oil in pumps and compressors and cable insulation.
It equals approximately 2800 BTU /fts
. with an equivalent severity of 2.3 minutes.
The combustible loading in 08/25/82 15-1 DIABLO CANYON APPR DEVI SEC 15
__,,,,_.___,,._,.-_m.mm.,,_
, _ _ - _ _,. - _ _ _ _, _ _,, _, _... - _ _ _.. - _ -, _ _, _.. _ _ _. _ _. -. _., _. _,. ~ _ _ _... _
. [
fire zone 3-J-1, consisting primarily of oil and cable insulation is i
36,900 BTU /ft2 with an equivalent severity of 27.7 minutes.
4 Existing fire protection includes an automatic sprinkler system and a smoke detection system in zone 3-J-1, a smoke detection system on this elevation of zone 3-C, manual fire hose stations and portable fire-extinguishers.
The common boundary between these fire zones is open,
-but is.provided with a 4-inch curb to prevent oil spillage from communicating zones.
2.
On elevation 75 feet of the Auxiliary Building, the component cooling water pumps are located in individual cubicles.
Each cubicle is bounded by i
{
walls having a 3-hour fire rating, except that the common walls between cubicles contain unprotected pipe and duct penetrations,, and the south perimeter wall is open to fire zone 3-C.
A 4-inch curb is provided at this opening to prevent oil spillage from spreading to this zone.
The pumps themselves are approximately 5 feet apart, separated by the partial fire wall.
The control circuitry for charging pumps 1-1, 1-2, and 1-3 is routed through fire zones 3-J-2 and 3-J-3.
However, the_ starting circuitry for i
each pump can be bypassed by individual switches located in the switchgear of fire area TB-4 for charging pump 1-1 and fire area TB-5 for charging pumps 1-2 and 1-3.
The in situ fire load in each of zones 3-J-1, 3-J-2, and 3-J-3 consists l
primarily of oil and cable insulation.
It equals approximately 11,150 BTU /fta for 3-J-1 and 3-J-2 and 6607 BTU /f ts for 3-J-3 with an equivalent severity of l
approximately 8.4 minutes and 5 minutes, respectively, on the ASTM E-119 time temperature curve. The combustible loading in adjacent zone 3-C is approximately 2800 BTU /fts with an equivalent severity of approximately 2 minutes.
Each pump cubicle is provided with automatic smoke detection and a wet pipe sprinkler system.
Smoke detection is provided throughout zone 3-C on elevations j
64 and 75 feet.
Additional protection includes portable fire extinguishers and manual hose stations.
08/25/82 15-2 DIABLO CANYON APPR DEVI SEC 15 r-e
-- - + + - - ' -
-*-v----
,6,+w
--v--e-
vw-en-wrevv--=--T---
-w,---*-g-wewm-----*-------
=.--ee
- ----+---------
4 l
The licensee justified the deviations in, these two locations ~ on the basis of I
the limited fire loading, the likely spread of hot gases up into the ceiling area away from the vulnerable shutdown systems, the existing passive fire protection including spatial separation and fire barriers, the automatic fire protection systems and manual fire fighting equipment.
15.3 Evaluation The technical requirements of Section III.G.2 are not met in these locations because of the lack of an area-wide automatic fire suppression system in zone 3-C.
l i
There are two concerns with these areas.
The first is that a fire within the j
fire zones may damage systems from both shutdown divisions.
The second is that a fire that originates outside of these areas, in Fire Zone 3-C, may spread into the fire zones and damage vulnerable shutdown systems.
+
If a fire were to occur within any of the three zones the existing smoke detection system would activate during the early stages of a fire and summon the fire brigade.
If room temperature rose significantly, the automatic sprinkler system would activate and suppress the fire while protecting the exposed shutdown systems.
Until the fire burned itself out, was extinguished manually by the fire brigade or automatically by the fire suppression system, s
enough passive fire protection is available to assure that one train remained free of damage.
This protection includes 15 feet of spatial separation and a.
2-hour fire barrier for the fuel transfer pump circuitry.
For the component cooling water pumps and related cabling, the protection consists of the partial fire walls separating the cubicles.
