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c UNITED STATES fi NUCLEAR REGULATORY COMMISSION 3
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,h J1:3, v, j WASHING To N. D. C. 20555
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. 1 198 NOV Docket No. 50-275 MEMORANDUM FOR:
for ucensing Division of Licensing FROM:
William V. Johnston, Assistant Director Materials, Chemical & Environmental Technology Division of Engineering
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 Co.
Docket No.:
50-275 Responsible Branch:
LB #3 Project Manager:
B. Buckley CMEB Reviewer:
D. J. Kubicki Status:
Compliance with Section III.J. of Appendix R is open By letter dated July 5, 1983, the licensee provided an Appendix R evaluation for the plant.
Thirty-two fire areas were determined tc 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 cther 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 111.0.
In our September 7, 1983 evaluation of this information, we concluded that the level of fire safety in twenty-one plant areas was equivalent to that achieved by compliance with the technical requirements of Appendix R and, therefore, recommended that the licensee's request for approved deviations in these areas be granted.
Based on our evaluation, we also concluded that the protection provided for five areas did not achieve an equivalent level of safety to that of Appendix R and, therefore, recommended that the licensee's request for approved deviations in the following areas be denied:
1 Containment (Fire Area 1) 2.
Peretration Area (Fire Area 3-88) 3.
Unlabeled Fire Doors (Generic) 4 Emergency Lighting 5.
RCP 011 Collection System (Containment Zone 1-8)
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lOf 1199 Thomas M. Novak By letters dated September 23 and 27,-October 3, 6, 11 and 14, 1983, the licensee provided additional information.
Our evaluation of the information pertaining to Items 1, 2, 3 and 5 is enclosed.
Based on our evaluation, we conclude that the licensee's request for approved deviation in Containment (Fire Area 1) is no longer necessary.
We also conclude that the level of fire safety in the following areas is equivalent to that achieved by compliance with Appendix R and, therefore, the licensee's request for approved deviations in these areas be granted:
" Penetration Area
" Unlabeled Fire Doors (Generic)
- RCP Oil Collection System (Containment Zone 1-B)
The information pertaining to Emergency Lighting is being reviewed by the Auxiliary Systems Branch.
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,.,$ k.d William V. Johnston, Assistant Director Materials, Chemical & Environmental Technology Division of Engineering
Enclosure:
As stated
Contact:
D. J. Kubicki x27743 cc:
R. Vollmer F. Nolan V. Benaroya S. Ebneter, Region I R. Ferguson T. Conlon, Region II T. Wambach C. Norelius, Region III S. Trubatch G. Madsen, Region IV R. Eberly P. Sternberg, Region V S. Pawlicki D. Notley T. Sullivan W. Shields
- 0. Parr D. Eisenhut J. Wermiel F. Rosa J. Taylor M. Srinivasan J. Stang G. Knighton D. Kubicki B. Buckley H. Schierling
o REQUEST FOR APPROVED DEVIATIONS DIABLO CANYON - UNIT 1 DOCKET NO. 50-275
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CONTENTS
.P. age 1
INTRODUCTION......................................................
1-1 2
CONTAINMENT (FIRE AREA 1).........................................
2-1 2.1 Requested Deviation..........................................
2-1 2.2 Discussion...................................................
2-1 2.3 Evaluation...................................................
2-2 2.4 Conclusion...................................................
2-2 3
RHR PUMP 1-1 At?D HEAT EXCHANGER ROOM (FIRE AREA 3-B-1)............
3-1 RHR PUMP 1-2'ANC HEAT EXCHANGER ROOM (FIRE AREA 3-B-2) 3.1 Requested Deviation..........................................
3-1 3.2 Discussion...................................................
'3-1 3.2.1 Fire Area 3-B-1.......................................
3-1 3.2.2 Fire Area 3-B-2.......................................
3-1 3.3 Evaluation...................................................
3-2 3.4 Conclusion...................................................
3-3 4
CENTRIFUGAL CHARGING PUMPS 1-1 and 1-2 ROOM (FIRE AREA 3-H-1).....
4-1 RECIPROCAL CHARGING PUMP ROOM (FIRE AREA 3-H-2)
TL'RBINE-DRIVEN AUXILIARY FEED PUMP (FIRE AREA 3-Q-1) 4.16-KV SWITCH GEAR VENTILATION FAN ROOM (FIRE AREA 13-E) 4.1 Requested Deviation..........................................
4-1 4.2 Discussion...................................................
4-1 4.2.1 Fire Area 3-H-1.......................................
4-1 4.2.2 Fire Area 3-H-2.......................................
4-1 4.2.3 Fire Area 3-Q-1.......................................
4-2 4.2.4 Fire Area 13-E........................................
4-2 4.3 Evaluation...................................................
4-3 4.4 Conclusion...................................................
4-3 5
PENETRATION AREA (FIRE AREA 3-BB).................................
5-1 5.1 Requested Deviation..........................................
5-1 5.2 Discussicn...................................................
5-1 5.3 Evaluation...................................................
5-2 5.4 Conclusion...................................................
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CONTENTS (Continued)
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CHEMICAL LABORATORY AND OFFICES (FIRE AREA 4-A)...................
6-1 6.1 Requested Deviation..........................................
6-1 6.2 Discussion...................................................
6-1 6.3 Evaluation...................................................
6-2 6.4 Conclusion...................................................
6-3 7
G BUS COMPARTMENT (FIRE AREA 4-A-1)...............................
7-1 H BUS COMPARTMENT (FIRE AREA 4-A-2) 7.1 Requested Deviation..........................................
7-1 7.2 Discussion...................................................
7-1 7.2.1 Fire Area 4-A-1.......................................
7-1 7.2.2 Fire Area 4-A-2.......................................
7-1 7.3 Evaluation...................................................
7-2 7.4 Conclusion...................................................
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SHOWERS, LOCKERS, AND ACCESS CONTROL (FIRE AREA 4-B)..............
8-1 8.1 Requested Deviation..........................................
8-1 8.2 Discussion...................................................
8-1 8.3 Evaluation...................................................
8-2 8.4 Conclusion...................................................
8-2 9
HOT SHUTDOWN PANEL AND NONVITAL SWITCHGEAR ROOM (FIRE AREA 5-A-4).
9-1 CONTROL ROOM COMPLEX (FIRE AREA CR-1) 9.1 Requested Deviation..........................................
9-1 9.2 Discussion...................................................
9-1 9.2.1 Fire Area 5-A-4.......................................
9-1 9.2.2 Fire Area CR-1.......................................
9-1 9.3 Evaluation...................................................
9-2 9.4 Conclusion...................................................
9-2 10 ELECTRICAL AREA WEST OF THE BATTERY ROOM (FIRE AREA 6-A-5)........
10-1 10.1 Requested Deviation..........................................
10-1 10.2 Discussion...................................................
10-1 10.3 Evaluation...................................................
10-1 10.4 Conclusion...................................................
10-2 11 CORRIDOR OUTSIDE THE DIESEL GENERATOR ROOM (FIRE AREA 11-D).......
11-1 11.1 Requested Deviation..........................................
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e on CONTENTS (Continued)
P_ag_e 11.2 Discussion...................................................
11-1 11.3 Evaluation...................................................
11-1 11.4 Conclusion...................................................
11-2 12 COMPONENT COOLING WATER HEAT EXCHANGER ROOM (FIRE AREA 14-E).....
12-1 12.1 Requested Deviation..........................................
12-1 12.2 Discussion ~...................................................
12-1 12.3 Evaluation...................................................
12-1 12.4 Conclusion...................................................
12-2 13 AUXILIARY SALTWATER PUMPS 1-1 AND 1-2 (FIRE AREAS 30-A-1 AND 30-A-2).......................................................
13-1 13.1 Requested Deviation..........................................
13-1 13.2 Discussion...................................................
13-1 13.3 Evaluation...................................................
13-1 13.4 Conclusion...................................................
13-2 14 DIESEL FUEL OIL TRANSFER PUMP VAULTS (FIRE AREAS 35-A AND 35-B)...
14-1 14.1 Requested Deviation..........................................
14-1 14.2 Discussion...................................................
14-1 14.3 Evaluation...................................................
14-2 14.4 Conclusion...................................................
14-2 15 AUXILIARY BUILDING AND FUEL HANDLING BUILDING (FIRE AREA AB-1)....
15-1 15.1 Requested Deviation..........................................
15-1 15.2 Discussion...................................................
15-1 15.3 Evaluation...................................................
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15.4 Conclusion...................................................
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l 16 DIESEL GENERATOR ROOMS (FIRE AREAS TB-1, TB-2, AND TB-3)..........
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l 16.1 Requested Deviation..........................................
16-1 16.2 Discussion...................................................
16-1 16.3 Evaluation...................................................
16-2 16.4 Conclusion...................................................
16-2 17 FIRE 000RS........................................................
17-1 17.1 Requested Deviation..........................................
17-1 17.2 Discussion...................................................
17-1 17.3 Evaluation...................................................
17-2 17.4 Conclusion...................................................
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CONTENTS (Continued) fa21 18 STEEL HATCHES.....................................................
18-1 18.1 Requested Deviation..........................................
18-1 18.2 Discussion...................................................
18-1 18.3 Evaluation...................................................
18-2 18.4 Conclusion...................................................
18-2 19 EMERGENCY LIGHTING................................................
19-1 19.1 Requested Deviation..........................................
19-1 19.2 Discussion...................................................
19-1 19.3 Evaluation...................................................
19-1 19.4 Conclusion...................................................
19-2 20 REACTOR COOLANT PUMP OIL COLLECTION SYSTEM........................
20-1 20.1 Requested Deviation..........................................
20-1 20.2 Discussion...................................................
20-1 20.3 Evaluation...................................................
20-2 20.4 Conclusion...................................................
20-3 21
SUMMARY
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l Request for Approved Deviations Diablo Canyon - Unit 1 Docket No. 50-275 1 INTRODUCTION By letter 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 Title 10 of the Code of Federal Regulations Part 50'(10 CFR 50).
The licensee provided this evaluation by letter dated July 15, 1983, and sup-plemental letters dated September 23 and 27, and October 3, 6, 11 and 14, 1983.
Thirty-two fire areas were determined to be in compliance with Section III.G, and two areas will be brought into compliance after plant modifications are completed.
The licensee requested approval for 22 deviations from the require-ments of Section III.G.
1pproval was requested for two other deviations from Section III.G for conditions that were not area specific', and the licensee also requested approval 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:
(1) Separation of cables and equipment and associated nonsafety circuits of redundant trains by a fire barrier having a 3-hour rating.
Structural steel forming a part of or supporting such fire barriers shall be protected to provide fire resistance equivalent to that required of the barrier.
(2)
Separation of cables and equipment and associated nonsafety 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.
(3)
Enclosure of cable and equipment and associated nonsafety 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
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in the fire area.
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If these conditions are not met,Section III.G.3 requires that there be an alternative shutdown capability independent of the fire area of concern, It also requires that a fixed suppression system be installed in the fire area of l
concern if it contains a large concentration of cables or other combustibles.
These alternative requirements are not deemed to be equivalent; however, they l
l provide equivalent protection 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 rather than the l
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design-basis fire are specified in the rule.
Plant-spicific features may require protection different from 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 tech-nical 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.
Either fire protection configurations must meet the specific requirements of Section III.G or an alterative fire protection con-figuration must be justified by a fire hazard analysis.
Generally, the staff will accept an alternative fire protection configuration if (1) The alternative ensures that one train of equipment necessary to achieve hot shutdown from either the control room or emergency control stations is free of fire damage.
(2) The alternative ensures that fire damage to at least one train of equipment necessary to achieve cold shutdown is limited so that it can be repaired within a reasonable time (minor repairs using components stored on the site).
(3) Fire-retardant coatings are not used as fire barriers.
(4) Modifications required to meet Section III.G would not enhance fire pro-tection safety levels above that provided by either existing or proposed alternatives.
(5) Modifications required to meet Section III.G would be detrimental to over-all facility safety.
The following sections of this report address each of the applicant's requests for deviations and present the staff's evaluation and conclusion regarding each request.
Section 21 summarizes the staff's review of the applicant's requests.
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g-i 2 CONTAINMENT (FIRE' AREA 1) 2.1 Requested Deviation The licensee requested approvai for a deviation from Section III.G.2 to the
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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 personnel access to various elevations within this zone.
Fire zone 1-B is a cylinder in the central part of the containment.
It is separated from fire zone 1-A by the unrated reinforced-concrete shield wall, which also serves as the support structure for the' polar crane.
This zone is separated from fire zone 1-C by the reinforced-concrete operating deck at elevation 140 feet.
Fire zone 1-C *ncludes 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-concrate containment wall.
The floor of fire zone 1-C is constructed of reinforced concrete with openings for stairways and open floor gratings for equipment access.
The equipment and cables required for safe shutdown that are located in the fire area are (1) residual heat removal (RHR) pump suction valves (2) valves-in the charging and boration flow path and related cabling (3) reactor coolant system (RCS) and steam generator instrumentation and circuitry (4) steam generator blowdown isolation valves and RCS temperature elements (5) safe shutdown circuits listed in Table 3-4 of the licensee's July 15, 1983 l
Appendix R report.
2 The in situ combustible fire loading in the area is approximately 26,200 Btu /ft l
or an~ equivalent severity of 19.6 minutes on the time-temperature curve of l
Standard E-119 of the American Society for Testing and Materials (ASTM E-119).
I The fire load consists primarily of oil in reactor coolant pumps, cable in cable 2-1 l
trays, grease in valve operators, oil and grsase in the crana cnd 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 extin-guishers; and manual hose stations.
By letter dated September 23, 1983, the licensee committed to provide either a radiant energy shield or a 1-hour fire-rated barrier between reactor coolant temperature instrumentation where redundant divisions are less than 20 feet apart.
