ML20211N818

Evaluation of Fire Protection Exemption Requests from 10CFR50.48 & App R to 10CFR50,Zion Station Units 1 & 2, Technical Evaluation Rept

ML20211N818
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	07/03/1986
From:	Ahmed N, Arnold D, Carfagno S CALSPAN CORP.
To:	Stang J NRC
Shared Package
ML20211N823	List: ML20211N818 ML20212K315
References
CON-NRC-03-81-130, CON-NRC-3-81-130 TER-C5506-619, NUDOCS 8607080156
Download: ML20211N818 (30)

Text

'

. i 7.

e'. ,

TECHNICAL EV LUATION REPORT .

E _

NRC DOCKET NO. 50-295/304 FRC PROJECT C5506 NRC LICENSE NO. DPR-39/48 FRC ASSIGNMENT 36 NRC CONTRACT NO. NRC-03-81130 FRCTASK 619

~

EVALUATION OF FIRE PROTECTION EXEMPTION REQUESTS FROM 10CFR50.48 AND APPENDIX R 'IO 10CFR50 l

COMMONWEALTH EDISON COMPANY ZION STATION UNITS 1 AND 2 TER-C5506-619 '

i Preparedfor

- Nuclear Regulatory Commission FRC Group Leader: N. Ahmed Washington, D.C. 20555 NRC Lead Engineer: J. Stang July 3, 1986 This report was prepared as an account of work sponsored by an agency of the United States Government. Ntither the United States Government nor any agency thereof, or any of their employees, makes any warranty, typressed or implied, or assumes any legal liability or responsibility for any third party's use, or the results of such use, of any information, appa-ratus, product or process disclosed in this report, or represents that its use by such third

, party would not infringe privately owned rights.

Prepared by: App.'oved by:

Redewep by:

/W +~

Principa\ Author bepartment ire (or Date: V 7/3[iS Date: 7!E!80 Date: ~3 - D I FRANKLIN RESEARCH CENTER DIVI $lON OF ARVIN/CALSPAN

- . .-. mm,-- ,. . ,

TER-C5506-619

• l, CONTENTS Section Title - - Page 1 INTRODUCTION . . . . . . . . . . 1 1.1 Pur~ pose of Roview . . . . . . . . 1 1.2 Generic Background . . . . . . . . 1 1.3 Plant *Sp=0ific Background . . . . . . 3 1.4 Rr, view Criteria . . . . . . . . 4 2 EVALUATION . . . . . . . . . . . 5 2.1 General . . . . . . . . . . 5 2.2 Main Control Room (Fire Area 2.0-0) . . . . 5 2.3 Auxiliary Electric Equipment Rooms, Fire Areas 5.6-1 and 5.6-2 . . . . . . . . . 7 2.4 Auxiliary Building, Residual Heat Removal ~ '

Pump Area, Elevation 542 Feet . . . . . 8 2.5 Auxiliary Building Component Cooling Water Pump Area, Elevation 560 Feet . . , . . . 10 2.6 Auxiliary Building Charging and Feedwater Pumps Area, Elevation S79 Feet . . . . . 12 l

2.7 Auxiliary Building, Elev.ations 592, 617, and l

i 642 Feet . . . . . . . . . . 16 l.

2.8 Main Control Room (Fire Zone 2.0-0) . . . . 18 2.9 Reactor Coolant Fump Lube Oil Collection System (Fire Zenes 1.3-1 and 1.3-2) . . . . 19 2.10, Main Steam Pipe Tunnel (Fire Zones 18.5-1 '

1.

and 18.5-2) . . . . . . . . . 21 2.11 Structural Steel . . . . . . . . 23 3 CONCLUSIONS . . . . . . . . . . . 25 l 4 REFERENCES . . . . . . . . . . . 27 l .

l O

i.11 e

l

O o TER-C5506-619 4

FOREWORD This Technical Evaluation Report was prepared by Frahklin

~

Research Center (FRC) under a contract with the U.S. Nucl3ar_

Regulatory Commission (Office of Nuclear' Reactor Regulation) for technical assistance in support of NRC operating reactor licensing actions. The technical evaluation was conducted in accordance with criteria established by the NRC.

Mr. Dan Arnold contributed to the technical preparation of this report thrcugh a subcontract with Rolf Jensen & Associates, Inc.

O O

V e

l TER-C5506-619 f

1. INTRODUCTION 1.1 PURPOSE OF REVIEW This technical evaluation report documents an indepindent review of exemptions or deviations from the fire protection requ"irements of 10CFR50.48 or Appendix R to 10CFR50 requested for Commonwealth Edison Company's (Ceco) Zion Station Units 1 and 2. This evaluation was performed with the following objectives:

o To assess if each exemption request demonstrates an i,

equivalent level of overall protection of plant safe shutdown capability following a disabling fire event l

o To determine the bases for acceptance or denial of each exemption request o To recommend the minimum level of fire protection the

~

licensen should provide to achieve an equivalent level of fire protection in case a request is denied.

1.2 GENERIC BACKGROUND l Following a major fire at the Browns Ferry Nuclear Station in March 1975, the NRC established a Special Review Group which initiated an evaluation of the need for improving the fire protection programs at all nuclear power plants. The group found serious design inadequacies regarding fire protection at Browns Ferry, and its report, " Recommendation Related to Browns Ferry Fire" (NUREG-0050, February 1976), contained over 50 recommendations regarding r- improvements in fire prevention and control in existing facilities.

The report also called for the development of specific guidance for implementing fire protection regulations, and for a comparison of that guidance with the fire protection program at each operating plant.

NRC developed technical guidance from the technical recom-mandations in the Special Group's report, and issued those guidelines

, as Branch Technical Position (BTP) APCSB 9.5-1 (1) . This guidance

! did not apply to plants operating at that time. Guidance to operating plants was provided later in Appendix A to BTP APCSB 9.5-1 (2),

which, to the extent practicable, relies on BTP APCSB 9.5-1. The guidance in these documents was also published as Regulatory Guide l 1.120 (3].

l By edrly 1980, most operating plants had implemented most of the

guidelines in Appendix A. However, the fire protection program has had some significant problems with implementation. To establish a definitive resolution of these problems in a manner consistent with the general guidelines in Appendix A to the BTP and to assure timely compliance by licensees, the Commission issued a proposed fire i protection rule and its Appendix R, which was described as setting -

I out minimum fire protection requirements for the unresolved issuas.