If a fire were to occur in either zone 3-J-2 or 3-J-3, where no passive protection exists between CCW circuity, i
the licensee has identified an independent means of starting the pumps from another fire area, i
i If a fire were to occur outside of these cubicles in zone 3-C, smoke and heat resulting from the fire would be dissipated throughout the area which would act as a heat sink. We expect the smoke detection system to activate and j
summon the fire brigade who would extinguish the fire before it would threaten 08/25/82 15-3 DIABLO CANYON APPR DEVI SEC 15
l s
the systems within the cubicles.
If a significant temperature rise did occur within the cubicles, the sprinkler system would activate to protect the exposed systems.
Therefore, a suppression system in zone 3-C would not enhance the fire protection level, and we have reasonable assurance that one shutdown divi-sion would remain free of fire damage.
15.4 Conclusion Based on our evaluation, we conclude that the existing fire protection will provide an acceptable level of fire safety, equivalent to that provided by Section III.G.2 and, therefore, the licensee's request for deviations in the Auxiliary Building and Fuel Handling Building (Fire Area AB-1) should be approved.
0 08/25/82 15-4 DIABLO CANYON APPR DEVI SEC 15
i 4
e 16.0 Diesel Generator-Rooms (Fire Areas TB-1, TB-2 and TB-3) 16.1 Requested Deviation 1
The licensee requested approval for deviations from Section III.G.2(a) in these areas to the extent that it requires that redundant shutdown divisions be separated by complete 3-hour fire rated barriers.
16.2 Discussion Fire areas TB 1, TB-2, and TB-3 are separate fire areas containing the emergency diesel generators, and their associated air supply and exhaust equipment.
Two of the three diesel generators are required for safe shutdown. These fire areas are situated side by side, with fire area TB-2 located between fire area T8-3 to the south and TB-1 to the north.
I These areas are located at the northwest corner of the Unit 1 turbine building at elevations 85 and 107 feet.
They are divided into two fire zones each to i
differentiate between the generator rooms and the ventilation intake and exhaust rooms, i
The areas are bounded by walls, floors and ceilings of 3-hour fire rated construction with the following exceptions:
I The north and west perimeter walls contain unprotected louvers to the outside.
The rooms are separated from an adjoining fire area on elevation 107 feet l
by a 3-hour fire rated barrier with unrated metal hatches.
I l
An unrated steel hatch and 1-inch thick sliding steel shield door I
(normally locked shut) are located in the perimeter walls of fire area TB-3.
08/25/82 16-1 DIA8LO CANYON APPR DEVI SEC 16 t
,,--,l----
e
, - - -,,_--,---,,.&-.'i'**
"~~%
~
~,_ ~
,,--~-:**?*$.-,
L The in situ fire load within each area is approximately 150,800 BTU /fts with an equivalent severity of 113 minutes.
The combustible loading is comprised primarily of diesel fuel and lubricating oil.
Existing fire protection includes complete automatic fire detection and carbon dioxide fire suppression systems in the diesel generator room, manual hose stations and portable fire extinguishets.
The rooms have a floor drain system and are also provided with curbs at door openings on elevation 85 feet to con-4 tain oil spills.
In the July 15, 1983 Appendix R Report, the licensee committed to upgrade the sheet metal personnel and equipment hatches on elevation 107 feet to achieve'a one hour fire rating.
l The licensee justified the deviations on the basis of the existing and proposed fire :)rotection.
16.3 Evaluation The technical requirements of Section III.G.2 are not met in these areas because the perimeter construction is not completely 3-hour fire rated.
Our principal concern is that a fire which originates within any one of these l
areas would propagate beyond the perimeter walls and damage redundant shutdown systems in other fire areas.
However, within the generator rooms themselves, any postulated fire would be detected and extinguished by the automatic carbon dioxide system.
Activation of the CO system would be annunciated in the 2
control room, which would summon the fire brigade.
Until the arrival of the fire brigade, the walls, floor and ceiling would confine the damage to the i
area of origin.
1 Within the ventilation intake and exhaust rooms the fire hazard is minimal.
Because of the limited combustibles any postulated fire would be of limited f
magnitude and extent.
Smoke and hot gases would either be vented outside I
08/25/82 16-2 OIA8LO CANYON APPR DEVI SEC 16 i
--v
-.-w
,-,c%,-,-y3-.-,y, w,w -,,w.