2.3 Evaluation With the installation of a 1-hour fire-rated barrier or radiant energy shield between redundant reactor coolant temperature instrumentation, the technical requirements of Section III.G.2 will be met in containment.
Originally, the staff was also concerned with the fire protection for the above instrumentation as well as the pressurizer liquid level instrument lines.
How-ever, in the September 23, 1983, letter, the licensee indicated that upon re-inspection it was discovered that redundant instrument lines were separated by 20 feet without intervening combustibles, as required by Section III.G.2 of Appendix R.
2.4 Conclusion This area now meets the staff guidelines and, therefore, a deviation from the requirements of Section III.G.2 of Appendix R in containment is no longer necessary.
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e 3 RHR PUMP 1-1 AND HEAT EXCHANGER ROOM (FIRE AREA 3-B-1)
RHR PUMP 1-2 AND HEAT EXCHANGER ROOM (FIRE AREA 3-B-2) 3.1 Requested Deviation The licensee requested approval for deviations in these areas from Section III.G.2(a) to the extent that it requires that redundant shutdown divisions be separated by complete 3-hour-fire-rated barrierse 3.2 Discussion 3.2.1 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:
(1) an overflow opening in the periceter wall at elevation 54 feet (2) three duct penetrations without fire dampers and a door opening with a-1 -hour-fire door in the perimeter wall at elevation 64 feet (3) an open doorway and unprotected penetrations in the perimeter wall at elevation 75 feet (4) a duct penetration without fire damper in the perimeter wall at elevation 104 feet These openings are in walls that form the perimeter of adjoining plant locations that the licensee has designated as separate fire areas.
Safe shutdown equipment 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.
2 with The in situ combustible loading in the area is approximately 862 Btu /ft an equivalent severity of 0.6 minute on the ASTM E-119 time-temperature curve.
The fire load consists primarily of oil and grease evenly distributed through-out the entire 675-square-foot area.
Existing fire protection includes an area-wide smoke detection system, portable fire extinguishers, and manual hose stations.
3.2.2 Fire Area 3-B-2 The RHR pump 1-2 and heat exchanger room is bounded by walls, floor, and ceiling of 3-hoar-fire-rated construction with the following exceptions:
(1) an overflow opening in the perimeter wall at elevation 54 feet-3-1
S (2) five duct penetrations without fire dampers and a door opening with a 1 -hour-fire door in the perimetar walls at elevation 64 feet (3) a duct penetration without a fire damper in the perimeter wall at eleva-tion 85 feet (4) a duct penetration without a fire damper in the perimeter wall at eleva-tion 104 feet These openings are in walls that form the perimeter of adjoining plant loca-tions that the licensee has designated as separate fire areas.
Safe shutdown equipment that 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 load consists primarily of oil and grease evenly distributed through-out the entire 675-square-foot area.
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 low fire load, the spatial separation between redundant shutdown divisions, 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 the perimeter walls.
The requirement for a 3-hour-fire-rated barrier between redundant shutdown divisions is intended to provide reasonable assurance that one division will remain free of damage as a result of a fire that 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 l
would tend to propagate slowly and with initially. low heat generation.
The i
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 these penetrations are located away from the redundant shut-down systems.
Therefore, hot gases passing through the penetrations would not affect components or cabling of the redundant division.
The remaining products of combusion would be so diluted by ambient air conditions and the temperature of the air mass would be 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 capa-bility and because they are located in an. easily accessible area within the 3-2
4 auxiliary building, the staff has reasonable assurance that a fire would be detected and controlled before significant propagation and damage would occur.
3.4 Conclusion Based on its evaluation, the staff concludes that the existing fire protection provides an acceptable level of fire safety equivalent to that provided by j
Section III.G.2, and, therefore, the licensee's request for approval for devia-tions in the RHR pump and heat exchanger rooms (fire areas 3-B-1 and 3-B-2) should be approved.
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4 CENTRIFUGAL CHARGING PUMPS 1-1 AND 1-2 ROOM (FIRE AREA 3-H-1)
RECIPROCAL CHARGING PUMP ROOM (FIRE AREA 3-H-2)
TURBINE-DRIVEN AUXILIARY FEED PUMP (FIRE AREA 3-Q-1) 4.16-kV SWITCHGEAR VENTILATION FAN ROOM (FIRE AREA 13-E) 4.1 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.
4.2 Discussion 4.2.1 Fire Area 3-H-1 The centrifugal charging pump room is bounded by walls, floor, and ceiling of 3-hour-fire-rated construction with the following exceptions:
(1) an open doorway with security gate and two sets of 1 -hour-fire doors with monorail cutouts in the perimeter walls (2) four duct penetrations without fire dampers in the perimeter walls and floor These openings are in walls and floor that form the perimeter of adjoining plant locations that the licensee has designated as separate fire areas.
Safe shutdown equipment located in this area consists of centrifugal charging pumps 1-1 and 1-2, their auxiliary lube oil pumps, and circuits listed in Table 3-4 of the licensee's Appendix R report.
The in situ fire loading in the area is approximately 6980 Btu /ft2 with an equivalent severity of 5.2 minutes on the ASTM E-119 time-temperature curve.
The fire load consists primarily of oil and grease evenly distributed over the entire 1000-square-foot area.
Existing fire protection includes an automatic wet pipe sprihkler system over the charging pumps, an area-wide smoke detection system, manual hose stations, and portable fire extinguishers.
4.2.2 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:
(1) an open doorway with security gate in the perimeter wall (2) four duct penetrations without fire dampers in the perimeter walls, floor, and ceiling.
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These openings are in fire barriers that form the perimeter of adjoining plant locations that the licensee has designated as separate fire areas.
Safe shutdown equipment 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.
2 with an The in situ fire loading in the area is approximately 28,100 Btu /ft equivalent severity of 21 minutes on the ASTM E-119 time-temperature curve.
The fire load consists primarily of oil and grease evenly distributed over the entire 235-square-foot area.
Existing fire protection includes an automatic wet pipe sprinkler system over the charging pump, an area-wide smoke detection system, manual hose stations, and portable fire extinguishers.
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- 4. 2.- 3 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:
(1) two 1 -hour-fire-rated doors in the perimeter walls (2) an unrated concrete shielding wall separating this area from an adjoining plant area (3) two duct penetrations without fire dampers and one duct penetration with a 1 -hour-fire damper in the perimeter walls and ceiling Safe shutdown equipment located in this area consists of auxiliary feedwater pump 1-1 and circuits listed in Table.3-4 of the licensee's Appendix R report.
The in situ fire loading in the area is approximately 10,700 Btu /ft: with an equivalent _ severity of 8.0 minutes on the ASTM E-119 time-temperature curve.
The fire load consists primarily of cable, oil, and grease evenly distributed over the entire 700-square-foot area.
Existing fire protection consists of area-wide automatic fire detection and suppression systems, manual hose stations, and portable fire extinguishers.
4.2.4 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 exceptions:
(1) unrated steel hatches covering personnel and equipment openings (2) 1 -hour-fire rated doors and dampers protecting doorways and dust penetrations (3) open louvers in the exterior walls (4) duct penetrations without fire dampers in walls common with other fire areas 4-2
(5) an unsealed diesel exhaust stack communicating with a vertically adjoining fire area This area contains no shutdown-related systems, but the area communicates with other areas that contain redundant divisions through ventilation ducts without fire dampers and through hatches that are not fire rated.
2 with an The in situ fire load witt.in this area is approximately 754 Btu /ft equivalent fire severity of 0.6 minute on the ASTM E-119 time-temperature curve.
The fire load consists primarily of grease, filters, cable, and fan belts.
Existing fire protection includes 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 bases of the low fire load, the spatial separation between redundant shutdown divisions, and the existing fire protection.
4.3 Evaluation The technical requirements of Section III.G.2.(a) are not met in these areas because of the unprotected penetrations in the 3-hour-fire-rated perimeter walls, floor, and ceiling.
The staff was concerned that because of the unpro-tected 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.
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.
With the automatic fire detection systems, the staff expects that a fire would be discovered in its early sages before serious damage occurs.
If a fire should generate high air temperatures, the automatic fire suppression systems would. activate to suppress it and to protect exposed shutdown systems.
Between the times the fire is detected and when it is extinguished as a result of intervention of the fire brigade or the activation of the fire suppression system, the existing passive protection (which consists of the partial fire walls and spatial separation) will provide reasonable assurance that one shut-down division will remain free of fire damage.
4.4 Conclusion Based on its evaluation, the staff concludes that the existing fire protection provides 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 auxiliary feed pump room, and the 4.16-kV switchgear ventilation fan room (fire areas 3-H-1, 3-H-2, 3-Q-1, and 13-E) should be approved.
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5 PENETRATION AREA (FIRE AREA 3-BB) 5.1 Requested Deviation The licensee requested approval for a deviation from Section III.G.2 in this area to the extent that it requires the separation of redundant shutdown divisions by 20 feet, free of intervening combust.ibles, and the installation of area-wide fire detection and suppression systems.
5.2 Discussion Fire area 3-BB consists of three levels that comprise the area between the containment structure and the auxiliary building from elevation 85 feet to elevation 115 feet.
This fire area is bounded on the north by the containment building wall, which is 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 fuel handling building to the east by concrete 3-hour-fire-rated walls ~ with 1- -hour-rated doors.
This fire area is separated from the turbine building to the west by a 3-hour-fire-rated barrier.
The. floor and ceiling of this area are 3-hour-fire-rated barriers.
The floors separating the three levels are concrete slabs with numerous unsealed penetrations.
Exceptions to the 3-hour-fire-rated barriers in this area are as follows:
(1) 1\\-hour-fire-rated doors in perimeter wall doorway openings at elevations 85 feet, 104 feet, and 115 feet (2) ventilation louvers without fire dampers in the northwest external wall at all three elevations (3) unsealed pipe penetrations in the south ceiling at elevation 140 feet (4) duct penetrations without fire dampers in perimeter walls at elevation
'85 feet These openings are in walls and ceiling that form the perimeter of adjoining plant locations that the licensee has designated as separate fire areas.
Safe shutdown equipment located in the area includes piping and valves asso-ciated 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 fire loads in the area, by elevation, are given below; they consists l
primarily of cable, grease, rubber, and hydrogen.
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x Elevation, ft Combustible Btu /ft2 Equivalent fire severity, min.
85 negligible negligible 100 9900 7.4 115 9900 7.4 Existing fire protection includes a partial smoke detection system that covers the post-loss-of-coolant-accident (LOCA) sampling room at elevation 85 feet and approximately 75% and 60% of the floor area at elevations 100 feet and 115 feet, respectively.
Additional protection consists of an automatic, wet pipe sprinkler system that provides area-wide coverage at elevations 100 and 115 feet, manual hose stations, and portable fire extinguishers.
By letter dated September 23, 1983, the licensee committed to provide 1-hour fire-rated barriers for three embedded pullbox covers located in the ceiling at elevation 100 feet to protect steam generator 1-3 and 1-4 pressure instru-mentation circuits, pressurizer level and reactor coolant pressure instrumenta-tion circuits, and steam generator 1-3 and 1-4 level instrumentation circuits.
The licensee also committed (1) to install additional smoke detectors at eleva-
' tion 115 feet to provide an early fire-warning capability throughout the area where shutdown-related instrumentation is located and (2) to provide a 1-hour fire-rated barrier for one train of reactor coolant pressure instrumentation where the provision for 20 feet of separation without intervening combustibles is not met.
The licensee justifies the deviations on the bases of the low fire load, the proposed and 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.
5.3 Evaluation The technical requirements of Section III.G.2 are~not met in this area because of (1) the absence of a fire detection and a fire suppression system throughout elevation 85 feet (2) the partial smoke detection systems at elevations 100 feet and 115 feet (3) the lack of 20 feet of separation distance free of intervening combustibles between redundant trains of reactor coolant temperature instrumentation and steam generator 1-3 and 1-4 pressure transmitter instrumentation at elevation 115 feet (4) the absence of 3-hour fire-rated doors and dampers to protect the openings in the 3-hour fire-rated perimeter walls and ceiling The staff had two concerns about the level of fire protection in this area as follows:
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(1) A fire on any elevation might damage redundant shutdown systems.
- However, the amount of combustible material on all three levels is limited.and widely dispersed.
Consequently, the staff does not expect a fire to pro-pagate quickly or to produce significant levels of smoke or heat.
The partial smoke detection systems in the area would activate after some time delay and would alert the plant fire brigade.
I If an unexpectedly severe fire occurred on elevation 85 feet and damaged reactor coolant pressure instrumentation circuits, a redundant circuit is available at elevation 100 feet.
Therefore, the absence of area-wide smoke-detection and fire suppression systems on this level would not prevent the ability to achieve and maintain safe shutdown.
If such a' fire occurred on elevation 100 feet or 115 feet, the automatic sprinkler system would activate to protect redundant shutdown-related systems and to suppress the fire.
Until the sprinkler system activated or the fire brigade arrived, the passive protection available to redundant i
systems, which includes spatial separation and/or 1-hour fire barriers, would provide reasonable assurance that one shutdown division would remain free of fire damage.
(2) The damaging effects of a fire might spread beyond the perimeter walls into adjoining plant locations.
However, because of the limited fire load and the existing smoke detection and sprinkler systems on elevations 100 and 115 feet, the staff expect the smoke and heat from a fire to be largely confined within the perimeter of this area.
Because all openings in the perimeter walls have not been protected, some smoke would be expected to infiltrate into adjoining plant locations.
But this smoke would be dif-fused and cooled so it would not pose a significant threat to the adjoining areas, other than to reduce visibility to some limited extent.