. _ , , - r __ _ _ _ , . _ . . . _ _ _ _ . _ . _ _ , _ _

TER-C5506-619 I

The fire protection features addressed included protection of safe <

shutdown capability, emergency lighting, fire barriers, associated circuits, reactor coolant pump lubrication system, and alternate shutdown systems. ,,

On February 17, 1981, the final rule 10CFR50.48 (4) nd Appendix l R to 10CFR50 (5) became effective, replacing the proposed rule. Only three of the 15 items in Appendix R were of such safety significance that they should apply to all plants, including those for which alternative fire protection actions had been approved previously by the staff. These items are protection of esfe- shutdown capability (including citernate shutdown systems), emergency lighting, and the reactor coolant pump lubrication system. Accordingly, the final rule required all reactors licensed to operate before January 1, 1979, to comply with these three items even if the NRC had previously approved alternative fire protection features in these areas. However, the final rule is more flexible than the proposed rule because Item III.G now provides three alternative fire protection features which do not require analysis to demonstrate the protection of redundant safe

_ shutdown equipment, and reduces the acceptable distance in'the physical separation alternative from 50 feet to 20 feet. In addition, the rule now provides an exemption procedure which can be initiated by a licensee's assertion that any required fire protection feature will not enhance fire protection safety in the facility or l that such modifications may be detrimental to overall safety.

l In summary,Section III.G is related to fire protection features for ensuring that systems and associated circuits used to achieve and i maintain safe shutdown are free of damage. Either fire protection configurations must meet the specific requirements of Section III.G or an alternative fire protection configuration must be justified by a fire hazards analysis. Generally, the staff will accept an

_ alternative fire protection configuration if:

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

o The alternative ensures that fire damege to at least one train of equipment necessary to achieve cold shutdown is limited so that it can be repaired within a reasonable time (minor repairs using components stored on the site). .

o Fire-retardant coatings are not used as fire barriers.

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

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

Guidance to the industry and the NRC position on certain requirements of Appendix R is covered by various documents, one of 1

. TER-C5506-619 them being Gencric Letter 83-33 [6), which has recently been superseded by Generic Letter 86-10 [7). "The interpretations of Appendix R" and "the resconses to industry questions," two sections of Reference 7, are written to facilitate industry implementation of Appendix R and represent NRC position on all issues covered.

Following the promulgation of the final rule, licensees have I

requested exemptions and deviations from Appendix R to 10CFR50, The exemptions and deviations are in the form of a fire hazards analysis.

The NRC is to review exemption requests and associated analysis to ensure each alternative to meeting the requirements of the rule

, provides an equivalent level of overall protection of plant safe shutdown capability. Franklin Research Center (FRC) was to provide technical assistance to the NRC within the context of the following scope of work [8):

Subtask 1: Review each exemption request for information

~

deficiencies. Provide Request for Information (RFI) to resolve such deficiencies.

Subtask 2: Review and evaluate each exemption or deviation

~

request submitted by the licensees and all additional information provided for conformance with acceptance criteria. Prepare final Technical Evaluation Report (TER) with recommendations, and their basis in support of granting or denying the exemption / deviation request.

1.3 PLANT-SPECIFIC BACKGROUND By latter dated July 30, 1982, Commonwealth Edison Company

~

(CECO, the Licensee) submitted an evaluation of compliance to i 10CFR50, Appendix R. The submittal requested six exemptions from the requirements of Appendix R,Section III.G. By a Safety Evaluation Report (SER) dated March 7, 1983, the NRC granted six exemption

'- requests.

By letter dated July 27, 1984, the Licensee submitted a reassessment of the 1982 Appendix R evaluation. The results of the reassessment indicated that of the previously approved six exemp-tions, only the exemptions for the service water pumps within the crib house (Fire Zones 18.4A-0 end 18.4B-0) still apply.

In the July 27, 1984 reassessment, the Licensee requested new exemptions from Fections III.G and III.O of Appendix R. The Licensee l revised Sections 1 and 6 of their Appendix R reassessment by letters dated August 31, 1984 and January 24, 1985. The Licensee provided additional information in support of the staff's review of these requests in a letter dated February 18, 1986. The July 27, 1984 submittal, as amended, consequently is the subject of this evaluation. -

F

6 l TER-C5506-619 s.

NRR and FRC fire protection engineers visited the site on December 11, 1985 to review the areas where exemptions from Appendix R have been requested and to gath'er additional information requested ~

in the RFI issued on November 12, 1985.

.5 _

1.4 REVIEW CRITERIA The criteria used in reviewing the Licensee-submitted exemption requests are based on the following documents:

1. Fire Protection Program for Operating ~ Nuclear Power Plants, e 10CFR50.48

2. Appendix R to 10CFR50

_ 3. Standard Review Plan, NUREG-0800, Branch Technical Position (BTP), APCSB 9.5-1, " Guidelines for Fire Protection for Nuclear Power Plants"

- 4. Appendix A to BTP APCSB 9.5-1

5. Generic Letter 86-10, " Implementation of Fire Protection Requirements," dated April 24, 1986. -

9 m

D D

G l

\

TER-C5506-619

2. EVALUATION 2.1 GENERAL .

This section presents review and evaluation of exemptions or deviations from 10CFR50.48 or Appendix R to 10CFR50 requested by the Licensee (Commonwealth Edison Company, CECO) of Zion Station Units 1 and 2. Evaluation of exemption requests for each fire area / zone singly or collectively follows a format suggested by the NRC and is arranged in the following subsections:

~

I o Exemption requested o Discussion o Evaluation o conclusion.

~

The fire area / fire zone numbering used in this section corresponds to that used in the Licensee's submittal.

2.2 MAIN CONTROL ROOM (FIRE ZONE 2.0-0) 2.2.1 Exemption Requested An exemption was requested from the requirements of Section III.G.3 to the extent that it requires a fixed fire suppression r- system throughout the main control room (Fire Zone 2.0-0).

2.2.2 Discussion The Licensee has committed to provide alternative shutdown capability independent of the main control room to safely shut down both units. Refer to Section 2.8 for additional information.

Fire Zone 2.0-0 is the main control room common to both units.

It is located on the 642-foot elevation of the auxiliary building and contains the normal and engineered safety features (ESF) control boards for both units. It is continuously manned by trained operators. The control boards for the safe shutdown systems are in an opposite-hand horseshoe arrangement.

The main control room has an approximate floor avea of 5,G62 square feet and is 23 feet high. The combustible materials consist primarily of cable insulation, ventilation duct insulation, and paper. The combustible loading is approximately 39,000 Btu per square foot, which translates into a fire severity of about 30 minutes on the ASTM E-119 time-temperature curvo. .

The boundaries of the main control room are reinforced concrete and have a 3-hour rating. Ventilation ducts which penetrate the control room boundary are provided with 3-hour rated fire dampers.

TER-C5506-619 Penetration seals are installed at cable penetrations. Fire doors in the boundary are 1-1/2- or 3-hour rated. .

The existing fire protection for the main control room consists of fire extinguishers, detectors, and Manual hose stations. ,

a 2.2.3 Evaluation The fire protection in Fire Zone 2.0-0 does not comply with the technical requirements of Section III.G.3 of Appendix R because automatic fire suppression is not installed in a zone for which alternative shutdown capability will be provided.

The principal concern with the level of fire protection was that, because of the absence of an area-wide fixed suppression

, system, a fire of significant magnitude could damage redundant safe shutdown systems.

The combustible loading in the main control room is relatively low. The combustibles are primarily cable insulation. If a fire were to occur, it is expected that it would develop slowly with initial low heat release and slow rise in rcom temperature.

The main control room is protected by a fire detection system.

t The system consists of ionization smoke detectors under the ceiling I slab and two detectors in the exhaust duct. The Licensee has l

committed to relocate and/or add new detectors in order to conform with the criteria of NFPA 72E (Standard on Automatic Fire Detectors).

- Because of the presence of these detectors and continuous manning by operators, a fire in the control room should be detected early and extinguished by the fire brigade.

