ML20210C233
| ML20210C233 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 09/10/1986 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20210C226 | List: |
| References | |
| GL-83-33, IEIN-84-09, IEIN-84-9, TAC-57854, TAC-57855, TAC-57856, TAC-60032, NUDOCS 8609180292 | |
| Download: ML20210C233 (90) | |
Text
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i ENCLOSURE 2 pu UNITED STATES j
p, NUCLEAR REGULATORY COMMISSION 5
- j WASHINGTON, D. C. 20655
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SAFETY EVALUATION BY-THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO EXEMPTION FROM 10 CFR 50, APPENDIX R ALARAMA POWER COMPANY JOSEPH M. FARLEY NUCLEAR PLANT, UNIT NO. 1 DOCKET NO. 50-348
1.0 INTRODUCTION
By letter dated May 31, 1985, supplemented by letter dated October 18, 1985, the ifcensee submitted the results of their Appendix R fire hazards analysis re-evaluation, dated May 1985 for review. The licensee contends that the re-evaluation was prompted by the interpretations to Appendix R promulgated.
in IE Notice 84-09 and Generic letter 83-33. Therefore, based on the results of this re-evaluation the licensee requested twenty-seven additional exemptions from the specific provisions of Section III.G of Appendix R for fire areas in Unit 1.
The Comission previously granted an exemption on December 30, 1983, for certain system cables or components located within the containment buildings of Units 1 and 2.
The Commission also granted an exemption on November 19, 1985, for certain shared fire areas of Unit No.- I with fire areas of Unit No. 2.
This evaluation treats exemptions as requested by the licensee for fire areas affecting Unit 1 only.
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:
i a.
Separation of cables and equipment and associated non-safety circuits of redundant trains by a fire barrier having a three-hour rating.
Structural steel fonning a part of or supporting such fire barriers shall be protected to provide fire resistance equivalent to that required of the barrier, b.
Separation of cables and equipment and associated non-safety circuits of redundant trains by a horizontal distance of more than 20 feet with no intervening combustibles or fire hazards.
In addition, fire detectors and an automatic fire suppression system shall be installed in the fire area.
c.
' Enclosure of cables and equipment and associated non-safety circuits of one redundant train in a fire barrier having a one-hour rating.
In addition, fire detectors and an automatic fire suppression system shall be installed in the fire area.
8609180292 860910 DR ADOCK 0000 9
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2 In summary,Section III.G is related to fire protection features for ensuring the systems and associated circuits used to achieve and maintain safe shutdown are free of fire damage. Fire protection configurations-
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must either meet the specific requirements of Section III.G or an alternative fire protection configuration must be justified by a fire hazard analysis.
If these conditions are not met,Section III.G.3 requires an alternative shutdown capability independent of the ' fire area of concern.
It also requires that a fixed suppression system be installed in the fire area of concern.if it contains a large concentration of cables or other combustibles.
These alternative requirements are not deemed to be equivalent; however, they. provide equivalent protection for those configurations in which they I
are accepted.
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Because it is not possible to predict the specific conditions under which fires may occur and propagate, the design basis protective features are specified in the rule rather than the design basis fire. Plant specific features may require protection different than the measures specified in 'Section III.G.. In such a case, the licensee must demonstrate, by means of a detailed fire hazards analysis, that existing protection or existing protection in conjunction with proposed modifications will provide a level of safety equivalent.to the technical requirements of Section III. G of Appendix R.
Our general criteria for accepting an alternative fire protection configuration are the following:
The alternative assures that one train of equipment necessary to achieve hot shutdown from either the control room or emergency control stations is free of fire damage.
The alternative assures that fire damage to at least one train of
' equipment necessary to achieve cold shutdown is limited such that it can be repaired within a reasonable time (minor repairs with components stored on-site).
Modifications required to meet Section III.G would not enhance fire l
protection safety above that provided by either existing or proposed l
alternatives.
Modifications requires to meet Section III.G would be detrimental to overall facility safety.
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As a result of a site visit during the week of August 19, 1985, we detemined that for five of the twenty-seven exemptions request additional technical information was required and some additional plant fire protectionmodifications(i.e.,additionalsprinklerprotectionand raceway fire barriers were necessary in order to assure that the licensee's alternative fire protection configurations would represent an equivalent level of safety to that achieved by full compliance.with Section III.G of Appendix R.
Thus, the licensee connitted to provide the necessary fire protection modifications and the additional technical information to support the five outstanding exemption requests. Therefore, we deferred our review and evaluation of exemption requests 1-17, 1-26, 1-31, 1-36 and 1-38 pending receipt of additional licensee infomation. The attachment to this evaluation completes our action based on infomation provided by the license by letter dated October 18. 1985.
I Our evaluaticns of the licensee's. alternate fire protection configurations and their justifications regarding the plant's alternative ability for specific redundant. shutdown fenctions to achieva and maintain safe shutdown conditions for fire conditior.s which affect those fire areas documented by twenty-two of the twenty-five exemption requests are as follows:
2.0 UNIT 1 AUXILI.ARY BUILDING CABLE CHASE TRAIN A - FIRE AREA 1-008 (EXEMPTION REQUEST 1-14)
UNIT 1 AUXILIARY EtIILDING TO DIESEL BUILDING CABLE TUNNEL TRAIN A - FIRE AREA 1-075 (EXEMPTION REQUEST 1-18)
UNIT 1 AUXILIARY BUILDING TRAIN A BATTERY ROOM - FIRE AREA 1-0:'
(EXEMPTION REQUEST 1-20)
UNIT 1 TRAIN A DC SWITCHGEAR ROOM AUXILIARY BUILDING EL. 121 ft. - 0 IN. - FIRE AREA 1-018 (EXEMPTION REQUEST 1-21)
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4 UNIT 1 AUXILIARY BUILDING EL. 139 ft. - 0 IN. - FIRE AREA 1-041 (EXEMPTION REQUEST 1-23)
UNIT 2 AUXILIARY BUILDING EL 139 ft. - 0 IN. - FIRE AREA 2-041?(EXEMPT 10N REQUEST 1-24)
UNIT 1 AUXILIARY BUILDING EL 139 ft. - 0 IN. - FIRE AREA 1-042] EXEMPTION REQUEST 1-25)
UNIT 1 AUXILIARY BUILDING CABLE CHASE TRAIN A - FIRE AREA 1-031 (EXEMPTION REQUEST 1-33) 2.1 EXEMPTIONS REQUESTED The licensee, in their exemption requests 1-14, 1-24, and 1-33 associated with the fire areas identified in Section 2.0 above., requested an exemption from the technical requirements of 10 CFR 50 Appendix R Section Ill.G.2 to the extent that one train of redundant safe shutdown cables be enclosed by a fire barrier having a one-hour fire rating.
In addition, the licensee's - exemption requests 1-20, 1-21, and 1-23 associated with the fire areas identified in Section 2.0 above requested an exemption from 10 CFR 50 Appendix R, Section III.G.2 to the extent that it requires one train of redundant safe shutdown cables be enclosed by a tire barrier having s one-hour fire rating and that-automatic fire suppression be installed in the area.
The licensee in their exemption request 1-18 requested an exemption from 10 CFR 50 Appendix R Section III.G.2 to the extent that it requires one train of redundant safe shutdown cables be enclosed by a fire barrier having a one-hour fire rating and the installation of an automatic fire detection system installed in the subject fire area.
Also, the licensee in their exemption request 1-25 requested an exemption from 10 CFR 5'O Appendix R, Sections III.G.2.a. and III.G.2.c to the extent that it requires that one train of cablicg, equipment and non-safety associated circuits of redundant trains be separated by a three-hour fire barrier or enclosed by a fire barrier having a one-hour fire rating.
2.2 DISCUSSION Fire Area 1-003 consists of only room 116 and is bounded by three-bour fire-rated ficer, ceiling, and walls.
Area boundary doors are UL Class A fire rated.
Fire Area 1-G75 cons-ists of a cable tunnel running from the Unit'I auxiliary building to the diesel generator building.
The fire area boundary floor, ceiling, and walls are three-hour fire rated. An UL Class A fire-rated door exists between the tunnel and 'the diesel building.
A non-fire-rated watertight door and bulkhead exist between the tunnel and auxiliary building
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4 room - 251f(area.1-031).
The non-rated door has a fire-resistant coating applied on the fire area 1-075 side.
m Fire Area 1-017 consists of only room 214 and is bounded by three-hour i
fire-rated floor, ceiling, and walls. Area boundary door is'UL' Class A fire rated.
Fire Area 1-018 consists of only room 224 and is. bounded by three-hour fire l
rated floor, ceiling, and walls. The door between fire area 1-018 and room 225 is UL Class A fire rated.
Fire Area 1-041 consists of rooms 335, 343, and 346. All fire area boundary walls, floors, and ceilings have a three-hour fire rating, with.all electrical and piping penetrations sealed for a three-hour. fire rating. All i-i vent 11stion ducting penetrating the fire area boundary have three-hour fire rated dampers installed. All doors located in the fire area boundary are UL listed Class A doors except for the door between rooms 345 and 346.
I Fire Area 2-041 consists. of rooms-2335, 2343, and.2346. All fire area boundary walls, floors, and ceilings have a three-hour fire rating, with all electrical and piping penetrations sealed for a three-hour fire rating. All l'
ventilation ducting area boundaries have three-hour fire rated dampers installed.
All doors 1ccated in the fire area boundary are.UL listed Class A doors except for the door between rooms 2345 and 2346.
Fire Area 1-042 consists of rooms 319, 339, and 345. All fire area boundary walls are three-hour fire rated with the exception of the wall adjacent to elevator No. I' and stairwell No. I which.are two-hour fire rated.
All electrical and piping penetrations are sealed and are three-hour rated. All ventilation ducting had three-hour fire rated dampers installed. All doors located in the boundary walls are Class A rated with the exception of a Class B rated do'or leading from room 345 into stairwell No.1 (area 1-501) and the door between rooms 345 and 346.- The floors and ceilings of Fire Area 1-042.are of reinforced concrete and-are three-hour fire rated with the exception of two hatchways with steel plate covers located-in room 345. The two hatches are located directly above one another in the floor and. ceiling of room 345 and communicate with Fire Areas 1-020 and 1-004.
l Fire Area 1-031 consists of rooms 250 (el 121 ft. - 0 in and 139 ft. - 0 i
in.) and 251 (el 127 ft. - 0 in.).
All area boundary walls, floors, and ceilings are three-hour fire rated except for a non-rated bulkhead between I
this fire area and the cable tunnel (area 1-075).
A non-fire rated l
watertight door and bulkhead exist between room 251 and cable tunnel (area 1-075), and an UL Class A fire rated door exists between rooms 250 and 235 (area 1-023). The non-rated door has a fire resistant coating applied on the fire area 1-075 side.
The licensee's re-evaluation has indicated that a fire in either fire areas 1-008, 1-018, 1-041, and 1-042 could damage control and power cabling associated with the Train A electrical distribution system. An analysis of the potential effects of a fire in any of these fire areas demonstrates that l
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the plant. could experience a fire induced failure of the total Train A electrical distribution systein, This could result in a loss of all reactor j
coolant system (RCS) hot leg temperature indication and neutron flux.
monitoring capabilities.
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A fire'in either fire areas 1-075, 2-041, or 1-031 could poteotf ally result in fire damage to the electrical circuitry of both Units 1 and 2 Trait A-diesel generators. This condition along with.an assumed loss of offsite power for Unit I could result in total loss of the electrical Train A distribution system.
This could result in the loss of the ' following instrumentation:
Instrumentation Function NIB 21TE413 (Loop-1)
RCS Hot Leg Temperature, Indication N1821TE423 (Loop-2)
RCS Hot Leg Temperat:r e, Indication N1821TE433 (Leop-3)
RCS Hot Leg Temperature, Indication Q1C55NE0048A-A Post-Accident Neutron Flux Monitor NIC55NE0031-P1 Source Range Neutron Flux Monitor NIC55NE0032-P2 Source Range Neutron Flux Monitor t)1N11PV3371A-A Main Steam Atmospheric Relief Valva (S.G. - 1A)
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Q1N11PV3371B-A Main Steam Atmospheric Ralief Valve (S.G. - IB)
Q1N11PV3371C-A Main Steam Atacspheric Relief Valve (S.G. - IC)
Note:
Fire Area 1-008 also contains cables required for post-fire operation of the main steam atmospheric relief valves.
In addition, a total loss of the electrical Train-A distribution system, as a result of a fire in either Fire Areas 1-008, 1-075, 1-017, 1-018, 2-041, 1-042, or 1-031 could also render main steam atmospheric relief valves electrically inoperable in the closed position.
Fire Area 1-017 contains electrical Train-A 125 V-dc plant batteries _and related 125 V-dc Train-A power cabling.
An evaluation of the potential effects of a fire in this area shows that the plant could experience a tetal
-loss of the 125 V-dc train-A distribution system. This condition along with an assumed loss of offsite power (LO5P) for Unit I will cause total loss of the electrical Train-A distributior. system. A total loss of the electrical Train-A distribution system could cause loss of RCS hot leg temperature indication and neutron flux monitoring instrumentation.
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The combustible materiaIs associated with the subject fire areas consists of cable insulation and/or plastic panel parts.
The following summarizes the fire loading associated with the subject fire areas-Fire Area Fire Load BTV/FT 1-008' 1,250,296 1-075 59,600 1-017 1,391 1-018 29,191 1-041 105,934 2-041 105,934 1-042 32,445 1-031 794,491' Fire Area 1-008 is protected by a smoke detection and an automatic sprinkler system. In addition,1 inch water type hose stations are located in rooms 185 (fire area 1-006) and 319 (fire area 1-042) and are available for manual fire brigade firefighting operations in Fire Area 1-008.
t Fire Area 1-075 is protected by an automatic water suppression system.
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In Fire Area 1-017 ar. area type smoke detection system is provided. This system alarms locally and is annunciated in the main control room. A CO2 hose reel and a I water type hose station is located in room 210 (fire area 1-020) and are available for fire brigade use in Fire Area 1-017.
An ionization smoke. detector is located in Fire' Area 1-018. In addition, a 1 inch water type hose station and a CO hose reel are located in room 210
,(Fire Area 1-020) and are available for fire brigade use in Fire Area 1-018.
b Fire Area 1-04 i s protected by an area smoke detection system.
In addition, heat detectors are located in the cabinets of the 600-V load center II,.4160-V.switchgear IA and 1F, 5-kV disconnect switch 1G, 600-V load center 10 an IA, and 4160-V switchgear 18 and IC. Heat detectors will actuate a total-ficoding C0 system in the load centers and switchgears. A CO hose reel located in room 339 (area 1-42), a water hose station in room 345 (area 1-42), and two water hose cabinets in room 319 (area 1-42), are available for use in this area.
Area smoke detection system is provided throughout Fire Area 2-041.
In addition, heat detectors are located in the cabinets of ' the 600-V load center 21, 4160-V switchgear 2A and 2F, 5-kV disconnect switch 2G, 600-V ioad center 20 and 2A, and 4160-V switchgear 2B and 2C. Heat detectors will actuate a. total-flooding CO2 system in the load centers and switchgears. A CO2 hose reel located in room 2339 (area 2-42), a wa'.er hose station in room 2345 -(area 2-42), and 2 water hose cabinets in room 2319 (area 2-42) are available for use in this area.
In Fire Area 1-042 ionization smoke detection is provided throughout the area. Two 1 inch water hose stations are located in room 319. A CO2 hose w
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reel is located lin room 319 and_ a' water hose in room 345. Automatic water
'. suppression systems are installed in the crea.to protect electrical cable
' from an. exposure fire and to provide coverage in the area of the' steel
. hatches. Appropriate barriers are provided for electrical cable.
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t The door between rooms 2346 (Fire Aree 2-041) and 2345 (Fire Area-2-042) ard between rooms 346 (Fire Area 1-041) and 345 (Fire Area 1-042) are provided with a removable transoms and cannot be labeled as UL Class A.
Two hatchways located in room 345 directly above one another have non-rated
' sheet plate covers, and communicate with Fire Areas 1-020 and 1*004.
Fire Area 1-031 is protected by an automatic ionization smoke detection
-system. In addition, automatic sprinkler protection is provided throughout the fire area. An 1 inch water type hose station is located in room 234 (Fire Area 1-020) and is available for use by-the fire brigade for manual firefighting in this area.
' The licensee justifies the acceptability of the exemptions requested in Section 2.1 on the basis of the existing fire protection, their alternative shutdown actions and the proposed plant modifications associated with the i
subject fire areas identified in Section 2.0.
2.3 EVALUATION
-One of the three main steam atmospheric relief valves and its related steam generator are required to be operable to achieve steam release _for cocidown.
The atmospheric' relief valves are provided with hand wheels such that the valves may be manually opened or closed without electrical controls or air supplies.
The operator can establish manual control of the. atmospheric relief valves by, closing the manual air control valves to isolate the air supply and by opening the manual air vent valve to bleed off air from. the diaphram of the valve actuator. Both the air control and air vent valves are located in the vicinity of their associated.atmospherte relief valve and l
would be accessible despite a fire in any of the subject: fire areas identified in Section 2.0 above. The capability to control steam generator-pressure and reactor coolant system temperature with the use of the manually controlled atmospheric relief valves was ' demonstrated during the Unit 2 natural circulation and cooldown startup testing. Consequently, fire in
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these fire areas would not prevent the operation of at least one redundant atmospheric relief valve.
Each. RCS Loop hot leg temperature instrumentation loop is powered from channelized inverter-1A. Inverter-1A is powered from 600 V-ac MCC 1A or 125 V-dc bus IA.
A fire in area 2-041 along with an assumed LOSP could result in loss of the 600 V-ac power supply to inverter 1A; however, inverter 1A will continue to operate from 125 V-dc bus IA and will supply power to the
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instrument loops for a minimum of two hours.
If after two hours power is lost, RCS hot leg temperature indication is available from the core exit thermocouples. A fire in either 1-008, 1-075, 1-017, 1-018, 1-041, 2-041, l
1-042 or 1-031 will not affect core exit temperature indication.
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In addition to the af terCate d: power supply, and cork etit twoperature
' availability; a dengn choge tts be iestdied as a restrit of Ras;ulatory Guide (RG) 1.07 will provfde,a Ndundcnt Qnai procesMM.and ind5 cation between RCS het leg temperature loops N 4?1TE413 W1E21 W T3, end H1821TE433.
Based upon RG 1.97 commitment-3schoMe, $mpler.astattor, of tAe ew41f'iention is currently planned for the seventh ecfueting outage resectly tetWduled to commence darit.g the fourth quarter of 1980. At.ter impitnenta. Mot cf, tM e modificaticn a fire 'in any of the fire ar,tas !denMfied 4 $rctJM 2.d thove will not affect the ability to monitor et leap of RCS hot 14 M*erato9.
Source range neutron flux monitors NI3%EH3kP1 ssd HIC 95MO%I43 ire powered from channelized inverteri,,lA 406 le, The post-accMe.l %det flux mor, iter QlC55NE0048A-A is powered fves inecter-1F, IereMo y M. %,
and 1F are all powered from 500 V-se MCC H or 125 V-de 605 4. Wr*bt neutron-flux monitor)ng following poteattat fD4 d4magt in the HA4 ed the resultant loss of 000 V-ae WCC 1A wiU N atdbble for e Mnk M of tuo hours. An RCS sample car. be obt.tWd after Wt4sthin of Ge Oft yJio by using portions of the RC5 samp1bg sy3 tert.61 AW Ur m. 2 e W ? #9pte valves Q1Pl$HV3195-B ard Q1PISW/410H for W.creetfA w W beren ccocentration and shutdown ancpn J411r=rieg a nre 44 er af $t A rr oren identified in Section 2.0.
The licensee, by letter May 31, 19E5s cc.%iutd 9 c(n% 4t00 d procedures specifically for ther wbject ffe? arvn 2 4t41 'y mis evaluation.
Yhese proceduret-wil? 1(tentMy tv 94@al DeM 4 #sWW required to regain control oi' Rt. 64% stus (**Actw,Cc nW,alv) and to monitor boren concentration ance wt.do.c mar.p% T(9e pyr.gsbrus Ivdl hs fully impimented by the end rf Ge IJnit 1 McW9 niOeMts etap.
The dcor/sranscom assemblies wpirectng hit i roam $41 @es arer ic-d4D and 345 (Fire Area 1-042) and Unit 2 r% ) Ud (ffre 4r4 bo4Q aMS MM (Fire Arer 2-042) are provided v5tb A reee@'s Pa;m> M owies 19 facilitate the movement of latta elecv:p! 4hf vure, hit dece gd (rotyr assemblies associated with these dcor8 mert tN 'A GN gm; &(wh od they bear a Class A UL labels, HwDer, riwe m PWu it f9mMb 4e subject door / transom assembHos cwot be MstM c d45 4 ty ut.
M respective tr.ansoms have been cedifhd by tM NkduWV M betof constructed of materials 3.r.d in a sceer.sWMr % ;/m M A $743 A ftto door. Therefore, based on the const@:tio% itit %stMat W U thop #Aur,s and the configuration of the inesito CHebot.th b i treM Unseda% vt 4
z have reasonable a$swant? thet a fire % volt ig tbc Wsb CCWM.db3es iii any of the subject fire arav would 50 p.91gabt drogh (*
u usom opening and spread ir.to th? adaacent fira arp).
The watertight door and the bulkhead betuton mDisty !.90SnQ pro f. 930 and cable tuariel (Area 1075) c net ecsol.y with uwmbcg/ f ts.trAW boundary require: rents. However, a 1 fire % 1,rn E0f:: ( M g eg u n; u.44 S ta 1-031 will not have any additional lenpart M can 4 pix mt&et. pcou I
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16 the sar,v rehndant sefe shutche fonctice tsbles are ccatained in both areas.
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It appaars,- that the sprinUce systen edsting in roca 345 will serve the
.parpop of a cata r;rtain to prevent the passace of fire from Area 1-042 to the adjacett f$re Ercas via th? con-rated steel hatches.
Thercfore, the tbcve acc below ecom 345 should p.reont 14 s,cread of i
3-042, A1) ott,er Gu:dron system assoc 16ted with the fire arcas. identified in Metson 2.0 han redgr; dant counterprts in other fire areas or are located.
in pynt arns obich recet the requirerent of 10 CFR $0 Appendix R Section
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Yit.G.2. As a re7A t, there 4 reasor,Mie assura.
i k1 any of tha 5MjE:Tt fTre 2Fla1 shfe ShutdcM could be achieved ar.d ccc that if a fire occurred cMetained.
2.4 WW. WON btes 01 oue evalutac6 Grre prpw.tita and %gtbn cethwa conc 1gle that the licensee's alternative v40 krNW an accec.fcMe level c?;. ration and ttteir proposed modiffcations f fire prctection to that required by the Dchoice) requiracuts.cf 15 CFR $9 Appadix R. Sectica III.G.2 and that no MJRional fire pYotectf09
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is ruuired to satisfy the requirements of 4
W;thn 111.G.3, Hic ercai, identifice in Iection 1,0 ebove should <te granted.ihtr
), ft WIT 1 CULIEY EUILtlM W!ICRGEn ROOM TRAIN B - FIRE AREA (I?b0 TICS M@EST I-D) i' TID 103 (ext @T.M KEQiEST I-19)N T l 5hXXIm EM Mtf i GII.IARY b!iLit;3 TRAIN O DC LITCHGEAR ROOM - FIRE A:.EA 1-019 dMCT@ FJQbEST !Wi) t
'3.1 CXErtPB7.iS RE$EST 1
The licensee 3 th: 1r excotien request 1-19 requested exemption froa the technical requtreurt A o* 10 CFR 50 Appendix R, Section III.G.2.C to the extert that it reqaires one train of redundant safe shutdown cables be
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enclosed by e fire barrier having a one hour fire retir4g.