5.4 Conclusion Based on its evaluation, the staff concludes that the existing fire protection, along with the proposed modifications, provides an acceptable level of fire safety equivalent to that provided by Section III.G.2.
Therefore, the licensee's request for a deviation in the penetration area (fire area 3.BB) should be approved.
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e 6 CHEMICAL LABORATORY AND OFFICES (FIRE AREA 4-A) 6.1 - Requested Deviation 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 1-hour-fire--
rated barrier and requires the installation of area-wide automatic fire detec-tion 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 are 2-hour-fire rated with the following exceptions:
(1) 1 -hour-rated fire doors in the south and west perimeter walls (2) duct penetrations without fire dampers and penetrations with 1 -hour-fire dampers in the perimeter walls Within this area, at elevation 93. feet, there is a continuous-membrane dropped ceiling consisting of a vermiculite plaster on metal lath with acoustical' ceil-ing tiles attached to the underside.
The fire area walls, the continuous-membrane ceiling, and the floor form an envelope to separate this area from safe shutdown circuitry routed in conduit above the dropped ceiling.
All ventilation duct register penetrations in the dropped ceiling have been pro-vided with 1 -hour-fire dampers.
All access hatches in the dropped ceiling but 4
one'are 1 -hour-fire rated.
The area above the dropped ceiling contains redundant shutdown circuits for the l
following systems:
auxiliary feedwater auxiliary saltwater charging and boration component cooling water emergency power l
residual heat removal ventilation equipment l
These circuits are listed in Table 3-4 of the Appendix R report.
2 with The fire loading in the chemical laboratory is approximately.4800 Btu /ft an equivalent severity of 3.7 minutes on the ASTM E-119 time-temperature curve.
This load includes flammable liquids and gases, clothing, and ordinary Class A I
combustibles evenly distributed throughout the lab.
2 with an equiva-The fire load in the store room is approximately 49,400 Btu /ft lent severity of 37 minutes.
This load is primarily flammable liquids, most of which are stored in an approved flammable-liquids storage locker.
The remainder 6-1 i
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.3 c< this load 'ncludes flammable gases, clothing, and ordinary Class A combusti-ales evenly distributed throughout the room.
i The fire load in the F. bus compartment is approximately 5160 Btu /fts with ar, equivalent severity of 4 minutes.
This load is primarily cabling in trays.
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In the remainder of this area, the fire load is approximately 7600 Btu /ft an equivalent severity of 5.7 minutes.
Existing fire protection includes a partial smoke detection system located below the drop ceiling in the laboratory and balance rooms; an autonsatic, wet-pipe sprinkler system throughout the area below the ceiling; manusi hose sta-tions; and portable fire extinguishers.
t In the July 15, 1983 Appendix R report, the licensee committed to in; tall a complete smoke detection system above the dropped ceiling in the fire area.
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 the absence of an automatic firu suppression system above the dropped ceil-ing, the lack of an area-wide fire detection system below the ceiling, and the insufficient physical separation between redundant shutdown divisions.
- Also, the perimeter walls of the fire area are not 3-hour rated.
The staff has 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 tnat a fire that originates above the ceiling would damage cables from redundant divisions.
j If a fire should occur within 'the chemical lab and ancillary areas, the staff would 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 syster does not cover the entire fire area, the rooms that are unprotected are a small fraction of the total floor area.
The distance from any location within th~e fire area to a detector is slight.
Thus, if a fire were to occur within an unprotected room, a detector in an adjoining room would activate after a short delay.
If the fire propagates rapidly and room temperatures rise, the automatic sprin-kler system will activate automatically to suppress the fire and limit damage.
During the time between the start 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 sustain-ing damage.
t There is no signifcant quantity of ignitable materials above the ceiling because all cables are enclosed in conduit.
6-2
-0 Therefore, if a fire should occur, it would be of limited magnitude and dura-tion and would not produce elevated temperatures that would pose a threat to j
the shutdown-related cables.
Because of the smoke detection system that the licensee has committed to install throughout the concealed ceiling area, a fire would be detected quickly and supressed manually before serious damage would occur.
Until a fire were extinguished, the passive protection provided to the cables by the conduit, the heat dissipated 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.
6.4 Conclusion Based on its evaluation, the staff concludes that the existing fire protection, along with the proposed modifications, provides 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 laboratory and offices (fire area 4-A) should be approved.
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7 G BUS COMPARTMENT (FIRE AREA 4-A-1)
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 redunoant shutdcwn divisions be separated by complete 3-hour-fire-rated barriers.
i 7.2 Discussion 7.2.1 Fire Area 4-A-1 4
The G bus compartment is bounded by walls, floor, and ceiling of 3-hcer-fire-rated construction with the following exceptions:
(1) 2-hour-fire-rated south perimeter wall (2) a 1 -hour-fire door in a doorway in the south wall (3) two duct penetrations.without fire dampers in the perimeter walls The openings are in walls that form the perimeter of adjoining plant locations that the licensee has designated as separate fire areas.
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 complete fire detection system in the area.
7.2.2 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:
(1) 2-hour-fire-rated south perimeter wall (2) a 1 -hour-fire door in the south wall (3) two duct penetrations without fire dampers in the perimeter walls These openings are in walls that form the perimeter of adjoining plant Ytre areas.
The area contains cable in conduit for various H bus safe shutdown components and equipment listed in Table 3-4 of the Appendix R report.
7-1
2 The fire loading in this area is approximately 6800 Btu /ft with En equivalcnt fire severity of 5.1 minutes on the ASTM E-119 time-temperature curve. The i
fire load is comprised of electric cable insulation in cable trays.
Existing fire pfotection includes manual hose stations and portable fire i
extinghuishers.
As'with the G bus compartment, the licensee has committed to f
i:nstall a complete fire detection system.
i The licensee justifies the deviations in these areas.on the bases of the low fire loading, the enclosure of safe shutdown cables in steel corduit, the spatial separation between redundant shutdown divisions, and the axisting and proposed fire protection.
j 7.3 Evaluation The technical requirements of Section III.G.2i(a) are not met ir, these areas
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Decause of the 2-hour-fire rating of the south perineter wall, the 1\\-hour-rated fire doors, and the unprotected dact penetrations in the perimeter Walls.
The staff was concerned that a fire that mig'nt originate in either bus compart-ment might damage cables of the redundant division.
However, tne ignitable mater'al in these areas is negligible and because of the limited size and estricted access, it is nct credible to postu1 ate a significant number of
~
e transientg.
Any fire wsuid be expected to be of limited magnitude and extent.
lhe effecte of a postulated fire would, to a great extent, be confined within the area of origin by the fire-rated walls and dcor.
Because of the lack of a l
Tire danper in the duct penetrations of tne perimeter walls, a limited amount of smote and not cases may enter adjoining areas.
But the products of combus-tion would be cooled and dissipated as tney expand into these areas. These areas are equipped with automatic smoke detection and fire suppression systems that should 11mit damage.
The bus cckpertments will be equipped with smoke detectors; thus, any postu-lated +1fa would te detected early and suppressed by the plant fire brigada.
Until the fire brigade arrives, the passive prote: tion (which includes the 1
steel conduits, firt-rated perimeter construction, spatial separation, and the fire suppression systems in adjoining plant locations) would provide reasonable assurance that enly ' ables from ore shutdown division would be damaged.
c 7.4 Con:1us,fon Based or,its evaluatiSn, the staff concludes that the existing fir 6 protection, with proposed modifications, will provide an acceptable level of fire safety l
equivalent to that provided b/ Section III.G.2 and, therefore, the licensee's request for devlations in the G and il bus compartments (, fire areas 4*A-1 and 4-A-2) stould be approved.
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-8 SHOWERS, LOCKER 5, AND ACCESS CONTROL (FIRE AREA 4-B) 8.1 Requestad Deviation The licensee requested approval for a deviation from Section III.G.2(c) to the extent that it requires the installation of an area-wide automatic fire detec-tion system where one shutdcwn disision is enclosed in a 1-hour-fire barrier and the area is protected by an automatic fire suppression system.
3.2 Discussion Fire area 4-B is the radiclogical centrol 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 with a 3-hour-fire rating with the folicwing exceptions:
(1) a 2-hour-rated north wall separating this area fece the chemical laboratory, with I\\-hour-rated fire doors and 1%-hour rated fire dampers in all but four of the duct penetrations (2) an unrated door providing access to stairway S-2 and a 1\\-hour-fire-rated door providing access to stairway S-1.
1 (3) several equipment natches and ceiling penetrations with unrated steel Covers (4) ventilation ducts without fire dampers penetrating the south wall of this area into the Unit 2 containment penetration area
'iafe shutdown systems located in the area ccnsist of cables associated with the following systems:
auxiliary saltwater compor.ent cooling water l
emergency power l
ventilatien equipment l
The fire loading within this area is approximately 4590 Btu /ft2 witn an equiva-l 1ent fire severity of 3.4 minutes en the ASTM E-119 time-temperature curve.
The combustible load cnnsists primarily of wood counters, electric cable insula-l tion, and anti-contamination clothing and respirators.
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Existing fire protection includes an area-wide automatic sprinkler systes.
l manual hose stations, and portable fire extinguishers.
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In the July 15, 1983 Appendix R report, the licensee connitted to separate j
redundant diese'l generator ard f uel transf er pump circuitt. 'cy a complete 1-hour-fire barrier.
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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 & safe shutdown capability after a fire.
S.3 Evaluation J
The technical requirements of Section III.G 2(c) are nct met in this area because of the lack of an area-wide fire detection system and insufficient l
physical separation between redundant circuits of the component cooling water (CCW) and auxiliary saltwater (ASW) systems.
In addition, the perimeter walls t
and ceiling are not completely 3-hour-fire rated.
The staff has two concerns in this area.
The first is that a fire within the i
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.
I If a fire should occur, the automatic sprinkler system would be expected to activate and suppress the fire, while protecting vulnerable shutdown systems.
Wnen the system activated, a waterflow alarm would be annunciated in the control room tnat would summon the fire brigade.
If the suppression system did not activate or if the fire brigade dio not arrive in time to prevent damage to both trains of the ASW system, the system valves can be annually activated i
outside the fire area.
Because one of the CCW system valves is normally cpen and because fire damage will cause the valves'to fail as is, the CCW flow path will be maintained.
The fire load in this area is icw.
Consequently, the staff does 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 j
damage.
The perimeter construction described above provides reasonable assur-ance 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 and hot gases may filter into an adjcining area (fire area j
4-A).
But the products of combustion would be cooled and dissipated as they expand into this area.
Therefore, shutdown systems would not tikely be threat-ened.
In addition, fire area 4-A is equipped with automatic smoke detection systems above and below the ceiling, whicn would provide early fire warning and L
an automatic sprinkler system.
Also, the ceiling registers from the ventilation system in fire area 4-A have been provided with fire dampers.
Therefore, if i
hot gases from a fire in the area were to propagate through the duct system, the fire dampers in the ceiling would close to limit damage below the ceiling.
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8.4 C,onclusion l
Basea on its evaluation, the staf f concludes that the exisitng fire protection with proposed modifications will provide an. acceptable level of fire safety equivalent to that provided 'oy Section III.G.2 and, therefore, the licensee's i
request for a deviatica in the showers, lockers and access control area (fire area 4-B) should be approved.
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9 HOT SHUTDOWN PANEL AND NONVITAL SWITCHGEAR ROOM (FIRE AREA 5-A-4)
CONTROL ROOM COMPLEX (FIRE AREA CR-1) 9.1 Requested Deviation The licensee requested approval for a deviation from Section III.G.3 in these areas to the extent that it requires the installation of an area-wide automatic fire suppression system in an area for which an alternate shutdown capability has been provided.
9.2 Discussion 9.2.1 Fire Area 5-A-4 The hot shutdcwn panel and nonvital switchgear room is bounded by walls, floor, and ceiling of 3-hour-fire-rated construction with the following exceptions:
(1) equipment access openings with unrated steel hatches in the floor and ceiling (2) a ventilation register without a fire damper in a common wall with stairway S-1 (3) 3-hour-fire-rated doors with filled metal panels in the perimeter walls (4) ventilation ducts without fire dampers or with 1 -hour-rated dampers penetrating the perimeter walls and ceiling Safe shutdown systems in the area consist of the hot shutdown panel and cables listed in Table 3-4 of the Appendix R report.
2 or an equivalent The fire loading in the area is approximately 25,167 Btu /ft severity of 19 minutes on the ASTM E-119 time-temperature curve.
The fire load consists primarily of cable in raceways evenly distributed over the entire 2702-square-foot area.
Existing fire protection includes an area-wide smoke detection system, manual hose stations, and portable fire extinguishers.
9.2.2 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:
(1) 3/4-hour-and 1\\-hour-fire-rated doors in the perimeter walls (2) open louvers and penetrations in the exterior perimeter walls and ceiling Safe shutdown systems in the area consist of the controls and instrumentation for all safety systems from both divisions located in the control boards and 9-1
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 fire load is approximately 29,420 Btu /ftz, 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 stations, 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.
The licensee justified the deviations on the bases of the availability of an alternate shutdown capability that 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 are.-wide fixed fire suppression systems.
The fire hazard 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 extin-guished before serious damaged occurred.
If serious damage should occur before the arrival of the plant fire brigade, an alternate shutdown capability exists that is independent of each of the rooms.
Therefore, safe shutdown could be achieved and maintained.
9.4 Conclusion Based on its evaluation, the staff concludes 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.
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i 10 ELECTRICAL AREA WEST OF THE 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 I
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:
(1) equipment access openings with unrated 1-inch-thick steel hatches in the floor and ceiling in the northwest corner of this area (2) several ventilation duct penetrations without fire dampers 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 that form the boundaries of adjacent fire areas.
Safe shutdown systems in this room are listed in Table 3-4 of the licensee's Appendix R report.