~ "

Another factor that reduces the fire risk in this zone is that alternative shutdown capability independent of the main control room is to be provided by the Licensee. For additional information regarding alternative shutdown in the main control room, see Section 2.8.

The installation of an area-wide fire suppression system would not significantly increase the level of fire protection in this zone.

2.2.4 Conclusion Based on the above evaluation, it is concluded that the existing fire protection features combined with alternate shutdown capability provide a level of fire protection equivalent to the technical requirements of Section III.G.3 of Appendix R. Therefore_, the exemption request from providing area-wide suppression in the main control room can be granted.  ;

l l

~

TER-C5506-619 2.3 AUXILIARY ELECTRIC EQUIPMENT ROOMS, FIRE AREAS 5.6-1 AND 5.6.2 2.3.1 Exemption Requested ,

An exemption was requested from the requirements of section III.G.3 to the extent that it requires a fixed fire suppression system throughout the auxiliary electric equipment rooms (AEERs)

(Fire Areas 5.6-1 and 5.6-2).

2.3.2 Discussion ft Fire Areas 5.6-1 and 5.6-2 are the AEERs 'for Units 1 and 2, l respectively. Each fire area is located on the 642-foot elevation of the auxiliary building and contains one division of dc power distribution panels for safe shutdown components, inverters (which supply power to the normal instrumentation channels), and cabling for the inverters and the normal instrumentation channels. Fire Area 5.6-1 contains Division 19 de distribution panels and associated cabling for the Unit 1 safe shutdown components, whereas Fire Area 5.6-2 contains the Division 29 components.

Each AEER has an approximate floor area of 2,220 square feet and is 24 feet high. The boundaries are concrete masonry units'or reinforced concrete of sufficient thickness to qualify as 3-hour fire rated. Ventilation ducts which penetrate the boundary fire barriers are protected by 3-hour rated fire dampers and seals are installed at cable penetrations. Fire doors in the boundary fire barriers are 3-hour fire rated.

f- The average combustible loading for Fire Areas 5.6-1 and 5.6-2 l' is about 63,000 Btu per square foot, which translates into a fire i

l severity of about 50 minutes based on the ASTM E-119 time-temperature '

curve. The combustibles consist primarily of cable insulatien and interior finishes.

The existing fire protection for the AEERs consists of fire extinguishers, ionization smoke detectors, and manual hose stations.

~

The Licensee has committed to provide alternate indication for safe shutdown instrumentation for each of these areas by rerouting cable to the remote shutdown panels and providing transfer / isolation switches in each unit's inner cable spreading room. Alternate power will be provided for the instrumentation to ensure that process monitoring capability is maintained.

2.3.3 Evaluation The fire protection in the AEERs (Fire Areas 5.6-1 and 5.6-2) does not comply with'the technical requirements of Section III.G.3 of Appendix R because fixed fire suppression is not installed in areas for which an alternative shutdown capability will be provided.

The primary concern was that, because an area-wide fixed suppression system was not installed, a fire of significant magnitude

TER-C5506-619 could damage redundant safe shutdown systems. However, the combustibles in these areas consist primarily of cable insulation.

If a fire were to occur, it is expected that it would develop slowly with initial low heat release and a slow rise in room temperature.

The AEERs are protected by a tire detection system consisting of ionization smoke detectors at the ceiling level. The Licensee has verified that these ionization smoke detectors meet the location and spacing requirements of NFPA 72E. Because of the presence of these detectors, a fire in these areas should be detected in its incipient stage. The alarms from these detectors are annunciated in the main control room. The fire brigade would be dispa~tched to extinguish the fire manually using the hose lines or portable extinguishers provided.

In the event that extinguishment is not successful, the Licensee has committed to provide alternate shutdown capability independent of the AEERs.

The installation of an area-wide fixed fire suppression system would not significantly increase the level of fire protection in these areas.

2.3.4 Conclusion Based on the above evaluation, is is concluded that the existing fire protection features combined with alternate shutdown capability provide a level of fire protection equivalent to the technical requirements of Section III.G.3 of Appendix R. Therefore, the exemption request from providing an area-wide fire suppression system in these areas can be granted.

l . 2.4 AUXILIARY BUILDING, RESIDUAL HEAT REMOVAL PUMP AREA, ELEVATION 542 FEET 2.4.1 Exemption Requested An exemption was requested from the requirements of Section III.G.2.b to the extent that it requires area-wide automatic suppression and detection systems and 20 feet of separation between redundant safe shutdown components for the auxiliary building fire area at elevation 542 feet.

2.4.2 Discussion Section III.G.2 of Appendix R contains requirements for fire protection features protecting systems necessary to achieve and maintain hot shutdown conditions. It does not apply to systems necessary to achieve and maintain cold shutdown. _

Section III.G.l.b of Appendix R states that systems necessary to achieve and maintain cold shutdown can be repaired within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

Additional staff guidance on the protection of cold shutdown equipment is provided in Generic Letter 86-10. Therefore, this

[ _ _ _

7 TER-C5506-619 elevation has been reviewed for conformance with Section III.G.1 of Appendix R and related guidance rather than under Section III.G.2.b as requested.

The 542-foot elevation of the auxiliary building fine area contains nine fire zones. Safe shutdown components on this elevation consist only of Units 1 and 2 residual heat removal (RHR) pumps and i associated cables. The Unit 1 pumps are located in Fire Zones 11.1A-1 and 11.1B-1, and the Unit 2 pumps are in Fire Zones 11.1A-2 and 11.1B-2. Each RHR pump is located in a separate cubicle with 24-inch-thick reinforced concrete walls. Each cubicle has a

', combustible loading of approximately 1,200 Btu per square foot, which translates into a fire as'ierity of less than 1 minute on the ASTM E-119 time-temperature curve.

~

The existing fire protection for the cubicles consists of one ionization smoke detector over each RHR pump. Portable extinguishers and manual hose stations are provided outside of the cubi.cles.

, The Unit 1 RHR pumps share a common T-shaped wall having a 3-hour fire rating. This wall is penetrated by a ventilation duct that is provided with a 3-hour rated fire damper. No other penetrations exist in this barrier. The same configuration exists for the Unit 2 RHR pumps.

Cables associated with the RHR pumps are routed outside of the pump cubicles in Fire Zone 11.1-0. Units 1 and 2 RHR pump cables are routed next to each other (less than 20 feet of separation). The minimum separation between Units 1 and 2 RHR pump power cables is approximately 50 feet. Fire Zone 11.1-0 is an open space with a a

floor area of approximately 17,300 square feet. It has a combustible loading of approximately 5,000 Btu per square foot and a fire severity of 4 minutes.

The existing fire protection for Fire Zone 11.1-0 consists of portable extinguishsrs, manual hose stations, and ionization smoke detectors at various locations. Detectors are not provided throughout the area containing the cables associated with the RHR pumps.

The Licensee has committed to maintain sufficient qualified I cable onsite and to formulate repair procedures to replace the cables of one RHR pump after a fire, before the pumps are needed for cold shutdown.

2.4.3 Evaluation The Licensee has committed to maintain sufficient qualified cable onsite and to formulate repair procedures so that the cables of one RHR pump for each unit can be repaired after a fire, -before the RHR pumps will be needed for cold shutdown. The Licensed has stated that only one RHR pump is required for cold shutdcwn for each unit.

TER-C5506-619 i

I e.