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In addition, the litersee in their exemption requests 1-15 and 1-27 requested an exemption (f or.i the technical requirements of 10 CFR 50 kpyendtx R, Sectien III.G.2.C to the extent that it requires one train cf rt$urdant safe shut 6q cables te be encic$ed by a fire barrier having a cat-han fire rating and the installation of an automatic fire suppression
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r 11 3.2 DISCUSSION Fire Area 1-021 consists of rooms 229 and 233 on auxiliary elevation building 121 ft - 0 in. All fire area boundary floors, ceilings, and walls are three-hour rated.
Fire area boundary doors are UL Class A fire rated, except for the door separating this fire area from Fire Area 1-020.
Fire Area 1-023 consists only of room 235 and is bounded by three hour
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fire-rated walls, floor, and ceiling. Area boundary doors are UL Class A l
fire rated, except for the door separating this fire area from Fire Area 1-020.
Fire Area 1-019 consists of room 226, the Train B DC switchgear room on auxiliary building elevation 121 ft - 0 in and is bounded by three hour fire rated walls, floor, and ceiling.
Fire area boundary doors are UL Class A fire rated.
Fire Areas 1-021, 1-023, and 1-019 contain either electrical Train B equipment and/or electrical Train B power and control cabling associated with the Train B electrical distribution system.
The analysis of the potential effects of a fire in any of these areas upon the equipment and cabling shows that the plant could lose the entire electrical Train B system. Due to the loss of the electrical Train B system caused by a fire in either fire area 1-021; 1-023; or 1-019, the following safe shutdown equipment could become inoperable in the closed position.
Equipment Function N1P19HV3885-B Instrument Air to Penetration Room Q1813HV2228-B Backup Air /N Supply to Pressurizer PORVs Q1831PCV0445A-A; Pressurizer PORV, Train A l
Q1831PCV0444B-B Pressurizer PORV, Train B Q1E2HV8145-N Pressurizer Auxiliary Spray The combustible materials associated wit'h the subject fire areas consists of cable insulation and plastic panel parts the following summarizes the fire loading associated with these fire areas:
. Fire Area Fire Load BTU /FT 1-021 109,062 1-023 68,002 1-019 34,375 In Fire Area 1-021, an area smoke detection system is installed. Heat detectors are provided in the 4.16-kV switchgear, the 5-kV disconnect switch, and the four 600-V load centers. These heat detectors activate the alarm horn located in the area and total-flooding C0 systems in each piece of equipment. A water hose is installed in room 234 (area 1-20) outside of room 235 (area 1-23) and would be available for manual fire brigade
12 firefighting operations. A CO hose reel located in room 210 (area 1-20) is also available for use by the fire brigade.
Four ion 11ation smoke detectors are provided in Fire Area 1-023 which activate an alarm bell in roce 234 (area 1-20) and annunciate in the control room. A total-flooding Halon system is provided which is activated by the detectors. A water hose installed in room 234 (area 1-20) outside of room 235 is available for use by the fire brigade as a backup.
An ionization smcke detector is located in Fire Area 1-019. A portable extinguisher is available in rooms 211 and 225 (area 1-20). In addition, a CO hose reel located in room 210 (area 1-20) is available for use by the fire brigade for firefighting operations in this area.
The doors separating room 233 (fire area 1-021) from 228 (Fire area 1-020) and rocm 235 (fire area 1-023) from 234 (fire area 1-020) are provided with removable transoms and cannot be labeled as UL Class A.
The licensee justifies the acceptability of exemptions requested in Section 3.1 on the basis of the existing fire prctection and their alternative shutdown actions associated with the subject fire areas identified in Section 3.0.
3.3 EVALUATION A fire in either Fire Arcas 1-021,1-023 or 1-019 will cause failure of valve Q1E21HVB145-N in the closed position.
This will disable the pressurizer auxiliary spray system which provides one method to achieve depressurization of the RCS.
~~
In addition, the.same fire in either of the subject fire areas, will affect pressurizer PORVs Q1B31PCV0a45A-A and Q1831PCV0446-B which provides the other means of achieving RCS depressurt2etion, Yalves N1P19HV3885-B and Q1813HV2228-B will fail in the closed position on loss of Train 8 DC power.
This will isolate the instrument air shpply to the pressuri2er PORVs i
Q1831P,CV0445A-A and Q1831PCV04445-B.
PORV Q1B31FCV044B-B will also be i
inoperable due to loss of the Train B DC power supply. However, the Train A l
DC supply te PORV Q1831pCV0444A-A is not affected due to a fire in this area. Since only one of the FORVs is required for RCS depressuritation, and RCS depressurization it 4 long term requirement, the operator has l
adequate time to take manual action to - restore the ir,strument air by handwheel operation of valve N1919HV3BB5-B located in room 189 (Fire Area 1-006).
i Once air is restored, PORV Q1831PCV0445A-A will be operable to achieve RCS l
depressurization.
The licensee, by letter dated May 31, 1935, committed to deve' lop detailed procedures spe'cifically for the supject fire areas covered by this l
evaluation.
1hese procedures will identify the manual operator actions required to regain control of the pressurizer power operated relief valves i
13 (PORVs).
These procedures will be fully implemented by the end of the Unit 1 seventh refueling cutage currently scheduled to commance during the fourth quarter of 1985.
The door / transom assemblies, separating rooms 223 (fire area 1-021) and 228 (Fire Area 1-020) rooms 235-(fire area 1-023) and 234 (fire area provided with a removable transom in order to facilitate the movement of large electrical equipment.
The door and frame assemblies associated with these doors meet th test criteria and they bear a Class A UL label.
However, since the transom is removable, the subject door / transom assemblie,s,. cennot be listed. as Class A by UL.
The respective transoms have been certified by the manufacturer as being constructed of materials and in a manner similar to that of a Class A fire door., Therefore, based on the ccr.struction, the installation of these doors, and the configuration of the in-situ com-bustibles in these fire areas, we have reasonable assurance that a fire involving the in-situ combustibles in any of the subject fire areas would not propagate through the transon opening and spread into the adjacent fire area.
All other shutdown systems associated with the fire areas identified in Section 3.0 have redundant counteracts in other fire areas or are lo planc areas which meet the requirements of 10 CFR 50 Appendix R, Section III.G.2.
in any of the subject fire areas, safe shutdon'n could be ach maintained.
3.4 CONCLUSION
Based on our evaluation, we conclude that the licensee's alternative fire protection and shutdown configurations will provide an acceptable level of fire protection to that required by th'e technical requirements of 10 CFR S0, Appendix R,Section III.G.2, and that no additional fire protection is required to satisfy the requirements of Section III.G 3.
licensee's request for exemption for the fire areas identified in Section Therefore, the 3.0 above should be granted.
4.0 UNIT I AUXILIARY BUILDING LOCAL HOT SHUTDOWN PANEL R (EAEMPTION REQUEST 1-32)
REQUEST 1-16) UNIT 1 AUXILIARY BUILCING VERTICAL CAB 4.1 EXEMPTION REQUESTED The licensee, in their exemption request 1-32, requested exemption from the technical requirements of 10 CFR 50, Appendix R, Section III.G.2.c to the extent tnat it requires cre train of redundant safe shutdown cables be enclosed by a fire barrier having a one-hour fire rating and that automatic fire suppression be installed in the area.
r O
14 In addition, the licensee's exemption request 1-013 requested an exemption from 10 CFR 50, Appendix R, Section III.G.2.c to the extent that it requires one train of redundant safe shutdown cabling to be enclosed by a fire barrier having a one-hour fire rating.
4.2 OISCUSSION Fire Area 1-013 consists of rooms 227 (el 128 ft - 0 in.), 300 (el 141 ft
- 0 in.) - 465 and 466 (el 155 ft - 0 in.), and 500 (el 168 ft - 6 in.).
All fire area boundary walls, floor, and ceiling are three-hour fire rated and fire area boundary doors are UL Class A fire rated.
Fire Area 1-012 consists cf only room number 254 and is bounded by three-hour fire rated floor, ceiling, walls, and UL Class A fire rated
- doors, Fire Areas 1-012 and 1-013 contain hot shutdown panel control cables for the following safe shutdown equipment:
Equipment Function 01B31PCV0445A-A Pressurizer Power Operated Relief Valve Q1013MOV800A-A Pressurizer PORV Block Valve 018135V2213A-A Reactor Head Vent Valve Q1B135V2214A-A Reactor Head Vent Valve The subject control cables are associated with control functions fror. the hot shutdown panel Q1H21NBAFP2605G-A.
In addition, control cables which shift control from the iriin control room to the hot shutdown panel via the
~
transfer relay cabinet Q1H22 LOO 2-A are located in these fire areas.
The analysis of the potential effects of a fire, in either of these fire areas, upon the cabling shows that a fire induced failure causing multiple hot shorts could cause the reactor inventory to letdown via the PORV or the reactor head vent path.
Fire Area 1-012 contains electrical train A control cables associated with the following main steam atmospheric relief valves.
Equipment Function IN Q1N11PV3371A-A Main Steam Atmospheric Relief Valve (SG-1A) 01N11PV3371B-A Main Steam Atmospheric Relief Valve (SG-18)
Q1N11PV3371C-A Main Steam Atmospheric Relief Valve (SG-1C)
The analysis of the potential effects of a fire upon these cables shows that the main steam atmospheric relief yalves could become inoperable in the closed position.
Fire area 1-013 contains hot shutdown panel control cables for the following safe shutdown components.
.~
9 15
'Ecoipment Function Q1N11SV3369AC-A Main Steam Isolation (SG-1A) 01N11SV3369BC-A Main Steam Isolation (SG-1B)
Q1N11SV3369CC-A Main Steam Isolation (SG-1C)
The subject cables are associated with control function frcm the hot shutdown panel Q1H21NBAFP2605G-A.
In addition, control cables which shift control from the main contr.o1 board to the hot shutdown panel via transfer relay cabinet Q1H22 LOO 3-A are in this fire area. A fire induced failure causing multiple hot shorts could cause these components to become inoperable in the open position.
In addition, electrical Train B main stes.m isolation valves could become inoperable in the open position due to loss of electrical Train B distribution system.
Fire Area 1-013 contains control and power cables for the Train B electrical distribution system. An analysis of the potential effects of fire induced failures of these cables demonstrates that the plant could experience a total loss of the electrical Tratr. B dist'ributien system. This could result in the following safe shutdown equipment becomirg inoperable in the closed position.
Equipment Function N1P19HV3885-B Instrument Air to Pe'netration Room Q1813HV2228-B Backup Air /N Supply to Pressuri:er PORVs in addition, Fire Area 1-013 contains control cables associated with valve Q1813HV2228-B arf the folicwing Unit 1 service air compressors.
Equipment Function N1P1SM001A-N Service Air Compressor - 1A N1P19M0018-N Service Air Compressor - IR N1PleM001C-N Service Air Compressor - IC N1P19M0010-N Service Air Compressor -- 10 l
The licensee's analysis of the potentici effects of fire inde:ed failures on i
these cables demonstrates that valve 01.613HV2228-6 could becov,e incperable in the slosed position and all service air co.nprc4scrs cculd be disabled.
The combustible loading asscciated with these fire areas consists primarily of cable insulation and plastic panel part.
Ths fire loading associated j
With Fire Areas 1-012 and 1-013 is 63,382 and 256,281 UTU/ft, respectively.
1 1
In Fire Area 1-012 a smoke detection'systes is.pfovided. In addition, a CO2 hose rkel is located in t ocm 210 (fire aren 1020) and is available for fire brigade firefighting operation in this area.
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Ionization smoke detectors are located throughout Fire Area 1-013. - An automatic water suppression system is provided for this area. Two portable fire extinguishers, and,two water hose stations located outside room 300 (el 139 ft. - 0 in.) in area 1-042 are available to the fire brigade as backup.
The licensee justifies the acceptability of L the exemptions requested in Section 4.1 on the basis of the existing f,i re protection and their alternative shu.tdown actions associated with the subject fire areas identified in Section 4.0.
4.3 EVALUATION A fire in either fire area 1-012 or 1-013 could cause fire induced failures (hot shorts) to the control cables for the transfer ' relay cabinet Q1H22 LOO 2-A could cause control for the pressurizer power operated relief and blocking valves and the reactor head vent valves, to shift from their-normal main control board alignment to the remote hot shutdown panel.
.Subsequant fire induced failures (hot shcrts from adjacent control cables ~ in the shared raceway) of the control cables for~01B31PCV0445A-A, pressurizer power operated valve relief valve,. and Q1B35V2213A-A and Q1B135V2214A-a,
-reactor head vent valves, could. result in the valves being energized to open.
The power relief blockintj valve (MOV)l could become electrically inoperative in the open position. In the unlikely event of the multiple' hot shorts occurring, this condition can be mitigated by removing power from the transfer relays and manual operation (handle) of the affected relays thereby shifting. control to the main control board.
To remove power from the.
transfer relay, open breaker 17 on dc distribution panel IB Q1R4L001B-A)!1n fire area 1-043' room 0343 go to transfer relay cabinet TRC-1 in Fire Area 7'
1-035 room 0347 and manually shift transfer relays TR1 (Q1B135V2213A-A), TR2 (Q1B13SV2214A-A), TR3 (01B31PCV0445A-A), and TRS- (Q1B13h0V8000A-A).
This will place control back into the control room and allow the operator to mitigate the let'down.
In addition, the plant's ability to provide RCS makeup utilizing the Train A chemical volume control system (CVCS) is not affected by a fire in either Fire Area 1-012 or 1-013.
One of the three main steam atmospheric relief valves and its related steam generator are required to be operable to achieve steam release for cooldown.
The atmospheric relief valves-are provided with hand wheels such that the valves may be manually opened or closed without electrical controls or air supplies. The operator would establish manual control of the atmospheric relief valves by closing the manual air control valves to isolate the air supply and by opening the manual air vent valve to bleed off air from the diaphragm of the valve actuator. Both the air control and air vent valves are located in the vicinity of their associated atmospheric relief v'alve and would be accessible despite a fire in area 1-012. The capability to control steam generator pressure and reactor coolant rystem temperature with the use of the manually controlled atmospheric relief valves was demonstrated during the Unit 2 natural circulation and co'oldown startup testing. Consequently, a fire in area 1-012 would not prevent the operation of at least one redundant atmospheric relief valve.
o 17 The only safe shutdown components which require instrument air are the pressurizer PORVs which are required to be operable for RCS depressurization.
initiate RHR.
RCS depressurization is a long-term action required to to restore instrument air / backup-NThis allows adequate time for manual a to the pressurizer PORVs.
The plant has existing precedures to restore the, instrument air on loss of the service air compressors.
operated to restore air to the pressurizer PORVs.Once air is restored Fire inducted failures (hot shorts) in fire area 1-013 to control ca
'the transfer relay cabinet Q1H22LO3-A could cause control for the main steam isolation valve Q1N11SV3368AC-A, Q1N11SV3369BC-A, acd_ Q1N11SV336 shif t from normal ma~in control board alignment to the remote hot shutdown panel.
Subsequent fire-induced failures of the cables for the main steam able in the open position. isolation valves listed above, could result in the v occurring, this condition can be mitigated by removing power from shiftir.g control to the main control board. transfer relays and manua
, thereby maintain main steam isolation using the Train A isolation valves.This will enable The licensee, by letter dated May 31, 1985, committed to develop detailed precedures specifically for the subject fire areas covered by this evaluation.
These procedures will ider,tify the manual operator actions required to regain control of the transfer relays for the PORVs, reactor and control of a main steam atr>cspheric relief valve. head ven These procedures will be fully implemented by the end of the Unit 1 seventh refueling outage currently scheduled to commence during the fourth quarter of 1936.
All other shutdown system:
associated with the fire areas identified in Section 2.0 have redundant counterparts in other fire areas or are located in plant areas which meet the recuirements of 10 CFR 50, Appendix R, Section III.G.2.
in any of the subject fire areas, safe shutdown could be ach maintained.
4.4 CONCLUSION
Based on our evaluaticn, we conclude that the licensee's alternative of fire protection to that require by the technical require 50, Appendix R,Section III.G.2, and that no additional fire protection is required to satisfy the requirements of Section III.G.3.
licensee's request for exemption for Therefore, the Section 4.0 above should be granted.
the fire areas identified in
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.= _.
18 5.0 UNIT.1 AUXILIARY BUILDING TO DIESEL BUILDING CABLE TUNNEL TRAIN B - FIRE-AREA 1-076 (EXEMPTION REQUEST 1-30)
I UNIT-1. AUXILIARY BUILDING CABLE CHASE TRAIN B - FIRE AREA 1-030 (EXEMPTION REQUEST 1-29)
UNIT 1 AUXILIARY BUILDING BATTERY ROOM TRAIN B - FIRE AREA 1-016 (EXEMPTION REQUEST 1-28) 5.1 EXEMPTION REQUESTED.
The licensee, in their exemption request 1-30, requested an exemption from Section III.G.2.c to the extent that 1t requires one train of redundant safe shutdown cables to be enclosed by a barrier having a one-hour fire rating and the installation of an automatic fire detection system.
In addition, the licensee in their exemption request 1-29 requested exemption from the technical requirements of 10 CFR 50, Appendix R, Section III.G.2, to the extent that it requires one train of redundant safe shutdown cables to be enclosed by a barrier having a one-hour fire rating.
The licensee, in their exemption request 1-28, requested an exemption from t
the technical requirements of 10 CFR 50, Appendix R, Section III.G.2, to the extent that it requires one train of redundant safe shutdown cables and equipment to be enclosed by a barrier having a one-hour fire rating and the installation of an automatic fire-suppression system.
5.2 DISCUSSION-i Fire Area 1-076 consists of a cable. tunnel running from the Unit 1 auxiliary building to the diesel building.
The fire area boundary walls, floor, and ceiling are three-hour fire rated except for a non-fire rated watertight door and bulkhead which exist between the cable tunnel and the auxiliary building (area 1-030).
The non-rated door has a fire-resistant coating
.l applied. ' An UL Class A fire rated door exists between the cable tunnel and i
the diesel building.
Fire Area 1-030 consists of rooms 249 (el 121 ft. - 0 in and 139 f t. - 0 in.) and 252 (el 127 ft. - 0 in.).
All fire area boundary walls, floors.
j l
and ceilings are three-hour fire rated, except for the door and bulkhead between room 252 and cable tunnel (area 1-076) which are non-fire rated and l
watertight.
The non-rated door has a fire resistant coating applied on the Fire Area 1-076 side.
UL Class A fire rated door exists between rooms 249 and 235 (area 1-023).
Fire' Area 1-016 consists only of room 212 at el 121.ft - 0 in, and is bounded by three-hour fire rated floor, ceiling, and walls.
The area boundary door is UL Class A fire rated.
Fire Areas 1-076,1-030' and 1-016 contain electrical power and control cables for the electrical Train B distribution system.
i i
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19 The licensee's analysis of the potential effects of a fire in either Fire Areas 1-076, 1-030, or 1-016 shows that the plant could lose Train-B emergency diesel backup power. In the event of a postulated loss of offsite power (LOSP) for Unit I along with a fire in any of these areas, the plant could experience a total loss electrical Train-B distribution system inoperable in the closed position.
EQUIPMENT FUNCTION N1P19HV3885-B Instrument Air to Penetration Room Q1813HV2228-B Backup Air /N/ Supply to Pressurizer PORVs Q1B31PCV0445A-A Pressurizer PORV, Train A Q1831PCV0444B-B Pressurizer PDRV, Train B Q1E21HV8145-N Pressurizer Auxiliary Spray The combustible materials associated with the subject fire areas consists of cable insulation and plastic panel parts. The following summarizes the fire loading associated with the subject fire areas:
FIRE AREA FIRE LOAD BTU /FT 1-076 39,000 1-030 423,898 1-016 1,567 Fire Protection Features provided for Fire Area 1-076 consists of an automatic water suppression system.
5-In Fire Area 1-030, a smoke detection system and automatic water suppression
. system are installed in this area-The manual hose station located in room 234 (area 1-020).is available for use by the fire brigade in this area.
A smoke detection system is installed in Fire Area 1-016.
In addition, a CO2 hose reel located in room 210 (area 1-020) is available for use.
Portable extinguishers are available in adjacent rooms 210, 211, and 225.
The licensee justifies the acceptability of the exemptions requested in Section 5.1 on the basis of the existing fire protection, and their alternative shutdown actions associated with the subject fire areas identified in Section 6.0.
5.3 EVALUATION Failure of valve Q1E21HV8145-N in the closed position will disable the pressurizer auxiliary spray system which provides one method to achieve depressurization of the RCS.
Pressurizer PORVs Q1B31PCV0445A-A and Q1831PV04448-B provide knother means
-of achieving RCS depressurization.
Valves N1P19HV3885-B and Q1B13HV2228-B will fail in the closed position on loss of Train-B dc power. This will isolate the instrument air supply to the pressurizer PORVs, Q1B31PCV0445A-A
l o-20 1
and Q1831PCV0444B-B.
PORV Q1831PCV0444B-B will also be inoperable due to loss of the train-B de power supply. However, the Train-A de supply to PORV Q1B31PCV0445A-A is not affected due to a fire in this area. Since only one of the PORVs is required for RCS depressurization and RCS depressurization is a ~ long term requirement, the operator has adequate time to take manual action to restore the instrument air by handwheel operation of valve N1P19HV3885-B.
Once air is restored, PORV Q1B31PCV0445A-A will be operable to achieve RCS
~
depressurization.
The licensee, by letter dated May 31, 1985, committed to develop detailed procedures specifically for the subject fire areas covered by this evaluation.
These procedures will identify the manual operator actions required to regain control of the pressurizer PORVs and the transfer relays for the PORVs and the head vent valves.' These procedures will be fully implemented by the end of the Unit I seventh refueling outage presently scheduled for the fourth quarter of 1986.
The watertight doors between Fire Areas 1-030 and 1-076 do not comply with the three-hour fire-rated fire area boundary requirements. However, a fire in either Fire Area 1-030 propagating into fire area 1-076 will not have any additional impact on Unit 1 safe shutdown capability because the same redundant safe shutdown function cables are contained in Unit 1 fire area.
5.4 CONCLUSION
' Based on our evaluation, we conclude that the licensee's alternative i '
fire protection and shutdown configurations will provide an acceptable level of fire protection to that required by the technical requirements of 10 CFR 50, Appeqdix R,Section III.G.2, and that no additional fire
- protection is required to satisfy the requirements of Section III.G.3.
Therefore, the licensee request for the fire areas identified in Section 5.0 above should be granted.
6.0 UNIT 1 AUXILIARY BUILDING, ELEVATION 100 FT. - 0 IN. CHARGING PUMP ROOMS AND STORAGE AREAS - FIRE AREA 1-005 (EXEMPTION REQUEST 1-34).
6.1 EXEMPTION REQUESTED The licensee, in their exemption request 1-34, requested an exemption from the technical requirements of 10 CFR 50, Appendix R, Section III.G.2.a to the extent it requires a three-hour fire barrier between redundant safe shutdown cabling and equipment.