The fire loading within this area is 11,960 Btu /fts, or an equivalent fire.
severity of 9 minutes on the ASTM E-119 time-temperature curve.
The fire load
- consists of electrical cable insulation and small amounts of lubricating oil.
Existing fire protection includes an area-wide smoke detection system, manual hose stations, and portable fire extinguishers.
The licensee justified the exemptions on the bases of the low fire loading, the existing fire protection, and the ability of the steel hatches to limit fire spread.
l 10.3 Evaluation The technical requirements of Section III.G.2 are not met in this area because
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of the unprotected penetrations of the perimeter walls and floor and the unrated steel hatches at equipment access openings.
The staff was 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.
Thus, a fire I
would not be expected to be of significant magnitude or duration.
Because of I
the smoke detection system, which covers the antire area, a fire would be detected in its initial stages before serious damage occurs.
Although the 10-1
perimeter construction of this room is not completely 3-hour-fire rated, it is substantial enough to confine most of the effects of a fire within the area of fire origin.
Because systems of only one shutdown division are located within the room, only one train would be damaged and, therefore, shutdown capability outside of the damaged area would remain.
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 through the ventilation system.
However, the products of combustion would not pose a threat to shutdown systems in other fire areas because of (1) the limited amount of combustibles, (2) the 1-hour-fire-rated enclosure of the ducts in the room, and (3) early fire detection and early response by the fire brigade.
In addi-tion, compensating fire protection is available in adjoining locations to miti-gate 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).
10.4 Conclusion Based on its evaluation, the staff concludes that the existing fire protection will provide an acceptable level of safety equivalent to that provided by Sec-tion III.G.2 and, therefore, the licensee's request for a deviation in the electrical area west of the battery room (fire' area 6-A-5) should be approved.
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11 CORRIDOR OUTSIDE THE DInSEL GENERATOR ROOM (FIRE AREA 11-D) 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:
(1) an unrated steel hatch and metal door in the perimeter wall (2) a duct penetration without fire. damper in the ceiling Safe shutdown systems in the corridor consist of cables, in conduit, that 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 would be transient combustible material 2
consisting of lube oil, solvent, and rags.
The fire load equals 16,050 Btu /ft with an equivalent severity of 12 minutes on the ASTM E-119 time-temperature curve.
i 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 enclose each of the circuits for'the diesel generators in a 2-hour-fire-rated barrier.
A 2-hour barrier already encloses the circuits for the fuel transfer pump.
In addition, the licensee committed to enclose the emergency stop push-button switches for two diesel generators in a 1-hour barrier to. prevent'a short circuit across the push-button contact from prematurely tripping the diesel.
The licensee also committed to install isolators for diesel' generator indica-tion circuitry to prevent a short circuit there from tripping the diesel generators.
The licensee justified the deviations on the bases 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 sydtem.
In addition, the perimeter construction is not completely 3-hour-fire rated.
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O The staff was concerned that because of the absence of a smoke detection system, a fire could damage redundant shutdown systems or propagate beyond the boundaries of the fire area.
However, if a fire should occur, the automatic sprinkler system would be expected to operate and extinguish the fire as well as protect the vulnerable systems.
When the sprinkler system activated, a waterflow alarm would annunciate 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 amount of combustibles in the corridor and the protection provided by the sprinkler system, even if the perimeter construction were not completely 3-hour-fire rated, it 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 ventilation ducts would be dissipated and cooled so they would not pose a threat to shutdown-related systems in adjoining fire areas.
11.4 Conclusion Based on its evaluation, the staff concludes that the existing fire protection plus 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 corridor (fire area 11-D) should be approved.
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a 12 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 I
i This room is in the southeast corner of the Unit 1 turbine building at elevation 85 feet.
It is bounded by construction that has a 3-hour-fire-resistance rating with all penetrations protected.
The equipment in this zone includes the two component cooling water (CCW) heat exchangers and the three motor-operated and two air-operated valves associated with the CCW system and auxiliary saltwater system for safe shutdown.
In addi-tion, cables associated with the auxiliary saltwater system, CCW system, and diesel-generator tachometer indication are located within the area.
A reinforced-concrete missile shield separates the redundant heat exchangers, and extends approximately 2.5 feet beyond the ends of the heat exchangers.
2 with an equivalent The fire loading in the room is approximately 16,000 Btu /ft fire severity of 12 minutes.
The fire. load is primarily cables in trays evenly distributed over an area of approximately 1700 square feet.
Existing fire protection includes a smoke detection system and an automatic sprinkler system that provide complete, area-wide coverage.
Manual fire fight-ing equipment includes portable extinguishers and fire hose stations.
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In the Appendix R report, the licensee committed to isolate the diesel generator tachometer circuits to prevent the possibility of diesel generator trip.
The licensee justified the deviation on the bases of the low fire loading, existing fire protection, proposed modifications, and the ability to maintain or manually restore flow paths for the component cooling water and auxiliary saltwater system after a fire.
12.3 Evaluation The technical requirements of Section III.G.2 are not met in this area because a complete 1-hour fire barrier has not been provided around one shutdown divi-sion.
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 and the associated conduits are located less than 10 feet apart.
Two CCW water motor-operated valves and the associated conduits are located less than 20 feet apart, and the CCW heat exchangers are less than 5 feet apart.
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The fire load is low.
Combustible materials that could ignite are widely scat-tered.
This provides reasonable assurance that if a fire should occur, it would propagate slowly, with initially low heat generation.
Because of a smoke detec-tion system, a fire would be detected and extinguished in its initial stages before serious damage occurred.
If a fire were to propagate rapidly and room temperature rise, the automatic sprinkler system would activate, both to sup-press the fire and to protect the vulnerable shutdown systems.
Until the sup-pression system would activate or the fire brigade arrive, the concrete shield wall and the existing spatial separation between redundant divisions would provide a degree of passive protection sufficient to keep one 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.
Because one is normally open and the other normally closed, and because flow through only one CCW heat exchanger is required, safe shutdown capability will be maintained.
If the fire should result in failure of the circuits to the auxiliary saltwater valves, time is available after the fire is extinguished to manually open the valves.
12.4 Conclusion Based on its evaluation, the staff concludes 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 licensee's request for a deviation in the component cooling water heat exchanger room (fire area 14-E) should be approved.
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13 AUXILIARY SALTWATER PUMPS 1-1 AND 1-2 (FIRE AREAS 30-A-1 AND 30-A-2) 4 13.1 Requested Deviation The licensee requested approval for deviations from Section III.G.2 to the I~
extent that it requires that redundant shutdown divisions be separated by complete 3-hour-fire-rated barriers.
13.2 Discussion Fire area 30-A-1 houses 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 those for fire area 30-A-2, which houses the redundant auxiliary saltwater pump 1-2.
Conditions described in this section apply to both fire areas.)
t 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 kept 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 The power supply to the auxiliary saltwater pump and its associated exhaust l
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 2 with an rubber boot on the pump discharge, which equals about 1700 Btu /ft l
equivalent severity of 1.2 minutes on the ASTM E-119 time-temperature curve.
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 protection.
13.3 Evaluation The technical requirements of Section III.G.2 are not met in these areas l
because the watertight doors are not 3-hour-fire rated.
The staff was concerned that the steel watertight door would not prevent the l
passage of smoke and heat through the doorway.
i 13-1
r The fire load within the pump room and on the intake 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 would not be concentrated near the doorway.
Because of the smoke detection system, if a fire should occur, it would be detected in its initial stages and suppressed by the fire brigade before sig-nificant damage occurred.
During the delay between the advent of a fire and when it is extinguished, because of the door's substantial steel construction and watertight nature, the door would be able to confine smoke and hot gases to one side of the barrier, thus providing reasonable assurance that one shutdown division would remain free of damage.
13.4 Conclusion Based on its evaluation, the staff concludes 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 for the auxiliary saltwater pump rooms (fire areas 30-A-1 and 30-A-2) should be approved.
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14 DIESEL FUEL OIL TRANSFER PUMP VAULTS (FIRE AREAS 35-A AND 35-8) 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-B), associated fuel oil piping, and power control circuitry.
These areas lie under the turbine building seismic buttress support, which houses the condensate polishing system, below elevation 85 feet.
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:
(1) a curbed personnel hatch in the ceiling df each area that communicates with the buttress area above.
A 3/8-inch-thick locked steel cover pro-tects these openings.
(2) concrete hatches providing restricted access to the areas for equipment removal.
Caulked gaps of approximately 1/4 inch in width may exist between the concrete hatch pieces.
(3) each fire area communicating with the associated fuel oil piping trench through an open pipeway (less than 30-square-inch area).
The pipe trench associated with pump 0-1 is separated from the pipe trench for pump 0-2 by 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.
Each area has a floor area of about 110 square feet.
The fire loading is with an equivalent severity of 106 minutes on the 2
approximately 141,370 Btu /ft ASTM E-119 time-temperature curve.
The fire load 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 bases 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 security cameras, and the existing fire protection.
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14.3 Evaluation 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 sup-port vigorous burning is limited.
Consequently, the restricted air supply would act to limit the fire and produce large quantities of smoke.as a result of incomplete combustion.
The smoke would be detected either by security cameras that survey the area or by operating personnel.
During the delay between the start of a fire and when it is extinguished, the reinforced-concrete-construction of the vault and trench, along with the steel hatches, would pro-vide sufficient passive fire protection to ensure that one division would be free of fire damage.
Another credible fire scenario would be a flammable liquid spill at 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, under worst-case assumptions a fire of this nature would cause damage to only one shutdown division.
14.4 Conclusion Based on its evaluation, the staff concludes that the existing fire protection will provide an acceptable level of safety equivalent to that provided by Sec-tion 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.
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15 AUXILIARY BUILDING AND FUEL HANDLING BUILDING (FIRE AREA AB-1) 15.1 Requested Deviation t
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 elevation 140 feet and the fuel pool and machine shop areas of the fuel handling building from elevation 99 to elevation 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 unpro-tected vents, equipment-hatches, manways, ducts, pipeways, electrical raceways, and other diverse openings, the staff considers this portion of the plant as a e
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) At elevation 75 feet of the auxiliary building, circuitry for diesel generator fuel transfer pumps 0-1 and 0-2 is located in the drain recovery and gas decay tanks area (fire zone 3-C) and the Unit I 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 compres-sors and cable insulation.
It equals approximately 2800 Btu /ft2 with an equivalent severity of 2.3 minutes.
The fire loading in fire zone 3-J-1, consisting primarily of oil and cable insulation, is 36,900 Btu /ft2 with an equivalent severity of 27.7 minutes.
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 walls that have 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 i
pumps themselves are approximately 5 feet apart, separated by the partial fire wall.
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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 4
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 fire loading in each of zones 3-J-1, 3-J-2, and 3-J-3 consists primarily of oil and cable insulation.
It equals approximately 11,150 Btu /fta for.3-J-1 and 3-J-2 and 6607 Btu /ft2 for 3-J-3, with equivalent sevarities of approxi-mately 8.4 minutes and 5 minutes, respectively, on the ASTM E-119 time-temperature curve.
The fire load in adjacent zone 3-C is approximately 2800 Btu /ft2 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 at elevations 64 and 75 feet.
Additional protection includes portable fire extinguishers and manual hose stations.
The licensee justified the deviations in these two locations on the basis of 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 pro-tection 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.
There are two concerns with these areas.
The first is that a fire within the 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 the 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, or was extinguished manually by the fire brigada or automatically by the fire suppression system, enough passive fire protection is available to ensure 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, the licens.' has identified an independent means of starting the pumps from another fire area.
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.
The smoke detection system would activate and summon the 15-2
fire brigade, which would extinguish the fire before it would threaten 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 protec-tion level, and the staff has reasonable assurance that one shutdown division would remain free of fire damage.
15.4 Conclusion' Based on its evaluation, the staff concludes that the existing fire protection will provide an acceptable level of fire sc ety equivalent to that provided by r
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.
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i 16 DIESEL GENERATOR ROOMS (FIRE AREAS TB-1, TB-2, AND TB-3) 16.1 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.
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 TB-3 to the south and TB-1 to the north.
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 differentiate between-the generator rooms and the ventilation intake and exhaust rooms.
The areas are bounded by walls, floors, and ceilings of 3-hour-fire-rated construction with the following exceptions:
(1) unprotected louvers to the outside on the north and west perimeter walls
.(2) separation from an adjoining fire area at elevation 107 feet by a 3-hour -
fire-rated barrier with unrated metal hatches (3) an unrated steel hatch and 1-inch-thick sliding steel shield door (normally locked shut) in the perimeter walls of fire area TB-3 The fire loading in each area is approximately 150,800 Btu /ft2 with an equiva-lent severity of-113 minutes..The fire loading is comprised primarily of diesel fuel and lubricating oil.
Existing fire protection includes complete automatic fire detection and carbon l
dioxide fire suppression systems in the diesel generator room, manual hose stations, and portable fire extinguishers.
The rooms have a floor drain system and are also provided with curbs at door openings at elevation 85 feet to con-
.tain oil spills.
In the July 15, 1983 Aopendix R report, the licensee committed to upgrade the sheet metal personnel and equipment hatches at elevation 107 feet to a 1-hour-fire rating.
l The licensee justified the deviations on the basis of the existing and proposed fire protection.
16-1
e 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.
The principal concern is that a fire that originates within any one of these 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 carbon dioxide system would be annunciated
-in -the control room, which would summon the fire brigade.
Until the fire brigade arrived, the walls, floor, and ceiling would confine the damage to the area of origin.
Within the ventilation intake and exhaust rooms, the fire hazard is minimal.
Because of the limited amount of combustiblet, any postulated fire would be of limited magnitude and extent.