The Licensee's commitment to formulate repair procedures using onsite capabilities meets the requirements of Section III.G.l.b and related staff guidance. ,

2.4.4 Conclusion ~ 7 -

Based on the above evaluation, it is concluded that the existing fire protection features in conjunction with cold shutdown repair procedures meet the technical requirements of Section III.G.l.b of Appendix R and related staff guidance. Therefore, the exemption request for providing area-wide automatic suppression and detection my= tam = and 20 feet of separation between redundant RHR pump pover cables on the 542-foot elevation of the auxiliary building is not necessary.

2.5 AUXILIARY BUILDING, COMPONENT COOLING WATER PUMP AREA, ELEVATION 560 FEET 2.5.1 Exemption Requested An exemption was requested from the requirements of Section III.G.2.b to the extent that it requires area-wide automatic suppression and detection systems and 20 feet of separation between redundant safe shutdown components located at the 560-foot elevation of the auxiliary building fire area.

2.5.2 Liscussion The 560-foot elevation of the auxiliary building fire area contains 16 fire zones. Safe shutdown components consist of the five component cooling water (CCW) pumps and associated cables, steam generator instrumentation cables, and cables associated with the RHR

~ pumps.

The five CCW pumps (OA through OE) are located side by side 4 along the east wall of Fire Zone 11.2-0. Two of the five pumps are j required to shut down both units simultaneously. The two most remote CCW pumps and associated cables are separated by more than 50 feet.

The cables for the CCW pumps are routed in conduits from the I pumps into separate solid bottom cable trays located above the pumps l and approximately 1 to 5 feet below the ceiling.

The cables for pumps OA and OB are routed in cable trays through the northern half of the 560-foot elevation. The cables for pumps OC, OD, and OE are routed in conduits into separate solid bottom cable trays through the southern half of the elevation. The trays run at least 60 feet away from the pumps and enter into separate vertical metal enclosed risers and exit through sealed penetrations in the ceiling at the 579-foot elevation. .

! Fire Zone 11.2-0 has a combustible loading of approximately 20,900 Btu per square foot and a fire severity of 16 minutes.

Intervening combustibles near the CCW pumps consist of two groups of l l l

. TER-C5506-619 four cable trays parallel to and over the middle three pumps. Each tray is provided with a solid bottom, and fire stops are located approximately 10 feet apart to prevent fire from spreading along intervening combustibles. The fire stops consisting of penetration i seal material are applied to 2-foot-long sections of the trays. ~

A local application CO fire suppression system is provided over the five CCW pumps. Thesuhpressionsystemisautomaticallyactuated by heat detectors located over each pump.

Ionization smoke detectors are also provided over the CCW pumps.

The Licensee has committed to expand the existing detection on the 560-foot elevation of the auxiliary building to provide coverage over the cable trays containing power feeds for the CCW pumps.

Additionally, portable extinguishers and manual hose stations are provided in the area.

Control of the CCW pumps is not required in the event of a fire t

on this elevation.

1 Steam generator pressure instrumentation cables for Units 1 and 2 enter the auxiliary building on this elevation. The minimum separation between the cables is approximately 100 feet on all levels of the auxiliary building. The Licensee has committed to in' stall a mechanical pressure gauge on the loop A main steam piping outside of the auxiliary building fire area for alternate indication.

Ionization smoke detectors on this elevation are located in the areas of and between the steam generator pressure instrumentation l,-

cablen.

, The cables associated with the RHR pumps on the 560-foot

.. elevation are separated by approximately 95 feet. The Licensee has committed to maintain sufficient qualified cable onsite and to formulate repair procedures to replace the cables of one RHR pump for each unit after a fire, before the pumps are needed for cold shutdown. For additional information, see Section 2.4.

2.53 Evaluftion The fire protection for the auxiliary building fire area does not comply with the requirements of Section III.G.2.b because automatic fire suppression is not installed throughout the area on the 560-foot elevation of the auxiliary building.

The principal concern with the level of fire protection was that because of the absence of an area-wide automatic suppression system, a fire of significant magnitude could damage all five CCW pumps.

, However, the combustible loading in zones containing safe

! shutdown equipment is relatively low. If a fire were to ' occur, it is l expected that it would develop slowly with initial low heat release.

Additionally, ionization smoke detectors are provided over the CCW pumps. The Licensee has committed to expand the existing detection l

I .

TER-C5506-619

.. on the 560-foot elevation to provide ionization detectors over the cable trays containing the power feeds for the CCW pumps. Because of 4 the presence of these detectors, a fire in these areas should be detected in its incipient stage. The alarms from these detectors are annunciated in the main control room. The fire brigade vould be dispatched to extinguish the fire manual}y, using hose lfhes or portable extinguishers provided.

A local CO 2 fire suppression system is provided over the five CCW pumps. The system is automatically actuated by heat detectors located over each pump. This system should provide fire control for a fire at the pumps until the fire brigade arrives. Manual control at the LLW pumps is not required for control of the individual CCW pumps during a fire in this area.

The steam generator pressure instrumentation cables are

. separated by approximately 100 feet. Ionization smoke detectors are located in the areas of and between these cables. The Licensee has

~

committed to install a mechanical pressure gauge outside of the auxiliary building fire area to provide alternate steam generator

- pressure indication.

The cables associated with the RHR pumps on the 560-foot elevation are separated by 95 feet. The Licensee has committed to l institute post-fire repair procedures and have qualified cable

available. For additional information, see Section 2.4.

l The installation of an area-wide automatic fire suppression system would not significantly increase the level of fire protection

on this elevation of the auxiliary building fire area.

2.5.4 Conclusion

_ .. Based on the above evaluation, it is concluded that the existing fire protection in conjunction with additional ionization detectors provide a level of fire protection equivalent to the technical requirements of Section III.G.2.b of Appendix R. Therefore, the exemption request from providing area-wide automatic suppression and

! detection systems and 20 feet of separation on the 560-foot elevation of the auxiliary building fire area can be granted.

2.6 AUXILIARY BUILDING, CHARGING AND FEEDWATER PUMPS AREA, ELEVATION 579 FEET 2.6.1 Exemption Requested An exemption was requested from the requirements cf Section III.G.2.b to the extent that it requires area-wide autumatic suppression and detection systems and 20 feet of separation between redundant safe shutdown components for the 579-foot elevation of the auxiliary building fire area.

.m _

TER-C5506-619 2.6.2 Discussion The 579-foot elevation of the auxiliary building fire area contains 16 fire zones. Safe shutdown components consist of both unit's centrifugal charging and auxiliary feedwater (AFW)epumps. The remote shutdown panels, the power feeds for the service water pumps, and cables associated with the RHR pumps are also located on this elevation.

Combustible loadinga for fire zones located on this elevation range from negligible to approximately 30,000 Btu per square foot.

~

The majority of the combustibles are confined "to the centrifugal and reciprocating charging pump cubicles located in Fire Zones 11.3A-1, 11.3A-2, 11.3B-1, 11.3B-2, 11-3C-1, and 11.3C-2. The combustibles consist primarily of 55 gallons of lubricating oil inside each pump

~

cubicle. The pump cubicles are separated from the remainder of the elevation by 24-inch-thick reinforced concrete walls and unrated hollow metal access doors. The combustible loading for Fire Zone 11.3-0, which contains all AFW pumps, is approximately 20'000 Btu per square foot and is equivalent to a 14-minute fire severity.