In addition, the licensee requested an exemption for rooms 172 and 181 withir. Fire Area 1-005 from the technical requirements of 10 CFR 50',
Appendix R,Section III.G.2.c to the extent that it requires 'one train of redundant safe shutdown cable to be enclosed by a fire barrier having a one-hour fire rating and an automatic suppression system.
7
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,va -,
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21 l
6.2 DISCUSSION s
Fire Area 1-005 consists of the three charging pump rooms (173,174, and 181), a hallway (172), a general storage area (171), and a contaminated storage area (182). The fire area boundary walls, floors, and ceilings are three-hour fire rated except for the containment wall.
The fire. area boundary door is fire rated.
Self expanding cork is installed between the fire area boundary walls and the containment.
Fire Area 1-005 contains the three redundant charging pumps, related valves,
-and air handling units. Fire Area 1-005 was subdivided into the four zones identified below to perform the fire hazards analysis.
' Zone 1:
Room'181 - Train A Charging Pump Room Zone 2:
Room 174 - Swing Charging Pump Room Zone 3:
Room 173 - Train B Charging Pump Room Zone 4:
Rooms 171, 172, and 183 - Storage Rooms and Hallway The licensee's reevaluation is based on the premise that a fire would be contained in one of the four zones listed above.
Room 172 in Fire Area 1-005 contains the redundant RWST isolation valves (LCV115B and LCV1150) and CVCS makeup valves (FCV114A-2 and FCV1138-A). The CVCS makeup valves control the flow of boric acid from the boric acid transfer pumps and control the flow of primary water from the primary water makeup pump. Fire barriers are not provided for the valves or cables. The analysis of the effects of a fire in the area shows that the RWST isolation valves could become electrically inoperable in the closed position and
.mtkeup to either the VCT or charging pump suction header could be isolated.
Control cables of the Train A pressurizer power operated relief and blocking valves Q1831PCV0'445A-A and Q1813MOV8000A-A and the reactor head vent valves Q1B135V2213A-A and Q18135V2214A-A are located in Fire Area 1-005.
The l
subject cables are associated with the control function from the hot shutdown panel Q1H21NBAFP2605G-A.
In addition, control cables which shift I
control from the main control board to the hot shutdown panel via the transfer relay cabinet Q1H22 LOO 2-A are in this area. A fire induced failure having multiple hot shorts could cause the reactor inventory to letdown via the PORV and reactor head vent paths.
I Combustible materials in Fire Area 1-005 primarily consists of cable insulation and lube oil. The following fire loading is associated with the rooms bounded by Fire Area 1-005:
ROOM NUMBER FIRE LOAD BTU /FT 173 27,563 Charging / Safety Injection Pump Room
22 174 28,508 Charging / Safety Injection Pump Room 181 47,414 Charging / Safety Injection Pump Room 171, 172 and 182 31,820 Hallway / Storage Areas Smoke detection systems are installed throughout Fire Area 1-005. A manual hose station, CO2 hose reel, portable extinguishers, and portable smoke removal equipment located in the corridor just outside the fire area are available for use in Fire Area 1-005. An automatic sprinkler system is installed in rooms 171 and 172.
The licensee justifies the acceptability of this exemption on the basis of the existing fire protection, their proposed modifications and their alternative shutdown actions associated with the charging pump ' rooms and storage areas (Fire Area 1-005).
6.3 EVALUATION The charging pump rooms (173,174, and 181) are watertight with 2-ft.-thick reinforced concrete walls. Penet.ation's in the pump room walls internal to Fire Area 1-005 are sealed to provide a watertight boundary. Tne seals utilized to provide the watertight boundary are of the type (foam, welded plate, or grout) to provide an adequate barrier to inhibit the spread of fire, smoke, or gas. The doors are watertight and are normally maintained closed.
Ltbricating oil and cable insulation are the only combustibles present in the pump rooms.
Lubricating oil would be contained within the individual rooms or would drain into the sump servicing the room.
In addition, there is a fixed suppression system installed in rooms 172 (hallway) and 171 which provide additional protection in the area of the pump room doors that communicate with this hallway. ' Room 171 is a designated combustibla material storage area with three-hour fire rated boundaries and door. Smoke ' detection systems are installed throughout the area including the three charging pump rooms.
The maximum combustible in-situ loading in any room of this fire area is estimated to be less than 48,000 Btu /f t with a maximum fire' severity of less than one hour. Based upon the evaluation of the protection provided, a credible fire would be contained within the zone of its initiation.
A one-hour barrier enclosure will be installed on portions of raceway sections AHFA15, AHF031, AFD-30, AEF028 that carry cables for RWST isolation i
valve LCV115B-A in room 172. Given a fire in room 172, this modification will ensure that all cables required for the operation of the ' redundant RWST l
isolation "alves (LCV1158 and LCV115D) are protected by a fire barrier.
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4-23 3
Although the redundant RWST isolation valve operators are in room 172,.they are separated by a distance of 18 feet. The duration and severity of a fire in room 172 would be limited due to low quantities of combustibles and partial automatic fire suppression system coverage. The combustible loading in room 172 consists of cable insulation and is of such quantity that the maximum expected fire severity is less than 30 minutes.
Raceway Section AHDB12 will be protected by a one-hour fire barrier enclosure over its entire route within Fire Area 1-005. This modification will protect cables for the subject valves in all portions of. Fire Area 1-005 with the exception of room 181. The modification will ensure that a single fire can not impact the RWST isolation valve operators and cause a loss of boration capability.
Fire induced failures (hot shorts) within the control cables for the transfer relay cabinet Q1H22 LOO 2-A resulting from a fire in room 181 could cause control for the pressurizer power operated relief and blocking valves and the reactor head vent valves to shift from their normal main control board alignment to the remote hot shutdown panel. Subsequent fire induced failures (hot shorts from adjacent control cables in the shared raceway) ~of the control cables for Q1831PCV0445A-A, pressurizer power operated relief valve, and Q18135V2213A-A and Q1B135V2214A-A, reactor head vent valves, could result in the valves being energized to open. The MOV could become electrically inoperatable in the open position.
In the unlikely event of the multiple hot shorts occurring, this condition can be mitigated by removing power from the transfer relays and manually aligning the affected relay (handle is provided), thereby shifting control to the main control board.
To remove power from the transfer relay open breaker 17 on dc distribution panel IB (Q1R41L001BV-A) in Fire Area 1-043 room 0343 then go to transfer. relay cabinet TRC-1 in Fire Area 1-035 room 347 and manually shift transfer. relays TRI (Q1B13SV2213A-A), TR2 (Q1813SV2214A-A), TR3 (Q1813PCV0445A-A), and TR5 (Q1B135V2214A-A).
This will restore control to the main control board and allow the operator to mitigate the letdown.
By letter dated May 31, 1985, the licensee committed to develop a detailed procedure specifically for this fire area covering the manual operator j
actions required to regain control of the transfer relays associated with the PORVs and the reactor head vent valves. This procedure will be fully implemented by the end of the Unit I seventh refueling outage. In addition, i
the licensee has also committed to install the proposed raceway fire barrier enclosures by the end of this refueling outage, which is currently scheduled for the fourth quarter of 1986.
I All other shutdown systems associated with Fire Area 1-005 have redundant counterparts in other fire areas or are located in plant areas which meet the requirements of 10 CFR 50, Appendix R, Section III.G.2. As a result, there is reasonable assurance that if a fire occurred in either rooms 173, 174, 171, 172, 181, or 182 (Fire Area 1-005), safe shutdown could be achieved and maintained.
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6.4 CONCLUSION
Based on our evaluation. we conclude that the licer.see's alternative fire protection and shutdown configuration, will provide an acceptable sevel of fire protection to that required by the technical requirements of 10 CFR 50, Appendix R, Section III.G.2 and that no additional fire protection is required to satisfy the requirements of Section III.G.3. Therefore, the licensee's request for exemption for Unit I auxiliary building elevation 100 ft. - 0 in. Charging Pump Rooms and Storage Areas (Fire Area.1-005) should be granted.
7.0 UNIT 1 AUXILIARY BUILDING, ELECTRICAL PENETRATION ROOM TRAIN A - FIRE AREA 1-035 (EXEMPTION REQUEST 1-37) 7.1 EXEMPTION REQUESTED The licensee, in their exemp an request 1-37, requested an exemption from the technical requirements of 10 CFR 50, Appendix R, Section III.G.2, to the extent that it requires one train of redundant safe shutdown cable and equipment to be enclosed by a one-hour fire-rated barrier and the installation of an automatic fire suppression system.
7.2 DISCUSSION Fire area 1-035 consists of rooms 333 and 347 at el 139 ft - 0 in. All fire area boundary walls, ceilings, and floors are three-hour fire rated and area boundary doors are UL Class A fire rated. Self-expanding cork is installed for the portions of the area boundary along the containment wall.
Fire Area 1-035 contains instrumentation cables associated with the following RCS hat leg temperature indication:
EQUIPMENT FUNCTION N1821TC45.3-P1 RCS Loop-1 Hot Leg Temperature Indication N1821TE423-P1 RCS Loop-2 Hot Leg Temperature Indication N1821TE433-P1 RCS Loop-3 Hot Leg Temperature Indication The licensee's analysis of the potential effects of a fire upon these cables shows that the plant could' lose hot leg temperature indication for all three RCS loops.
In addition, Fire Area 1-035 contains power and control cables and equipment (MCC-IU) associated with the following valve.
EQUIPMENT FUNCTION Q1E21MOV8106-A Charging Pump Miniflow Isolation Valve
25 The licensee's analysis of the potential effects of a fire upon the equipment and these cables shows that the subject valve could become inoperable in the closed position, isolating charging pump miniflow.
Power and control cables associated with the following valves are routed through Fire Area 1-035:
EQUIPMENT FUNCTION Q1E21MOV8131A-A Charging Pump Suction Header Isolation Valve Q1E21MOV8133A-A Charging Pump Discharge Header Isolation Valve The licensee's analysis of the potential effects of a fire upon the equipment and these cables shows that the subject valves could become inoperable in the closed position. This condition will result in loss of seal injection water flow when the -swing charging pump 1B is operational.
These valves cannot be locked open because they are needed for train separation during a LOCA event.
Also, Fire Area 1-035 contains control cables associated with the following safe shutdown equipment:
EQUIPMENT FUNCTION Q1B31PCV0445A-A Pressurizer PORV Q1813MOV8000A-A Pressurizer PORV Block Valve 018135V2213A-A Reactor Head Vent Valve 7-Q18135V2214A-A Reactor Head Vent Valve
,The subject cables are associated with control from both the hot shutdown panel and the main control board. Fire induced failures having multiple hot shorts could cause the reactor inventory to letdown the PORV and reactor head vent paths.
Combustible materials in Fire Area 1-035 primarily consists of cable insulation and plastic panel parts. The fire loading associated with this area is approximately 83,542 BTU /FT.
An ionization smoke detection system is installed in Fire Area 1-035. A hose station is located in room 334 (Fire Area 1-004) and is accessible to this area for manual firefighting purposes.
The licensee justifies the acceptability of this exemption on the basis of the existing fire protection, their proposed modifications, and their alternative shutdown actions associated with the Unit I auxi' pry building electrical penetration room Train A (Fire Area 1-035).
26 7.3 Evaluation Each RCS loop hot leg temperature instrumentation loop is powered from channelized inverter-1A.
Inverter-1A is powered from 600 V-ac MCC 1A or 125 V-dc bus 1A.
A fire in area 1-035 along with an assumed loss of offsite power (LOSP) for Unit I could result in loss of the 600 V-ac power supply to inverter 1A; however, inverter 1A will continue to operate from 125 V-dc bus IA and will supply power to the instrument loops for a minimum of two hours.
If after two hours power is lost, RCS hot leg temperature indication is available from the core exit thermocouples.
Core exit thermocouple temperature indication will not be affected by a fire in area 1-035.
In addition to the alternate de power supply for a minimum of two hours and core exit temperature indication availability, a design change to be installed as a result of RG 1.97 will provide a redundant signal processing and indication between RCS hot leg temperature loops N1821TE413, N1B21TE423, and N1821TE433.
Based upon the RG 1.97 connitment schedule, implementation of the modification is currently planned for the seventh refueling outage presently scheduled to commence during the fourth quarter of 1986.
After implementation of this modification, a fire in Fire Area 1-035 will not affect the ability to monitor one loop of RCS hot leg temperature.
A design modification is proposed to install disconnect breakers in the power supply circuits of these valves outside the electrical penetration room during the next outage of sufficient duration subsequent to design and procurement completion.
The next outage is currently scheduled to commence during the fourth quarter of 1986.
In the interim, the operators will be instructed of the potential inadvertent closure of the charging pump suction and discharge valves in the event of a fire in this area.
The charging pump can be run safely with miniflow isolated and with a minimum of 24 gpm seal injection flow for a period of up to one hour. This will allow the operator time to deenergize MCC-10 and take manual action to open the valve and reestablish the min.iflow.
Fire induced failure (hot short) of the individual control cables for Q1831PCV0445A-A, power operated relief valve, and Q1813SV2213A-A and Q18135V2214A-A, resactor head vent valves, could result in the valves to be l
energized to open.
The power operated relief blocking valve could become l
electrically inoperatable in the open position.
In the unlikely event of l
the multiple fire induced failures (hot shorts from adjacent control cables in the shared raceway) occurring, this condition can be mitigated by removing 125 V-dc power from cables in the shared raceway.
This can be l
accomplished by opening the breakers on the 125 V-dc switchgear bus IA (Q1R428001A-A) for 125 V-dc distribution panels 1A,1B, and 1C and by opening feeder breaker numbers 4 and 16 on V-dc distribution panel 1G N1R41L001G-N.
l The licensee, by letter dated May 31, 1985, committed to develop detailed l
procedure specifically for the subject fire areas covered by this l
l
i.
27 evaluation.
This procedure will identify -the manual operator actions required to regain the control of the pressurizer power operated relief valves. This procedure will be fully implemented by the end of the Unit I seventh refueling outage.
All other shutdown systems associated with Fire Area 1-035 have redundant counterparts in other fire areas or are located in plant areas which meet the requirements of 10 CFR 50, Appendix R, Section III.G.2. As a result, there is reasonable assurance that if a fire occurred in the Unit 1 auxiliary building electrical penetration room Train A, safe shutdown could be achieved.
7.4 CONCLUSION
Based on our evaluation, we conclude that the licensee's alternative fire protection and shutdown configuration will provide an acceptable levei of fire protection to that required by the technical requirements of 10 CFR 50 Appendix R, Section III.G.2, and that no additional fire protection features are required to satisfy the requirements of Section III.G.3.
Therefore, the licensee's request for exemption for the Unit 1 auxiliary building electrical penetration room Train A (Fire Area 1-035) should be granted.
8.0 UNIT 1 AUXILIARY BUILDING ELEVATION 100 FT. - 0 i n., 121 FT. - 0 IN.,
130 FT. - 0 IN., 139 FT. - 0 IN., 155 FT. - 0 IN., 175 FT. - 0 IN., AND 184 FT. - 0 IN. - FIRE AREA 1-004 (EXEMPTION REQUEST 1-39).
8.1 Exemption Reque'sted The licensee, in their exemption request 1-39, requested an exemption from the technical reguirements of 10 CFR 50, Appendix R, Section III.G.2.c.
T0 the extent that it requires one train of redundant safe shutdown cables to be enclosed in a one-hour fire barrier and that automatic fixed suppression be installed throughout the fire area.
In addition, the licensee requested an exemption from Appendix R Section III.G.2.a to the extent that it requires separation of redundant cables and equipment by a fire barrier having a three-hour rating.
8.2 DISCUSSION 4
Fire Area 1-004 consists of the following rooms:
El 100 Ft.' - 0 In.
Room 151 Waste Gas Decay Tank Rooms Room 152 Valve Compartment Room Room 153 Waste Gas Compressor Room Room 154 Waste Evaporator Steam Generator Room Room 155 Passageway to Unit 2 simu r i ii i g
I 28 Room 156 Holdup Tank Room Room 157 Holdup Tank Room Room 158 Holdup Tank Room Room 159 Recycle Evaporator Feed Pump Room Room 160 Hatch Area Room 161 Corridor Room 162 Hallway Room 163 WDS Control Panel Room Room 164 Storage Room / Laundry and Hot Shower Tank Room Room 165 Waste Gas Decay Tank Room Room-166 Waste Gas Decay Tank Room Room 168 Chemical and Laundry Drain Tank Room Room 170 Letdown Heat Exchanger Room Room 175 Hallway Room 176 Secondary Spent Resin Storage Tank Room Room 177 Pump Room Room 178 Filter Room Room 179 Valve Room / Combustible Storage Room.180 Recycle Evaporator Stear, Generator Room Room 186 Boric Acid Area Room 187 Hydro Test Pump Room Room 188 Boric Acid Tank Area El 121 Ft. - 0 In.
Room 203 Waste Condenser Tanks and Pump Room Room 204 Waste Evaporator Package Room Room 205 Passage to Unit 2 Room 206 Heat Exchanger Room Room 207 Hatch Area Room 208 Corridor Room 209 Wallway Room 215 Duct and Pipe Chase Room 216 Valve Compartments Area Room 217 Volume Control Tank Room Room 218 Chiller Unit Room Room 219 Pipe Chase Room 220 Valve Compartment Room Room 221 Primary Spent Resin Storage Tank Room Room 222 Corridor Room 230 Recycle Evaporator Package Room Room 231 Sluice Pump Room Room 232 Sluice Filter Room Room 236 HVAC Duct Chase Room 237 Corridor Room 238 Cask Storage Area Room 239 Transfer Canal Room 240 Spent Fuel Pool Room Room 253 Valve Compartment
'#O" M '
o 29 El 130 Ft. - 0 In.
Room 601 Drumming Area Psom 602 Passageway Room 603 Drum Storage Area - Combustible Storage Area Room 604 Passage Room 605 Blowdown Pumps and Surge Tank Room Room 606 Filter Room Room 607 Filter Room Room 608 Blowdown Heat Exchanger Room Room 609 Storage Room Room 610 Valve Compartment Room El 139 Ft. - 0 In.
i Room 301 Seal Water Filter Room Room 302 Recycle Evaporator Feed Filter. Room Room 303 Reactor Coolant Filter Room 1
Room 304 Waste Monitor Tank Filter Room Room 305 Seal Injection Filter Room Room 306
. Recycle Evaporator Feed Demineralizer Room Room 307 Valve' Compartment Room Room 308 Waste Condensate and Monitor Tank Demineralizer Room Room 309 Hatch Area Room 310 Valve Compartment Room Room 311 Recycle Evaporator Concentrates Filter Room Room 312 Corridor Room 313 Floor Drain and Laundry Tank Filter Room Room 314 Waste Evaporator Feed Filter Room Room 315 Recycle Waste Condenser Filter Room Room 316 Passage to Unit 2 Room 322 Hallway Room 323 Sample Room High Activity Radioactive Lab Room 324 Room 325 Counting Room Room 326
. Gas Analyzer Room Room 327 Valve Access Area Room 328 BTR Demineralizer Room Room 329 Pipe Tunnel Room 330 Chiller Surge Tank Pump Room Room 331 Valve Access Area Room 332 MCC 1A Area Room 340 Demineralizer Compartment Room 341 Pipe ~ Chase Room 342 Spent Fuel Pool Pump Room Room 348 Cask Wash Area El 155 Ft. - 0 In.
Room 402 Passway to Unit 2 I
._,___m.
_,___,__,m_,m,__.
_m_,_._
30 Room 403 New Resin Storage Room 404 Filter Hatches Room / Combustible Storage Room 405 Hatch Room Room 406 Decon Room Room 407 Hot Machine Shop Room 408 Hallway Room 409 Hallway Room 410A 600-V Load Center (Station Service Transformer P.oom)
Room 410B 600-V Load Center Room 415 Corridor Room 417 Corridor Room 418 Auxiliary Building and Containment Purge Vent Equipment Room Room 419 Demineralizer Hatch Area Room 420 Drum Storage Room Room 421 Drumming Station Room Room 422 Corridor Room 423 Valve Compartment Room 424 Demineralizer Compartment Room 425 Demineralizer Compartment Room 426 Demineralizer Compartment Room 427 Demineralizer Compartment Room 429 Containment Purge Air Equipment Room Room 430 Disrobe Area Room 431 Health Physicist Room Room 432 Corridor Room 433-Corridor Room 434 Passage Room 435 Hot Shower i'
Room 436 Hot Toilet Room 437 Hot Janitor Room 438 Hot Water Heater Room Room 439 drying Area Room 440 Laundry Area Drying Area Room 441 Room 442 First Aid Room Room 443 Locker Room Room 444 Clean Linen Storage Room 445 Spent Fuel Pool Heat Exchanger Room Room 446 Hallway Room 447 Cask Wash Storage Room Room 448 SFPC Pump Room Room 449 Demineralizer Room Room 450 Valve Compartment Room 451 Filter Room Room 452 Clean Shower Room 453 Clean Janitor Room Room 454 Lobby Room 455 Clean Toilet Room Room 456 Drying Area Room 461 Environmental Low Activity Lab
31 Room 462 Non-Radioactive Vent Equipment Room Room 463 Nitrogen Storage Room Room 464 Nitrogen Storage Room Room 467 SFP Hiat Exchanger Room Room 478 Motor Control Center Room El 175 Ft. - 0 In.
Room 506 Component Cooling Surge Tank Room El 184 Ft. - 0 In.
Room 504 Stair No. 6 Room 505 Spent Fuel Pool Vent Equipment Room All of the fire area boundary walls are rated as a three-hour fire barrier with all electrical and piping penetrations sealed for a three-hour rating.
All doors that are part of the fire area boundary are UL Class A doors except for Class B doors to stairwells used for access and egress and for doors in the fire area boundary leading to the outside which are not rated.
The floors and ceilings of Fire Area 1-004 which bound other fire areas are rated for three-hour with the exception of two non-rated steel hatch covers.
A non-rated steel hatch cover in the floor of room 163 (a'rea 1-004) communicates with room 103 (area 1-001) and a non-rat?d steel hatch cover in the floor of room 454 (area 1-004) communicates with room 345 (area 1-042).
All internal floors of Fire Area 1-004 are reinforced concrete, and exposed structural steel has been protected by fire proofing.
. Fire Area 1-004 contains redundant safety-related MCCs, (IA) Q1R17B001A-A s
,and (IB) Q1R17B0018-B.
These motor control centers provide power for various Train-A pnd Train-B safa-slutdown components, respectively.
Power supply cabling and subject mot introl centers are not protected by fire barriers and full coverage auto..... suppression is not provided.
Fire Area 1-004 also contains redundant safety re. lated de distribution panels (IC) Q1R41L001C-A and (1F) Q1R41L001F-B. These 125 V-dc distribution panels provide power for various Train-A and Train-B safe-shutdown components, respectively.
Power suppiy cabling and distribution panels are not protected by barriers.
Rooms 462 and 464 contain redundant steam generator pressure transmitters and cabling. The redundant steam generator pressure.-
uments provide the following signals:
Equipment Function Q1N11PT3371A-A S/G-A Press, Atmospheric Relief Val, i
and Hot Shutdown Panel Pressure Inc c Q1N11PT0474-P2 S/G-A Press, Protection Signal, Indic a
32
-Q1N11PT0475-P3 S/G-A Press, Protect f en Signal, Indication.