Smoke and hot gases would either be vented out-side through the louvers 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 its evaluation, the staff concludes that the existing fire protection will provide an acceptable level of safety equivalent to that provided by Sec-tion 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.
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17 FIRE DOORS 17.1 Requested Deviation 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 that separate redundant shutdown divisions have a fire rating equal to the barrier.
17.2 Discussion Approximately 50% of the Underwriters Laboratory (UL)-listed 3-and 1 -hour-fire-rated doors in the plant have been installed in frames that are not UL listed.
In addition, doors of metal construction that are not fire rated have been installed in both UL-listed and unlisted frames in several areas.
- Also, unlisted metal panels, installed in conjunction with doors, have been provided for protection of large fire area barrier openings needed for equipment access.
By letters dated October 6, 11, and 14, 1983, and orally in a subsequent meeting, the licensee committed to the following actions:
(1) Underwriters Laboratories (UL) personnel will inspect the unlisted doors and frames.
Representative doors will also be destructively tested to verify that they are equivalent to UL-labeled fire doors.
(2)
If upon inspection and testing, certain doors and/or frames do not meet UL specifications for listing, the modifications identified in Options 1 through 4, as listed below, will be implemented.
(3) For unlisted wall panels and transoms, the modifications described below will also be implemented.
Option 1:
Additional UL-listed rolling fire doors or double fire door assem-blies will be installed to protect or replace the existing doors, panels, and transoms.
Option-2:
The existing doors,-panels, and transoms will be replaced with an assembly that has been tested by an independent authority and found capable of I
withstanding a fire exposure consistent with the fire rating of the wall.
Option 3:
Directional, closed-head automatic sprinkler protection will be provided on both sides of the doors, dampers, or transoms.
Option 4:
The licensee will utilize other fire resistive configurations that have been previously evaluated and approved by the staff as satisfying the technical requirements of Section III.G.2 of Appendix R (e.g., removable interlocking concrete block walls with steel retainers).
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i 17.3 Evaluation With the exception of the use of automatic sprinklers as described in Option 3, the licensee's proposed course of action will achieve compliance with Section III.G.2 of Appendix R.
Consequently, a deviation is not required.
4 The staff was concerned that a door that had not been tested by an approved laboratory would not be able to maintain its integrity when subjected to ele-vated temperatures during a fire.
The use of sprinklers on both sides of un-listed doors, panels, and transons is intended to inundate the assembly in a spray of water and, thus, prevent the door from being adversely affected by a fire.
Because of the existing fire detection systems and the availability of plant personnel, the staff expects that a fire would be discovered in its early i
stages, before significant propagation occurs.
The fire brigade would then be summoned.
Before the arrival of the brigade, the smoke and heat from a fire would initially be generated upward into the ceiling area and away from the doors themselves.
As the stratified hot gas layer descended over time, the doors, panels, and i
transoms would begin to feel the effects of the elevated temperatures.
At that point, the sprinkler system would be expected to operate to protect the doors, I
panels, and transoms from further damage, thereby maintaining their integrity.
The staff, therefore, finds that the unlisted assemblies, in conjunction with directional automatic sprinkler systems, would provide reasonable assurance that they would withstand the effects of a postulated fire in the plant.
17.4 Conclusion t
Based on its evaluation, the staff concludes that Options 1, 2, and 4 will achieve compliance with Section III.G.2.
Option 3--the use of directional sprinklers in conjunction with the existing steel doors, panels, and transoms--
will achieve a level of fire safety equivalent to Section III.G.2 of Appendix R.
Therefore, the licensee's request for a deviation should be granted.
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_ _ _ -.. _ _ _ _ _ - _. _ _ _ _ _. _ _ _. ~., _,.. _. _
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L 18 STEEL HATCHES 18.1 Requested 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 that 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:
(1) the ceiling of the showers, lockers, and access control area (fire area 4-B)
(2) the floor and ceiling of the hot shutdown and nonvital switchgear room (fire area 5-A-4)
(3) the floor and ceiling of the electrical area west of the battery room (fire area 6-A-5)
(4) the floor of the cable spreading room (fire area 7-A)
Excluding the cable spreading room, the above areas are described in Sections 8, 9, and 10, respectively, of this report.
The cable spreading room is bounded by walls, floors and ceiling of 2-hour-fire-rated construction with the following exceptions:
(1) the unrated steel hatch in the floor (2) an unprotected duct penetration and unrated fire doors in the perimeter walls Safe shutdown systems in the room include cables and components for the fol-i lowing systems:
. auxiliary feedwater auxiliary saltwater
- charging and boration component cooling water
- emergency power safe shutdown instrumentation main steam reactor coolant residual heat removal The shutdown-related circuits are listed in Table 3-4 of the licensee's Appendix R report.
18-1
t 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 I
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 it is extinguished either manually or automatically.
The staff has addressed 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 report.
The staff concluded that because 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 4
smoke and hot gases from a fire rise to the ceiling, the staff is not concerned that the floor hatch would 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 suppres-sion system.
Therefore, there is reasonable assurance that if a fire should occur, it would be detected early and extinguished manually by the fire brigade or automatically by the carbon dioxide system before serious damage occurred.
The staff has 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 I
Based on its evaluation, the staff concludes 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 devia-tions in these areas should be approved:
(1) showers, lockers, and access control area (fire area 4-B)
(2) electrical area west of the battery room (fire area 6-A-5)
(3) hot shutdown and switchgear room (fire area 5-A-4)
(4) cable spreading room (fire area 7-A) 18-2 l
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4 19 EMERGENCY LIGHTING 19.1 Requested 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 needed for operation of safe shutdown equipment and in access and egress routes thereto.
i 19.2 Discussion Emergency lighting at the plant consists of three independent systems:
i (1) emergency ac lighting i
(2) emergency de lighting (3) emergency self-contained lighting (sealed beam lights with an 8-hour battery supply) i Locations required for safe shutdown that are.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 poten-tial-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.
were necessary to prevent fire damage.
As a result of that analysis, the licensee committed in Section 4.3 of the Appendix R report to provide additional battery powered emergency lighting l
units or modify the ac system (by protecting or rewiring circuits) in the fol-i lowing areas:
CCW heat exchanger room (fire area 14-E) corridor-(fire zone 14-A) stairway (fire area S-1) at elevation 140 feet hot shutdown panel area (fire area 5-A-4) boric acid and waste evaporator area (fire zone 3-L)
For 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.
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The staff.is concerned that if a fire occurred, it would damage portions of the ac lighting system so that no emergency lighting would be available in areas needed for operation of safe shutdown equipment.
The licensee has analyzed 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 an independent staff review.
Consequently, the staff does not have reasonable assurance that the licensee has considered all relevant factors.
19.4 Conclusion Based on its evaluation, the staff concludes that reliance on the ac lighting system will not achieve an acceptable margin of safety equivalent to that pro-vided by the technical requirements of Section III.J.
Therefore, the licensee's request for a deviation should be denied.
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20 REACTOR COOLANT PUMP OIL COLLECTION SYSTEM l
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 cil collection tank (s) be drained to a safe. location when the collection system is designed to provide capacity to i
hold the lube oil inventory of one reactor coolant pump (RCP) with margin.
20.2 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 l'
l biological shield serves as a barrier between the north area in which RCPs 1-1 i
and 1-2 are located and the south area in which RCFs 1-3 and 1-4 are located.
l The north and 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 140 feet.
Each I
RCP is separated from the others by approximately 45 feet.
T The lubricating oil system for the RCP motor consists of two parts, the upper l
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 i
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-j and between the collection pans for conduit, pipes, and other such items are.
surrounded by drip shields draining to the collection pans.
A skirt is in-stalled around the pump motor coupling to direct leaks on the outside of the 1
motor casing to the collection pans below.
The oil lift pump and piping are enclosed by a sheet metal shield.
A spray from a potential oil lift pump leak would be confined within the shield.
A spray 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 they are collected above the main pump flange.
The main pump flange is surrounded by a 2-inch rim with an over-flow drain to the collection pans.
All joints are caulked to prevent leakage.
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Each collection pan is equipped with a drain pipe connected to a drain line.
The drain lines for each pump connect to a 2-inch common header and enter the containment annulus through penetrations in the shield wall.
The common header drain line is routed to an oil collection tank located under the fuel transfer canal in the containment annulus at elevation 91 feet.
The RCP oil collection tank has a 300 gallon capacity and is eouipped with a
{
l valved drain, a 2-inch. overflow, and a 2-inch vent.
The vent is equipped with i
a flame arrester.
The tank is designed to contain the oil ' inventory of one RCP motor plus a margin of 35 gallons.
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The RCP lube oil collection tank overflow pipe discharges downward to a recessed trench in the floor at elevation 91 feet, along the outside of the shield wall. This trench is sloped so that overflow of lube oil from an P.CP pump would be to the containment drain sump.
The overflow pipe will be designed and installed to withstand the safe shutdown earthquake and provide reasonable assurance that overflowing lube oil will be directed into the trench and not be dispersed through the area.
A wet pipe automatic sprinkler system is provided for each RCP.
The water flow alarm annunciates in the continuously manned control room.
A smoke detector is provided each RCP and the corresponding steam generator.
Additional detectors are provided in the containment annulus in the exhaust air flow path for zone 1-B.
Additional fire protection includes portable fire extinguishers and manual fire hose stations.
The licensee justifies the deviation on the bases of the design of the oil collection system, the existing fire protection, the use of high flashpoint lube oil, the lack of a source of ignition for the oil, and the routing of safe shutdown circuits in conduit.
20.3 Evaluation The technical requirements of Section III.0 are not met because the oil hold-ing tanks are not large enough to hold the entire lube oil system inventory for the four RCPs.
I i
In its original evaluation of this system in the SER, the staff espressed con-cern that an unmitgated fire involving lube oil could damage safety-related equipment in the vicinity.
Consequently, the licensee agreed to install th oil i
collection system to provide a capability for collecting leakage from vulnerable
(
components, and to provide an automatic sprinkler system to spray the areas around the pumps.
The staff was also concerned that if overflowing lebe oil ignited, the r.ssulting fire would damage shutdown systems.
However, the overflow line discharges into a trench that is sloped to channel any potential oil spill to the containt.ent drain sump.
The oil has a flash point of 480*f and would, therefore, represent a significant hazard only if atomized cr if the oil came in contact with a I
high-energy ignition source.
Because the oil collection syst6m is presently designed to withstand the safe shutdown earthquake and because there are no ignition sources in the anticipated flow path of the overflowing oil, the staff does not expect the oil to ignite.
If a fire were to occur at the oil collection tank, the smoke detectors in the area would activate and summon the fire brigade to extinguish the fire with portable fire-fighting equipment.
However, although safe shutdown systems coulo be damaged, the loss of these.systens would not impair the ability to achieve and maintain safe shutdown.
Additional nodifications to safisfy the requirements of Appendix v1 would not
.significantly enhance the level of fire safety.
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20.4
{onclusico o
Based on its evaluation, the staff concludes that the licensee's fire protection configuration will achieve an acceptable level of fire protection equivalent to that provided by Sestion III.O.
Therefore, the licensee's request for a devia-tlon for the RCP oil collectfin system holding tanks should be granted.
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21 $UMMARY I
dased on its evaluation, the staff finds that the level of fire safety in the areas listed below is equivalent to that achieved by compliance with the tech-nical requirement: of Section III.G of Appendix R and, therefore, the licensee's request for apprcved deviations In these areas should be granted:
(1) RHR pump 1-1 and heat exchanger room (fire area 3-9-1)
(2) RHR pump 1-2 and heat exchanger room (ff re area 3-B-2)
(3) centrifugal charging pumps room (fire area 3-H-1)
(4) reciprocal charging pump roca (fire area 3-H-2)
(5) turbine-driven auxiliary feed pump (fire area 3-Q-1)
(6) 4.36-kV switchgear fan room (fire area 13-E)
(7) chemical laborator) and offices (fire area 4-A)
(8) G bus compartment (fire area 4-A-1)
(9) H out compartment (fire araa 4-A-2)
(10) shower, locker, anJ access control (fire area 4-B)
(11) hot shutdown panel and ronvital switchgear rors (fire area 5-A-4)
(II) control rcom complex (fire area CR-1)
(13) electrical area west of the battery room (fire area 6-A-5)
(14) corridor outside the diesel generator room (fire area 11-0)
(1b) component coolint water heat exchanger (fire area 14-5)
'(16) auxiliary saltwater punp rooms 1-1 and 1-2 (fire areas 20-A-1 and 30-A-2)
(17) diesel fuel oil transfer pump vaults (fire areas 35-A snd 35-B)
(18) sexiliary building and fuel handling building (fire area AB-1)*
(19) diesel generator rooms (fire areas TE-1, TE-2, and TB-3)
(20) steel natches (fire areas 4-8, 6-A-5, 5-A-4, 7-A)
(21) containnent (fire area 1)
(22) penetration area (fire area 3-28)
(23) unlabeled fire doors (24) RCP oil collection system (containment zote 1-0)
The evaluation of the licentte's request for a deviation for emergency lighting is under review.
s l
- Two exemotions I
21-1
UNITaD STATS 4 NUCLEAR REGULATORY Coh' MISSION
. [ g;..qj' A W2sHINCToN. o. C. 20685
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R NOV 011383 NG10RANDUM FOR:
Chairmen Palladino Comissioner Gilinsky Commissioner Roberts Comissioner Asselstir.e Commissioner lernth01 FRON:
William J. Dircks
(,'
Executive Oir,ector for Operations
SUBJECT:
DIABl.0 CMYON Enclosed in response to the Secretary's limited oistribution memorandum of Hovember 4,1983, on Diablo Canyon is the staff evaluation of items The enclosed evaluation previously identified as requiring resolution.
