ML20210B764

Application to Amend License DPR-54,revising Fire Protection Safety Evaluation.Proposed Revs,Justification & NSHC Evaluation Encl.Fee Paid

ML20210B764
Person / Time
Site:	Rancho Seco
Issue date:	01/16/1986
From:	Reinaldo Rodriguez SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	Miraglia F Office of Nuclear Reactor Regulation
References
RJR-85-394, TAC-61485, TAC-61486, NUDOCS 8602100047
Download: ML20210B764 (7)

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$ SMUD SACRAMENTO MUNICIPAL UTILITY DISTRICT : : 6201 S Street, PO. Box 15830, Sacra.

"M8) 7 CA 958521830,1916) 452 3211 AN ELECTRIC SYSTEM SEHVING HEM T OF CALIFORNIA RJR 85-394 SEG Jet 30 nl 1: r1 REG;CilV M January 16, 1986 DIRECTOR OF NUCLEAR REACTOR REGULATION ATTENTION FRANK J MIRAGLIA JR DIRECTOR PWR-B DIVISION US NUCLEAR REGULATORY COMMISSION WASHINGTON DC 20555 DOCKET 50-312 OPERATING LICENSING NO. DPR-54 RANCHO SECO NUCLEAR GENERATING STATION, UNIT NO. 1 REQUEST FOR LICENSE AMENDMENT REVISION As part of a comprehensive re-evaluation of Appendix R requirements, the District updated the Rancho Seco Fire Hazard Analysis Report (FHAR). This 1985 Rancho Seco FHAR update revised fire boundaries such that a number of doors and dampers described in the imC fire protection Safety Evaluation for License Amendment 19 are no longer required. Therefore, the District requests the NRC to issue a revision to Rancho Seco License Amendment 19, issued February 28, 1978.

Attachment I contains the proposed revisions to Paragraphs 3.1.5(1),

3.1.30(1), 3.1.25(1), and 3.1.40(5) of the NRC Fire Protection Safety Evaluation. The attachment also includes the associated justification for the changes. Attachment II contains the "No Significant Hazards Consideration Evaluation. ** As part of the August 1,1985 letter on proposed Amendment 137, the District submitted the 1985 Rancho Seco FHAR update (Revision 1). As a result of the August 12-16, 1985 NRC audit, the District prepared Revision 2 of the 1985 Rancho Seco FHAR update to more clearly reflect the analyses used in its development. Attachment III is a copy of the 1985 Rancho Seco FHAR update Revision 2 supporting the proposed license change.

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.Hugh Thompson January 16, 1986 Pursuant to 10CFR170.12, enclosed is payment of the application fee of $150.00.

If you have any questions concerning the attachments, please contact Larry You of my staff, at (916) 452-3211, extension 4816.

R. . RIG Z ASSISTANT G MANAGER, NUCLEAR

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' Attachments (4)

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ATTACHMENT I

1. License Condition 3.1.5(1)

A. Turbine Deck Corridor - Install fire dampers in all duct penetrations except the emergency control room ventilation duct (4.9.3).

B. Proposed Revision - Revise item to read as follows:

' Install fire dampers in all duct penetrations to Fire Areas 1, 2, 6, 62, RG1, and RG3 from Fire Area RT1 (as defined in 1985 Rancho Seco FHAR update) except emergency control room ventilation ducts.

> C. Justification - The original commitment was not totally satisfied

• in j that dampers were not installed in one duct at plant coordinates L i and 10.3, one duct at M and 10.3, one duct at P and 10.3, one duct at S and 10.6, and three ducts at R.8 and 11.7 (i.e., 7 total ducts).

These dampers are no longer required because the ducts do not penetrate the new fire boundary of Fire Area RT1. Fire Area RT1 includes former Fire Areas 3, 4, 5, 7, 8, 9, 10, 11, 12, 13, and 14.

Other missing dampers described in LER 85-004 have been installed.

2. License condition 3.1.30(1)

A. Containment Penetration Valve Area West (5.14) - Install fire dampers in ducts to Fire Areas 46, 58, and 59.

B. Proposed Revision - Revise item to read as follows:

Install fire dampers in ducts to Fire Areas 46, 58, and 59 except for duct in corridor 045.