2.6.2.1 Centrifugal Charging Purps The Unit 1 centrifugal charging pumps (1A and 2B) are l'ocated in Fire Zones 11.3A-2 and 11.3B-2. The Unit 2 centrifugal charging pumps are in Fire Zones ll.3A-2 and 11.3B-2. Each charging pump is located in a separate cubicle. Within each unit, the charging pump cubicles are located side by side with the walls of each cubicle constructed of 18-inch-thick reinforced concrete. An unrated door

~

with a metal transom provides access into each cubicle. The charging pumps for each unit are separated by a 3-hour fire rated wall. The only penetration through each of these walls is a ventilation duct.

The Licensee has committed to install a 3-hour rated fire damper in i'

these penetrations.

Outside of the Unit 1 charging pump cubicles, the power cables l for pump 1A will be rerouted in conduits with approximately 20 feet i

l of separation from the power feeds for pump 1B in Fire Zone 11.3-0.

Intervening combustibles between redundant centrifugal charging pump power feeds in Fire Zone 11.3-0 consist of the remote shutdown panels and an open cable tray. The power feeds are located in the area of the Unit 1 AFW pumps (see Section 2.6.2.2). The Licensee has committed to provide a 1-hour fire wrap on the power feeds for charging pump 1A from the point where they exit the pump cubicle i throughout their entire run on the 579-foot elevation (Fire Zone l

l 11.3-0).

outside of the Unit 2 charging pump cubicle, the power feeds for charging pump 2A will be rerouted in conduits, and more than a i 20-foot separation free of intervening combustibles will te I

maintained between the power feeds for pumps 2A and 2B. -

one centrifugal charging pump per unit is required to achieve and maintain hot shutdown. The closest charging pump cubicle and

,. TER-C5506-619

~

power feed separation distance between Units 1 and 2 is more than 50 feet. The centrifugal charging pump and power feeds for each unit are routed through the upper levels of the auxiliary building and terminate on the 617-foot elevation. .

2.6.2.2 Auxiliary Feedwater Pumps ~~

The Unit 1 AFW pumps are located side by side in the south part of Fire Zone 11.3-0. They are orientated with the two motor-driven pumps to the south and a turbine-driven pump to the north. The Unit 2 AFW pumps are in a similar orientation in the north part of Fire

, Zone 11.3-0. The minimum separation distance'between the most remote motor-driven pump and the turbine-driven pump for Unit 1 is

! approximately 23 feet; for Unit 2, it is approximately 16 feet. The Units 1 and 2 AFW pump areas are separated by more than 31 feet with no intervening combustibles.

Intervening combustibles near the AFW pumps consist of cable

. trays. The Licensee has committed to provide each cable tray with fire stops to prevent fire spread along intervening combustibles.

The fire stops c?nsisting of penetration seal material are to be installed in 2-foot-long sections along the trays.

Located batween the motor-driven and turbine-driven pumbs of each unit is a 7-foot-high concrete wall. Each pump is surrounded by a dike. The dike area is provided with a drain leading directly out of the 579-foot elevation for removal of lube oil spills from the base of each pump.

Er.ch AFW pump is protected by a local application CO 7 suppres-

~

sion system that is actuated by heat detectors located directly over each pump.

Ionization smoke detectors are provided over the AFW pumps and

, portable extinguishers and ranual hose stations are also provided in the area.

The Licensee has committed to reroute the power cables for l motor-driven AFW pumps 1C and 2C in conduits with 1-hour fire rated wrap. Additionally, existing steel plate enclosures for the Unit 2 motor-driven AFW pumps will be extended to the south side of the pump motors to prevent a direct line of site contact with the Unit 2 turbine-driven pump.

AFW pump control circuits are not protected on this elevation.

The Licensee stated that the motor-dri.*en AFW pumps can be started  !

manually by closing the 4-kV switchgear breaker in the switchgear '

, room after disconnecting the de control power. The turbine-driven l

ATW pumps can be started manually by failing to open the turbine l steam supply flow control valve. - 1 l

l l

l i

TER-C5506-619 2.6.2.3 Remote Shutdown Panels Also of concern relative to the operability of the AFW pumps discussed above are the remote shutdown panels (RSPs). There are four RSPs per unit, with three containing functions impontant to safe shutdown and the fourth containing balance of plant functions.

The RSPs are adjacent to the redundant charging pump cubicles of each unit discussed in Section 2.6.2.1. A minimum of 80 feet of separation exists between Units 1 and 2 panels. The RSPs are unit-specific and are not redundant to each other.

'L There is alte.rnate shutdown capability should a fire occur near the RSPs; however, the alternate shutdown capability is based on the operability of at least one AFW pump per unit. For additional

~

inform tion on AFW pump separation, see Section 2.6.2.2. The minimum separation between the motor-driven AFW pumps and the RSPs is approximate 1*J 20 feet, whereas the distance between the turbine-driven pumps and the RSPs is approximately 30 feet.

~

2.6.2.4 Service Water Pump Power Cables The power feeds for the service water (SW) pumus enter on the 579-foot elevation in Fire Zone 11.3-0. They are routed in metal enclosed risers along the turbine / auxiliary building interface prior to entering the cable spreading room on the 630-foot elevation.

A minimum of 147 feet separates the SW power feeds, of which at least 20 feet is free of intervening combustibles. Ionization smoke

_ detectors are provided between the power feeds on the 579-foot elevation.

2.6.2.5 Steam Generator Pressure Transmitters Cabling for redundant steam generator pressure transmitters is routed along the south wall of this elevation up to the cable spreading room on the 634-foot elevation. A minimum of 120 feet of separation exists between the cabling, of which at least 20 feet is free of intervening combustibles. Ionization smoke detectors are provided between the power feeds on the 579-foot elevation. The Licensee has committed to provide alternate indication for steam generator pressure via a mechanical gauge that will be installed in Fire Zones 18.5-1 and 18.5-2.

2.6.2.6 RHR Pump Cables The cables associated with the RHR pumps on the 579-foot elevation are separated by approximately 200 feet. The Licensee has committed to maintain sufficient qualified cable onsite and to formulate repair procedures to replace the cables of one RHR pump after a fire, before the pumps are needed for cold shutdown. For additional information, see section 2.4.

i - -

\

I

, TER-C5506-619 j 2.6.3 Evaluation The fire protection for the' auxiliary building fire area does not comply with the technical requirements of Section III.G.2.b because automatic fire suppression and detection systems are not installed throughout the area and 20 feet of separation free of intervening combustibles does not exist between redundant safe shutdown components located at the 579-foot elevation of the auxiliary building fire area.

The principal concern with the level of f,, ire protection was that, because of the absence of an area-wide automatic suppression system, a fire of significant magnitude could damage redundant safe shutdown systems. The Licensee has stated that AFW control circuits are not required for manual operation of the pumps.

, However, the speed of the turbine-driven pumps is manually l controlled by a governor valve located at the pumps. There is j concern that due to the close proximity of the motor-driven and l- _ turbine-driven pumps and their associated local application Co l

systems, access to this valve could be restricted in the event 2,f 3 fire at the motor-driven AFW pumps. There is also a concern that several safe shutdown components and circuits are located in close proximity on this elevation. The southern portion of Fire Zone 11.3-0 contains all three Unit 1 AFW pumps, both trains of CCW power feeds, steam generator pressure cables, and SW pump power feeds.