Q1N11PT0476-P4 S/G-A Press, Protection Signal, Indication Q1N11PT3371B-A S/G-B Press, Atmospheric Relief Valve Control and Hot Shutdown Panel Pressure Indication Q1N11PT0484-P2 S/G-B Press, Protection Signal, Indication Q1N11PT0485-P3 S/G-B Press, Protection Signal, Indication Q1N11PT0486-P4 S/G-B Press, Protection Signal, Indication 01N11PT3371C-A.
S/G-B Press, Atmospheric Relief Valve Control and Hot Shutdown Panel Pressure Indication Q1N11PT0494-P2 S/G-C Press, Protection Signal, Indication j
Q1N11PT0495-P3 S/G-C Press, Protection Signal, Indication Q1N11PT0496-P4 S/G-C Press, Protection Signal, Indication The redundant pressure transmitters and their cabling are not protected by fire barriers and full coverage automatic suppression is not provided.
In addition, Fire Area 1-004 contains redundant instrument air system I
de power and control cabling ' hich serve N1P195V3825-A (instrument air i
w l
containment isostion valve) Train A, and Q18135V2228-B (power relief penetration room isolation valve), Q1P195V3611-A (instrument air i
valve backujp air supply) Train B.
The de power and control cabling ar not protected by barriers, and full automatic fixed suppression i
coverage is not provided.
~
Redundant' power and control c.abling of battery charging room coolers Q1E16M006A-A and Q1E16M0068-B, Trains A and B, respectively, and battery room exhaust ~ fans and exhaust dampers, Q1V47C012A-A, i
Q1V47C0128-B and Q1V47MOV3644-A, Q1V47MOV3643-B, Trains A and B, respectively, are routed :hrough Fire Area 1-004. The subject power and control cabling is not protected by barriers and full coverage i
i automatic fixed suppression is not provided.
Flow from the charging pumps is required for reactor coolant boration and makeup, reactor coolant system depressurization, and reactor coolant pump seal integrity.
The. following independent conditions concern cables related to the charging pumps and charging pump room coolers:
Fire Area 1-004 contains redundant charging pump Train-A and -B power cables. One train of redundant power cables is not provided with a fire rated barrier for its entire route in the fire area, i
~
33 nor is full suppression coverage provided for both redundant trains throughout their entire route in the fire area.
Fire Area 1-004 contains redundant charging pump room cooler power and control cables.
One train of redundant power and control cable is not provided with a fire rated barrier for its entire routine in the fire area, nor is full suppression coverage provide for both redundant trains throughout the entire route in.the fire area.
In addition, Fire Area 1-004 contains de distribution panel (1C)
Q1R41 LOGIC-A which supplies solenoid power for atmospheric relief valves, Q1N11PV3371A, Q1N11PV33718, and Q1N11PV33710.
The subject panel and cables are not separated by fire barriers.
Fire area 1-004 contains power and control cables for S/G-1C steam supply to TDAFW pump valve Q1N12SV3235B-AB and TDAFW pump steam admission valve Q1N12SV3226-AB.
The subject cables are not separated by fire barriers nor is full coverage automatic suppression provided.
Redundant instrumentation cabling and equipment Q1C55NM0048-A of neutron flux monitoring 01C55NE0048A-A (post-accident neutron flux monitor) and NIC55NE0031-P1, and NIC55NE0032-P2 (source range neutron flux monitors) are located in Fire Area 1-004. The subject cabling and equipment is not separated by fire barriers and automatic fixed suppression is not provided.
Fire Area 1-004, also contains cabling for redundant RCS and pressurizer sample line boundary valves.
The RCS valves are Q1P16HV3103-B, Q1P15HV3102-B, and Q1P15HV3765-A.
The pressurizer valves are Q1P15HV3103-A and Q1P15HV3881-B. The subject cables are not separated by fire barriers and full coverage automatic fixed suppression is not provided.
In addition, non-fire-rated steel hatch covers are located in the floor of Rooms R 163 and 454 (Fire Area 1-004).
These hatches communicate with Rooms 103A (Fire Area 1-001) and 354 (Fire Area 1-042),
respectively.
Combustible materials in Fire Area 1-004 primarily consists of cable insulation, charcoal filter media, lube oil, plastic panel parts, flamable liquids and gases and various miscellaneous materials.
The following fire loading is associated with the rooms bounded by Fire Area 1-004:
Maximum Room Numbers /
Fire Load Fire Titles (Btu /ftr)
Severity 151 Waste Gas 15,877(a) less than 30 min (a)
Decay Tank Rooms,
o-34 152 Valve Compartment Room, 165 Gas Decay Tank Room, and 166 Waste Gas Decay Tank Room 153 Waste Gas Compressor Room 34,733 less than 30 min t
159 Recycle Evaporator 26,783 less thar. 30 min Feed Pump Room 168 Chemical and 52,037 less than 1 h Laundry Drain Tank Room 175 Hallway 29,580 less than 30 min 154 Waste Evaporator 27,995(b) less than 30 min (b)
Steam Generator Room, 155 Passageway to Unit 2, 160 Hatch Area, 161 Corridor, 162 Hallway, 163 WDS Panel Room, 164 Laundry and Hot Shower Tank Room, 177 Pump Room, and 178 Filter Room 215 Duct and Pipe Chase 0
0 176 Secondary Spent Resin Storage Tank Room 0
0 179 Valve Room /
2,7E4 less than 30 min Combustible Storage (c) 180 Recycle 23,536(d!
less then 30 min (d)
Evaporator Steam Generator
- Room, 186 Boric Acid Area, and 187 Hydro Test Pump Room 204 Waste 4,953 less then 30 min Evaporator Package Room
\\
t --
35 219 Pipe Chase 0
0 203 Weste 40,542(e) less than one hr. (e)
Condenser Tanks and Pump Room, 205 Passageway to Unit 1, 207 Hatch Area.
108 Corridor, 209 Hallway,-
218 Chiller Unit Room, 222 Corridor, 237 Corridor, and 253 Valve Compartment 156 Holdup 11,209 less than 30 min Tank Room 157 Holdup 13,879 less than 30 min Tank Room 158 Holdup 10,769 less than 30 min Tank Room 188 Boric 619 less than 30 min Acid Tank Area 206 Heat 6,305 less than 30 min Exchanger Room 220 Valve 3,200 less than 30 min Compartment Room 230 Recycle 17.048 less than 30 min Evaporator Package Room 231 Sluice 17,258 less than 30 min Pump Room 232 Sluice 25,132 less than 30 min Filter Room 236 Duct Chase 0
0
36 216 Valve 6,549 less than 30 min Compartments Area 217 Volume 0
0 Control Tank Room 221 Primary 0
0 Spent Resin Storage Tank Room 235 Cask Storage 1,234(f) less than 30 min (f)
- Area, 239 Transfer Canal.
240 Spent Fuel Pool Room, and
'348 Cask Wash Area 447 Cask Wash 21,236 less than 30 min Storage Area /
Combustible Storage,(c) 309 Hatch Area, 312 Corridor, 29,989(g) lessthan30 min (g) 325 Counting
- Room, 322 Hallway, 316 Passageway to Unit 2, 327 Valve.
Access Area, 332 MCC 2A, 307 Valve Compartment
- Room, 310 Valve Compartment Room, and 330 Chiller Surge Tanks Pump Room 301 Seal 392(h) less than 30 min (h)
Water Filter
- Room, 302 Recycle Evaporator
- - - - =
37 7
Feed Filter
- Pump, 303 Reactor Coolant Filter
- Room, t
304 Waste i
Monitor Tank Filter Room, 311 Recycle Evaporator Concentrates i
Filter Room, a
313 Floor Drain and Laundry Tank Filter Rnom.
314 Waste Evaporator Feed Filter
- Room, 315 Recycle Waste Condenser i
Filter Room, and 305 Seal Injection Filter Room I
306 Recycle' 0
0 Evapoartor Feed Demin.
1 9
Room 308 Waste 0
0 Cor.densate and Monitor I
5 Tank Demin.
Rcom 323 Sample 35,280 less than 7) c.in t
Rocm 324 High 23,950 less than 30 mir, f
Activity i
Radioactive Lab 326 Gas 1,889 less than 30 min Analyzer Room i
329 Pipe 0
0 Tunr.el i
?
p.
38 331 Valve 10,936 less than 30 min
~
Access Area 342 Spent 5,247 less than 30 min Fuel Fool Pump 340 (Jamin-0
- 0 eralizer Compartment 4
328 BTR Demin.
0 0
Room 601 Druerning 2,141(i) lesst' nan 30 min (i)
- Area, 602 Passageway, and 603 Drus Storage Area Combustible Storage Area 604 Passage 3,859 less than30 min 605 Blowdown 8,885 less than30 min Pumps and surge Tank
~
Room 606 Filter 7,208 less than30 min Room 607 Filter 563 less than30 min Room 608 Blewdown
.1,720 less than30 min Heat Exchanger Room f
609 Storage 3,891 less than30 min Room f.10 Valve 616 less than30 min Lompartment Roem 341 tipe 0
0
(,hase f
1
)
~ _ _, -, - _ _,,, -. _
~_
a 0
39 445 Spent 24,570(j) less than 30 min (j)
. Fuel Pool Heat Exchanger Room, and 448 SFPC Fump Room 451 Filter 0
0 Room 449 Demin-0 0
eralizer Room i
450 Valve 0
0 Compartment 406 Decontam-5,702 less than 30 min ination 407 Hot 4,488 less than 30 min l
Machine Shop L
409 Hallway.
35,737(k) less than 30 min (k) 410A 600-V Load Center, l
4105 600-V l
Load Center, 405 Hatch f
Room.
419 Demin-eralizer Hatch Area, 408 Hallway, 422 Corridor, 446 Hallway, and 423 Valve Compartment 420 Drum 12,212(1) less than 30 min (1)
Storage Room, and 421 Drumming Station Room 424 Demineralizer 0
Compartment 425 0
Demineralizer Compartment
40 425 Demineralizer 0
Compartment 426 0
Demineralizer Compartment 427 Demineralizer 0
Compartment 418 Auxiliary 58,754 less than 45 min Building and Containment Purge Vent Equipment Room 404 Filter 306 less than 30 min Hatch Room /
Combustible Storage (c) 403 Hot 3,852 less than 30 min Instr. Shop 402 Passage 57,839(m) less than 45 min (m) to Unit 2, 417 Corridor, 430 Disrobe
- Area, 435 Hot
- Shower, 439 Drying
- Area, 441 Drying
- Area, 434 Passage, 433, and 415.
443 Locker 3.376 less than 30 min Room 440 Laundry 20,626 less than 30 min Area 438 Hot Water 4,770 less than 30 min Heater Room 432 Corridor 61,284 less than 45 min
41 454 Lobby 0
462 Mon 7.673 less than 30 min.
Radicactive Vent Equipment Room 463 Storage 4,542 less than 30 min Room 464 Storage 7,518 less than 30 min Room 467 SFP Heat 1,704 less than 30 min Exchanger Room i
429 188,885 less than 2-1/2 h Containment Purge Air Equipment Roon 431 Health 28,391 less than 30 min Physics Rcom 461 18,077 less than 30 min Environmental Low Activity Lab i
436 Hot 296 less than 30 min Toilet 437 Hot Janitor 442 First 9.933 less than 30 min Aid Rcom 478 Motor 39,085 less than 30 min Control Center Room 504 Stairwell 925 less than 30 min No. 6 Floor, El 184 Ft -
i 0 in.
l I
i i
t i
I
1
.=
42 505 Spent 27,117 less than 30 min i
fuel Pool Vent Equipment Room 506 Component 947 less than 30 min Cooling Surge Tank Room 170 Letdown 2,198 less than 30 min Heat Exchanger Room a.
Applies to rooms, 1.51, 152, 165, and 166 collectively.
b.
Applies to rooms 154,155,160,151,162,163,164,177, and 178 collectively c.
These rooms are occasionally utilized as combustible storage areas, particularly during outage periods.
They w' sprinkler iU have three-hour rated boundaries, smoke detection, and systems that provide a density of 0.30 gal /m/f t upon completion of modifications, d.
Applies to rooms 180, 186, and 187 collectively.
e.
Applies to eooms, 203, 205, 207, 208, 209, 218, 222, 237, and 253.
f.
Applies to rooms 238, 239, 240, and 348.
9 Applies to rooms 309, 312, 325, 322, 316, 327, 332, 307, 310, and 330 collectively.
h.
Applies to rooms 301, 302, 303, 304, 311, 313, 314, 315, and 305 collectively, i.
Applies to rooms 601, 602, and 603 collectively.
j.
Applies to rooms 445 and 448 collectively.
k.
Applies to rooms 409, 410A, 4108, 419, 408, 422, 446, and 423 collectively.
1.
Applies to rooms 420 and 421 collectively.
m.
Applies to rooms 402, 417, 430, 435, 439, 441, 434, 433, and 415 collectively.
l
I i
.43 Smoke detection Systems are installed in all rcoms containing safe-shutdown equipment (except roems 236 and 341) or where there- !s appreciable combust.ible material. Automatte suppression is provided in 1
the fol!owing rooms 160 (partial), 151, 162, 163, 164, 158, 175, 205 (partial), 207 (partial), 208,209,222,212(partial), 316, 322, #02, i
403, 404, 415 (consealed space), 417 (consealed space), 420, 421 and 447. The 5-kV disconnect switches in room 161 and the load centers in rooms 410A and 410B have an automatic heat-actuated CO2 suppression system. Hose stations are installed throughout the fire. area and are spaced in such a manner to provide an effective hose line to all rocas in Fire Area 1-004. Portable extinguishers and portable smoke removal equipment are provided on each elevation.
The licensee justified the acceptability of this exemption request on the basis cf the existing fire protection, their propcsed modifications and their alternative shutdown actions associated with Unit 1 Auxiliary Butiding elevations 100 FF.- 0 in.,121 Ft. - 0 in.,120 ft. - 0 in.,
139 ft. - 0 in., 155 ft., - 0 in., 175 ft. - in., and 184 ft. - 0 in.
(Fire Area 1-004).
8.3 Evaluation a
Based on our evaluation of the electrical distribution system associated with MCC (IA) Q1R178001A-A and (13) Q1R17B0018-B demon-strates that a fire would be limited to one MCC and/or its associated power feed and would act effect the redundant MCC and/or its associated power feed.
Therefore, only one train of redundant electrical 1
distribution could be lost due to a credible fire in area 1-004. MCC IA is located in room 332, el 139 ft. - 0 in. having its power feed continue through room 312 then up to el 155 ft - 0 in. MCC IB is j
~
located in room 209 el 121 ft. - 0 in. having its power feed exit this room into an adjacent fire area. The redundant MCCs are separated by a 2-ft-thick reinforced concrete floor at el 139 ft - 0 in.
Unsealed penetrations located in the subject floor have been reviewed and will l
not effect the separation afforded by the concrete floor. The minimum
~
horizontal separation between components is approximately 60 ft.
between MCC IB (el 121 ft. - 0 in.) and MCC 1A power feed (el 155 ft.
- 0 in.).
This 60 f t horizontal separation has complete automatic suppression coverage at el 121 ft. - 0 in.
In addition our evaluation of de power distribution panels, IF and 1C demonstrates that a fire limited to one de distribution panel and/or its associated power feed and would not effect the redundant panel and/
or its associated power feed.
Therefore, only one train of redundant de distribution panels could be lost.
DC distribution panel IC is locatedin room 312, el 139 ft. - 0 in., and de distribution panel IF is located in room 209, el 121 ft - 0 in. The redundant de distributinn panels are separated by a 2-f t-thick reinforced concrete floor at el 139 ft. - 0 in. Unsealed penetrations located in the subject floor have been revicwed and will not effect the t
~ -.- - - _,
m._a w._
c 44 separation afforded by the concrete floor.
The minimum-horizontal separation between these redundant panels is approximately 40 ft. and has complete automatic suppression coverage at 11 121 ft. - 0 in. and 139 ft. - 0 in. A smoke detection system is installed in all rooms containing the subject equipment. The detection system would provide early warning of a fire, allowing the fire brigade adequate time to respond. Manual hose stations, portable extinguishers, and portable smoke removal equipment are available for use on the subject elevations.
Room 464 of Fire Area 1-004 contains cabling and pressure instruments for steam generator A.
Based upon a review of unsealed penetrations in the subject wall and the approximate 32-ft. horizontal separation between redundant steam generator pressure instruments and cabling, a credible fire in room 464 would not propagate into room 462.
Early warning provided by the smoke detection system in room 464 would provide adequate time for fire brigade personnel to extinguish the fire in room 464. In addition, initia-tion of the automatic fixed suppression system and the barriers provided for redundant cabling in room 462 would protect the redundant S/G B and C instrumentation.
For a fire in room 462 a portable extinguisher and manual hose station are available for use in room 464.
A fire rated barrier has been provided in room 462 for redundant steam ger.erator instrument cabling raceway 2IE047, 2IE048, 3IE017, 4IE019, and 4IE017 The barrier extends from pull box to wall penetration or to pressure instrument. The barrier consists of two 1-in. layers of Kaowool and an overall layer of Zetex fabric.
A fire rated barrier inside the following conduits is provided where they attach to pull boxes located in room 462. This barrier is the same as those provided inside conduit which penetrates a fire rated barrier
The conduits are 2IE045, 2IE047, 3IE018, 3IE020, 4IE017, and 4IE019.
An automatic fire partial suppression system presently covers the area of modification in the eastern portion of room 462.
Room 462 of Fire Area 1-004 contains S/G A, B, and C pressure instruments I
and associated cabling for the pressure instruments.
Based upon the modification, the existing raceway barriers, smoke detection, and fixed suppression in the area, a credible fire in room 462 would not effect the i
ability to monitor S/G A pressure.
One functional steam generator is sufficient for safe shutdown. The evaluation of the instrument air system demonstrated that a fire would be' limited to one train of redundant PORV instrument air header isolation valve cabling.
Train A Instrument Air cabling is located in rooms 168, 163, and 162, el 100 ft. - 0 in.,
and rooms 322, and 323, el 139 ft. - 0 in. Train B Instrument Air cabling. is located in rooms 203 and 209, el 121 ft - 0 in.
The redundant cables are separated by a 2-ft.-thick reinforced concrete floor at el 121 f t. - 0 in. and '.39 ft. - 0 in. Unsealed penetrations in the subject floors have been reviewed and will not effect the separation afforded by these concreted floors.
The train A cables have full suppression coverage on el 100 ft_ - 0 in, and el 139 ft. - 0 in. Train B j
i
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45 i
i cables have full suppression coverage on el 121 ft. - 0 in.
A smoke detection system is installed in all rooms containing the subject cabling.
The detection system would provide early warning of a fire, allowing the fire brigade adequate time to respond. Manual hose stations and.portabic extinguishers are available for use on the subject elevations.
Fire induced failures in control and power cables for the battery charging room coolers, and battery room exhaust fans and dampers could potentially result in the loss of ventilation in both the redundant Train A and B battery and battery charger rooms. A failure of the ventilation system will not result in a failure of the redundant Train-A or -B 125 V-dc battery systems. Therefore, the potential fire induced failure of the power and control cable for the redundant battery and battery charger room ventilation fans and dampers will not result in the loss of systems necessary to achieve and maintain hot shutdown conditions. The safe shutdown requirement for battery and battery charger room ventilation is a long term requirement. If ventilation is lost due to a fire in area 1-004, either portable ventilation equipment will be installed in the effected room (s) or the damaged ventila-tion system will be repaired within 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> of post-fire hot shutdown initiation to insure that battery room hydrogen concentrations do not exceed acceptable limits.
Our evaluation of boration/ makeup, depressurization and reactor coolant pump seal integrity evaluation was based on the following modifications:
A fire rated barrier is being provided for Train-A power cable raceway ADDA21, ADDA18, ADDA15, and ADOA09.
The subject barrier will extend the complete route of the Train-A changing pump power cable in Fire Area 1-004.
The existing fire rated barrier on raceway BFDB03 is being extended and a fire rated barrier for raceway BHFA03 is being provided along its entire length on el 100 ft. - 0 in.
In addition, an open penetration approgimately 2 ft. - 6 in, north of column 18 and 15 ft. - 8 in, west of column N, el 121 ft. - 0 in., floor slab has been sealed.
In conjunction with the above modifications, it can be demonstrated that a fire. involving the in-situ combustibles would be limited to only one train of redundant charging pump power cabling and charging pump cooler power and control cabling.
Train-A Charging Pump power cabling is located in rooms 161, 162, 163, and 168. Train-B cabling is located in rooms 175, 160, 159, 158, 157, 156, 155, 154, 153, 152, 151, 165, and 166. The redundant Charging Pump power cables are provided with a barrier (two 1-in.-thick wraps of Kaowool blanket) having a fire rating greater than that of the projected fire in the following rooms in Fire Area 1-004: Train A in rooms 161, 162, 163, and 168; Train B in rooms 175, 160 and 159. Full fixed suppression coverage is.
provided in rooms 163, 162, 161, 160, 175, and 186.
In addition, the redundant power cables are separated minimally by a 2-ft-thick reinforced concrete wall bounding rooms 159, _l58,157,156,154, 153, 152, 151, 165, i
a 46 and 166, with the exception of room 155 where there is approximately 32 ft.
of separation.
Unsealed penetrations in the subject walls have been reviewed and the walls are considered to afford adequate separation.
A smoke detection system is installed in all rooms containing the subject Charging Pump cabling. The detection system would provide early warning of a fire, allowing the fire brigade adequate time to respond. Manual hose stations, portable extinguishers, and portable smoke removal equipment are available for use on this elevation.
El 100 f t. - 0 in. contains redundant charging pump room cooler power and control cables.. Train-B cables are protected by a fire rated barrier which extends to a point of 40-ft. horizontal separation from the redundant Train-A cables.
Automatic fired suppression and smoke detection systems provide coverage for the subject cables.
El 121 ft. - 0 in. contains the same redundant charging pump room cooler cables which have a minimum horizontal separation of approximately 40 ft.
The Train-B power and control cables are provided with automatic suppression and smoke detection coverage for their entire route on this elevation.
Fire induced failures (hot shorts) to the cables associated with S/G-1C supply valve to the turbine driven auxiliary feedwater pump (TDAFW) could cause the subject valves to open, causing auto start of the TDAFW pump and the dragging of steara from S/G-1C.
In the unlikely event of multiple hot shorts occurring, this condition can be mitigated by manually tripping the TOAFW pump throttle valve Q1N12MOV3406-A.
Loss of de distribution panel IC would render the main steam atmospheric relief valves electrically inoperable.
One of the three main steam atmospheric reitef valves and its related steam generator are required to be operable to ach'ieve steam. release for cooldown.
The atmospheric relief valves are provided with hand wheels such that the valves may be manually opened or. closed without electrical controls or air supplies. The subject valves are not located in Fire Area 1-004. The capability to control steam generator pressure and reactor coolant system temperature with the use of the manually controlled atmospheric relief valves was demonstrated during the Unit 2 natural circulation and cooldown startup testing. Consequently, a fire in area 1-004 would.not prevent the operation of at least one redundant atmospheric relief valve.
Instrumentation cables for the source range neutron flux monitors N1C55NE0031-P1 and NIC55NE0032-P2 traverse Fire Area 1-004 through conduit embedded in the floor slab at el 155 ft. - 0 in., and are accessible through embedded pull boxes on this elevation.
The instrumentation cables for the neutron flux monitors Q1C55NE0048A-A are routed through Fire Area 1-004 on el 100 ft. - 0 in., 121 ft'- 0 in. and 139 ft. - 0 in. The amplifier 01C55NM0048-A for the neutron flux monitor is located on elevation 139 ft. - 0 in.