, discusses each of the 31 open items identiff ad in Table C.8.1 of SER Supplement No.19 and the 15 follow-up iterns in Table C.8.3 of that prior to authoritation of Step 1 (fual load) gnated for reso
' suppl ement.
It concludes that all items desi have beers acceptably.
The evaluation also provides the basis for the resolved for Step 1.
staff conclusion that resolution of the remaining items can be deferred to a later time.
Since the evaluation is being furnished to the Ccmmission in response 3
('i.,
to a limited distribution memorandum from the Secretary, the enclosed staff evaluation has not been made available publicly or to the other parties.
The ~ staff hat' no objectior to releasing'.this evaluation to l
the parties and to the publ-(c.
(Signed) J4Ck W. Roe William J. Dircks Exacutive Director for Operations
^
Enclosure:
As stated cc W/ encl.
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STAFF EVALUATION OF ITEMS IDENTIFIED AS REQUIRING RESOLUTION SER Supplement No.19. Table C.8.1, identified 31 open items from the SER Supplement No.18 review performed by the staff which require resolution.
Further SER. Supplement No.19. Table C.8.3, identified 15 follow-up items which require only confirmatory documentation, testing or staff verification to complete. All modifications identified thus far regarding the follow-up items have been completed subject to verification by the staff.
The following is the status and schedule for completion of the 31 open items and 15 follow-up items with respect to the three-step licensing approach approved by the Comission.
1.
31 Open Items All of the 31 items listed in SER Supplement No.18 had undergone substantial evaluation during the course of the staff review up to the publication date of the supplement.- The items listed represented the residual of the discussions and information exchanges that took place over the previous 18 months.
Step 1 Of the 31 open items,15 (numbers 1 through 4; 7, 10, 16, 17, 18, 19, 23, 24 M
27, 30 and 4 were designated for resolution prior to authorization of Step 1 b
(fuel load) based on the following general criteria:
(a) Matters related to the containment or containment internal structures; or (b) Matters related to other structures, systems and components required by the# plant technical specifications to be operable during modes 5
and 6 where the potential for significant rea'nalysis or modifications could not be classified as highly unlikely based on the staff review and audits up to that time; (c) Matters requiring an early commitment to assure the completion of confirmatory analyses prior to authorization of full power operation.
Nine of the 15 items required for Step 1 (numbers 3, 4, 7, 10, 16, 19, 23, 24 and 27) were fully resolved in SER Supplement No.19. The remaining six items (numbers 1, 2, 17, 18, 29 and 30) are discussed individually below.
For each of the six items, the licensee's responses provided significant additional information but, although those reponses appeared refonable, they either were incomplete in terms of technical content required for full documentation or contained some apparent inconsistencies that needed to be clarified.
1.
Free-hand averaging of spectra for containment annulus structure should be in accordance with staff-approved technique.
(SSER 18, page C.3-9; SSER 19, page C.3-1)
It was not clear, based on existing documentation submitted that acceptable spectrum averaging techniques had been uniformly applied throughout the reverification effort. The information submitted in the PG&E responses on this matter, dated August 30 September 9, and October 12, 1983, contained samples of spectra that had obviously been plotted incorrectly although the text of the response and previous discussions with the engineering staff of the Diablo Canyon Project indicated that acceptable practices had been employed.
Correctly
3' plotted spectra were submitted on October 14, 1983, and this issue is now considered resolved.
2.
Cutoff frequency for 20 Hz for generation of floor response spectra in containment annulus structure should be justified.
(SSER 18, page C.3-9; SSER 19, page C.3-2)
The annulus steel structure has been stiffened to assure that all structural members have a primary response frequency of 20 Hertz or above, referred to as a 20 Hertz cutoff frequency.
The energy available in seismic ground motion drops off rapidly from approximately 20 Hertz to 33 Hertz.
At 33 Hertz no amplification of the ground motion input occurs.
In the 20 Hertz to 33 Hertz range e amplification can theoretically occur in the annulus struu'.re with an attendant increase in the acceleration experienced by piping supported by the annulus members. The DCP has provided analyses of the combined structure-piping system that indicate very small effects due to amplification in the 20 Hertz to 33 Hertz range. Although some additional analyses may be requested by the staff to provide a well documented record for future reference, the staff review to date has progressed to the point where the likelihood of additional modifications is low.
Any modifications which may be necessary will not likely affect systems or components needed for fuel load or otherwise interfere with activities associated with modes 5 and 6.
Therefore it is acceptable to the staff to consider this matter resolved for Step 1.
O 17.
Buckling criteria forgnera supports, specifically the Euler buckling l
equation for calculating critical buckling loads for all slenderness l
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ratios, should be evaluated and justified.
(SSER 18, page C.3-48; SSER 19, page C.3-4)
This item relates to an interpretation of subsection NF of the.ASf1E Boiler and Pressure Vessel Code.
Specifically, the staff does not accept the upper range of the design curve employed by the DCP to implement the code requirements for evaluation of allowable buckling loads (compressive stress) on some pipe support meitbers.
In a response provided during a transcribed meeting on September 28, 1983, the DCP stated that the matter was largely moot because the upper range of the design curve was rarely, if ever, used due to the nature of the supports at Diablo Canyon, i.e., short, stiff members with low compressive stresses.
In a submittal dated October 6, 1983, the DCP provided a sample of calculated compressive stress from 24 supports demonstrating compressive stresses well within the range consistent with the staff's interpretation of the ASME Code intent. At a staff audit in San Francisco on October 25-26, 1983, the DCP agreed to provide the compressive stress data for approximately 400 supports (on the order of 4000 individual supports are in Unit 1) throughout Unit 1 to provide final confirmation.
The progress of the staff review to date indicates that the likelihood of additional modifications is low. Any modifications which may be necessary will not likely affect systems or components needed for fuel load or otherwise interfere with activities associated with modes 5 and 6.
Therefore it is acceptable to the staff to consider this matter resolved for Step 1.
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18.
Calculations for selected piping systems analyzed previously in ITR '12 and ITR 17 should be repeated with revised support configurations and current loadings to verify that piping and supports satisfy corresponding design criteria.. Results of piping system reevaluation with high tl$ermal load should be verified'.
(SSER 18, page C.3-48; SSER 19, page C.3-3)
' his matter concerns a comitment to perform confirmatory analyses of T
two piping systems.
Because this is a long-lead item, the staff required a commitment to' perform the required analyses prior to approval of Step 1 in order to insure timely completion of the task. The. '
procedures and criteria for all piping analyses performed by the DCP s
were reviewed and found acceptable by the IDVP.
However, consistent with current practice, following the five-plant shutdown in 1979, the staff requires a final _ confirmatory analysis to be performed by an' independent party, in this instance the IDVP.
The IDVP has initiated confirmatory analyses on two piping systems selected by the staff.
Based on the IDVP results, the staff concludes that no significant modifications are likely to be required. Any modifications which may be necessary will not likely affect systems or components needed for
~
fuel load or otherwise interfere with activities associated with modes 5 and 6.
It is therefore acceptable to the staff to consider this matter resolved for Step 1.
29.
Consideration of jet impingement loads in design and qualification of all safety-related piping and equipment should be clearly demonstrated.
(SSER 18, page' C.4-29; SSER 19, page C.4-2)
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As noted in SER Supplement No. 19, the staff concluded that the licensee has met the FSAR commitment regarding the consideration of jet impingement loads inside containment, confirming the basis upon which the operating license was originally granted.
Under contemporary staff practice, aspects of jet impingement analyses that were judgemental for plant; of the Diablo Canyon era are required to be demonstrated by deterministic analyses.
To provide the basis for a jet impingement evaluation consistent with current practice, the DCP has completed a pipe break and jet target evaluation, and this effort has been reviewed and found acceptable to current standards by the IDVP.
Based on this source and target evaluation, certain piping and structural members that could be subjected to jet loading,in the unlikely event that~a large pipe rupture occurred inside containment, are currently being evaluated by analysis to determine what, if. any, additional protection might be required to fully meet current requirements.
In consideration of the possible impact on construction efforts, this item was upgraded from Step 2 as shown in Table C.8.1 of SER Supplement No. 18 to Step 1 as shown in SER Supplement No. 19.
The progress of the jet impingement evaluation discussed above is sufficient to demonstrate that the licensing basis for the Diablo Canyon Plant has been met and that significant modifications to fully meet current jet impingement protection requirements are unlikely. Any modifications which may be necessary will not likely affect systems or components needed for fuel load or otherwise interfere with activities associated with modes 5 and 6.
Therefore it is acceptable to the staff to consider this matter resolved for Step 1.
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30.
It should be clearly indicated that rupture restraints inside and outside e
containment have been properly designed and installed.
(SSER18,page C.4-31; SSER 19, page C.4-2)
As noted in'SER Supplement No. 19, the matters remaining for final closure of this item related to a staff audit.of the test data and design criteria employed for those pipe ' whip restraints inside containment that contain crushable bumpers.
Restraints of the type under consideration are required only in the unlikely event of a complete rupture of a pipe
~
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containing high energy fluid and are therefore not required during modes-5 and 6, since all systems inside containment are essentially unpressurized.
Further, the IDVP and staff review of this matter has progressed to the point where the likelihood of significant additional modifications is low.
Any modifications which may be necessary will not likely affect systems.or components needed for fuel load or otherwise interfere with activities associated with modes 5 and 6.
Therefore it" is acceptable to the staff to consider this issue resolved for Step 1.
Step 2 The 14 items listed in SER Supplement No.18 as designated for completion prior to authorization of Step 2 (low-power testing up to 5s power) (numbers 5, 6, 8, 9, 12, 14, 15, 20, 21, 22, 25, 26, 29 and 31) were selected based on the following general criteria:
(a) Matters related to structures, systems and components that' are j
I not required to be operable by the plant technical specifications for modes 5 and 6 (Step 1); or, (b) Matters that have been sufficiently reviewed to allow an assessment that the likelihood of additional significant modifications is low.
i
z 5.
Assumptions in model for auxiliary building floor slab qualification regarding rigidity / flexibility should be clarified and justified, including documentation of parametric studies.
(SSER 18, page C.3-22)
The seismic stick model used by the DCP to predict the structural loads and produce the floor response spectra is of the generally accepted type for normal seismic analysis and has many simplifications and inherent assumptions.
One assumption is that the floor slabs are rigid as compared to the walls.
The DCP use of a hand calculation method for distributing the stick model responses to the individual elements resisting the loads, resulted in higher stresses than allowable in the floor slabs.
The DCP had used the concept of floor slab flexibility to redistribute loads as a basis for explaining this apparent overstress condition.
This~
explanation was not acceptable to the staff.
The DCP subsequently constructed a three-dimensioal finite element model to more realistically distribute the stick model loads to the resisting elements. The results of this finite element analysis indicate the stresses in the floor slabs are within the code allowables.
The IDVP has verified and accepts the methodology used by PG&E.
The staff is currently completing its review of this matter.
The progress to date 'for the resolution of the staff concern indicates that the possibility of additional significant modifications to the structure is remote. Any modifications which may l
be necessary will not likely affect systems or components needed for fuel load or otherwise interfere with activities associated with modes 5 and 6.
Therefore it is acceptable to the staff to defer the resolution of the auxiliary building floor slab apparent overstress to Step 2.
1
f 7
l 6.
Use of different versions of ACI code in FSAR and in design verification effort of auxiliary building should be justified.
(SSER 18, page C.3-22)
The ACI 318-63 code is the basis for the acceptance criteria for design of the auxiliary building. This 1963 version of the code does not explicitly provide guidance in evaluating in-plane forces in shear walls although Section -104 of ACI 318-63 allows criteria based on test data to be used for the design of structural components for loads not covered by its provisions.
Initially, the ITP used the ACI 318-77 code, which explicitly provides criteria for in-plane shear, until criteria could be developed consistent with the provisions of ACI 318-63.
The ITP developed Appendix 2A to the Phase I Final Report to provide criteria for evaluating the in-plane loads.
The provisions of this document are based on available test data for in-plane shear consistent with the ACI 318-63 code originally accepted; the ACI 318-77 code was used by the ITP for the final member evaluation of some members and is more conservative than Appendix 2A.
By using ACI 318-77, the provisions of~
Appendix 2A (and, therefore, ACI 318-63) are also met.
The IDVP has verified the methodology and accepts the use of Appendix 2A.
The Appendix is currently under review by the staff.
The progress to date for the resolution of the staff concern indicates that the possibility of additional signi.ficant modifications to the structure is remote.
Any modifications which may be necessary will not likely affect systems l
and components needed for fuel load or otherwise interfere with activities associa'ted with modes 5 and 6.
Therefore it is acceptable to the staff to defer the resolution of the use of Appendix 2A to Step 2.
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UW 8.
Use of translational and torsional response of auxiliary building as input to base of fuel handling. building should be documented, including parametric studies.
(SSER 18, page C.3-26)
The dynamic analysis of the auxiliary building included a simple represen-tation of the fuel handling building. The fuel handling building was decoupled from the auxiliary building and analyzed separately using a detailed three-dimensional finite element model and the coupled model motion at the fuel handling building base. This motion consists of two parts, the translation and the torsional motion to the finite element model.
This method of decoupling structural systems is generally accepted by the profession and yields satisfactory results. The IDVP has verified and accepts the methodology used by PG&E.
The results presented for the finite element model have been preliminarily reviewed by the staff and appear consistent with the coupled model.
The staff is currently completing the review of this matter.
The progress to date for the resolution of the staff concern indicates that-the possibility of additional significant modifications to the structure is remote. Any modifications which may be necessary will not likely affect systems or components needed for fuel load or otherwise interfere with activities associated with modes 5 and 6.
Therefore it is acceptable to the staff j
to defer the resolution of the fuel handling building input motion to Step 2.
9.