C. Justification - Former Fire Area 50, which includes corridor 045, has ,

been incorporated into new Fire Area RBl. Former Fire Area 46 has j been incorporated into new Fire Area RB2. The original commitment was not satisfied

• in that dampers were not installed in a 32-inch diameter duct in corridor 045 that crosses the fire boundary between l RBI and RB2. The duct is above an existing 6' x 20' opening in the l 3 fire boundary between RBI and RB2. The District has requested that l this opening not be closed in Exemption 7 in the November 7,1985 l 1etter to the NRC. In this exemption request, the District committed to add sprinklers above the opening to provide a water separation barrier. The duct traverses corridors 045 (RB1) and 036 (RB2), with no openings in either corridor. The heavy gauge of the 32" diameter duct precludes a fire in either corridor entering the duct to i propagate to the other fire area. The light combustible loading in l

. the areas RB1 or RB2 precludes a fire propagating into the duct

• See Rancho Seco LER 85-004, dated March 8,1985, RJR 85-119. ,

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I openings, travelling through the duct, and burning through the 32" diameter heavy gauge ducting in Fire Area RB1 or RB2. Also, the duct opening does not significantly increase the size of the opening.

Therefore, the installation of a damper in this location is not required, since it would not provide additional protection.

3. License Condition 3.1.25(1)

A. Waste Solidification Area - Provide a minimum Underwriter's Laboratory "C" rated door in doorway to Room 110, Fire Area 34 (4.9.2).

B. Proposed Revision - Delete item.

C. Justification - Former fire Areas 34 and 39 have been incorporated into new Fire Area RGl. Door assembly AU149 (door to Room 110) is no longer a part of a fire area boundary and, therefore, the door is not required to be rated.

4. License Condition 3.1.40(5)

A. Fire Door - The licensee has proposed to upgrade fire doors in five locations (4.9.1) - Item (5) between Fire Areas 58 and 50.

B. Proposed Revision - Delete item (5).

C Justification - Former Fire Areas 50 and 58 have been incorporated into new Fire Area RBl. Door assembly AUB01 (door between Fire Areas 50 and 58) is no longer part of a fire area boundary and, therefore, the door is not required to be rated.

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ATTACHMENT II

1. The original commitment in License Amendment 19 [3.1.5(1)] was not totally satisfied in that seven dampers were not installed in ducts from the turbine deck corridor (former Fire Area 14). These seven duct s are at plant coordinates L and 10.3 (one duct), M and 10.3 (one duct), i . i 10.3 (one duct), S and 10.6 (one duct), and R.8 and 11.7 (three ducts). These ducts no longer require dampers since they do oot penetrate the fire boundary.

This change is a "No Significant Hazard Consideration" based on the following evaluation of the three criteria of 10CFR50.92(c). The 1985 Rancho Seco FHAR update defines a new Fire Area RT1 which includes former

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Fire Areas 3, 4, 5, 7, 8, 9, 10, 11, 11, 13, and 14. The seven ducts without dampers are through the interior walls of Fire Area RT1 and do not penetrate the fire boundary of RT1, thus they do not provide a path for the spread of fire outside RT1. The fire loadings of these areas in the 1977 FHAR have been compared to the fire loading in the 1985 Rancho Seco FRAR update and there are some differences due to plant modifications over the years. However, the changes in fire loadings are not significant.

Based on the fire loading the fire boundary used for Fire Area RT1, the fire is contained in the area and safe shutdown equipment in other fire areas is adequately protected. This analysis is documented in the section on Fire Area RT1 of the 1985 Rancho Seco FRAR update.

Thus the proposed amendment does not:

(1) Involve a significant increase in the probability or consequences of an accident previously evaluated; or, (2) Create the possibility of a new or different kind of accident from an accident previously evaluated; or, (3) Involve a significant reduction in a margin of safety.

2. The original commitment in License Amendment 19 [3.1.30(1)] was not totally satisfied in that a damper was not installed in a 32-inch duc' in corridor 045 (former Fire Area 50) that goes into former Fire Area 46.

This 32-inch duct is above an existing 6' x 20' opening (i.e., opening to corridor 045) and the District has requested in Exemption 7 of the November 7,1985 letter that these openings not be closed.

This change is a "No Significant lazard Consideration" based on the following evaluation of the three criteria of 10CFR50.92(c). Former Fire Area 50 which includes corridor 045 has been incorporated into new Fire Area RBI and former Fire Area 46 has been incorporated into new Fire Area RB2. In Exemption 7 the District committed to add sprinklers above the 6' x 20' opening to provide a water separation barrier. The duct traverses corridors 045 (RB1) and 036 (RB2) with no openings in either corridor.

The heavy gauge of the 32 inch diameter duct precludes a fire in either corridor entering the duct to propagate to the other fire areas.