47 The redundant Neutron Flux Monitor cables are. separated by a 2-ft-thick reinforced concrete floor slab at el 155 ft. - 0 in.
Unsealed penetrations in the subject floor slab have been reviewed and are considered not to effect the separation afforded by the concrete floor.
l Based on our evaluation of the reactor coolant boundary integrity, the effects of fire upon redundant RCS and pressurizer sample line isolation valves show that it would take multiple hot shorts to energize.the solenoids to open all valves.
In the unlikely event of multiple hot shorts (induced from adjacent control cables in the shared raceway) occurring, the condition can be mitigated for the Train-A powered valves Q1P15HV3765-A and Q2P15HV3103-A by removing power from all cables in the shared raceway. This can be accomplished by opening the supply breaker on 125 V-dc switchgear IA (Q1R428001A-A) for 125 V-dc distribution panel IC (Q1R41L001C-A).
Distribution panel 1A is located in Fire Area 1-018 room 0224.
Fire induced failures (hot shorts) within the control cables for the transfer relay cabinet Q1H22 LOO 2-A could cause control for the pressurizer power operated relief and blocking valves and the reactor head vent valves to shift from their normal main control board alignment to the remote hot shutdown panel.
Subsequent fire induced failures (hot shorts from adjacent control cables in the shared raceway) of the control cables of Q1B31PCV0445A-A, pressurizer power cperated relief valve, and Q1B135V2213A-A and Q1B135V2214A-A, reactor head vent valves, could result in the valves (MOV) becoming electrically inoperative in the open position.
In the unlikely event of the multiple hot shorts occurring, this condition can be mitigated by removing power from the transfer relays and manually aligning the affected relay (handle is provided), thereby shifting control to the main control board. To remove power from the transfer relay open breaker 17 on de distribution panel IB (Q1R41L001BA) in Fire Area 1-043 room 0343, go to transfer relay cabinet TRC-1 in Fire Area 1-035 room 0347 and manually shift transfer relays TRI (Q18135V2213A-A), TR2 (Q18135V2214A-A), TR3 (Q1813PCV0445A-A), and TR5 (Q1B13MOV8000A-A). This will place control back into the centrol room and allow the operator to mitigate the letdown.
Room 163 (area 1-004) contains an automatic fixed suppression system which provides suppression coveraga in the area of the subject non-fire rated l
steel hatch cover.
In addition, our evaluation of the safe shutdown circuits in room 163 (Fire Area 1-004) and room 103 (Fire Area 1-001) showed that physical separation between redundant safe shutdown cabling in each fire area was adequate. Therefore, with the detection system provided in rooms 163 and 103 and the suppression provided in the area of the hatch in room 163, fire rating of the subject hatch cover is not required.
The existing sprinkler systems in rooms 345 (1-042) and 454 (1-004) will serve the purpose of a water curtain to prevent the passage of fire from Fire Area 1-004 to the adjacent fire area via the non rated steel hatch.
Rooms 236 (duct chase), 341 (pipe chase), and 342 (spent fuel pool pump room) have safe shutdown control and instrumentation cabling which pass through them and smoke detection is not provided.
a 48 The licensee has committed to install smoke detection in room 342. Room 236 (duct chase) contains safe shutdown cabling. All cabling in this chase is routed in conduit.
The duct chase is considered to have low in-situ combustibles. The duct chase runs vertically from el 121 ft. -0 in. through 139 ft. - 0 in. and 155 f t. - 0 in.
Based on our evaluation there is no redundant safe shutdown cabling in room 236 therefore, the addition of fire detection in this room would not enhance the plant's ability to achieve safe shutdown with a fire in this plant location.
Room 341 (pipe chase) contains safe shutdown cabling. All cabling in this pipe chase is installed in conduit. The pipe chase is considered to have low in-situ combustibles. The pipe chase exits the auxiliary building at el 139 f t - 0 in, which is below grade.
Based on our evaluation it was determined that there were no redundant safe shutdown cabling. in room 341.
Therefore, the addition of the fire detection in this room would not enhance the plant's ability to achieve safe shutdown with a fire in this plant area.
4 By letter dated May 31, 1985, the licensee committed to develop detailed procedures specifically for this fire area covering the manual operator actions required to regain control of the transfer relays associated with the PORVs and the reactor heat vent valves, restoration of the battery room ventilation system, tripping of the TDAFW pump,. manual control of one main steam atmospheric relief valve, and isolation of RCS and pressurizer sample line isolation valves. These procedures will be fully implemented by the end of the Unit 1 seventh refueling outage. In addition, the licensee has also committed to install additional fire detection, raceway fire barrier enclosures and extend the sprinkler coverage around the steel hatch cover separatir.g Fire Areas 1-004 and 1-001 by the end of the Unit I seventh refueling outage currently scheduled for the fourth quarter of 1986.
All other shutdown systems associated with Fire Area 1-004 have redundant counterparts in 'other fire areas or are located in plant areas which meet the requirements of 10 CFR 50 Appendix R, Section III.G.2. As a result, there is reasonable assurance if a fire were to occur in any of the rooms identified in Section 8.2 safe shutdown could be achieved and maintained.
8.4 CONCLUSION
Based on our evaluation. we conclude that the licensee's. alternative fire protection and shutdown configuration will provide an acceptable level qx of fire protection to that required by the technical requirements of 10 CFR 50 Appendix R Section III.G.2 and that no additional fire protection features are required to satisfy the requirements of Section III.G.3.
Therefore, the licensee's request for exemption for the Unit I auxiliary building elevation 100 ft.
0 in.,
121 ft. - 0 in.,
130 ft. - 0 in.,
139 ft. - 0 in.,155 ft. - 0 in.,175 ft. - 0 in., and 184 ft. - 0 in (Fire Area 1-004) should be granted.
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49 9.0 UNIT 1 AUXILIARY BUILDING STAIRWELL NO. 2 - FIRE AREA 1-502 (EXEMPTION REQUEST 1-22) 9.1 EXEMPTION REQUESTED The licensee in their exemption request 1-22 requested an exemption from the technical requirements of 10 CFR 50 Appendix R, Section III.G.2 to - the extent it requires the~ installation of an automatic fire suppression system.
9.2 DISCUSSION Fire Area 1-502 extends vertically from el 77 ft. - 0 in. to its ceiling at el 163 ft. - 0 in. All fire area boundary walls are at a minimum two-hour fire rated. All doors are Class B fire doors with the exception of door 317A (el 139 ft. 0 - in.) and the door in the ceiling (el 163 ft. - 0 in.)
which are Class A fire doors.
Fire area 1-502 contains redundant safe shutdown control cabling that is required for operation of the following safe shutdown systems and supporting functions which are not separated by a distance greater than 20 ft. with no intervening combustibles, a.
Instrument Air (Containment Supply) b.
Component Cooling Water System c.
Reactor Coolant Pump Seal Integrity d.
Boration/ Makeup e.
Reactor Coolant System Boundary Integrity f.
Residual Heat Removal System
, The licensee's reevaluation of the potential effects of a fire upon these cables has shown that fire induced failures could result in component maloperation wh{ch would impair the operation of the above systems and functions.
Combustible materials in Fire Area 1-502 primarily consists of cable insulation.
The fire loading associated with this area is approximately 39,678 BTU /Ft.
No automatic fire suppression system - i s provided in this fire area.
However, the fire area is protected by an automatic smoke detection system which alarms locally and is annunciated in the main control room.
In addition, all redundant cabling associated with the subject safe shutdcwn functions are wrapped with a fire barrier material consisting of two 1-inch thick Kaowool blankets and an overall wrap of Zetex woven fabric. Manual hose stations are provided at all floor elevations and can provide ' hose coverage throughout the stairwell.
The licensee justifies the acceptability of this exemption on' the basis of the existing fire protection associated with auxiliary building stairwell No.1 (Fire Area 1-502).
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a 50 9.3 EVALUATION Redundant safe shutdown cabling in Fire Area 1-502 has been enclosed in a fire barrier and an early warning smoke detection system will be provided of cable insulation with a maximum fire severity of les which is less than the fire rating of the proposed raceway fire barriers.
In addition, all non-safe shutdown cables in this fire area are enclosed in conduit.
All other shutdown systems associated with Fire Area 1-502 have redundant counterparts in other fire areas or are located in_pl. ant areas which meet the requirements of 10 CFR 50 Appendix R, Section III.G.2.
there is reasonable assurance that As a result, if a fire occurred in the Unit 2 auxiliary building stairwell No.1 safe shutdown. could be achieved and.
maintained.
9.4 CONCLUSION
Based cn our evaluation, we conclude that the licensee's alternative fire protection and shutdown configuration will provide an acceptable level of fire protecticn to that required by the technical requirements of 10 CFR 50 Appendix R, Section III.G 2.
Therefore, the licensee's request for exemption for the No. I stairwell (Fire Area 1-502) should be granted.
10.0 UNIT 1 AUXILIARY EUILDIN3, ELECTRICAL PENETRATION ROOM TRAIN B AN PENETRATION ROOM FILTRATION SYSTEM EQUIPMENT ROOM -
(EXEMPTION REQUEST 1-35)
FIRE AREA 1-034 10.1 EXEMPTION REQ' JESTED The licensee in their exemption request 1-35 requested an exemption from the technical requirements of 10 CFR 50. Appendix R,Section III.G.2.c to the extent that it requires cne train of redundant safe shutdown cable and equipment to be installation of an automatic fire suppression system. enclosed by a on 10.2 DISCUSSION Fire Area 1-034 consists of rooms 334 and 317 at el.139 f t. - 0 in.
walls, ceilings, and floors forming the area boundary are 3-hour fire rated.
The These rooms communicate via two stainless steel pipes used in the penetration room filteration system.
in concrete and contain no combustibles.The stainless steel. pipes are encased A expanding cork non-fire rated penetration seal is ' installed for the portion of the area boundary along the containment wall.
UL Class A fire rated doors exist between rooms 334 and 333 (area 1-035),
334 and stairwell no. 2, and 317 and 322 (area 1-004).
51
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The licensee's reevaluation indicates that Fire Area 1-034 contains power and control cables and equipment (MCC-IV) associated with the following valve:
Equipment Function Q1P16MOV3130B-B Service Water _ Inlet to CCW HX-1B Valve Q1P16MOV3130B-B is required to be maintained open to maintain service l
water flow to CCW heat exchanger IB. In the event'that CCW pump-1C and CCW i
heat exchanger IC are out of service for maintenance and the swing CCW pump 1B is aligned to electrical Train-A power, the effects of a fire in area 1-034 upon the control cables of valve Q1P16MOV3130B-B could fail the valve in the closed position causing loss of service water to the CCW heat exchanger 18.
In addition, Fire Area 1-034 contains MCC-1V associated with the following valves:
Equipment Function Q1E21MOV81308-B Charging Pump Suction Header Isolation Valve Q1E21MOV8133B-B Charging Pump Discharge Header Isolation Valve For a fire in this area, seal injection flow will be established using either charging pump 1A or chargir.g pump IB aligned to electrical Train-A power.
Valves Q1E21MOV81308-B (suction header) and Q1E21MOV8133B-B (discharge header) are required to be maintained in the open position to supply seal injection water from the RWST through charging pumps IA or 18.
Due to the effects of a fire in this area -upon the control cables for the subject valves,'the valves could fail in the closed position and become inoperable. This will cause the plant to lose seal injection water and seal integrity.
These valves cannot be locked in the open position because they are needed for train separation during a LOCA event.
Fire Area 1-034 also contains power and control cables and equipment MCC-IV associated with the following valves:
Equipment Function 01E21MOV8109A-B Charging Pump 1A Miniflow Valve Q1E21MOV8109B-B Charging Pump 1B Miniflow Valve Valve Q1E21MOV8109A-B or Q1E21MOV81098-B is required to be maintained in the open position to establish miniflow for charging pumps 1.A or IB, respectively.
Due to the effects of a fire in this area upon the control cables for the subject valves, the valves could fail in the closed position and become inoperable, thereby isolating charging pump miniflow.
52 Control cables associated with the following RCS and pressurizer ' sample valves are located in Fire Area 1-034:
Equipment Function Q1P15HV3332-B Pressurizer Liquid Sample CTMT Isolation-Valve Q1P15HV3881-B Pressurizer Liquid CTMT Isolation-Valve Q1P15HV3765-A RCS Hot Leg Sample Line CTMT Isolation-Valve Q1P15HV3333-B RCS Hot Leg Sample Line CTMT Isolation-Valve RCS and pressurizer sample line valves Q1P15HV3333-B, Q1P15HV3765-A, Q1P15HV3332-B, and Q1P15HV3881-B are required to be maintained in the closed position to maintain RCS boundary integrity. Due to the effects of a fire in this area upon the control cables of the subject valves, the valves could fail in the open position and become inoperable.
Equipment Function Q1B31PCV0444B-B Pressurizer PORV Q1813MOV8000B-B Pressurizer PORV Block Valve Q1B135VV2213B-B Reactor Head Vent Valve Q1B13SV2214B-B Reactor Head Vent Valve The subject cables are associated with control from both hot shutdown panel and main control board.
Fire induced failures having multiple het shorts could cause the r;eactor inventory to letdown via the PORV and reactor head vent paths.
Instrumentation cable for the following safe shutdown instrumentation is located in Fire Area 1-034:
Equipment Function Q1831PT0455-P1 Pressurizer Pressure Transmitter Q1831PT0444-4 Pressurizer Pressure Transmitter Q1B31PT0444Z-4 Pressurizer Pressure Transmitter Q1831PT0456-P2 Pressurizer Pressure Transmitter Q1831PT0457-P3 Pressurizer Pressure Transmitter N1831PT0445-3 Pressurizer Pressure Transmitter
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53 At least one of the above pressure transmitter signals is required for safe shutdown.
Due to the effects of a fire in this area upon the instrumentation cables of 'the pressurizer pressure transmitters, all the pressure transmitter signals will be lost.
Combustible materials in Fire Area '1-034 primarily consist of cable insulation, plastic panel parts and charcoal filter media. The following summarizes the fire loadings associated with this fire area:
Fire Load Room Number BTU /FT 1
334 Electrical Penetration Room 90,955 Train B 317 Penetration Filteration 24,606 Equipment Room Smoke detectors are provided in rooms 317 and 334. A manual hose station located in room 316 (area 1-004) is available for use by the fire brigade fire fighting operations in this area.
The licensee justifies the acceptability of this exemption on the basis of the existing fire protection, proposed modifications and their alternative shutdown actions associated with Unit 1 Auxiliary' Building electrical penetration room Train B and penetration room filteration system equipment room (Fire Area 1-034).
10.3. Evaluation In order to preclude the spurious operation of service water inlet to CCW heat exchanger '1h isolation valve Q1P16MOV1308-B will be maintained in the open position by racking out the power at the MCC breaker whenever CCW pump IC and CCW heat exchanger IC are out of service.
A design modification is proposed to install disconnect breakers in the power supply circuits of charging pump isolation valves outside the electrical penetration room during the next outage of sufficient duration subsequent to design and procurement completion.
The next outage is currently scheduled to commence during the fourth quarter of 1986.
In the interim, the operators will be instructed of the potential inadvertent closure of the charging pump suction and discharge valves in the event of a fire in this area.
The licensee's analysis shows that the charging pump can be run safety with miniflow isolated and with a maximum of 24 gal /m of seal injection flow for a period of I hour. This will allow the operator time to deenergize MCC-1V and take manual action to open the valve and reestablish the miniflow.
In addition, the IC charging pump is still available and can be. utilized to support RCS makeup if required.
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The open position of the RCS and pressurizer sample line valves will allow an RCS sample to flow to the VCT, through the sample cooler. This flow is of no immediate significance for safe shutdown. An operator action will tue performed to close manual valves Q1P15V051A and Q1P15V051B to stop the flow of RCS and pressurizer liquid. Valves Q1P1V051A and Q1P15V051B are located in the sample room 323 outside of Fire Area 1-034.
Fire induced failure (hot short) of the individual control cables for Q1B31PCV04448-B (reactor head vent valve) Q18135V2213B-B and Q18135V22148-B
. (reactor head vent valves), could result in-the valves being energized to open. The power operated relief blocking valve could become electrically inoperatable in the open position.
In the unlikely event of the multiple fire induced failures (hot shorts from adjacent control cables in the shared -
raceway) occurring, this condition can be mitigated by removing 125 V-dc power from cables in ' the shared raceway.
This can be accomplished by opening breakers on the 125 V-dc switchgear bus IB. (Q1R428001B-B) for 125 V-dc distribution panels ID, IE, and IF, feeder breaker 12 on 123 V-dc distribution panel N1R41 LOO 1G-N, and breaker 15 on 125 V-dc distribution panel NIR41L001H-N.
Instrumentation-cable for pressurizer pressure transmitter Q1B31PT0455-P1 has been rerouted out of-Fire Area 1-034 so that pressurizer pressure signal from at least one pressure transmitter, Q1B31PT0455-P1, is available.
By letter dated May 31, 1985, the licensee committed to develop a detailed procedure specifically for this fire area covering the manual operator actions to restore the control of the.PORVs and reactor head vent valves, isolation RCS and pressurizer sample line valves, pre-fire alignment of CCW heat exchanger valves and the reestablishment of charging pump miniflow.
This procedure will be fully implemented by the end of the Unit I seventh refueling outage; currently scheduled for the fourth quarter of 1986.
All other shutdown systems associated with Fire Area 1-034 have redundant counterparts in other fire areas or are located in plant areas which meet the requirements of 10 CFR 50, Appendix R, Section III.G.2. As a result, there is reasonable assurance that if a fire occurred in Unit I auxiliary building electrical penetration room Train B and penetration room filteration system equipment room (fire area 1-034) safe shutdown could be achieved and maintained.
10.4 CONCLUSION
Based on our evaluation, we conclude that the licensee's alternative fire protection and shutdown configuration will provide an acceptable level of fire protection to that required by the technical requirements of 10 CFR 50 Appendix R, Section III.G.2, and that no additional fire protection is required to satisfy the requirements of Section III.G.3.
Therefore, the licensee's request for exemption for' Unit I auxiliary building electrical penetration room Train B and penetration room filteration room (fire area 1-034) should be granted.
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55 11.0 UNIT 1 AUXILIARY BUILDING FIRE AREAS 1-004 AND 1-005 UNITT 2 AUXILIARY BUILDING FIRE AREAS 2-004 AND 2-005 (EXEMPTION REQUEST 1-40) 11.1 Exemption Requested The licensee in their exemption request 1-40 requested an exemption from the technical requirements of 10 CFR 50 Appendix ~R,Section III.G.2 in that it requires separation of fire areas by a barrier having a:three-hour fire rating.
11.2 Discussion Non-fire rated reach-rod penetrations are located in the walls between the following rooms for Units 1 and 2:
Number of Room Numbers / Titles Penetrations 173 Charging / Safety Injection 2
Pump Room (Fire Area 1-005) and 161 Corridor (Fire Area 1-004) 171 Combustible Storage Area 8
(Fire area 1-005) and 170 Letdown Heat Exchange Room (Fire Area 2-004) 175 Corridor (1-005) and 5
173, 174, 181 Charging Pump Rooms (Fire Area 1-004) 2173 Charging / Safety Injection 3
Pump Room (Fire Area 2-005) and 2161 Corridor (Fire Area 2-004) 2170 Letdown Heat Exchange Room 10 (Fire Area 2-004) and 2171 Combustible Storage Area (Fire Area 2-005) 2175 Corridor (Fire Area 2-005) 6 and 2173, 2174, 2181 Charging Pump Rooms (Fire Area 2-0004)
The licensee justifies the acceptability of this exemption on the basis of the existing fire protection associated with Fire Areas 1-004, 1-005, 2-004, and 2-005.
56 1
11.3 Evaluation The reach-rod penetrations are non-fire rated, nor can they be fire rated.
These penetrations range in size from 2 in., to 10 in., with the majority being of the 2 in. size. The cross-sectional area of all penetrations is reduced by using a welded steel plate on one side penetrated by the reach-rod. The only opening in the penetration is the gap between the rod and the steel plate which allows for the operation of the reach-rod. The fire severity in the affected rooms is less than 30 minutes for all cases.
In addition, there is a sprinkler system installed in rooms 161, 179. 2161, and 2179 and smoke detection systems in all rooms which will provide early warning capability and protection from the spread of a fire from one room to the next. Therefore, the existence of these non-rated penetrations will not affect the ability of the plant to achieve safe shutdown.
If a fire were to occur in any of the rooms identified in section 11.2 above.
11.4 Conclusion Based on our evaluation, we conclude that the non-fire rated reach-rod design and the existing fire protection configuration will provide an acceptable level of fire protection to that required by the technical requirements of 10 CFR 50 Appendix R.Section III.G.2. Therefore, the licensee's request for exemption for the reach-rod penetrations associated with.the fire barrier walls separating rooms 173 and 161,175 and 173, 175 and 174, 175 and 181, 171 and 170, 2173 and 2161, 2170 and 2171, 2175 and ?173, 2175 and 2174, and 2175 and 2181 should be granted.
12.0
SUMMARY
AND CONCLUSION ON TWENTY-TWO SPECIFIC FIRE AREA EXEMPTIONS FOR UNIT 1 Based or our evaluation of the licensee's May 1985, 10 CFR 50 Appendix R fire hazards analysis re-evaluation provided by letter dated May 31, 1985, and on our site visit during the week of August 19, 1985, we conclude that the licensee's alternate fire protection configurations in the following plant fire areas represented an equivalent level to safety to that achieved by compliance with Section III.G of Appendix R:
Unit 1 Auxiliary Building Cable Chase Train A - Fire Area 1-008 (exemption request 1-14)
Unit 1 Auxiliary Building Switchgear Train B - Fire Area 1-021 (exemption request 1-15)
Unit 1 Auxiliary Building Vertical Cable Chase - Fire Area 1-013 (exemption request 1-16)
Unit 1 Auxiliary Building to Diesel Building Cable Tunnel Train A -
Fire Area 1-075 (exemption request 1-18)
Unit 1 Auxiliary Building, E1. 100 ft. - 0 in., 121 ft. - 0 in., 130 ft. - 0 in., 139 ft. - 0 in., 155 ft. - 0 in., 175 ft. - 0 in., and 184 ft. - 0 in., Fire Area 1-004 (exemption request 1-39)
Units 1 and 2 Various Auxiliary Building Fire Areas (exemption 1-40)
57 Unit 1 Auxiliary Building Control Rod Drive Switchgear Room Train-B -
Fire Area 1-023 (exemption request 1-19)
Unit 1 Auxiliary Building Train A Battery Room - -Fire Area 1-017 (exemption request 1-20)
Unit 1 Train A DC Switchgear Room, Auxiliary Building, EL. 121 ft. - 0.
in. - Fire Area 1-018 (exemption 1-21)
Unit 1 Auxiliary Building Stairwel_1 No. 2 - Fire Area 1-502 (exemption request 1-22)
Unit 1 Auxiliary Building, EL. 139 f t. - 0 in. - Fire Area 1-041 (exemption request 1-23)
Unit 2 Auxiliary Building, EL. 139 f t. - 0 in. - Fire Area 2-401 (exemption request 1-24)
Unit 1 Auxiliary Building, EL. 139 Ft. - 0 In. - Fire Area 1-042 (exemption request 1-25)
Unit 1 Train B DC Switchgear Room, Auxiliary Building, EL. 121 Ft. - 0 in.'- Fire Area 1-019 (exemption request 1-27)
Unit 1 Auxiliary Building Battery Room Train B - Fire Area 1-016 (exemption request 1-28)
Unit 1 Auxiliary Building Cable Chase Train B - Fire Area 1-030 (exemption request 1-29)
Unit 1 Auxi.11ary Building to Diesel Building Cable Tunnel Train B -
Fire Area 1-076 (exemption request 1-30)
Unit l' Auxiliary Building, Local Hot Shutdown Panel Room - Fire Area 1-012 (exemption request 1-32)
Unit 1 Auxiliary Building Cable Chase Train A - Fire Area 1-031 (exemption request 1-33)
Unit 1 Auxiliary Building, EL. 100 ft. - 0 in. Charging Pump Rooms and Storage Areas - Fire Area 1-005 (exemption request 1-34)
Unit 1 Auxiliary Building Electrical Penetration Room Train B and Penetration Room Filtration System Equipment Room - Fire Area 1-034 (exemption request 1-35)
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Unit 1 Auxiliary Building Electrical Penetration Room Train A - Fire Area 1-035 (exemption request 1-37) l
58 Dated:
Principal Contributors:
P. Madden E. Reeves
ATTACHMENT c#
UNITED STATES y
' 't NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 e
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO EXEMPTION FROM 10 CFR 50, APPENDIX R ALABAMA POWER COMPANY JOSEPH P. FARLEY NUCLEAR PLANT, UNIT NO. 1 DOCKET NO. 50-348
1.0 INTRODUCTION
TO ATTACHMENT This safety evaluation is an Attachment to Enclosure 2, the safety evaluation which concluded that twenty-two exemptions of twenty-seven exemptions requested by the licensee for Unit I were acceptable. The remaining exemptions are considered in this Attachment. The same general criteria and introduction applies to this Attachment also.