Selection of set of degrees of freedom in dynamic model for fuel handling building should be justified.
(SSER 18, page C.3-26)
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ll A statement in the Phase I Final Report regarding the dynamic degrees of freedom in the fuel handling building finite element model was not clear.
The staff interpretation of this statement was that the DCP had reduced the number of degrees of freedom from 156 to 20. The reason for the staff concern is that recent studies have shown that reductions of this type could result in errors in the individual member loads. The DCP used the public domain program STARDYNE to analyze the fuel handling building-finite element model.
Comparison of results from the finite element model and the stick model appear to show the results to be consistent for base shears, root accelerations and displacements. The staff is currently completing the review of this matter.
The progress to date for the resolution of the staff concern indicates that the possibility of additional significant modifications to the structure is remote.
Any modifications which may be necessary will not likely affect systems or components needed for fuel load or otherwise interfere with activities associated with modes 5 and 6.
Therefore it is acceptable to the staff to defer the resolution of the degrees of fri.< dom in the fuel handling building model to Step 2.
12.
Effect of one continuous exterior wall in analysis of turbine building should be evaluated.
(SSER 18, page C.3-37)
The vertical seismic analysis of the turbine. building utilized four different models. The basis for using the four different models is the fact that the large openings in the floors at the turbine pedestal divide the floors into separate areas. The staff concern was over the coupling of these models through the exterior walls and their affect on the final results. The vertical walls themselves are not continuous due
IL u*
to large openings in the walls. Where coupling could possibly occur, l
the walls are stiff in their own plane and do not significantly amplify the ground motion. Therefore, little or no coupling appears to occur between the separate models. The IDVP sample included only one of the four models but did verify that resistance of adjacent bays were properly acccunted for. The staff is currently completing the review of this matter. The progress to date for the resolution of the staff concern indicates that the possibility of additional significant modifications to the structure is remote. Any modifications which may be necessary will not likely affect systems or components needed for fuel load or otherwise interfere with activities associated with modes 5 and 6.
Therefore it is acceptable to the staff to defer the resolution of the effect of the exterior walls on the vertical response to Step 2.
14.
The use of alternative procedures for modal combinations by SRSS method should be explained and clarified.
(SSER 18, page C.3-37)
The Phase I Final Report contained the statement that alternative procedures are being reviewed to assure that turbine building modal combinations using the SRSS method are acceptable.
The staff was concerned that some method other than the SRSS method was used to evaluate the structures. The DCP did in fact evaluate the dynamic response of the turbine building using the double algebraic sum method of combining modal responses in addition to using the SRSS method.
The structure was shown capable of withstanding the loads calculated by either method and satisfies the FSAR requirements.
The IDVP states in their reports that the alternate method (double algebraic sum) was not
13' used for final member evaluation in the IDVP sample. The staff is currently reviewing this matter in more detail. The progress to date for the resolution of the staff concern indicates that the possibility of additional significant modifications to the structure is remote.
Any modifications which may be necessary will not likely affect systems or components needed for fuel load or otherwise interfere with activities associated with modes 5 and 6.
Therefore it is acceptable to the staff to defer the resolution of the concern regarding use of alternative procedures for modal combinations by the SRSS method to Step 2.
15.
Use of increased allowable stresses in accordance with AISC-Code, 8th edition, should be justified with respect to criteria delineated in FSAR.
(SSER 18, page C.3-37)
The AISC Code, 7th edition, shows certain values for the allowable bearing of bolts against the member material.
For the Hosgri event the force resisting members are allowed inelastic deformation as indicated in the Hosgri Report. The provisions of AISC Code, 8th edition, allow 4
l higher bearing values and could be an acceptable criteria for meeting the conditions of the Hosgri Report commitments. The IDVP states that the lower of 1.7 times the AISC allowable stress or yield strength was used and the license criteria was met. The staff is currently reviewing
'this matter in more detail. The progress to date for the resolution of
~
the staff concern indicates that the possibility of additional significant modifications to the structure is remote. Any modifications which may be necessary will not likely affect systems or components needed for fuel load or otherwise interfere with activities associated with modes 5 and 6.
14 Therefore it is acceptable to the staff to defer the resolution of the use of AISC Code, 8th edition, to Step 2.
20.
All equipment listed in Table 2.3.1 of DCP Phase I Final Report should be seismically qualified for nozzle loads and component configurations should be verified.
(SSER 18, page C.3-59 and C.3-70)
The results of the DCP mechanical equipment review are listed in Table 2.3.1-1 of the DCP Phase I Final Report. Each analysis is stated to have demonstrated that the equipment is qualified to perform its safety function without modification for the controlling spectra and load combination.
However, this Table also indicated that the following equipment had not yet beon qualified for nozzle loads:
(1) boric acid tank (2)
CCW heat exchanger (3)
CCW pump lube oil cooler (4) diesel generator (5) diesel transfer filter (6) waste gas compressor The DCP anticipated that this equipment ~ or connected piping supports may be modified or that the calculated loads could be reduced by further analysis.
In addition, field verification of some component configurations had not been completed.
Finally, because not all final spectra had been issued, some of the calculations might have to be revised to ensure that the affected equipment was qualified.
IS The IDVP has reviewed the DCP approach to resolution of nozzle loads and found this approach and a sample of results to be acceptable.
In a response' dated September 9,1983, the DCP reported that all nozzle load allowables for items 2, 3 and 6 had been met and that further qualification for items 1, 4 and 5 was underway. This is a typical approach to resolution of. nozzle loads, and based on the October 11, 1983, revision to the DCP Phase I Final Report corrective actions for all remaining items are well underway.
Modifications beyond those currently underway are not anticipated. Any modifications which may be necessary will not likely affect systems or components needed for fuel load or otherwise interfere with activities associated with modes 5 and 6.
Therefore it is acceptable to the staff to defer final resolution to Step 2.
21.
Stresses in extreme fibers at interface between valve nozzle and pipe should be evaluated and results be documented.
(SSER 18, page C.3-66)
The initial IDVP review of valves sampled the PG&E approach to evaluation of the portions of valve structures that support the operators (commonly the most highly stressed portion of the valve body under seismic loading) and found this aspect of the PG&E design acceptable. An additional staff requirement for valves that must function during and after a seismic l
event (active valves) is that the maximum stress at the valve nozzle, i
l pipe intersection remain below the yield stress to assure elastic action in the valve body. The IDVP has subsequently verified a sample of DCP valve analyses and found the stress levels acceptable.. Subject to final review and evaluation, the staff considers this matter resolved.
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- 22. Stresses'in pump flanges should be verified to be within allowable limits.
(SSER 18, page C.3-69)
Early IDVP reviews identified some situations where the approach to evaluation of stresses in pump flanges was not fully acceptable and recommended reevaluation.
In ITR-67.Rev. 1, dated September 9, 1983, the IDVP concluded that the seismic qualification of equipment, including pumps, was performed acceptably.
In the IDVP Phase I Final Report the IDVP reported that the verification sample for stresses in pump flanges showed acceptable results.
Subject to confirmation that the acceptable evaluation metho'ds have been uniformly applied with regard to pumps requiring seismic qualification, the staff considers this matter resolved.
25.
Total lateral forces, total resistance to sliding and factor of safety against sliding of intake structure should be fully evaluated.
(SSER 18, page C.3-86)
The staff concern was that the total lateral forces on the intake structure were not evaluated.
These forces consist of lateral static and dynamic earth pressure, hydrodynamic pressures and seismic forces. The structure is keyed into the underlying rock material and sliding at the structure rock interface is not of concern. The staff is concerned about sliding occurring in possible clay seams in the rock foundation.
Some additional borings data has become available that can be used to address these concerns.
The IDVP will use this data in their ' evaluation and review their findings and report them in a revision to ITR 40.
It is expected that the results of this additional investigation will show the intake structure is stable against sliding.
Any modifications which may be necessary will
='
q not likely affect systems or components needed for fuel load or otherwise interfere with activities associated with modes 5 and 6.
Therefore it is acceptable to the staff to defer the resolution of the factor of safety against sliding to Step 2.
- 26. Additional analyses of buried diesel fuel oil tanks should be performed (analyses with refined mesh and without deconvolution, partially filled tank,examinationofproperties).
(SSER 18, page C.3-99)
The staff consultants, Brookhaven National Laboratory (BNL), performed an inedpendent analysis of the buried diesel fuel oil storage tank.
The results of this analysis were compared to the PG&E analysis and showed that some deficiencies existed in the FG&E analysis.
PG&E committed to reanalyzing the tanks using different models. The results of the later PG&E analysis showed the tanks can withstand the Hosgri event. The IDVP has verified that the PG&E reanalysis has addressed the deficiencies identified in the BNL analysis.
The staff is currently reviewing this matter in further detail.
The progress to date for the i
l resolution of the staff concern indicates that the possibility of additional significant modifications to the structure is remote.
Any modifications which may be necessary will not likely affect systems or components needed for fuel load or otherwise interfere with activities associated with modes 5 and 6.
Therefore it is acceptable to the staff to defer qualification of the buried diesel fuel oil tanks to Step 2.
[
- 31. The combination of codirectional responses to 3 components of earthquake motion for the turbine building should be explained.
(SSER 18, page C.3-37)
I?
The PG&E Phase I Final Report contained a statement that the codirectional response due to the three orthogonal components of ground motion are combined on an SRSS basis or equivalent. This statement indicated that the provisions of the FSAR'may not have been followed and failed to specify what equivalent method was used.
PG&E subsequently informed the staff that the equivalent method used was the full value of one component added to the sum of 40% of each of the other two components. This approach appears to lead to an acceptable resolution of this concern, and the staff is near completion of the review of this matter. The progress to date for the resolution of the staff concern indicates that the possibility of additional significant modifications to the structure is remote. Any modifications which may be necessary will not likely affect systems or components needed for fuel load or otherwise interfere with activities associated with modes 5 and 6.
Therefore it is acceptable to the staff to' defer this matter of codirectional responses to Step 2.
Step 3 Three items (numbers 11,13 and 28) were designated for resolution prior to authorization of Step 3 (full power operation) based on the following general criteria:
(a) Matters concerning structures, systems and components remote from the reactor coolant system; or, (b) Matters re:garding structures, systems and components which do not present a safety concern during low power testing.
One of the three items required for Step 3 (no. 28) was fully resolved ii. SER Supplement No. 19.
The re.naining two items (nos.11 and 13) are discussed be.ow.
19 11.
Modeling of roof trusses in the turbine building should be clarified and justified.
(SSER 18, page C.3-36)
The staff was concerned that the method of modeling the roof trusses by using two generalized uniaxial members and obtaining responses from the members may not produce the maximum response in each individual truss member.
PG&E stated that the generalized truss model was used only for calculating global responses and that individual member forces were obtained from a model that contained all truss members.
The responses from the global model w:!re applied to the individual member model as static loads.
The IDVP has verified the' calculations and concluded that the idealization of the roof trusses into two uniaxial members was done properly. The staff is currently completing the review of this matter.
The progress to date for the resolution of the staff concern indicates that the possibility of' additional significant modifications to the structure is remote.
Any modifications which may be necessary will not likely affect systems or components needed for fuel load or otherwise
~
interfere with activities associated with modes 5 and 6.
Therefore it is acceptable to the staff to defer modeling of the turbine building roof trusses to Step 3.
13.
Differences in turbine building modeling of steel frame and roof truss for two vertical models should be clarified.
(SSER 18, page C.3-37)
The staff was concerned that the differences in the number of degrees of l
freedom for the nodes above elevation 140 used in the two vertical models of the roof trusses was not consistent with the response of the structure.
PG&E stated that since the trusses near each end of the turbine building l
20 can produce horizontal motion from a vertical input while those nearer the center of the building could not, the models were appropriate. The IDVP sampled one of the models for their evaluation and found that model acceptable. The staff is currently reviewing this matter in further detail. The progress to date for the resolution of the staff concern indicates th' t the possibility of additional significant modifications a
to the structure is remote. Any modifications which may be necessary will not likely affect systems or components needed for fuel load or otherwise interfere with activities ascociated with modes 5 and 6.
Therefore it is acceptable to the staff to defer the resolution of the degrees of freedom for the vertical models to Step 3.
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II. 15 Follow-Up Items Presented below is a brief discussion of each of the'15 follow-up items, the milestone for their close-out and the basis for the milestone. The staff expects a complete update of the FSAR from PG&E by March 1984.
For any of the items involving FSAR revisions with a milestone prior to this date PG&E will provide the necessary information per the milestone date.
1.
PG&E will perform a startup test of AFWS runcut control system to confirm dynamic stability.
(SSER18,pageC.4-3)
An analysis performed by the IDVP indicated that the pressure control setpoints for the AFWS runout control system may not be low enough to permit minimum required flow to the steam generators when only one motor-driven AFW pump is operating.
PG&E changed the low pump discharge pressure setpoints and committed to perform a startup test of the runout control system to confirm dynamic stability. The IDVP review of the new setpoints and startup test commitment indicated that the proposed resolution was acceptable.
The staff concurred with this f
resolution in SSER 18.
The test will be completed prior to entering mode 3.
The AFWS is not required to be operable by plant technical specifications prior to entering mode 3.
Therefore it is acceptable to the staff to defer the testing to Step 2.
2.
PG&E will delete from design drawing steam trap in steam supply line for turbine-driven pump of AFWS.
(SSER 18, page C.4-5) i The IDVP performed a field walkdow.1 of the AFUS to verify compliance i
l of the as-built installation with the design documents. The as-built installation was confirmed to meet. design drawings except that a steam 1
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- 2. 2-trap on the turbine-driven AFW pump steam supply line was not provided.
. PG&E indicated that the design drawings would be revised to delete the steam trap on the steam supply line because satisfactory testing of the turbine-driven pump was completed without the need for the trap.