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The light loading in the areas RB1 or RB2 precludes a fire propagating into the duct openings, travelling through the duct, and burning through the 32" diameter heavy gauge ducting in Fire Area RB1 or RB2. The 1985 Rancho Seco FHAR update considered this duct without a damper as part of the 6' x 20' opening, and shows that the fire protection features provided and the low fire loading preclude the propagation of the fire beyond the boundaries defining the fire areas. Also the fire loading of these areas in the 1977 FRAR have been compared to the fire loading in the 1985 Rancho Seco FHAR update and there are some differences due to plant modifications over the years. However, the changes in fire loading are not significant. Based on the fire loadings and fire boundaries used for Fire Areas RBI and RB2, the fires are contained in their areas and safe shutdown equipment in other fire areas is adequately protected. The se analyses are documented in the sections on Fire Areas RBI and RB2 of the 1985 Rancho Seco FHAR update.

{ Thus the proposed amendment does not:

(1) Involve a significant increase in the probability or consequences of an accident previously evaluated; or, (2) Create the possibility of a new or different kind of accident from an accident previously evaluated; or, (3) Involve a significant reduction in a margin of safety.

3. The original commitment in License Amendment 19 [3.1.25(1)] was satisfied by the installation of the rated door AU149. The 1985 Rancho Seco FHAR update has combined former Fire Areas 22, 34, 35, 39, and 65 into Fire Area RG1, and door assembly AU149 (door to room 110) was on the boundary between former Fire Areas 34 and 39. This door is no longer required to be rated because the door is not part of the fire boundary of Fire Area RGl.

This change is a "No Significant Hazard Consideration" based on the following evaluation of the three criteria of 10CFR50.92(c). The 1985 Rancho Seco FHAR update combines former Fire Areas 22, 34, 35, 39, and 65 into Fire Area RG1, and door assembly AU149 (door to room 110) was on the boundary between former Fire Areas 34 and 39. This door is no longer required to be rated because the door is not part of the fire boundary of Fire Area RGl. The door is between the interior walls of Fire Area RG1 and does not penetrate the fire boundary of RG1, thus it does not provide a path for the spread of fire outside RGl. The fire loadings of these areas in the 1977 FHAR have been compared to the fire loading in the 1985 Rancho Seco FRAR update and there are some differences due to plant modifications over the years. However, the changes in fire loadings are not significant. Based on the fire loading and fire boundary used for Fire Area RG1, the fire is contained in the area and safe shutdown equipment in other fire areas is adequately protected. This analysis is documented in the section on Fire Area RG1 of the 1985 Rancho Seco FRAR update.

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1 Thus the proposed amendment does not: '

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(1) Involve a significant increase in the probability or consequences of an accident previously evaluated; or, (2) Create the possibility of a new or different kind of accident from an accident previously evaluated; or, (3) Inycive a significant reduction in margin of safety.

4. The original commitment in License Amendment 19 [3.1.40(5)] was satisfied by the installation of the required fire rated door AUB01. The 1985 Rancho Seco FHAR update has combined former Fire Areas 49, 50, 51, 52, 58 and 60 into Fire Area RBI and door assembly AUB01 was on the boundary between former Fire Areas 50 and 58. This door is no longer required to

.be rated because the door is not part of the fire boundary of Fire Area RBl.

This is a "No Significant Hazard Consideration" based on the following evaluation of the three criteria of 10CFR50.92(c). The 1985 Rancho Seco FRAR update combines former Fire Areas 49, 50, 51, 52, 58 and 60 into Fire Area RBI, and door assembly AUB01 (door to room 044) was on the boundary between for_ar Fire Areas 50 and 58. This door is no longer required to be rated because the door is not part of the fire boundary of Fire Area RB1, thus it does not provide a path for the spread outside RBl. The fire loadings of these areas in the 1977 FHAR have been compared to the fire loading in the 1985 Rancho Seco FHAR update and there are some differences due to plant modifications over the years. However, the changes in fire loadings are not significant. Based on the fire loading and fire boundary used for Fire Area RB1, the fire is contained in the area and safe shutdown equipment in other fire areas is adequately protected. This analysis is documented in the section on Fire Area RB1 of the 1985 Rancho Seco FRAR update.

Thus the proposed amendment does not:

(1) Involve a significant increase in the probability or consequences of an accident previously evaluated; or, (2) Create the possibility of a new or different kind of accident from an accident previously evaluated; or, (3) Involve a significant reduction in margin of safety.

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