Ionization smoke detectors in this area of Fire Zone 11.3-0 are not located in accordance with NFPA 72E. Due to the ceilings'

- height, construction, and obstructions, there is no reasonable assurance that a fire in this area will be detected in its incipient stage. In the event of a fire in this location, the close proximity

_ .. of the AFW pumps and the operation of the local CO fire suppression systems could hinder fire brigade operations in th$ area and access to the required governor valve.

2.6.4 Conclusion Based on the above evaluation, it is concluded that the existing level of fire protection in conjunction with the committed modifications on the 579-foot elevation of the auxiliary building has not been shown to provide a level of fire protection equivalent to l*

the technical requirements of Section III.G.2.b of Appendix R.

l Therefore, the exemption request for the 579-foot elevation of the

( auxiliary building fire area should be denied.

2.7 AUXILIARY BUILDING, ELEVATIONS 592, 617, AND 642 FEET 2.7.1 Exemption Requested Exemptions were requested from the requirements of Section III.G.2.b to the extent that it requires area-Wide automatic suppression and detection systems and 20 feet of separation free of intervening combustibles between redundant safe shutdown components.

TER-C5506-619 P 2.7.2 Discussion Elevation 592 feet of the auxiliary building contains 12 fire zones. Safe shutdown components consist of cabling associated with the Units 1 and 2 RHR, CCW, AFW, centrifugal charging, .ard SW pumps, ~

and steam generator pressure instrumentation.

Cabling for these components passes through this elevation prior to entering the cable spreading room. A minimum separation of 20 feet without intervening combustibles exists between the cables of redundant components as the cables pass through this elevation, with the exception of the steam generator pressure dnstrumentation. The Licensee has committed to install a mechanical steam generator pressure gauge outside of this area and to implement a repair procedure for RHR pump power cables. Refer to Sections 2.4 and 2.5 for additional information.

Ionization smoke detectors are provided in the area of these cables on the 592-foot elevation.

Elevation 617 feet of the auxiliary building contains 13 fire

~

zones. Fire Zone 11.5-0, which encompasses the main open floor area of this elevation, contains the same cabling as the 592-foot elevation. Ionization smoke detectors are provided in the areas of and between the redundant cables. A minimum sc7aration of 20 feet free of intervening combustibles exists between redundant cables.

Fire Zone 11.7-0 is the only fire zone on the 642-foot elevation of the auxiliary building fire area. No safe shutdown components are located on this elevation of the fire area.

2.7.3 Evaluation The fire protection for auxiliary building elevations 592, 617, and 642 feet does not comply with the requirements of Section III.G.2.b because automatic fire suppression is not installed throughout the fire zones.

The principal concern with the level of fire protection was that, because of the absence of an area-wide automatic suppression system, a fire of significant magnitude could damage redundant safe shutdown s'ystems.

Fire detectors which alarm in the main control room are located I

in the areas of and between redundant rafe shutdown cables on these elevations. Upon detection of a fire, the fire b*1gade would be dispatched to extinguish the fire with the hose 1.~.nss or portable extinguishers that are provided.

Significant spatial separation free of intervening combustibles exista between redundant cabling on these elevations. Also, there are intermediate noncombustible barriers. Until the fire is

, extinguished, the spatial separation and intermediate barriers between safe shutdown cables, the low combustible loadings, and the

,. TER-C5506-619 I

ionization smoke detecdors provide sufficient protection to ensure that one safe shutdown division would remain. free of fire damage.

2.7.4 Conclusion -

Based on the above evaluation, it is concluded that the~ existing level of fire protection on the 592 , 617 , and 642-foot elevations of the auxiliary building fire area provides a level of fire protection equivalent to the technical requirements of Section III.G.2.b of Appendix R. Therefore, the exemption request for these elevations of the auxiliary building fire area.can be granted.

2.8 MAIN CONTROL ROOM (FIRE ZONE 2.0-0) 2.8.1 Exemption Requested An exemption was requested from the requirements of Section III.G.3 to the extent that a fire in the main control room could result in fire damage to both unit's control boards simultaneously.

~

2.8.2 Discussion Fire Zone 2.0-0 is the main control room for both units,. It is located on elevation 642 feet of the auxiliary building and contains the normal and ESF control boards for the operation of both units.

For additional information concerning the main control room, refer to Section 2.2.

The Licensee's justification for an exemption to the extent that

~

a fire in the main control room could result in fire damage to the control boards of both units simultaneously included the following:

a. An area-wide fire detection system is provided.

b. Manual fire suppression equipment is provided (fire extinguishers and hose stations).

c. The control rooms are continuously manned.

d. Alternate safe shutdown procedures have been developed for evacuation of the main control room.

The Licensee's evaluation assumes that the unit affected initially by the fire in the main control room will be shut down by using alternative shutdown capability. Effects of smoke spread on the unaffected unit such that spurious operations could occur are not assumed. The Licensee has stated that smoke propagation is the most likely mode for transmitting fire effects between units.

During the site visit, the Licensee stated that sufficient operators would be available to shut down the unaffected unit, assuming spurious actuations within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. In a letter dated February 18, 1986, the Licensee estimated that the time for the smoke

1 TER-C5506-619 l l

- layer to reach the unaffected main control boards, given no fire brigade or operator response, is approximately 22 minutes based on an assumed fire scenario.

l 2.8.3 Evaluation _{ .

l The fire protection in Fire Zone 2.0-0 does not comply with the 1 technical requirements of Section III.G of Appendix R because safe l shutdown of both units is not possible if both main control boards l

are damaged simultaneously and evacuation becomes necessary.

The Licensee has not demonstrated that a Tire in one control room or in the common corridor would not affect both control rooms simultaneously and/or cause simultaneous evacuations. Factors to be considered include heat and smoka propagation, fire hose use, corrosive vapor products, and transient fire hazards such as temporary storage of paper and plastics. Generic Letter 86-10 states, in part, that "The damage... in the control room for a fire

... cannot be predicted."

Two control rooms in a single fire zone represent a significant risk given the parameter of an alternative shutdown manpower shortage. There is no reasonable assurance that a single fire incident will not affect both control rooms simultaneously; *

! therefore, an acceptable level of fire protection equivalent to l Section III.G of Appendix R does not exist.

2.8.4 Conclusion l

Based on the above evaluation, it is concluded that the existing level of fire protection in the control roca area has not been shown to provide a level of fire protection equivalent to the technical i requirements of Section III.G.3 of Appendix R to the extent that fire damage to only one control board can be assumed. Therefore, this exemption request should be denied.

2.9 REACTOR COOLANT PUMP LUBE OIL COLLECTION SYSTEM (FIRE ZONES 1.3-1 AND 1.3-2) 2.9.1 Exemption Requested An exemption was requested from the requirements of Section III.O to the extent that it requires the reactor coolant pump (RCP) lube oil collection system to be capable of collecting lube oil from all pressu.rized leakage sites and qualified to withstand a safe shutdown earthquake.