By letter dated October 18, 1985, the licensee provided the additional technical infonnation to substantiate the technical equivalency of the five remaining exemptions. The licensee also committed to provide additional fire protection trodifications as described in specific plant fire areas for Unit 1.
Our evaluations of the licensee's revised alternate fire protection configurations and their justifications regarding the plant's alternative ability for specific redundant shutdown functions to achieve and maintain safe shutdown conditions for fire conditions which affect those specific fire areas' are as follows:
2.0 NON-RAD SIDE CORRIDOR - AUXILIARY BUILDING EL 121 FT. - 0 IN - FIRE AREA 1-020 (EXEMPTION REQUEST 1-17) 2.1 EXEMPTION REQUESTED The licensee, in their exemption request 1-17, requested an exemption from the technical requirements of 10 CFR 50, Appendix R, Section III.G.2 to the extent that it requires on train of redundant safe shutdown cables to be enclosed by a one-hour fire rated barrier.
2.2 DISCUSSION Fire Area 1-020 consists of rooms 234, 228, 221, 210, 213, 244, 225, and 245 which constitute the corridor, battery service area, and battery room mezzanine on el 121 ft. - 0 in, on the non-rad side of the auxiliary building.
Fire Area 1-020 contains control and power cables for the train-B electrical distribution system. An analysis of the potential effects of fire induced failures of these cables demonstrated that the plant could experience a J
2 total loss of the electrical train-B distribution system. This could result in the following instrument air isolation valves becoming inoperable in the closed position.
These valves isolate the primary air and backup air /N to the pressurizer Power Operated Relief Valves (PORVs):
EQUIPMENT -
FUNCTION I'
N1P19HV3885-B Instrument Air.to the Penetrations Room Q1813HV2228-B Backup Air /N, Supply to Pressurizer PORVs In addition, hot shutdown (HSP) control cables for the following safe shutdown components are routed through Fire Area 1-020:
EQUIPMENT FUNCTION Q1831PCV0445A-A Pressurizer Power Operated Relief Valve Q1813MOV8000A-A Pressurizer PORV Block Valve
-Q1813SV2213A-A Reactor Head Vent Valve Q1B13SV2214A-A Reactor Head Vent Valve The subject cables are associated with control functions from the hot I
shutdown panel.
In addition, control cables which shift control from the main control board to the' hot shutdown panel via transfer relays are in this fire area.
A fire induced failure causing multiple hot shorts could cause these components to become inoperable in either a closed or opened condi-tion, resulting in the plant's inability to depressurize, -letdown, or maintain the RCS boundary as may be required.
Fire Area 1-020 contains instrumentation cables for redundant condensate storage tank level instrument channels.
EQUIPMENT FUNCTION
}
Q1P15LT515-A CST Level Train A Q1P15LT516-8 CST Level Train A The licensee's re-evaluation shows that both trains of CST level indication could be damaged by the fire.
Fire' Area 1-020 also contains HSP control cabling associated with the following safe shutdown components:
EQUIPMENT FUNCTION Q1N11SV3368AC-A Main Steam Isolation SG-1A Q1N11SV3369BC-A Main Steam Isolation SG-1B Q1N11SV3369CC-A Main Steam Isolation SG-1C The subject cables are associated with the control function from hot shutdown panel Q1H21NBAFP2605G-A.
In addition, control cables which shift control from the main control board to the hot shutdown panel via transfer
t 3
relay cabinet Q1H22 LOO 3-A are in this fire area.
A fire induced failure causing multiple hot shorts could cause these components to become inoper-able in the open position.
In addition, electrical train-B main steam isolation valves could become inoperable in the open position due to loss of the electrical train-B distribution system.
Control cabling associated with post-fire operation of the following safe shutdown components are routed through Fire Area 1-020:
EQUIPMENT FUCNTION Q1N11PV3371A-A Main Steam Atmospheric Relief Valve (S.G.-1A)
Q1N11PV33718-A Main Steam Atmospheric Relief Valve (S.G.-18)
Q1N11PV3371C-A Main Steam Atmospheric Relief Valve (S.G.-1C)
The potential effects of a fire upon these cables demonstrate that these valves could become electrically inoperable in the closed position.
Since, a fire in area 1-020 could result in the loss of the train-B electrical distribution system.
This could cause the following samples valves to fail closed:
VALVES FUNCTION Q1P15SV3881-B Pressur1:er Sample Q1P155V3332-B Pressurizer Sample Q1P15SV3101-B RCS Loop 1 Hot Leg Sample Q1P15SV3333-B RCS Hot Leg Sample Q1P15SV3105-B RHR Heat Exchanger Sample Q1P15SV3106-B RHR Heat Exchanger Sample In addition, cables for neutron flux monitors NIC55NE0031-P1, NIC55NE0032-P2, and Q1C55NE0048A-A are in the fire area. An analysis of the potential effects of fire induced failures of these cables demonstrated that these monitors may become inoperable.
Control cables for the following valves are routed through Fire Area 1-020.
VALVES FUNCTION Q1E21LCV01158-A RWST to Charging Pump Suction Q1E21LCV01150-B RWST to Charging Pump Suction Control cables in Fire Area 1-020 for Q1E21LCV01158-A and Q1E21LCV01150-B are associated with control of the valves from the hot shutdown panel.
In addition, control cables which shif t control from the main control board to the hot shutdown panel via transfer relays are in the fire area.
A fire induced failure causing multiple hot shorts could cause these components to become electrically inoperable in the closed position.
At a point in the shutdown process, one of these valves may be required to be open in order to line up the charging pump suction to the RWST.
4 Two hatchways in room 234 directly above one another have 'non-rated steel plate covers.
These hatchways comunicats with Fire Areas 1-042 er.d 1-006.
The door between room 235 (Fire Area 1-023) and 234 (Fire Ana 7.-020) is provided with removable transoms.
The duor end transom assently cannot be certified as UL Class A.
The combustible materials in Fire Area 1-020 primarily consists of cable insulation and plastic panel parts.
The fcllowing fire loading is associ-ated with the rooms bounded by Fire Area 1-0E0:
Room Number Combustible Fire load Maximum and Title Material HTU/FT2)
Fire Severity 210 Corridor, Cable Insulation 77,754 Less Than 211 Corridor, 30 minutes 213 Battery Service Room, 228 Corridor, and 234 Hallway.
244 Battery Cable insulation.
14,556 tess Than Rcom "B",
and Plastic Penel 30 minutes 245 Battery Parts Room "A",
and 225 Battery Charger Area An ionization smoke detection system provides coverage to the entire fire area.
Automatic water suppression systens covers the. entire fire area except room 225.
A CO,3 hose reel is located in room 210 and a water hose is provided in rooms 211 'and 234 for manual fire brigade firefighting purposes.
Portable extinguishers are provided throughout the area.
All doors in the boundary fire barrier walls of Fire Area 1-020 are three-hour VL fire rated Class A doors except for the transom door between rooms 235 (Fire Area 1-023) and 234 (Fire Area 1-020) and the UL Class B (one/one half-hour fire rated) door which exists between room 234 and stairway No.1.
The licensee justifies the acceptability of this exemption request on the basis of the existing fire protection, and their alternative shotdown I
actions associated with Unit I non-rad side corrider area (Fire Area 1-020).
2.3 EVALUATION A fire in Fire Area 1-020 could affect pressurizer PORVs Q1831PCV0445A-A and 01831PCV044B-B which provides a means of achieving RCS depressurization.
Valves N1P19HV3885-B and Q1813HV2228-B will fail in the closed position on the loss of train B DC Control Power. This will isolate tne instrument air
O 5
supply to the pressurizer PORVs Q1631PCV0445A-A and Q1831PCV0444B-B.
POR'I Q1B31PCV044B-B will also be inoperable due to loss of the train-B DC power supply.
However, the train-A DC supply to PORV Q1831PCV0444A-A is not affected due to a fire in this area.
Since only one of the PORVs is required for RCS depressurization, and RCS depressurization is a long-term requirement, the operator has adequate time to take manual action to restore the instrument air by handwheel operation cf valve N1P19HV3885-B 1.ocated in room 189 (Fire Area 1-006). Once air is. restored, PORV Q1831PCV0445A-A will be cperable to achieve RCS depressurization.
Fire induced failures (hot shorts) within the control cable for the transfer relays could cause control of the valves to shift from the main control.
board to the remote hot shutdown p'anel.
Subsequent fire induced failures (het shcrt from adjacent control cables in the shared raceway or open circuits) of the control esbies for pressurizer PORV Q1831PCV0445A-A and reactor head vent valves-Q1813SV2213A-A and Q1813SV2214A-A could result in the valves failing ir. undesirable positions.
The power relief blocking valve (MOV) could become electrically inoperative in the open position.
In the unlikely event of the multiple hot shorts occurring, this condition can be mitigated by removing power from the transfer relays and manually aligning the affected relay (handle is provided), thereby shifting control to the main control board.
To remove power from the transfer relay open breaker.17 on de distribution panel IB (Q1R41L001B-A) in Fire Area 1-043 room 0343. Then go to transfer relay cabin'et Q1H22L002-A in Fire Area 1-035 room 347 and manually shift transfer relays TR1 (01B13SV2213A-A), TR2 (Q18135V2214A-A), TR3 (Q1813PCV0445A-A), and TRS (Q1B13M0V8000A-A) restoring control to the main control board to allow the operator to mitigate the letdown.
In addition, fire induced failures (hot shorts) within control cables for the transfer relays could cause control for the main steam isolation valves Q1N11SV3369AC-A, Q1N11SV3369BC-A, and Q1W11SV3369CC-A to shift from the main control board to the remote hot shutdown panel.
Subsequent fire induced failures of the cables for the main steam isolation valves listed above, could result in the valves becoming inoperable in the open position.
In the unlikely event of the multiple hot shorts occurring, this condition can be mitigated by removing power from the transfer relays and manually resetting the affected relays (handle is provided), thereby shifting control to the main control board.
This will enable the plant to maintain main stean isolation using the train-A isolation valves. To remove power from transfer relays, open breaker 17 on 125V de distribution panel IB.
Then go to transfer rely cabinet TRC-2 (Q1H22 LOO 3-A) located in Fire Area 1-006, room 0190 and snually shift transfer relays TR6 (Q1N11SV3369AC-A), TR7 (Q1N11SV3369BC-A) and TRS (Q1N11SV3369CC-A), placing control back to main control board, to allow operator to achieve main steam isolation.
One of the three main steam atmospheric relief valves and related steam generator is required to be operable to achieve steam release for cooldown.
The atmospheric relief valves are provided with hand wheels such that the valves may be manually opened or closed without electrical controls or air supplies.
The operator would establish manual control of the atmospheric
l g
relief valves by closing the manual air control valves to isolate the air supply and by opening the manual air vent valve to bleed off-air from the diaphragm of the valve actuator.. Both the air control and air vent valves are located in'the vicinity of their associated atmospheric relief valve and would be accessible despite a fire in Fire Area 1-020.
The capability to control steam generator pressure and reactor coolant system temperature with the use of manually controlled atmospheric relief valves was demonstrated
~
during the Unit 2 natural circulation and cooldown startup testing.
Consequently, a fire in Fire Area 1-020 would not prevent the oper.ation of I
at least one redundant atmospheric relief valve.
]
A fire in Fire Area 1-020 could result in a loss of-train-B power.
l Therefore, this justification addresses the operation of the Train A RWST to l
charging pump suction valve only.
In the unlikely event of the multiple hot j
shorts occurring, the valve _ can be aligning by removing power from the i
transfer relay and~ manually aligning the affected relay (handle is provided), thereby shifting control to the main control board.
To remove j
power from the transfer relay open breaker 17 on de distribution panel IB (Q1R41L0018-A) in Fire Area 1-043 Room 0343.
Then go to transfer relay cabinet Q1H22L002-A in Fire Area 1-035 room 347 and manually shift transfer l
relay TR4 (Q1E21LCV01158-A) restoring control to the main control board to allow the operator to align charging pump suction to the RWST.
In the interim, charging flow can be maintained with make-up via the normal make-up system.
By letter dated May 31, 1985, the licensee committed to develop detailed procedures specifically for Fire Area 1-020. These procedures will identify the manual operator actions required to regain control of the pressurizer PORVs transfer relays for PORVs, main steam isolation valves and RWST charging pump suction valves and the main steam atmospheric relief valves and establish CST level indication.
These procedures will be fully imple-mented by the end of the Unit 1 seventh refueling outage currently scheduled to commence during the fourth quarter of 1986.
The door / transom assembly, separating rooms 235 (Fire Area 1-023) and 234 (Fire Area 1-020) is provided with a removable transom in order to facili-tate the movement of large electrical equipment.
The door and frame assembly associated with this door meets the UL fire test criteria and they bear a Class A UL label.
However, since the transom is removable, the subject door / transom assembly cannot be listed as Class A by UL.
The respective transom has been certified by the manufacturer as being const-ructed of materials and in a manner similar to that of a Class A fire door.
Therefore, based on the construction, the installation of these doors, and the configuration of the in-situ combustibles in these fire areas, we have reasonable assurance that a fire involving the in-situ combustibles in any
-of the subject fire areas would not propagate through the transom opening and spread into the adjacent fire area.
The sprinkler system installed in room 234 will serve the purpose of a water curtain 'to prevent the passage of a fire from Fire Area 1-020 to the adjacent fire areas via the non-rated steel hatches.
Sprinkler systems
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.+
e
- 7
^
existing in the hatch area of the fire areas above and below room 234 will crevent the spread of fire from these areas foto Fire Area 1-020.
All other shutdown systems associated with Fire Area 1-020 have redundar,t E-counterparts in other fire areas or are located in plant areas which meet the requirements of 10 CFR 50, Appendix R Section III.G.2.
As a result, there is reasonable assurance that if a fire occurred in any of the rooms asscciated with Fire Area 1-020-, safe shutdown could be achieved and maintained.
2.4 CONCLUSION
Based on our evaluation, we conclude that the licensee's alternative fire protection and shutdown configuration will provide an acceptable level of fire protection to that required by the technical requirements of 10 CFR 50, Appendix R, Section III.G.2 and that no additional fire pfotection is required to satisfy the requ'irements of Section III.G.3.
Therefore, the 1
f licensee's request for exemption for non-rad corridor, auxiliary building elevation 121ft.-0in.(FireArea1-020)shouldbegranted.
3.0 UNIT 2 AUXII.IARY BUILDING - EL. 139 FT. - 0 IN, - FIRE AREA 2-042 (EXEMPTION REQUEST 1-26) 3.1 EXEMPTION REQUESTED The licensee in their exemption requr-t 1-26 requested a.n exemption from the technical requirements of 10 CFP. 50 Appendix R., Section 112.12 to thc extent that it requires one train of redundant safe shutdown cables to be er. closed by a fire barrier having a one-hour fire rHing.
3.2 DISCUSSION Unit 2 Fire Area 2-042 is separated from Unit 1 Fire Area 1-042 by rein-forced concrete walls having a three-hour fire rating, with all piping and electrical penetrations sealed for a three-hour fire rating.
The door separating these two fire areas is a UL listed Class A dogr.
A fire in Unit 2 Fire Area 2-042 cculd potentialiy result in dantage to the electrical circuitry of both Units 1 and 2 train-A diesel generatofs. This condition along with an assumed loss of offsite power (LOSP) for Unit I could cause loss of the following main steam atmospheric relief valves, RCS hot leg temperature instrumentation, and neutron flux monitoring instru-mentation:
EQUIPMENT FUNCTION Q1N11PV3371A-A Nain Steam Atmospheric Relief Valve (S.G.-1A)
Q1N11PV33716-A Main Steam Atmospheric Relier Valve (S.G.-18)
QlN11PV3371C-A Main Steam Atmospheric Relief Valve (S.G.-1C)
.. ~.
8 N1B21TE413 (LOOP-1)
RCS Hot leg Temperature, Indication H1821TE423-(LOOP <2)
RCs Hot Leg Temperature, Indication HIB21TE433(LOOP-3)
RCS Hot Leg Temperature, Indication Q1C55NE0043A-A Post-Accident Neutron Flux Monitor NJC5SNE0031eP1 Source Range Neutron Flux Moniter N1C55NE0032-P2 Source Range Neutron Flux Monitor The combustible materiols in Fire Area 2-042 (Corridors 2319, 2339 and hallway 2345) consists prinarily of cable insulation.
The fire loading associated with Fire Area 2-042 is approximately 32,455 BTU /FT2 The door between room 2346 (Fire Area 2 041) and 2345 (Fire Area 2-042) is provided with a removable transom. The door and transom assembly cannot be certified as UL Class A.
A detection system is provided for all rooms in Fire Area 2-042.
Four portable extinguishers are located in rooms 2319 and 2339.
Two water hose stations are located in rcom 2319. A CO hose reel is presently located in 2
room 2339 and a water hose in room 2345.
An automatic water suppression I
system ccvers the area except for room 2339.
Appropriate barriers are prnvfded for one train of safe shutdown electrical cabling.
The licensee justifies the acceptebility of the exemption on the basis of the existing fire protection, their proposed RG 1.97 modifications and their alternative shutdown actions associated with the Unit 2 Auxiliary Building, elevation 139 f t.-0 in. corridor 2319, corridor 2339 and hallway 2345 (Fire-Area 2-042).
3.3 EVALUATION t
One of the three main steam atmospheric relief valves and its related steam generator are r6quirad to be operable to achieve steam release for cooldown.
Tha atmospheric rallef valves are provided with hand wheels such that the.
valves may be c.enually opened or closed without electrical controls or air supplies.
The operator would establish manual control of the atmospheric relief valves by closing the manual air control valves to isolate the air supply and by opening the manual air vent valve to bleed off air from the diaphragm of the valve actuator.
Both the air control and air vent valves are 1ccated in the vicinity of their associated atmospheric relief valve and would be acsessible despite a fire in area 2-042.
Each RCS loop hot leg temperature instrumentation loop is 90wered from c.hannelized 1.1yerter<1 A.
Inverter-1A is powered froa 600 V-ac MCC 1A or 125 V-dc bus 1A.
A fire in area 2-042 along with an assumed loss of offsite power (LOSP) could result in loss of the 600 V-ac po.ser supply tr inverter 1A; however, inverter IA will continue to operate from 125 V-dc bus IA and will supply pcwer to tne instrument loops for a minimum of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
If af ter two hours powcr is lost, RCS hot leg temperature indication is
J 9'
available from the core exit thermocouples.
Core exit temperature indica -
' tion will not be affected by a fire in area 2-042.
In addition to the alternate dc power supply for a minimum of two hours and core exit tempera.
ture availability, a design change to be installed as a result of RG 1.97 will provide a redundant signal processing and indicating between RCS hot' leg temperature loops N1821TE413 NIB 21TE423, and N1621TE433.
Based upon the RG 1.97 comitment schedule, implementation of the modification is currently planned for the seventh refueling outage presently scheduled to comence during the fourth quarter of 1986.
After implementation of this
)
modification, a fire. in Fire Area 2-042 will not affect the ability to l
monitor one loop of RCS hot leg temperature.
Source range neutron _ flux. monitors NIC55NE0031-P1 and NIC55NE0032-P2 are I
powered from channelized inverters IA and 18.
The post-accident neutron flux monitor Q1C55NE0048A-A is powered from inverter-1F.
Inverters IA, IB, and IF'are all powered from 600 V-ac MCC 1A or 125 V-dc bus-1A.. Therefore, neutron-flux monitoring following potential fire damage in Fire Area 2-042 1
and the resultant loss of 600 V-ac MCC 1A will be available for a minimum of i
two hours.
A RCS sample can be obtained after initiation of the RHR system by using portions of the RCS sampling system and RHR Heat Exchanger No.1 and 2 sample valves Q1P15HV3105-B and Q1P15HV3106-8 for determination of the
-l boron concentration and shutdown margin following a f f re in Fire Area 2-042.
By letter dated May 31, 1985, the licensee comitted to develop detailed procedures specifically for this fire area covering the manual operator L
actions required to regain the control of one main steam atmospheric relief.
valve and to monitor RCS boron concentration. The licensee intends to have l
these procedures fully implemented by the end of the Unit 1 seventh refueling outage currently scheduled to commence during the fourth quarter of 1986.
The door assembly between rooms 2346 (Fire Area 2-041) and 2345 (Fire Area 2-042) is provided with a removable transom to facilitate the movement of large equipment.
The door and frame assembly associated with this door meets the UL fire test criteria and they bear a Class A UL label.
However, since the transom is removable, the subject door / transom assembly cannot be listed as Class A by UL.
The respective transom has been certi-
- fied by the manufacturer as being constructed of materials and in a manner similar to that of. a Class A fire door.
Therefore, based on the construc-tion, the installation cf these doors, and the configuration of the in-situ.
combustibles in these fire areas, we have reasonable assurance that a fire involving the in-situ combustible in any of the subject fire areas would not propaga'.e through the transom opening and spread into the adjacent fire area.
All othe shutdown systems associated with Fire Aten 2-042 have redundant counterpi rts in other fire areas or are located in plant areas which meet the requ rements of 10 CFR 50, Appendix R Section III.G.2.
As a result, there is reasoni. ole assurance that if a fire occurred in any of the rooms
h.
10 associated with fire area 2-042, safe shutdown could be achieved and maintained.
3.4 CONCLUSION
Based on our evaluation, we conclude that the licensee's alternative fire protection and shutdown configuration's will provide an acceptable level of fire protection to that required by the technical requirements of 10 CFR 50,
~
Appendix P,,
Section III.G.2 and that no additional fire protection is required to satisfy the requirements of Section III.G.3.. Therefore, the licensee's request for exemption.for Fire Area 2-042 (corridors 2319, 2339 and hallway 2345) should be granted.