,,--,m
,--.w
,w,w
,,,,,n r,-.w,---m.s
through the lourers.in the exterior wall or confined within the area by the fire rated perimeter construction and the steel hatches and door until the fire brigade arrived.
16.4 Conclusion Based on our evaluation, we conclude that the existing fire protection will provide an acceptable level of safety, equivalent to that provided by Section III.G.2 and, therefore, the licensee's request for deviations in the Diesel Generator Room (Fire Areas TB-1, TB-2, and TB-3) should be approved.
l l
08/25/82 16-3 DIA8LO CANYON APPR DEVI SEC 16 l
,m.-r.
I i
l 17.0 Fire Doors 17.1 Requested Deviation 4
The licensee requested blanket approval for deviations from Section III.G.2 to the extent that it requires that doors installed in fire rated barriers, which separate redundant shutdown divisions, have a fire rating equal to the barrier.
17.2 Discussion 1
l Approximately fifty percent of the U.L. listed 3 and 1 -hour fire rated doors in the plant have been installed in unlisted frames.
In addition, doors of metal construction that are not fire rated have been installed in both listed and unlisted frames in several areas.
Also, unlisted metal panels, installed i
in conjunction with doors, have been provided for protection of large fire area barrier openings r.eeded for equipment access.
i The licensee justifies the deviation on the basis that the construction and i
installation of the doors, frames and panels are similar to those that are I
fire rated and listed by an independent testing laboratory.
17.3 Evaluation i
The technical requirements of Section III.G are not met because the protection for door openings in fire barriers which separate redundant shutdown divisions have not been tested to withstand anticipated fire exposures as defined by the time-temperature curve of ASTM E-119.
Our concern is that because the doors, frames and panels have not been analyzed by an independent testing laboratory, they may fail under fire conditions while the plant is in operation and serious damage may occur to redundant shutdown systems.
Because approximately 50 percent of the door frames in the plant are j
unlisted, we also have concerns about the quality control program implementation.
08/25/82 17-1 DIA8LO CANYON APPR DEVI SEC 17 9-y.m-,-
-r wmm-me
,a-
--r-w--emey g--yggu m mmew=-g yy y - ww
---v-gy--w wwc-ww wr m new '
v'--
o a
Without actual test results on the unlisted doors, frames and panels or without a U.L. on FM label on the components, we have no reasonable way of knowing how they will' perform under fire conditions.
Consequently, we do not have reason-able assurance that one train of shutdown systems would remain free of fire damage.
The licensee has not identified all of the areas where unlisted frames and metal panels have been installed.
No fire hazard analyses was performed or compensating fire protection identified.
Consequently, the magnitude of the fire safety problem as it relates to Appendix R compliance is at this time unknown.
17.4 Conclusion Based on our evaluation, we conclude that the existing unlisted doors, frames and panels do not achieve an equivalent level of fire safety to that provided by lection III.G.2 and, therefore, the licensee's request of a deviation for these components should be denied.
9 08/25/82 17-2 DIABLO CANYON APPR DEVI SEC 17
i l
i 18.0 Steel Hatches i
18.1 Reauested Deviation The licensee requested approval for deviations from Section III.G.2 to the extent that it requires that hatches installed in fire rated barriers, which separate redundant shutdown divisions, have a fire rating equal to the barrier.
18.2. Discussion One-inch thick steel access hatches are located in the following plant areas:
The ceiling of the showers, lockers, and access control area (Fire Area 4-8)
I i
The floor and ceiling of the hot shutdown and non-vital switchgear room (Fire Area 5-A-4)
+ The floor and ceiling of the electrical area west of the battery room (Fire Area 6-A-5)
The floor of the cable spreading room (Fire Area 7-A).
Excluding the cable spreading room, the above areas are described in Sections j
8, 9 and 10, respectively, of this report.
i The cable spreading room is bounded by walls, floors and ceiling of 3-hour fire rated construction with the following exceptions:
j The unrated steel hatch in the floor
- An unprotected duct penetration and unrated fire doors in the perimeter l
walls.
l t
j 08/25/82 18-1 DIA8LO CANYON APPR DEVI SEC 18 l
m s-Safe shutdown systems in the room include cables and components for the following systems:
auxiliary feedwater auxiliary saltwater charging and boration
+ component cooling water emergency power
+ safe shutdown instrumentation
+ residual heat removal The stutdown related circuits are listed in Table 3-4 of the licensee's Appendix R report.