2.9.2 Discussion There are four RCPs per unit, each of which has a self-contained lubricating oil system of approximately a 265-gallon capacity.

A lube oil collection system has been installed at each pump.

The collection system consists of a set of catch basins, drip pans, l

TER-C5506-619 and enclosures assembled as~ attachments to the pump to contain or catch any leaking oil. The oil is then directed to a main ring header connecting the collection system of all four pumps via rubber hoses. The main ring header, with an approximate capacity of 68

-110.3, ends in a capped discharae pipe that penetrates -the missile wall.

The Licensee has committed to install a new pipe from the lube oil collection system ring header to the spare cavity flood system sump located in the basement of the containment at the 568-foot elevation. This sump has a capacity of 5,000 gallons, which exceeds

>r the total lube oil inventory for all RCPs. The spare cavity flood sump is vented to the containment atmosphere and will be provided with a flame arrester. This new pipe and the main ring header have been analyzed to ensure that this portion of the collection system meets the requirements of Appendix R,Section III.O.

l The existing lube oil collection system is designed to collect i

oil resulting from low pressure leaks. The only source of high-pressure leaks is the lift pump. The lift pump is pressurized only when it is operating during initial RCP start-up. Once the RCPs are operating, the lift pump is secured and the high pressure is relieved.

The Licensee has stated that the lift pump runs for 5 minutes or less for initial start-up and is totally contained by the oil collection casing. The lift pump is operating when the RCP is at low temperature, maintaining the temperature of the lube oil below its flash point.

The oil collection system is designed to keep oil leakage away from hot spots on the pump, the pump motor, and other RCP hot

.. surfaces. The leakage points protected include 4-inch connectors, drain plugs, fill points, upper and lower reservoirs, site glasses, lift pumps, and external oil coolers.

The Licensee has committed to implement administrative procedures requiring an operat,or to be near each RCP on all starts in order to notify the main control room of any problems, noises, or

hazards.

As previously stated, the main ring header for the lube oil collection system is seismically qualified, with the exception of r

short sections of rubber hose that connect the collection system to the main header. The Licensee has stated that the rubber hose is flexible to withstand some measure of vibration.

Four ionization smoke detectors are provided over each pump. In i

addition, other means are available to the plant operator _s for fire detection such as high RCP bearing temperatures, abnormal. oil reservoir levels, and increasing pump vibration readings.

l i

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

T TER-C5506-619 2.9.3 Evaluation The RCP lube oil collection system does not comply w,ith the technical requirements of Section III.O of Appendix R because the entire system is not capable of collecting oil from all pressurized leakage sites, and there is no reasonable assurance that the entire system including the rubber hose connection will withstand an SSE.

The only source of a pressurized leak is the lift pump, which is totally contained within the RCP. The lift pump runs only during initial start-up, after which it is secured and the pressure is

!: relieved. The Licensee has committed that an operator, in direct communication with the main control room, will be near each RCP on all starts.

The lube oil collection system is deemed seismically qualified with the committed modifications incorporated, except for short sections of rubber hose that connect the collection system to the

. main header. The Licensee's justification is that the rubber hose is flexible and will withstand some measure of vibration in case of a seismic event. The effects of an oil leak at the hose during an SSE were not evaluated. The Licensee has not shown that the lube oil collection system is capable of preventing a fire during normal and design basis accident conditions. There is no reasonable assurance that oil from all potential pressurized and unpressurized leakage points would be safely collected and drained into the sump.

Additional guidance concerning oil collection systems for RCPs can be found in Generic Letter 86-10.

2.9.4 Conclusion Based on the above evaluation, it is concluded that the Licensee has not demonstrated that the existing fire protection features combined with the proposed modifications provide a level of fire protection equivalent to the technical requirements of Section III.O of Appendix R. Therefore, the exemption request for the RCP lube oil collection system in Fire Zones 1.3-1 and 1.3-2 should be i

denied.

2.10 MAIN STEAM PIPE TUNNEL (FIRE ZONES 18.5-1 AND 18.5-2) 2.10.1 Exemption Requested l

Exemp'tions were requested from the requirements of Section III.G.2.b.to the extent that it requires automatic suppression and detection systems throughout the main steam pipe tunnels (Fire Zones 18.5-1 and 18.5-2).

2.10.2 Discussion '.

l l Fire Zones 18.5-1 and 18.5-2 are the main steam pipe tunnels (1 per unit) and main steam valve houses (2 per unit) for Units 1 and 2, respectively. Each zone contains all three divisions of steam generator pressure transmitters and associated cabling.

l .___. _ _ _ _ _ _ - - . --- .

TER-C5506-619 The pressure transmitters for loops A and C are located in the lower level of the east main steam valve house; and loops B and D are in the lower level of the west adin steam valve house. Also contained in each zone are the main steam lines, the main. steam isolation valves (MSIVs), the atmospheric steam dump valvps, and the main steam code safety valves. -

The main steam pipe tunnels and the upper sections of the main

,- steam valve house of Fire Zones 18.5-1 and 18.5-2 are free of combustible material. The combustible loading in these two zones is contained entirely within the lower sections of each main steam valve house. The combustibles consist of 30 gallons of hydraulic fluid in une Msiv nyaraulic units. This results in an equivalent fire severity of 21 minutes in the lowar MSIV compartments.

The lower level of the east main steam valve house contains the steam generator pressure transmitters for loops A and C, and the lower level of the west main steam valve house contains those for j _

loops B and D. The pressure transmitters and associated cabling for

. loops A and D are considered redundant. Cabling for the pressure transmitters is routed from the respective main steam valve house into the main steam pipe tunnel and enters the auxiliary building.

The cabling for redundant pressure transmitters is routed within close proximity to each other in the main steam pipe tunnel.'

, The main steam valve houses, which contain the pressure

- transmitters, are separated by approximately 150 feet. Should a fire originating in a valve house propagate into the main steam pipe tunnel, there is potential for damage to all pressure transmitter cables.

To ensure that the steam generator pressure indication is maintained, the Licensee has committed to install a mechanical gauge to provide alternate steam generator pressure indication. The gauge will be located such that access is available in the event of a fire in these zones.

2.10.3 Evaluation g Fire Zones 18.5-1 and 18.5-2 do not comply with the technical d requirements of Section III.G.2.b because full area automatic i suppression and detection systems are not installed in the zones.

The principal concern with the level of fire protection was that because of,the absence of fire detection and suppression systems, a fire of significant magnitude could damage redundant steam generator pressure indication transmitters and cables.

However, the combustible loading in these zones is low. The principal combustible is hydraulic fluid located within the lower portion of the main steam valve houses. There are no intervening combustibles between the valve houses and the main steam pipe tunnel containing cabling for all four steam generator transmitters.

ELE P E E

r

- . . __ --------s--

. 7 . - _.

W w - - _

TER-C5506-619 2.11.3 Evaluation A review of the evaluation indicates thst the level of fire protection for the identified areas has not been shown to,be equivalent to that achieved by compliance with the technical requirements of Section III.G of Appendiy R. The principalP concerns with the analysis include:

o The equivalent fire severity based strictly on the total energy available within the space was used to calculate the expected fire duration. The fire duration is not representative of the actual burn rates for the combustibles I installed, o The effects of localized heating on unprotected structural steel due to direct exposure to fire plumes from localized combustible packages were not evaluated. The Licensee's statement that their structural steel analysis was deemed to

_ be a greater threat to barrier integrity than direct exposure

, to flames or a plume arising from burning material does not provide reasonable assurance that failure of steel due to localized effects will not occur.