4.0 TRAIN B INSIDE CASLE CHASES, AUXILIARY BUILDING-FIRE AREA 1-009 (EXEMPTION I
REQUEST 1-31) 4.1 EXEMPTION REQUESTED The licensee in their exemption (request 1-31) requested an exemption from the technical requirements of 10 CFR 50, Appendix R, Section III.G.2 to the extent that it requires one train of redundant safe shutdown cables to be Enclosed by a onE-hour fire rated barrier, 4.2 DISCUSSION Fire Area 1-009 consists of cable chase rooms 117 and 246 and are separated from all other plant areas by three-hour fire rated fire barriers const-ructed of reinforced concrete.
All piping and electrical penetrations through Fire Area 1-009 boundary are sealed with silicone foaa or. Nelsen Frame Fittings and the door openings are provided with three hour fire rated doors.
Fire Area 1-009 contains control and power cables for the train-B electrical distribution system.
An analysis of the potential effects of fire induced failures of these cables demonstrates that the plant could experience a total loss of the electrical train-B distribution system. This could result in the following instrument air isolation valves becoming inoperable in the closed position.
These valves isolate the primary air and backup air /N to 2
the pressurizer PORVs.
EQUIPMENT FUNCTION N1P19HV3885-B Instrument Air to Penetration Room
'Q1813HV2228-B Backup Air /N Supply to Pressurizer PORVs 2
Auxiliary feedwater isolation valves Q1N23MOV37648, Q1N23MOV3764C, and Q1N23M0V3764E are redundant to one another from the point of view that they isolate flow in redundant auxiliary feedwater supply lines. Control cables for all three valves are routed through the fire area. The analysis of the l
potential effects of a fire on these control cables shows that spurious i
~ - -
,ne-
--e-ne.a
11 operation of the auxiliary feedwater isolation valves could occur, resulting in auxiliary feedwater flow isolation.
In addition, Fire Area 1-009 contains a control cable for the CCW heat exchanger IB service water discharge valve (Q1P165V3009-B). A fire induced failure resulting in a hot short from adjacent cables in the same raceway, could energize-the solenoid and close the valve. This condition can~ impact safe-shutdown only when CCW heat exchanger IB is aligned and operating as the train-A heat exchanger.
Multiple cable failures can cause the redundant steam generator 1C main steam isolation valves (Q1N115V3369BC-A and Q1N11SV3370BC-A) to become electrically inoperative in.the open position.
A fire causing multiple hot shorts (shorts between control cables sharing the same raceway) could cause the train-8 pressurizer PORV, (01B31PCV04448-B) and/or the train-B reactor vessel head vent valves (Q1813SV2213B-B and Q18135V22146-B) to open.
The pressurizer PORV blocking valve (Q1B13MOV8000B-B) could become electrically inoperative in the open position.
The corr.bustible materials in Fire Area 1-009 primarily censist of cable insulation. The following fire loading is associated with the rooms bounded by Fire Area 1-009:
Room Kumber~
Combustible Fire load Maximum And Title Material (BTU / Fir)
Fire Severtiy 117 Cable Cable 2,921,199
.Less Than Chase Insulation 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 246 Cable Cable 180,180 Less Than Chase Insulation 21 hours2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br /> A smoke detection system and automatic water suppression system are provided' e
throughout the chase.
In addition, water boses and portable extinguishers located in room 185 (Fire area 1-6) and room 319 (Fire area 1-42) are available for use in the area by the fire brigade.
The licensee justifies the acceptability of this exemption request on the basis of the existing fire protection configuration, their alternative shutdown actions and the proposed fire protection modifications associated with cable chases 117 and 246 (Fire Area 1-009).
4.3 EVALUATION A fire in Fire Area 1-009 could affect pressurizer PORVs Q1831PCV0445A-A and Q1831PCV044B-B which provides a means of achieving RCS depressurization.
. Valves N1P19HV3885-B and -Q1813HV2228-B will fail in the closed position on the loss of train-B power Distribution.
.~. --.
s 12 l
This will isolate the instrument air supply to the pressurizer PORVs Q1631PCV0445A-A and Q1831PCV0444B-B.
PORV Q1831PCV0448-B will also be inoperable due to loss of the train-B DC power supply. However, the train-A DC supply. to PORV Q1B31PCV0444A-A is not affected due to.a fire in this Since only one of the PORVs is required for RCS depressurization, and area.
RCS depressurization is a long-term requirement, the operator has adequate time to take manual action to restore the instrument air by handwheel operation of valve N1P19HV3885-B located in room 189 (Fire Area 1-006).
Once air is restored, PORV Q1831PCV0445A-A will be operable to achieve RCS depressurization.
In order to preclude auxiliary feedwater flow isolation, due to a fire in Fire Area 1-009, the control cables associated with at least one of the euxiliary feedwater isolation valves will be protected by an equivalent one-hour fire barrier enclosure which will consist of two 1-inch layers of Kaowool blanket with an overall layer of Zetex fabric.
In addition, in order to prelude the loss of CCW, when the IB heat exchanger is aligned &nd operating as the train-A heat exchanger, plant procedures will be written' to maintain valve Q1P16SV3009-B in the open position by removing power.
In the evm1t that the steam generator 1C main steam isolation valves fail to isolate due to fire induced failures, the main turbine stop valves would provide isolation.
In the event that the multiple hot shorts caused by a fire in Fire Area 1-009 occur, the condition can be mitigated by removing 125 V-dc power from cables in the shared raceway.
This can be accomplished by opening the breaker on 125 V-dc switchgear bus 1B (Q1R428001B-B) for 125 V-dc distribu-tion panels ID, 1E, and IF.
In the interim, alternate charging flow is available to keep up with the spurious letdown.
Plant' procedures will be written to incorporate the above actions for a fire in this area.
The licensee, by letter dated May 31, 1985, committed to develop detailed procedures specifically for this fire area covering the manual operator actions required to regain control of the pressurizer PORVs and assure CCW to the IB heat exchanger when it is aligned and operating as the train-A heat exchange. In addition, the licensee committed to enclose, in Fire Area 1-009, one train of control cables associated with one of the auxiliary feedwater isolation valves in a one-hour equivalent fire barrier.
The licensee intends to have the fire barrier installed and have the procedures fully impleacnted by the end cf the Unit 1 seventh refueling outage currently scheduled to commence during the fourth quarter.of 1986.
All other shutdown systems associated with Fire Area 1-009 have redundant counterparts in other fire areas or are located in plant areas which meet the requirements of 10 CFR 50, Appendix R, Section III.G.2.
As a result, there is reasonable assurance that if a fire occurred in any of the rooms associated with Fire Area 1-009, safe shutdown could be achieved and maintained.
t
1 13
4.4 CONCLUSION
Based on our evaluation, we conclude that the licensee's alternative fire protection configurations and their proposed modifications will provide an acceptable level of fire protection to that required by the technical Therefore, the requirements of 10 CFR 50, Appendix R, Section III.G.2.
licensee's request for exemption for Fire Area 1-009 should be granted.
UNIT 1 AUXILIARY BUILDING, EL. 83 FT. - 0 IN., 100 FT. -0 IN., AND 121 FT. -
5.0
- 0. IN. - FIRE AREA 1-001 (EXEMPTION 1-36) 5.1 EXEMPTION REQUESTED The licensee in their exemption (request 1-36) requested an exemption from the technical requirements of 10 CFR 50, Appendix R, Section III.G.2 to the extent that one train'of redundant safe shutdown cables be enclosed by the one-hour fire barrier and that automatic fire suppression be installed throughout the fire area.
5.2 DISCUSSION Fire Area 1-001 consists of th'e following rooms:
EL 83 Ft - 0 In.
Room 101 Waste Decay Tank Room Room 102 Valve Compartment Room Room 103 Corridor Room 104 Passageway to Unit 2 Room 105 Catalytic H Recombiner A Room Room 106 Catalytic H Recombiner B Room Room 107 Storage Roo Room 108 Waste Monitor Tank Room Room 109 Waste Monitor Tank Pump Room Room 110 Monitor Control Panel Rcom Room 111
. Containment Spray Pump Room A Room 112 Access to Tendon Access G:liery Room 113 Valve Encapsulation Room 114 Pipe Chase Room 115 Hallway Room 118 Floor Drain Tank Room Room 119 Waste Holdup Tank Room Room 120 Corridor Room 121 Floor Drain Tank Pump Room Room 122 Waste Evaporator Feed Pump Room Room 123 Pipe Chase Room 124 Valve Encapsulation Room 125 Containment Spray Pump Room B Room 126 Pipe Chase Room 127 Pipe Chase
14 Roam 128
'RHR Heat Exchanger Room Room 129 RHR Lowe Head Pump Room B Room 130 Pipe Chase Room 131 RHR Low Heat Pump Room A El 100 Ft - 0 In.
Room 183 Tendon Access Gallery Entrance Room 184 Piping Penetration Room
' Room 169 Pipe and Duct Chase Room 196 Tendon Access Gallery El 121 Ft - 0 In.
Room'223 Piping' Penetration Room The Floors and walls forming the area boundary are of reinforced concrete.
l ceiling of room.223 has tendon access openings to room 334 (Fire Area 1-34).
l Steel plates with three-hour rated coatings and which are ~ topped by remov-able concrete slabs have been installed over the tendon access openings.
There is a non-rated steel hatch cover' over the hatchway _between rooms 103 and 163 (Fire Area 1-004).
An airtight. UL Class B door is installed between room 223 and stairway No. 2.
The door between rooms 184 and 162 (Fire Area 1-4) is an airtight UL l
Non-airtight Class B doors are installed between rooms 110 Class A door.
and 115 and stairway No. 2.
Penetrations through the area boundary are sealed with silicone foam.
i Three-hour rated fire dampers are installed between rooms 169 and 163 (Fire Area 1-4).
A hatchway in the ceiling of room 103 communicates wi.th room 163 (Fire Area l
1-004). A non-rated steel plate covers the hatchway.
Control cables for instrument air isolation valves Q1P19HV3611 and 1
A fire induced failure in the Q1P19HV3825 are routed through area 1-001.
The-control cable for either valve could cause the valve to' fail closed.
' subsequent loss of instrument air would cause the normal charging line l'
isolation valve Q1E21HV8146 and the alternate charging line isolation valve l'
Q1E21HV8147 to fail opened.
It may be necessary to close these valves during the course of shutdown to isolate charging flow.
supply valve The -control cable for the pressurizer PORV backup air /N,duced failure in A fire in Q1813HV2228-B is also routed through area 1-001.
the control cable could cause the valve to fail close.s If the pressurizer supply valve (Q1813HV2228-B) and either instrument air PORV backup air /N isolation valves (Q1B13HV3611 or Q1P19HV3825) fail closed, the pressurizer 2
PORVs will be inoperable in the closed position.
Operation of the pressu-rizer PORVS may be' required to achieve depressurization-of the RCS.
i t
i 4
-m.
-ry e
w
..w.
,.y,.
,--..,--y c.
-r-
--r----
-,-+-wq, -,,
w vv
15 Fire induced failures (hot shorts) within the control cables for the for the power transfer relay cabinet Q1H22L002-A could cause control operated relief and blocking valves and the reactor head vent valves to shif t from their normal main control board alignment to the remote hot shutdown panel.
Subsequent fire induced failures (hot shorts from adjacent control cables in the shared raceway) of the control cables for Q1B31PCV0445A-A, pressurizer power operated relief valve, and Q1813SV2213A-A and Q1813SV2214A-A, reactor The head vent valves, could result ir. the valves being energized to cpen.
power relief blocking valve (MOV) could become electrically inoperative in the opened position.
Control cables associated with the three redundant atmospheric relief valves An analysis of potential effects of a are routed through Fire Area 1-001.
fire upon these cables has shown that the subject valves could become inoperable in the closed p"4f tion.
Train-A cables for the following equipment are routed through room 183 in Fire Area 1-001:
Train-A Charging Pump Room Cooler - Q1E16M001A-A Swing Charging Pump _Q1E21M001B-AB Swing Charging Pump Room Cooler - Q1E16M0018-AB Train-A _RWST lsolation Valve - Q1E21LCV01158-A Train-B cables for the following equipment are routed through room 223 in Fire Area 1-001:
Train-B Charging Pump Room Cooler
-Q1E16M001C-B Swing Charging Pump Room Cooler - Q1E16M0018-AB_ (power cable to MCC)
The cables associated with these two groups of equipment are redundant to one another.
The combustible material in Fire Area 1-001 consist of cable insulation, The following lube oil, charcoal filter media, and plastic panel parts.
fire loadings are associated with the room bounded by the Fire. Area 1-001:
Room Number
- Combustible Fire Load Maximum And Title Material (BTU /FT2)
Fire Severtiy 101-Waste Gas Cable Insulation 1,252 Less Than 30 minutes Decay Tank Room, 102-Valve compartment room and 103-corridor
16 105-Catalytic Cable Insulation 7,634 Less~Than H2 Recombiner "A" and Plastic Panel 30 minutes Room, and 106-Parts Catalytic H2 Recombiner "B" Room 107-Storage Cable Insulation 22, 561 Less Than Room, and and Charcoal 30 minutes 104-Passageway Filter Media To Unit 2 109-Waste Monitor Cable Insulation, 5,742 Less Than Tank Pump Room -
Lube Oil, and 30 minutes 110-Monitor Plastic Panel Control Pannel Parts Room 108 Waste Monitor Cable Insulation, 19,457 Less Than l
Tank Room and Charcoal Filter 30 minutes 169 Duct and Pipe None 0
0 i
Chase 118 Floor Drain Cable Insulation 831 Less Than 30 minutes Tank Room 119 Waste Holdup Cable Insulation 2,711 Less T'han l
30 minutes Tank Room 120 Corridor Cable Insulation 5,540 Less Than 30 minutes l
121 Floor Drain Cable Insulation,-
21,402 Less Than Tank Pump Room and Lube oil 30 minutes 122 Waste Evaporator Cable Insulation, 21,402 Less Than Feed Pump Room and Lube oil 30 minutes 127 Pipe Chase None 0
0 128 RHR Heat Cable Insulation 2,607 Less Than 30 minutes Exchar.ger Room 129 RHR Low Head Cable Insulation 3,837 Less Than 30 minutes Pump Room B 130 Pipe Chase None 0
0 131 RHR Low Head Cable Insulation 6,332 Less Than 30 minutes Room A
17 126 Pipe Chase None 0
0 124 Valve Encapsula-Cable Insulation 6,329 Less Than 30 minutes tion 125 Containment Cable Insulation, 3,569 Less Than Spray Pump Room B and Lube oil 30 minutes 114 Pipe Chase Cable Insulation 3,885 Less Than 30 minutes 111 Containment Cable Insulation, 3,469 Less Than 30 minutes Spray Pump Room A 113 Valve Encapsula-Cable Insulation 3,333 Less Than 30 minutes tion l
115 Hallway Cable Insulation 1,655 Less Than 30 minutes 112 Access to Tendon Cable Insulation 175 Less Than 30 minutes l
Access Gallery 196 Access to Tendon Cable Insulation 175 Les. Than 30 i b stes Access Gallery 123 Pipe Chase None 0
0 183 Tendon Access Cable Insulation 6,405 Less Than 30 minutes Gallery Entrance and 184 Piping Penetration Room 223 Piping Penetration Cable Insulation, 40,625 Less Than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> room A detection system covers the majority of the area.
Exceptions to this coverage 112, 114, 115, 123, 126, 127, 130, 169, and 196. The western half of are rooms the piping penetration room on el 121 ft - 0 in. and the floor area of room 184 beneath the covered tendon ~ hatchway into room 223 above are the only parts of Fire Area 1-001 covered by automatic sprinkler system.
Portable extinguishers, smoke removal equipment, and water hose cabinets ~are located throughout the fire area for use by the fire brigade.
The licensee justifies the acceptability of this exemption request on the basis fire protection features, the proposed sprinkler of the existing plant modifications and their alternative shutdown actions associated with Fire Area 1-001.
e i
18 5.3 EVALUATION Instrument air isolation valves Q1P19HV3611 and Q1P19HV3825 located in rooms 184 (Fire-Ar'ea 1-001) and 189 (Fire Area 1-006) respectively, are equipped with a handwheel to facilitate manual operation.
In the event that one or
'both valves - fail closed, an operator can manually open them.
This action-will restore instrument air to the charging line isolation valves and n
pressurizer PORVs.
Consequently, action would not have to be taken on the.
4 y
' pressurizer PORV backup air /N, supply valve Q1813HV2228-B.
In the unlikely event of the multiple hot shorts occurring in control cables in the transfer relay associated with the control of the pressurizer PORVs and block valves, this condition can be mitigated by removing power from the transfer relays and manually aligning the affected relay (handle is To remove provided), thereby shifting control to the main control board.
power from the transfer relay open breaker 17 on de distribution panel IB (Q1R41L001B-A) in Fire Area 1-043 Room 0343.
Then go to transfer relay cabinet TRC-1 in Fire Area 1-035 room 347 and manually shift transfer relays TR1 (Q18135V2213A-A), TR2 (Q1B13SV2214A-A), TR3 (Q1813PCV0445A-A), and TR5 (Q1B13MOV8000A-A) restoring control to the main control board to allow the operator to mitigate the letdown.
One of the three main steam atmospheric relief valves and its related steam generator are required to be operable to achieve steam release for cooldown.
The atmospheric relief valves are provided with hand wheels such that the valves may be manually opened or closed without electrical controls or air The operator would establish manual control of the atmospheric supplies.
relief valves by closing the manual air control valves to isolate the air supply and by opening the manual air vent valve to bleed off air from the diaphragm of the valve actuator.
Both the air control and air vent valves are located in the vicinity of their associated atmospheric relief valve and would be accessible despite a f. ire in area 1-001. The capability to control' steam generator pressure and reactor coolant system temnerature with the use of the manually controlled atmospheric relief valves was demonstrated during the Unit 2 natural circulation and cooldown startup testing. Consequently, a fire in area 1-001 would _not prevent the operation of at.least one l
redundant atmospheric relief valve.
Although both rooms 183 and 223 are in Fire Area 1-001, there is a high degree:of separation between them.
Room 183 is located on el 100 ft. - 0 in. and room 223 is located on el 121 ft. - 0 in.
The routing of the charging pump room cooler cables is such that the redundant groups are separated by 10 ft. horizontally in addition to the vertical separation between elevations.
The slab between rooms 183 and 223 is 2 ft. thick and The penetrated by only two 8 in, and one 12 in. mechanical penetrations.
part of room 223 through which the train-B charging pump room cooler and the swing charging pump room cooler cables are routed is covered by an automatic sprinkler system and both rooms are protected by automatic smoke detection system.
1 i;
I.
.~
~,-n-,,
,~-+----...----.----,.~,,--,...,.e-,-.
... ~ -,,- -, +--, -
,..n n
,,--,-----,w------
-~n
e' 0,
19 Therefore, the separation afforded between rooms 183 sand 223 will preclude a fire from damaging both redundant trains of cabling associated with the charging pump rcom coolers.
The licensee committed to modify the sprinkler system installed.in the hatchway area of room 163. Upon completion of the sprinkler system modifi-cations, the sprinkler system in room 163 upon activation will form a water curtain which will prevent the spread of fire to other plant areas via the hatchway.
By letter dated May 31, 1985, the licensee committed to develop detailed procedures specifically for this fire area covering the manual operator actions required to regain the control of the charging line isolation valves, pressurizer PORVs and block valves and the main steam atmospheric relief valves. The licensee intends to have the sprinkler modifications and the procedures fully implemented by the end of the Unit I refueling outage currently scheduled to commence during the fourth quarter of 1986.
All other shutdown systems associated with Fire Area 1-001 have redundant counterparts in other fire areas or are located in plant areas which meet the requirements of 10 CFR 50, Appendix R, Section III.G.2.
As a result, there is reasonable assurance that if a fire occurred in any of the rooms associated with Fire Area 1-001, safe shutdown could be achieved and maintained.
5.4 CONCLUSION
Based on our evaluation, we conclude that the licensee's alternative fire protection configurations will provide an acceptable level of fire protec-tion to that required by the technical requirements of 10 CFR 50, Appendix R, Section III.G.2 and that no additional fire protection is required to satisfy the requirements of Section III.G.3.
Therefore, the licensee's request for exemption for Fire Area 1-001 should be granted.
6.0 UNIT 1 AUXILIARY BUILDING, EL 100 FT. - 0 IN.,127 FT. - 0 IN.,139 FT. - 0 IN.,155 FT. - 0 IN., AND 175 FT. - 0 IN., FIRE AREA 1-006 (EXEMPTION REQUEST 1-38).
6.1 EXEMPTION REQUESTED The licensee in their exemption request 1-38 requested an exemption from the technical requirements of 10 CFR 50, Appendix R, Section III.G.2 to the extent that one train of redundant safe shutdown cables and equipment be enclosed by a one-hour fire barrier and fire suppression be installed throughout the fire area.
6.2 DISCUSSION Fire Area 1-006 consists of the following rooms:
El 100 Ft. - 0 In.
~
20 c
Room 128 RHR Heat Exchanger Room Room 129 RHR Lowe Head Pump Room B Room 130 Pipe Chase Room 131 RHR Low Heat Pump Room A El 100 Ft - 0 In.
Room 183 Tenden Access-Gallery Entrance Room 184 -
Piping Penetration Room Room 169
. Pipe and Duct Chase Room 196 Tendon Access Gallery 1
El 121 Ft - 0 In.
Room 223-Piping Penetration Room Floors and walls forming the area boundary are of reinforced concrete. The ceiling of room 223 has tendon access openings to room 334 (Fire Area 1-34).
Steel plates with three-hour rated coatings and which are topped by remov-able concrete slabs have been installed over the tendon access openings.
There is a non-rated steel' hatch cover over the hatchway between rooms 103 and 163 (Fire-Area 1-004).
An airtight, UL Class.B door is installed between room 223 and stairway
~
No. 2.
The door between rooms 184 and 162 (Fire Area 1-4) is an airtight UL Class A door.
Non-airtight Class B doors are installed' between rooms 110 and 115 and stairway No. 2.
Penetrations through the area boundary are sealed with silicone foam.
Three-hour rated fire dampers are installed between rooms 169 and 163 (Fire Area 1-4).
A hatchway in the ceiling of room 103 communicates with room 163 (Fire Area 1-004). A non-rated steel plate covers the hatchway.
Control cables for instrument air isolation valves Q1P19HV3611 and Q1P19HV3825 are routed through area 1-001.
A fire induced failure in the control cable for either valve could cause the valve to fail closed.
The subsequent loss of instrument air would cause-the normal charging line isolation valve Q1E21HV8146 and the alternate charging line isolation valve Q1E21HV8147 to fail opened.
It may be necessary to close these valves during the course of shutdown to isolate charging flow.
The control cable for the pressurizer PORV backup air /N, supply valve Q1813HV2228-B is also routed through area 1-001. A fire induced failure in the control cable could cause the valve to fail close.
If the pressurizer i
PORV backup air /N, supply valve (Q1813HV2228-B) and either instrument air isolation valves (Q1813HV3611 or Q1P19HV3825) fail closed, the pressurizer
]
PORVs will be inoperable in the closed position.
Operation of the pressu-rizer PORVS may be required to achieve depressurization of the RCS.
f
o 21 Fire induced failures (hot shorts) within. the control cables for the transfer relay cabinet Q1H22L002-A could cause control for the power operated relief and blocking valves and the reactor head vent valves to shift from their normal main control board alignment to the remote hot shutdown panel.