The IDVP confirmed that the actual AFWS installation was acceptable and no technical concern existed.
The staff concurred with the above resolution in SSER 18. The staff will verify incorporation of the drawing change and confirm as-built drawings prior to entering mode 3.
The AFWS is not requi ed to be operable by plant technical specifications t
prior to entering mode 3.
Therefore it is acceptable to the s'caff to defer as-built confirmation to Step 2.
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3.
PG&E will revise FSAR to reflect acceptability of as-built conditions regarding separation and color coding of electrical circuits for AFWS.
(SSER 18, page C.4-8)
Discrepancies regarding the as-built conditions for separation and color coding of AFWS electrical circuits-was identified by the IDVP.
PG&E committed to revise FSAR Section 8.3.3 to reflect acceptability of as-built conditions regarding separation and color coding. The staff concluded in SSER 18 that these concerns have been acceptably resolved and that plant modifications or additional verification is not required.
FSAR revisions confirming AFliS electrical circuit l
separation and color coding will be submitted by P6&E prior to entering mode 3.
The AFUS is not required to be operable by plant technical specifications prior to entering mode 3.
Therefore it is acceptable to the staff to defer the FSAR revision to Step 2.
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23 4.
PG&E will correct table in environmental qualification report with respect to flow transmitters and flow control valves in AFUS.
(SSER18, page C.4-12) r The IDVP review of the environmental qualification of AFWS equipment indicated that a flow transmitter and flow control valve, which are exposed to a harsh environment resulting from a high energy line break.
were not listed as located in harsh environments, PG&f. respondec Qy
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noting that the flow transmitter was identified under a different identification number and that vendor provided justific4tton for interim operation pending completion of the environmental qualifir.ation, The flow control valve was conditionally qualified, s' object, to an org ing 1
maintenance surveillance program, but was erro.neously listed as a ccmponent not subject to a harsh environmer.t.
PG&E will c:rrect errcrs in the qualification report tables.
The IDVP withdrew its concern on this matter.
The staff concurred with the IDVP resolution of this matter in SSER 18.
Environmental qualification (EQ) documentat-ion for the AFWS will be revised and sulc1tted by FG&E prior to entering mode 3.
The AFUS is nut required to be operaLle by plant technical specsfications prior to er.tering acdc 3.
Therefore it is acceptable t.o the staff to deter EQ documentation update to Step 2.
5 PG&E will conduct aralyses to determi.ne qualified life of mstor capacit.or for steam generator control egives.
(SSER 18, page C.4+12) i 1
The IDVP review of the env.ircamental qualification, of AFWS e49 pr.ent indicated that steam generatar level control valves may not be qualified l
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for harsh environments resulting from high er.ercy liine breaks as required because the cotor capacitor qualificati6n report was not yet complete. The qualification report did include justification for interim operation with freplacement of this component folloaing 20,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> of operation.
FG&E indicated that an analysis to determine the qualified life of this component is being conducted. The IDVP concluded that the PG&E response resolved this concern. The staff concurred with the conclusion's of the IDVP on this matter in SSER 18. Suhnittal of the analysis regarding motor capacitor qualificattion life is required prior to entering rode 3.
The steam generator level control valves (on the AFW lines) are not erquired to be operable by plant technical specifications prier to entering mcde 3.
Therefere it is acceptable to the staff to defer completion of the staff review of the analyses to Step 2.
In any event, justification for interim operction has previously l
been submitted by PG&E.
6.
PG&E will amend FSAR to indicate that pipe breaks are not postulated in
' steam supply line to turbine-driven pump of AFWS.
(SSER 18, page C.4-16)
The 1DVP review of high energy line cracks indicaced that certain ARis conponents were exposed to a postulated break in the steam supply line to the turbiae-driven AFWS pump.
PG&E reevaluated the high energy line crack analysis against the FSAR connitments (Giambusso letter dated December 18,1972).
It was determined that the line establ~ished in the IDVP analysis as a source affecting the motor-driven AFW pumps and pressure transmitters (lecated on the steam supply line to the turbine-driven AFW pump downstream of the flow control valve) was not subject to i
9
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d cracks because it is not pressurl:e.1 during any rormel plant operating conditions, including startup and snutdown.
PG&E ' committed to rsvise the FSAR to indicate the above point. The 30VP 6 greed with the above resolution. The staff concurred with the resolution in SSER 18 FSAR
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revisions confirming AFWS turbine sttam supply lins [,ipe break resolution j
will be submitted by PG&E prior to en1:ering mode 3.
The AJWS is no't i
1 required to be cperable price to antering made 3-Therefore it is acceptable to the staff to defer the F.SAR revision to Step 2.
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7.
PGLE will amend FSAR to inc'tude all changes *or equipment qua'lification (CRVPS and AFWS) that resulted from re&nalysis of pipe break environments outside containment.
(SSER 18, page C 4-16)
The ID'.'P review of high energy line crac h indicated that certain. AFWS ard CRVPS components may not have been qualified for the resulting environnents.
PG&E performed a reana!ysis of the blowdown jet temperature from the pcstulated high energy line crack source affecting the AFkiS level valves using the At45 Standard 58.2 methodology in lieu of the t;SC method documented en the FSAR.
The result's of this reanalysis showec a jet temperature below the qualificatica temperature for the valves.
PG&E committed to revise the FSAR te incorporate this reanalysis. Additionally, for cables / wires and splices in the AFWS and CRVPS identified as targets l
by the IDVP, PG&E responded by providing documentation that indicated that the affected cables / wires innd splices were environmentally qu:lified for the resulting high energy line cr6ck blowdown jet environment and further corxaitted to updato environmental qualification documentation.
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The IDV? concurred with the above resolutions. The staff concurred with 4.
the res61ution in SSER 18, FSAR revisions confirming satisfactory 1
resolutioh of jet impingecent terr.parature methodology and cable / wire l
aquipment qualification documentation will be submitted by PG&E prior to exceeding 140' F (modes 5 and 6).
No erivironmental qualification corccrns are present at such a low temperature since a harsh environmenc cannot result.
Tnerefore it is acceptable to the staf'f to defer docunentation to Step 2.
(Also see items 13 and 14 below.)
8.
PG&E will revise FSAR licensing ::ommitment regarding need foF protective shields for AFW5 components (valves) against effects of moderage ehergy i
line breaks.
($S[R 18. page C.4 17)
Tha 10VP review of moderate 6nergy line breaks indicated that two AFHS were not provided with protective shield: as documented in a licensing e
corsitment. /dG&E indicated that the flow centrol valves (suction supply valves from the alternate AFWS water sour'ce., tt.e raw water storage I
reservoir) ar? net required to operate to ensJre AFWS safety function following the postulcted moderate energy ifne break; therefore, they are not required to be prGt' acted from the pipe break effects.
PG&E committed to revise the licensing commitzcnt to delete the need for protective shields for these valves The IDVP Egreed with this respense. The staff co1 curred uith the resolution in SSEF.18.
PGSE letter dated June 15, 1933, da:uments deletion of the prctective shields fo+ the lcng-term witer l
supoly va' ves for the AFWS.
Therefore this concern has txten closed out.
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2:7 9.
Staff will ccnfirm that any modifications required in safety-rciated systerrs with respect to pressure / temperature rating and power cperated vailve operability are implement.ed.
(SSER 18, page C.4-26)
As a result of concerns identified by the IDVP regarding compliance with applicable design codes fcr the selection of the auxiliary feedwater system (AFES) design pressure, isolation of low-pressure portions of the system from hign-pressure portions, and the specification of low 2
differential pressure for the motor-operated steam supply valvas to the AFW turbina-driven pump, the IDVP determined that additional sampling in these areas was required.
PGSE undertcot a review of the above concerns for all safety-related systems within their design secpe.
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This generic review resulted in several modifications to safety-related systems as decuinented in PG&E letter dated October 7,1983, which have been completed. The staff will verify that required modifications documnted in PG&E letter dated October 7,1983, are.in place prior to Step 2.
Prior to Step 2, the plant will not be in an operating condition wnicn tvould result in pressure / temperature rating and power-operated valve operability considerations.
Therefore it is acceptable to the staff to defer as-built verification te Step 2.
10-PG&E will verify assumptioris regarding closing / opening of doors and ope,ation of ventilation systems in their continuing pressure / temperature I
environmental reanalysis.
(SSER 18, page C.4-27) i As a result of the IDVP concerns r:agarding the method for establishing pressure / temperature environments following postulated high energy pipe breaks outside containment, PG&I undertook a reanalysis in this area.
28 Specific concerns identified by the IDVP were with respect to assumptions regarding door positions and ventilation system operation.
PG&E will provide verification c,f the assumptions regarding the above aspects of the reanalysis and will submit the reanalysis results including assumptions prior to exceeding 140' F.
No environmental qualification concerns are present at icw temperature. Therefore it is acceptable to the staff to defer verification of the assumptions to Step 2.
11.
PG&E will make Inodifications and provide revised documentation as necessary based on restilts of pressure / temperature environmental reanalysis.
(SSER 18, page C 4-27)
As a result of the IOVP concerns regarding the method for establishing pressure / temperature environments following postulated high energy pipe breaks outside containment, PG&E undertook a reanalysis in this area.
The IDVP review of the resulting presscre and temperature transient l
conditions determined that the reanalyses methodology for the remaining l
auxiliary building areas was consistent with that used in areas GE and GW ar.d in the turbine building.
PG&E indicated that results obtained are conservative for the break compartment.
PG&E has committed to make any modifications necessary as a result of this reanalysis, and provide revised documentation of this work.
The IDVP concluded that the reanalyses i
I satisfactorily resolved the IDVP concerns.
Because of this conclusion, the IOVP determined that a further verification of the PG&E continuing i
effort in the selection of pressure and temperature conditions and associated environmental qualification of safety-related equipment was not necessary.
PG&E will submit the results of the pressure / temperature i
27 environmental reanalysis and complete necessary modifications or provide a
justification for interim operation prior to exceeding 140' F.
Any modifications required would be outside containment and would be expected to be of a minor nature. No environmental qualification concerns are present at low temperature. Therefore it is acceptable to the staff to defer completion of modifications to Step 2.
12.
Staff will evaluate results of reanalysis with respect to assuring environmental qualification of equipment.
(SSER 18, page C.4-27)
As a result of the IDVP concerns regarding the method for establishing pressure / temperature environments following postulated high energy pipe breaks outside containment, PG&E undertook reanalysis in this area.
Included in the PG&E effort is a verification of-environmental qualification of equipment to the environments resulting from the reanalysis.
The staff will confim satisfactory environmental qualification (EQ) has been provided to the reanalyzed environments (see item 11 above) or acceptable interim operation justification has been provided prior to exceeding 140' F.
No environmental qualification concerns are present at low temperature.
Therefore it is acceptable to the staff to defer EQ confirmation to Step 2.
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l 13.
PG&E will revise FSAR to incorporate use of ANS 58.2 jet impingement temperature calculational method where applicable.
(SSER 18, page C.4-14 and 16) l l
The IDVP review of high energy pipe crack concerns indicated that jet l
impingement may result in temperatures in excess of the qualification l
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30 value for certain AFWS and CRVPS components.
PG&E utilized the ANS 58.2 jet impingement temperature calculation method in lieu of that identified in the FSAR to verify that the qualification temperature was l
not exceeded.
PG&E comitted to revise the FSAR to incorporate use of ANS 58.2 jet impingement temperature calculational method. The IDVP reviewed this method and verified that it provides acceptable results.
The staff concurred in this resolution in SSER 18.
FSAR revisions confirming use of ANS 58.2 jet impingement temperature calculational method will be submitted by PG&E prior to exceeding 140' F.
No environmental qualification concerns are present at low temperature.
Therefore it is acceptable to the staff to defer FSAR revisions to Step 2.
14.
PG&E will revise equipment qualification documentation to include qualified AFWS cable / wire other than that previously identified.
(SSER 18, page C.4-16)
The IDVP review of high energy pipe crack concerns indicated that cable /
wire other than that previously identified as environmentally qualified for use in the AFWS was utilized, and was subject to high temperature jet impingement.
PG&E provided documentation which indicated that the cable / wire was qualified to the resulting jet impingement temperature.
I PG&E committed to revise the environmental qualification documentation.
The IDVP reviewed the documentation and concurred with the resolution.
The staff concurred with this resolution in SSER 18.
Equipment environ-mental qualification documentation confirming satisfactory qualification
(
of cables / wires will be submitted by PG&E prior to exceeding 140* F.
No environmental qualification concerns are present at low temperature.
Therefore it is acceptable to the staff to defer documentation to Step 2.
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eu 15.
FG&E will revise FSAR to incorporate results of moderate energy line break analyses on the CRVPS.
(SSER 18, page C.4-17)
The IDVP review of moderate energy line breaks indicated that PG&E had failed to meet its licensing commitment by not including the CRVPS in the original moderate energy line break analysis.
PG&E provided a subsequent analysis indicating that only one CRVPS electrical train is affected by the postulated break identified by the IDVP. When combined with a single failure in the redundant electrical train, a loss of the CRVPS would occur, resulting in degradation of control room habitability.
However, safe shutdown can be provided from the remote shutdown panel in the event the control room becomes uninhabitable.
The IDVP concurred with this analysis.
The staff also concurred with this resolution in SSER 18.
FSAR revisions confirming satisfactory moderate energy line break protection for the CRVPS will be submitted by PG&E prior to initial criticality.
Remote shutdown capability is provided in the event of loss of the CRVPS due to a moderate energy line break as indicated above.
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Moreover, because no fission product inventory is present, control room habitability is not of concern and offsite release consequences are not present. Therefore it is acceptable to the staff to defer 'the FSAR revision to Step 2.
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