Existing fire protection includes an area-wide automatic carbon dioxide fire suppression system, a complete smoke detection system, manual hose stations and portable fire extinguishers.
The licensee justified these deviations on the basis of previous staff approval.
18.3 Evaluation The technical requirements of Section III.G.2 are not met in this instance because the steel hatches have not been tested by an Independent authority to withstand anticipated fire exposures as defined by the time temperature curve of ASTM E-119.
The principal concern with the steel hatches is that they would not be able to limit the spread of fire to the area of origin until either manual or automatic fire extinguishment.
We have reviewed the acceptability of the fire protection in Fire Areas 4-B, 5-A-4, and 6-A-5, including the hatches, in Sections 8, 9 and 10 of this 08/25/82 18-2 DIA8LO CANYON APPR DEVI SEC 18
o 4
report.
We concluded that, on the bases of the limited fire load, and the existing active fire protection systems, the steel hatches would be able to prevent the passage of products of combustion to adjoining areas until the fire brigade arrived or the fire was extinguished automatically.
In the cable spreading room, the hatch is located in the floor.
Because the smoke and hot gases from a fire rise to the ceiling, we are not concerned that the floor hatch will be breached and products of combustion penetrate into the area below (Fire Area 6-A-5).
Nevertheless, the cable spreading room is equipped with an automatic fire detection and carbon dioxide fire suppression system.
We, therefore, have reasonable assurance that a fire, if one should occur, would be detected early and extinguished manually by the fire' brigade or automatically by the CO: system before serious damage occurred.
We have evaluated the ability of the floor hatch to prevent damage from a fire below (in Fire Area 6-A-5) in Section 10 of this report.
18.4 Conclusion Based on our evaluation, we conclude that the steel hatches in the following areas will provide an acceptable level of safety, equivalent to that provided by Section III.G.2 and, therefore, the licensee's request for deviations in these areas should be approved:
Showers, Lockers and Access Control Area (Fire Area 4-8) i Electrical Area West of Battery Room (Fire Area 6-A-5)
Hot Shutdown and Switchgear Room (Fire Area 5-A-4)
J Cable Spreading Ro,om (Fire Area 7-A)
)
i l
i j
08/25/82 18-3 OIA8LO CANYON APPR DEV! SEC 18 I
i n.
n n.
_,,,,,,,_,,_.,,,,,,,,__c
4 1
19.0 Emeroency Lichtina 19.1 Reauested Deviation The licensee requested approval for a deviation from Section III.J to the extent that it requires that emergency lighting units with at least an 8-hour battery supply be provided in all areas net.ded for operation of. safe shutdown equipmentandinaccessandegressroutesdhereto.
19.2 Discussion Emergency lighting at the plant consists c'f three independent systems:
1.
Emergency AC Lighting System; 2.
Emergency DC Lighting System; and 3.
Emergency Self Contained Lighting, Sealed Beam Lights with 8-hour battery supply.
Locations required for safe shutdown that.tre provided with self contained lighting units are listed in Section 4.1 of the July 15, 1983 Appendix R Report.
In addition, the licensee evaluated other areas.where credit was taken for manual operation of equipment to achieve safe shutdown.
These locations are listed in Section 4.2 of the Appendix R Report.
They were evaluated for potential loss of the emergency AC lighting system to determine if 8-hour battery pack lights were required or a modification of the emergency AC lighting system was necessary to prevent fire damage.
As a result of that analysis, the licensee coiunitted in Section 4.3 of the i
Appendix R Report to provide additional battery powered emergency lighting units or modify the AC system (by protecting or rewiring circuits) in the j
following areas.
I 08/25/82 19-1 DIA8LO CANYON APPR DEVI SEC 19 1
CCW Heat Exchanger Room (Fire Area 14-E) j Corridor (Fire Zone 14-A)
Stairway (Fire Area S-1) at elevation 140 feet i
Hot Shutdown Panel Area (Fire Area 5-A-4)
Boric Acid and Waste Evaporator Area (Fire Zone 3-L)
In the remaining areas the licensee concluded on the basis of its. analysis that the existing AC lighting was sufficiently reliable to justify the absence of 8-hour battery powered lighting units.