Subsequent fire induced failures (hot shorts from adjacent control cables in the shared raceway) of the control cables for Q1831PCV0445A-A, pressurizer power operated relief valve, and Q1B13SV2213A-A and Q1813SV2214A-A, reactor head vent valves, could result in the valves being energized to open. The power relief blocking valve (MOV) could become electrically inoperative in the opened position.
Control cables associated with the three redundant atmospheric relief valves are routed through Fire Area 1-001.
An analysis of potential effects of a fire upon these cables has shown that the subject valves could become inoperable in the closed position.
Train-A cables for the following equipment are routed through room 183 in l
Fire Area 1-001:
1
)
Train-A Charging Pump Room Cooler - Q1E16M001A-A Swing Charging Pump -_Q1E21M0018-AB Swing Charging Pump Room Cooler - Q1E16M0018-AB Train-A RWST Isolation Valve - Q1E21LCV01158-A Train-B cables for the following equipment are routed through room 223 in Fire Area 1-001:
Train-B Charging Pump Room Cooler.- Q1E16M001C-B Swing Charging Pump Room Cooler - Q1E16M001B-AB (power cable to MCC)
The cables associated with these two groups of equipment are redundant to one another.
The combustible material in Fire Area 1-001 consist of cable insulation, lube oil, charcoal filter media, and plastic panel parts.
The following fire loadings are associated with the room bounded by the Fire Area 1-001:
Room Number Combustible Fire Load Maximum And Title Material (BTU /FT2)
Fire Severtiy 101-Waste Gas Cable Insulation 1,252 Less Than Decay Tank 30 minutes Room, 102-Valve compartment room and 103-corridor
[...
s.
22 105-Catalytic Cable Insulation 7,634 Less Than H2 Recombiner "A" and Plastic Panel 30 minutes Room, and 106-Parts Catalytic H2 Recombiner "B" Room 107-Storage Cable Insulation 22, 561 Less Than
. Room, and and Charcoal 30 minutes 104-Passageway Filter Media To Unit 2 109-Waste Monitor Cable Insulation, 5,742 Less Than Tank Pump Room -
Lube Oil, and 30 minutes 110-Monitor Plastic Panel Control Pannel-Parts Room 108 Waste Monitor Cable Insulation, 19,457 Less Than Tank Room and Charcoal Filter 30 minutes 169 Duct and Pipe None 0
0 Chase 118 Floor-Drain Cable Insulation 831 Less Than Tank Room 30 minutes 119 Waste Holdup Cable Insulation 2,711 Less Than Tank Room 30 minutes 120 Corridor Cable Insulation 5,540 Less Than 30 minutes 121 Floc-Drain Cable Insulation, 21,402 Less Than Tank Pump Room and Lube oil 30 minutes 122 Waste Evaporator Cable Insulation, 21,402 Less Than Feed Pump Room-and Lube oil 30 minutes 127 Pipe Chase None 0
0 128 RHR Heat Cable Insulation 2,607 Less Than Exchanger Room 30 minutes 129 RHR Low Head Cable Insulation 3,837 Less Than Pump Room B 30 minutes 130 Pipe Chase None 0
0 131 RHR Low Head Cable Insulation 6.332 Less Than Room A 30 minutes
r 23 126 Pipe Chase None 0
0 124 Valve Encapsula-Cable Insulation 6,329 Less Than tion 30 minutes 125 Containment Cable Insulation, 3,569 Less Than Spray Pump Room B and Lube oil 30 minutes 114 Pipe Chase Cable Insulation 3,885 Less Than 30 minutes 111 Containment Cable Insulation, 3,469 Less Than Spray Pump Room A 30 minutes 113 Valve Encapsula-Cable Insulation 3,333 Less Than tion 30 minutes 115 Hallway Cable Insulation 1,655 Less Than 30 minutes 112 Access to Tendon Cable Insulation 175 Less Than Access Gallery 30 minutes 196 Access to Tendon Cable Insulation 175 Less Than Access Gallery 30 minutes 123 Pipe Chase None 0
0 183 Tendon Access.
Cable Insulation 6,405 Less Than Gallery Entrance and 30 minutes 184 Piping Penetration Room 223 Piping Penetration Cable Insulation, 40,625 Less Than room I hour A detection system covers the majority of the area. Exceptions-to this coverage are rooms 112, 114, 115, 123, 126, 127, 130, 169, and 196. The western half of the piping penetration-room on el 121 ft - 0 in. and the floor area of room 184 beneath the covered tendon hatchway into room 223 above are the only parts of Fire Area 1-001 covered by automatic sprinkler system.
Portable extinguishers, smoke removal equipment, and water hose cabinets are located throughout the fire area for use by the fire brigade.
The licensee justifies the acceptability of this exemption request on the basis of the existing plant fire protection features, the proposed sprinkler modifications and their alternative shutdown actions associated with Fire Area 1-001.
. s 24
^
5.3 EVALUATION i
Instrument air isolation valves Q1P19HV3611 and Q1P19HV3825 located in rooms
- 184 (Fire Area 1-001) and 189 (Fire Area 1-006) respectively, are equipped with a handwheel to facilitate manual operation.
In the event that one or -
both valves fail closed, an operator can manually open them.
This. action will restore instrument air to the charging line isolation valves and
+
pressurizer PORVs.
Consequently, action would not have to be taken on the pressurizer PORV backup air /N, supply valve Q1813HV2228-B.
In the unlikely event of the multiple hot shorts occurring in control cables in the transfer relay associated with the control of the pressurizer PORVs
'and block valves, this condition can be mitigated by removing power from the
!~
transfer relays and manually aligning the affected relay (handle is-l
- provided), thereby shifting control to the main control board.
To remove power' from the transfer relay open breaker 17 on dc distribution panel IB (Q1R41L001B-A) in Fire Area 1-043 Room 0343.
Then go to transfer relay cabinet'TRC-1 in Fire Area 1-035 room 347 and manually shift transfer relays TR1 (Q1B135V2213A-A), TR2 (Q1B13SV2214A-A), TR3 (Q1B13PCV0445A-A), and TR5 (Q1B13MOV8000A-A) restoring control to the main control board to allow the operator to mitigate the letdown.
One of the three main stecm atmospheric relief valves and its related steam generator are required to_ be operable to achieve steam release for cooldown.
The atmospheric relief valves are provided with hand wheels such that the valves may be manually opened or closed without electrical controls or air supplies.
The operator would establish manual control of the atmospheric j
. relief valves by closing the manual air control valves to isolate the air i
supply and by opening the manual air vent valve to bleed off air from the diaphragm of the valve actuator.
Both the air control and air vent valves 4
are located in the vicinity of their associated atmospheric relief valve and i
would be accessible despite a fire in area 1-001. The capability to control steam generator pressure and reactor coolant system temperature with the use 1
of'the manually controlled atmospheric relief valves was demonstrated during l
the Unit 2 natural circulation and cooldown startup testing. Consequently, a fire in area 1-001 would not prevent the operation of at least one redundant atmospheric relief valve.
Although both ronms 183 and 223 are in Fire Area 1-001, there is a high degree of separation between them.
Room 183 is located on el 100 ft. - 0 in.' and room 223 is located on el 121 ft. - 0 in.
The routing of the charging pump room cooler cables is such that the redundant groups are separated by 10 ft. horizontally in addition to the vertical separation between elevations.
The slab between rooms 183 and 223 is 2 ft. thick and penetrated by only two 8 in, and one 12 in, mechanical penetrations.
The 1
part of room 223 through which the train-B charging pump room cooler and the swing charging pump room cooler cables are routed is covered by an automatic i
d both' rooms are protected by automatic smoke detection j
sprinkler syster i
system.
}
1 2
}
e
,.---.n-
-.....-......-um
.y
--e.,
---~
.e
_,.._w_w,.-,w~,-.-----%
-__m-n,,.-,,i-ev~rw'"'-
'*-w-w-++w-'-
e*----9-'
- - * ~ - * ~ '
25 Therefore, the separation afforded between rooms 183 sand 223 will preclude a fire from damaging both redundant trains of cabling associated with the charging pump room coolers.
The licensee _ committed to modify the sprinkler system installed in the hatchway area of room 163.
Upon completion of the sprinkler system modifi-cations, the sprinkler system in room 163 upon activation will form a water curtain which will prevent the spread of fire to other plant areas via the hatchway.
By letter dated May 31, 1985, the licensee committed to develop detailed procedures specifically for this fire ' area covering the manual operator actions required to regain the control lof the charging line isolation valves, pressurizer PORVs and block valves and the main steam atmospheric relief valves. The licensee intends to have the sprinkler modifications and the procedures fully implemented by the end of the Unit I refueling outage currently scheduled to commence during the fourth quarter of 1986.
All other shutdown systems associated with Fire Area 1-001 have redundant counterparts in other fire areas or are located in plant areas which meet the requirements of 10 CFR 50, Appendix R, Section III.G.2.
As a result, there is reasonable assurance that if a fire occurred in any of the rooms associ',ted with Fire Area 1-001, safe shutdown could be achieved and maintained.
5.4 CONCLUSION
Based on our evaluation, we conclude that the licensee's alternative fire protection configurations will provide an acceptable level of fire protec-l tion to that required by the technical requirements of 10 CFR 50, Appendix R, Section III.G.2 and that no additional fire protection is required to satisfy the requirements of Section III.G.3.
Therefore, the licensee's request for exemption for Fire Area 1-001 shduld be granted.
6.0 UNIT 1 AUXILIARY BUILDING, EL 100 FT. - 0 IN., 127 FT. - 0 IN., 139 FT. - 0 IN.,155 FT. - 0 IN., AND 175 FT. - 0 IN., FIRE AREA 1-006 (EXEMPTION REQUEST 1-38).
6.1 EXEMPTION REQUESTED The licensee in their exemption request 1-38 requested an exemption from the technical requirements of 10 CFR 50, Appendix R, Section III.G.2 to the extent that one train of redundant safe shutdown cabics and equipment be enclosed by a one-hour fire barrier and fire suppression be installed throughout the fire area.
6.2 DISCUSSION Fire-Area 1-006 consists of the following rooms:
El 100 ft. - 0 In.
E 26 Room 167
-Combustible Storage Room Room 185 Component Cooling Water Heat Exchanger Room i
Room 189 Plant Heating Equipment Room Room 190 Motor Control Center IE Room Room 191 Auxiliary Feedwater Pump Room (Train A)
Room 192 Auxiliary Feedwater Pump Room (Train B) l Room 193 Auxiliary Feedwater Pump Room (Turbine Driven)
Room 194 Lower Equipment Room i
Room 195 Access Hatch Area El 127 Ft. - 0 In.
Room 241 Main Steam and Feedwater Valve Room Room 242 Pipe Chase Room 243 Pipe Chase The floors, walls, and ceilings of Fire Area 006 that form the boundary between area 1-006 and adjacent fire areas are of reinforced concrete and rated for three-hours with the exception of a hatchway with a steel plate cover between rooms 185 (area 1-006) and 234 (area 1-020).
All electrical and piping penetrations between adjacent fire areas are sealed for a three-hour rating.
All doors between adjacent fire areas are UL Class A or B rated i
with two exceptions.
There are non-rated doors between stairway No.1 and room 190 and between stairway No. I and room 241.
These doors are water-tight and pressure tight,-respectively.
The two redundant motor driven auxiliary feedwater pumps and the turbine driven auxiliary feedwater (AFW) pump are located within Fire Area 1-006.
Cables for all three pumps are routed through the area.
Protection and/or separation of component cooling water system cables and equipment complies ~with 10 CFR 50, Appendix R section III.G.2.c throughout Fire Area 1-006 with _the exception of the component cooling water heat exchanger room (185). This room, contains all three component cooling water (CCW) pumps.
The CCW pumps are located on 21-ft. centers and fire barriers are provided for the pump control and power cables.
However, there are intervening combustibles consisting primarily of cable insulation between the pumps and the pumps are not provided with fire barriers.
In addition, the service water inlet valves to redundant component cooling water heat exchangers (M0V3130A-B, M0V31308-B, and M0V3130C-A) and service water discharge valves from redundant component cooling water heat exchangers (SV009A-B, SV0098-B, and SV009C-A) are located less than 20 ft. apart.
Although the cables for the train-3 valves are provided with fire barriers and automatic suppression, the valves themselves are not provided with fire barriers.
Cables for the redundant main steam isolation valves traverse rooms 185, 189,190, and 194 on el 100 ft. - 0 in. unprotected by fire barrier and in close proximity to one another.
In the main steam and feedwater valve room (241) on el 127 ft. - 0 in., the redundant main steam isolation valves are
s s
27 back-to-back in each of the three main steam lines and the associated valve control cables are separated by less than 20 ft.
Control cables for the redundant main steam atmospheric relief valves (MSARV) traverse rooms 185,189,190, and 194 on el 100 ft. - 0 in.. These cables are separated by less than 20 ft. in the rooms mentioned above. One train of the redundant MSARV control cables'is not protected by a fire barrier on el 100 ft. - 0 in..The local control station and related control cabling for all three MSARVs are located together in room 189.
Fire barriers are not provided -to protect the local control stations or control
-cabling.
On el 127 f t. - 0 in., the three valves and their control cabling are located in one room -(241).
Adjacent valves are within 20 ft. of one another.
Fire barriers are not provided to protect the valves or control cabling, and fire suppression is not-provided in room 241.
A hatchway located in room 185 has a non-rated steel plate cover.
The hatchway communicates with room 234 (Fire Area 1-020).
The combustible materials in Fire Area 1-006 consists of cable insulation, lube' oil, plastic panel parts, and miscellaneous combustibles.
The following fire loadings are associated with the rooms bounded by Fire Area 1-006:
Room Number Combustible Fire Load Maximum Fire and Title Material (BTU /FTz)
Severity 167 Cable insulation, 5,323 Less than 30 min.
Combustible and Miscellaneous Storage Room Material 185 Cable insulation, 34,774 Less than 30 min.
Component 5-kV disconnect Cooling Water switch, and Lube Oil Heat Exchanger Room 191 Cable insulation, 20,107 Less than 30 min.
Auxiliary and Lube Oil Feedwater Pump Room 192 Cable insulation, 26,411 Less than 30 min.
Auxiliary and Lube Oil Feedwater Pump Room 189 Cable insulation, 27,356 Less than 30 min.
Plant Heating and Lube Oil, and Equipment Plastic Panel Parts Room, 190 Motor Control
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28 Center IE
~ Room 193 Auxiliary.
Feedwater Pump Room, 194 Equipment Room and 195 Access Hatch Room 241 Cable insulation 3,869 Less than 30 min..
Main ~ Steam.
and Feedwater
. Valve Room
-242 Cable insulation 1,287 Less than 30 min.
Pipe Chase 243 Cable insulation 1,670 Less than 30 min.
Pipe Chase.
A detection system covers the entire area except for rooms 195, 242, and 243.
Room 167 has a wet-pipe sprinkler system which activates a local fire alarm bell and trouble horn that annunciates'in the control room. Automatic water suppression systems are provided for rooms 189,190,194, and 185.
Heat detectors are provided in the 5-kV disconnect switch in room 185 that alarm both locally and "in the control room.
The 5-kV disconnect switch cabinets are provided with a total-flooding C0 system which is activated by the heat detectors.
Twowaterhose-stations,bocatedinrooms185and189, are provided.. A portable extinguisher is located in room 185 outside room 167.
'A hose station in room 234 (area 1-20) will be available for use in
-this area. -Automatic water suppression systems are provided for rooms 185, 189, 190, an( 194.
The licensee justifies the acceptability of this exemption request on the basis of the existing plant fire protection features, the proposed sprinkler modifications and their alternative' shutdown actions associated with Fire Area 1-006.
6.3 EVALUATION A fire barrier has been provided over the raceways carrying cables for the
. train-B-motor driven auxiliary feedwater pump throughout Fire Area 1-006 with the exception of the train-B pump room (192). The barrier consists of two 1-in. layers of Kaowool blanket wraps with ene overall layer of Zetex woven fabric.
The subject raceways are BDDA09, BDDA06, BDDA03, BDDA0A, BEE 016, and BFDDOM.
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29 An analysis was performed to demonstrate that a fire limited to one of the AFW pump rooms would not defeat the auxiliary feedwater system. A fire in any one of the pump rooms would cause the loss of one AFW pump and AFW flow to one steam generator.
The AFW pump rooms are highly segregated watertight rooms with 2-feet thick reinforced concrete walls and watertight doors that are maintained closed.
Lubricating oil and cable insulation are the only combustibles present in the pump rooms.
Leaking oil would be contained within the individual rooms or would drain into the sump servicing the room. The combustible loading of any one pump room is estimated to be less than 30,000 BTU /ft.2 with a maximum fire severity of less than 30 mirutes.
A smoke detection system is installed in each of the three auxiliary feedwater pump rooms. The detection system would provide early warning of a fire, allowing the fire brigade adequate time to respond.
A manual hose station, portable extinguishers, and portable smoke removal equipment are available for use in the area.
The room construction coupled with a low quantity of combustible material, the presence of smoke detection system, and the availability of equipment for use by the fire brigade ensures that a fire in one of the AFW pump rooms would be confined to the affected room.
Such a fire would not prevent auxiliary feedwater flow to at least one steam generator.
In order to ensure that fire will not propagate from one auxiliary feedwater compartment to another, the electrical penetrations and the mechanical pipe penetrations have been sealed with fire resistive silicone foam.
The licensee has committed to include these penetrations into their fire barrier surveillance program.
The component cooling water (CCW) pump and heat exchanger room 185 is protected by an automatic smoke detection and sprinkler system.
The licensee has committed to modify the sprinkler system, by the end of the Unit 1 seventh refueling outage, in the area of the CCW pumps to provide unobstructed sprinkler protection for the subject pumps.
The combustible fire loading in the room is less than 35,000 BTU /ft2 with a maximum fire severity of less than 30 minutes.
The detection system in the room would provide early warning of a fire allowing the fire brigade adequate time to respond.
A manual hose station, portable extinguishers, and portable smoke removal equipment are available for use in the area.
The CCW pumps are located on 21-ft. centers. Heat detectors are provided in the 5-kV CCW pump disconnect switch which alarms locally and in the control room.
The 5-kV disconnect switch cabinets are provided with a total-flooding CO2 system that is activated by the heat detectors.
The CCW pump cables are wrapped with two 1-in. layers of kaowool with the exception of the train-A cables for the swing CCW pump which are wrapped with a single 1-in. layer.
All trains of CCW pump cables are covered by an automatic sprinkler system.
- o 5 +.
30 Cables for the train-B service water inlet and discharge valves on the CCW heat exchangers are protected by two 1-in.. layers of Kaowool and covered by automatic suppression.
Cables for the train-A service water inlet and discharge valves on the CCW heat exchanger are not protected.
Although' neither train-A or train-B service water valves are provided with fire barriers, the nearest ~ redundant valves are separated by a distance of approximately.10 f t.
Intervening combustibles between redundant valves are minimal, consisting primarily of cable insulation.
Due to the existing level of fire detection and protection features provided as discussed above, fire damage in room 185 would be limited such that one train of redundant CCW system components and cabling would'be available for safe shutdown.
In the event that the me.in steam isolation valves fail to isolate due to fire induced failures in the valves or valve control circuitry, the main' turbine stop valves would provide isolation of the main steam lines.
The main turbine stop valves and related control circuitry would not be affected by a fire in Fire Area 1-006.
The main steam atmospheric relief valves are located in the main steam and feedwater valve-room 241 on el 127 ft. - 0 in. The backup air compressors and local control station for the atmospheric relief valves are located in the plant heating equipment room 189 on el 100 ft. - 0 in. The combustible loading of either room is such that the maximum expected fire severity is less than 30 minutes.
The main steam and feedwater valve room is a rest-ricted area with limited personnel access during plant operation.
A smoke detection system is installed in both rooms. An automatic sprinkler system covers the plant heating equipment room. The main steam and feedwater valve room does not have sprinkler coverage.
The detection system would provide early warning of a fire, allowing the fire brigade adequate time to respond.
A manual hose station, portable extinguishers and portable smoke removal equipment are available for use in both rooms.
The main steam and feedwater valve room is a large room divided into three bays. The bays are separated by partial walls, 14 ft. in height. One main steam line lies in each bay.
The main steam lines and their atmospheric relief valves are -on 18-ft. centers.
The floor of the main steam and feedwater valve room is watertight. The only communication between the main steam and feedwater valve room is an equipment hatch. On el 127 ft. - 0 in.
the equipment hatch area is enclosed in'a separate room.
In the event of fire induced failures affecting the redundant MSARV control cables or the local control stations located on el 100 f t. - 0 'in., the atmospheric relief valves located in room 241 on el 127 ft. - 0 in. are provided with hand wheels such that the valves may be manually opened or closed without electrical controls or air supplies.
Due to the degree of separation provided between MSARVs and related control cabling in room 241, r.
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i-o l
31 the minimum combustible loading, the presence of an early warning smoke detection system, and the administrative controls imposed at the plant to -
limit access to room 241 during plant operations, a fire involving the in-situ combustibles in room 241 would not result in the inability to operate the MSARV associated with one steam generator.
The non-fire rated steel plate hatchway cover located in the fire rate floor slab separating rooms 234 (Fire Area 1-020) and 185 is protected by a sprinkler system. The sprinkler system coverage is provided in both rooms and upon sprinkler actuation the system will create a water curtain affect which will prevent fire propagation from Fire Area 1-006 to Fire Area 1-020.
All other shutdown systems associated with Fire Area 1-006 have redundant counterparts in other fire areas or are located in plant areas which meet the requirements of 10 CFR 50, Appendix R, Section III.G.2. As a result, there is reasonable assurance that if a fire occurred in any of the rooms associated with Fire Area 1-006, safe shutdown could be achieved and maintained.
6.4 CONCLUSION
Based on our evaluation, we conclude that the licensee's alternative fire protection configurations and their proposed modifications will provide an acceptable level of fire protection to that required by the technical requirements of 10 CFR 50, Appendix R, Section III.G.2. Therefore, the licensee's request for exemption for Fire Area 1-006 should be granted.
7.0
SUMMARY
AND CONCLUSION FOR REMAINING FIVE SPECIFIC FIRE AREA EXEMPTIONS FOR UNIT 1 Therefore, based on ~our evaluation of the licensee's October 18, 1985 response, we conclude that the licensee's proposed fire protection modifications and their revised technical justifications pertaining to the plant's alternative ability to achieve and maintain safe shutdown conditions and the existing fire protection configurations in the following plant fire areas represented an equivalent level to safety to that achieved by compliance with Section III.G of Appendix R:
Unit 1 Non-radiation Side Corridor, Auxiliary Building, EL 121 ft.
- 0 in. - Fire Area 1-020 (exemption request 1-17)
Unit 2 Auxiliary Building, EL 139 ft. - 0 in. - Fire Area 2-042 (exemption request 1-26)
Unit 1 Train B inside Auxiliary Building Cable Chase - Fire Area 1-009 (exemption request 1-31)
Unit 1 Auxiliary Building, EL 83 ft. - 0 in.,100 ft. - 0 in., and 121 ft. - 0 in. - Fire Area 1-001 (exemption request 1-36)
Unit 1 Auxiliary Building, EL 100 ft. - 0 in.,'121 ft. - 0 in.,
127 ft. - 0 in., 139 ft. - 0 in., 155 ft. - 0 in., and 175 ft. -
0 in. - Fire Area 1-006 (exemption request 1-38) u
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32 Dated:
Principal Contributors:
P. Mafiden E. Reeves b
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