2.11.4 Conclusion -

Based on the above evaluation, it is concluded that the existing level of fire protection has not been shown to provide a level of fire protection equivclent to the technical requirements of Section III.G.2.a of Appendix R. Therefore, this exemption request for unprotected structural steel should be denied.

a 6

S

~

. TER-C5506-619 Redundant pressure transmitters are separated by over 150 feet with no intervening combustibles.

I The Licensee has committed to install a mechanical pressure l

gauge to provide alternate steam generator pressure indiqation in a ~

location that assures access in the event of a fire in these zones.

2.10.4 Conclusion l

Based on the above evaluation, it is concluded that the existing i

fire protection combined with proposed modifications provide a level

, of protection equivalent to the technical requirements of Section III.G.2.b of Appendix R. Therefore, the exemption request from the requirement for fixed fire suppression and detection systems throughout Fire Zones 18.5-1 and 18.5-2 can be granted.

2.11 STRUCTURAL STEEL i

2.11.1 Exemption Requested 1

Exemptions were requested from Section III.G.2.a to the extent that it requires structural steel forming a part of or supporting required fire barriers be protected to provide a fire resistance equivalent to that of the barrier.

2.11.2 Discussion The Licensee has identified several areas where required fire barriers do not meet the requirements of Section III.G.2.a because

- structural steel forming a part of or supporting a required barrier is not protected to provide fire resistance equivalent to that required of the barrier.

By letter dated July 27, 1985, the Licensee submitted a structural steel survivability analysis. Two methods of evaluating the impact of exposed structural steel on boundary fire barriers and safe shutdown system separation are discussed in the analysis. The first method describes the traditional passive and active fire protection concepts based on combustible loadings and automatic suppression and detection. The second method uses a thermal analysis model to evaluate the length of time that exposed columns and beams can withstand the ASTM E-119 test fire prior to failure. The evaluation compares this time with the actual fuel loads in each area. The computational method is devised to simulate an ASTM E-119 test fire to evaluate the performance of the exposed structural steel.

Tha effects of localized heating due to direct exposure by fire plumes from local combustible packages was not evaluated. The equivalent fire severity, which is based strictly on the' fuel load of the zone, and the area beneath the ASTM E-119 time-temperature curve were used to calculate the expected fire duration. The actual burn rates fer combustibles within each zone was not used.

TER-C5506-619

3. CONCLUSIONS i This section is provided to consolidate the results of the evaluation contained in Section 2 concerning the exemptio_ns requested by the Licensee from the requirements of Section III.G of Appendix R to 10 CFR 50 for Zion Station Units 1 and 2. It is not meant as a substitute for the specific conclusions reached in the various subsections of Section 2 for which the reader is referred to specific l

subsections.

Based on the evaluation, the level of fir's safety in the areas listed below is equivalent to that achieved by compliance with the technical requirements of Section III.G of Appendix R; therefore, the Licensee's request for the following exemptions can be granted:

~

1. Main Control Room, Fire Zone 2.0-0.

Lack of a fixed fire suppression system throughout the main

_ control room. Refer to Section 2.2 for detailed information.

2. Auxiliary Electric Equipment Rooms, Fire Areas 5.6-1 and l 5.6-2.

Lack of a fixed fire suppression system throughout each AEER. Refer to Section 2.3 for additional information.

3. Auxiliary Building, Component Cooling Water Pump Area,

- Elevation 560 Feet.

Lack of fixed automatic suppression and detection systems

. ,, and 20 feet of separation free of intervening combustibles between redundant safe. shutdown equipment for the 560-foot elevation of the auxiliary building fire area. Refer to Section 2,5 for additional information.

4. Auxiliary Building, Elevations 592, 617, and 642 Feet.

Lack of automatic fire suppression and detection systems and 20 feet of separation free of intervening combustibles between redundant safe shutdown components. See Section 2.7 for details.

5. Main Steam Pipe Tunnels (Fire Zones 18.5-1 and 18.5-2).

Lack of full area detection and automatic fire suppression.

Refer to Section 2.10 for more details.

Based on the evaluation, the level of fire safety in" the areas c by listed below has not been shown equivalent to that achiev~d compliance with the technical requirements of Sections III.G or III.O of Appendix R; therefore, the Licensee's request for exemption in these areas should be denied: -

. TER-C5506-619

1. Auxiliary Building, Auxiliary Feedwater Pump Area, Elevation 579 Feet.

7.ack of automatic fire suppression and detection systems and 20 feet of separation between redundant safe shutdown components on the 579-foot elevation of the auxiliary building fire area. Refer to Section 2.6 for additional information.

2. Main Control Room, Fire Zone 2.0-0.

r A main control room fire could result ~ in fire damage to both units simultaneously. Refer to Section 2.8 for additional information. .

. 3. Reactor Coolant Pump (RCP Lube Oil Collection System, Fire l Zones 1.3-1 and 1.3-2).

t l

Ability of the existing lube oil collection system to

_ collect pressurized spills and withstand a safe shutdown earthquake. Refer to Section 2.9 for additional information.

4. Structural Steel.

Structural steel forming a part of or supporting required fire barriers be protected to provide a fire resistance equivalent to that or the required barrier. Refer to Section 2.11 for additional information.

Based on the evaluation, the level of fire safety in the area l listed below meets the technical requirements of Section III.G.1.b of l_ .. Appendix R and, therefore, the Licensee's request for exemption from

. Section III.G.2.b is not necessary.

1. Auxiliary Building, Residual Heat Removal Pump Area, Elevation 542 feet.

Lack of automatic fire suppression and detection systems and 20 feet of separation free of intervening combustibles between redundant safe shutdown components on the 542-foot elevation of the auxiliary building fire area. Refer to Section 2.4 for additional information.

l

• 9 l

l

TER-C5506-619 t

4. REFERENCES

1. BTP APCSB 9.5-1 " Fire Protection Program," July 1981- (Standard Review Plan, NUREG-0800) -

y-

2. Appendix A to BTP APCSB 9.5-1, " Guidelines for Fire Protection for Nuclear Power Plants Docketed Prior to July 1, 1976," August i 23, 1976

3. Regulatory Guide 1.120, "Fira Protection Suidelines for Nuclear r Power Plants," Hovember 1977 l

l 4. 10CFR50, " Fire Protection Program for Operating Nuclear Power Plants," November 19, 1980

~

5. Appendix R to 10CFR50, " Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979," November .

19, 1980 -

6. Generic Letter 83-33, "NRC Position on Cartain Requirements of -

Appendix R to 10CFR50," October 19, 1983

7. Generic Letter 86-10, " Implementation of Fire Protection -

Requirements," April 24, 1986

8. Final Work Assignment No. 36, transmitted by M. Carrington (NRC) to Dr. S. Pandey (FRC) on July 17, 1985 i

,_ 9. Request for Information (RFI), transmitted by N. Ahmed (FRC) to J. Stang (NRC) on December 17, 1985.

July 3, 1986 9

l i

. _-- _ _ - . __ .. _. - _ _ _ _ - _. _.