19.3 Evaluation The technical requirements of Section III.L. are not met in this instance because all areas needed for operation of safe shutdown equipment and access routes to these areas are not provided with 8-hour battery powered lighting units.
We are concerned that if a fire occurred, it would damage portions of the AC i
lighting system such that no emergency lighting would be available in areas j
needed for operation of safe shutdown equipment.
The licensee has conducted an analysis of the AC system and concluded that with the exception of those areas listed in Section 20.2, the system is "sufficiently reliable." However, the licensee has not provided enough information for our independent review.
Consequently, we do not have reason-able assurance that the licensee has considered all relevant factors.
19.4 Conclusion Based on our evaluation, we conclude that reliance on the AC lighting system will not achieve an acceptable margin of safety equivalent to that provided by i
l the '.echnical requirements of Section III.J.
Therefore, the licensee's request for a deviation should be denied.
l l
1 l
l l
08/25/82 19-2 DIA8LO CANYON APPR DEVI SEC 19 i
i
,;s-l 20.0 RCP Oil Collection System 20.1 Requested Deviation The licensee requested approval of a deviation from Section III.0 to the extent that it requires that any overflow from oil collection tank (s) be drained to a safe location when the collection system is designed to provide capacity to hold the lube oil inventory of one reactor coolant pump with r.argi n.
23.2 Discussion The RCPs are located in two areas within containment fire zone 1-B.
The biological shield wall separates zone 1-B into two areas (north and south) above elevation 110 feet.
Each RCP is above this elevation, and therefore the biological shield serves as a barrier between the north area in which RCP 1-1 and 1-2 are located and the south area in which RCPs 1-3 and 1-4 are located.
The north a.nd south areas communicate through open areas from approximately elevation 110 feet to the containment floor slab at elevation 91 feet and through open ventilation gratings above each RCP at elevation.'W feet.
Each RCP is separated from the others by approximately 45 feet.
The lubricating oil system for the RCP. motor consists of two parts, the upper I
oil pot and the lower oil pot (240 gallons) and oil pan (25 gallons).
The oil collection system consists of a series of collection pans surrounding each pump draining to a lube oil collection tank.
The collection pans surrounding each pump consist of 18 gage sheet metal fastened to the platform grating at elevation 110 feet.
All openings through and between the collection pans for conduit, pipes, etc., are surrounded by drip shields draining to the collection pans.
A skirt is installed around the pump motor coupling to direct leaks on the outside of the motor casing (upper 08/25/82 20-1 DIA8LO CANYON APPR DEVI SEC 20 l. _ _. _
9,.
af j
lube oil cooler, level instrumentation, etc.) to the collection pans below.
The oil lift pump and piping is enclosed by a sheet metal shield and spray from a potential oil lift pump leak would be confined to within the shield and the oil directed to the collection pans.
Leaks internal to the motor casing are diverted to the collection pans below by a gutter inside the coupling area or collected above the main pump flange.
The main pump flange is surrounded by a 2-inch ria with an overflow drain to the collection pans.
All joints are caulked to prevent leakage.
j Each collection pan is equipped with a drain pipe connected to a drain line.
l The crain lines for each pump connect to a 2-inch common haader, and enter the i
containment annulus through penetrations in the shield wall.
The common header i
drain line is routed to an oil collection tank located under the fuel transfer canal in the containment annulus at elevation 91 feet.
j The RCP oil collection tank has a 300 gallon capacity and is equipped with a valved drain, a 2 inch overflow, and a 2 inch vent.
The vent is equipped with a flame arrester.
The tank is designed to contain the oil inventory of one j
RCP motor plus a margin of 35 gallons.
A wet pipe automatic sprinkler system is provided for each RCP.
The water flow alarm annunciates in the continuous manned control room.
)
i A smoke detector is provided each RCP and the corresponding steam generator.
I Additional detectors are provided in the containment annulus in the ekhaust i
air flow path for zone 1-B.
k Additional fire protection includes portable fire extinguishers and manual l
fire hose stations.
l The licensee justifies the deviation on the basis of the desi n of the oil 0
collection system, the existing fire protection, the use of high flashpoint i
lube oil, the lack of a source of ignition for the oil, and the routing of i
l safe shutdown circuits in conduit.
1
)
l I
i 08/25/82 20-2 DIABLO CANYON APPR DEVI SEC 20 i
I
_::~12:7*= ~;2~" ~*~~~~~r ~ ~ m -... -.
"v=-~~*
- ?:r ~ m: : ~ ~ ~~ ~ : "~m.r ~ : = = m ---
sn, 1, P 20.3 Evaluation The technical requirements of Section III.0 are not met because the oil hold-ing tanks are not large encugh to hold the entire lube oil system inventory for the four RCPs.
We are concerne'd that if overflowing lube oil ignited, the resulting fire would damage shutdown systems.
In a significant seismic event, we postulate the loss of the oil inventory for all four RCPs.
The lube oil will then over-flow the holding tanks and accumulate in a recessed trench in the elevation 91 feet floor. The trench is sloped so that the spilling oil would flow to the containment drain sump.
Safe shutdown systems are located in the area and would be vulnerable if the oil ignited.
The existing sprinkler system only covers the RCPs and would, therefore, offer no protection to the exposed systems.
A partial smoke detec-tion system exists, but by the time a fire were detected and the plant fire brigade intervened, redundant shutdown divisions might be damaged.
i 20.4 Conclusion Based on our evaluation, we conclude that the existing design of the oil collec-tion system holding tanks does not achieve an equivalent level of fire safety to that provided'by Section 111.0 and, therefore, the licensee's request for a deviation should be denied.
08/25/83 20-3 DIABLO CANYON APPR DEVI SEC 20
e 21.0 Summary Based on our evaluation, we find that the level of fire safety in the areas listed below is equivalent to that achieved by compliance with the technical requiFements of Section III.G of Appendix R and, therefore, the licensee's request for approved deviations in these areas should be granted:
1.
RHR Pump 1-1 and Heat Exchanger Room (Fire Area 3-B-1) 2.
RHR Pump 1-2 and Heat Exchanger Room (Fire Area 3-B-2) 3.
Centrifugal Charging Pumps Room (Fire Area 3-H-1) 4.
Reciprocal Charging Pump Room (Fire Area 3-H-2) g 5.
Turbine Driven Auxiliary Feed Pump (Fire Area'3-Q-1) 6.
4.16 KV Switchgear Fan Room (Fire Area 13-E) 7.
Chem. Lab and Offices (Fire Area 4-A) 8.
G Bus Compartment (Fire Area 4-A-1) 9.
H Bus Compartment (Fire Area 4-A-2) i 10.
Shower, Locker and Access Control (Fire Area 4-B) 11.
Hot Shutdown Panel and Non-Vital Switchgear Room (Fire Area 5-A-4) 12.
Control Room Complex (Fire Area CR-1) j 13.
Electrical Area West of Battery Room (Fire Area 6-A-5) l i
14,.
Corridor Outside Diesel Generator Room (Fire Area 11-D) i 15.
Component Cooling Water Heat Exchanger (Fire Area 14-E) l 16.
Auxiliary Saltwater Pumps 1-1 and 1-2 (Fire Areas 30-A-1/30-A-2) l 17.
Diesel Fuel Oil Transfer Pump Vaults (Fire Areas 35-A/35-8) i 18.
Auxiliary Building and Fuel Handling Building (Fire Area A8-1) 19.
Diesel Generator Rooms (Fire Areau TB-1/TB-2/TB-3) i 20.
Steel Hatches Based on our evaluation, we also conclude that the protection provided for the i
I areas listed below does not provide an equivalent level of safety and, there-t fore, the licensee's request for approved deviation in these areas should be i
I denied:
l t
l i
1 08/25/82 21-1 DIA8LO CANYON APPR DEVI SEC 21 l
l
.. =
. = =
- e, )o
-o B,-
1.
Centainment (Fire Area 1) i 2.
Penetration Area (Fire Area 3-BB) 3.
Unlabeled Fire Doors (Generic) 4.
5.
RCP Oil Collection System (Containment Zone 1-B) i i
1 i
d 08/25/82 21-2 OIABLO CANYON APPR DEVI SEC 21 l
l
{
'