ML20211P260

Safety Evaluation Accepting Util 860116 Request for Amend to License DPR-54,redefining Fire Area Boundaries Required to Be Operable to Separate safety-related Fire Areas & Reassessing Adequacy of Components in Fire Area Assemblies

ML20211P260
Person / Time
Site:	Rancho Seco
Issue date:	02/19/1987
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20211P226	List: ML20211P222 ML20211P260
References
GL-86-10, TAC-61485, TAC-61486, NUDOCS 8703020328
Download: ML20211P260 (14)

Text

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AtEai:hment.No.1- k FIRE PROTECTION SAFETY EVALUATION '

BY THE OFFICE OF' NUCLEAR REACTOR REGULATION _

SUPPORTING AMENDMENT NO.

-TO FACILITY OPERATI $ LICENSE NO. DPR-54 SACRAMENTO MUNICIPI:L UTILITY DISTRICT.

RANCHO SECO NUCLEAR GENERATING STATION 00CKET.N0. 50-312 I. INTRODUCTION A. DESCRIPTION OF PROPOSED ACTION

> The proposed action would amend Appendix A of the Technical' Specifications for the Rancho Seco Nuclear Generating Station by:

'(1) redefining fire area boundaries required to be operable to separate safety related fire areas or redundant safe shutdown trains; (2) re-assessing the adequacy of components in fire area boundary assemblies (fire doors, fire dampers and penetration seals) acting as sealin'g devices which are subject to Technical Specification Operability requirements; and (3) deleting certain

. original fire area boundaries and sea' ling devices;from the Technical-Specification Operability requirements. ,

By letter dated January 16, 1sSS, the licensee requested an NRC, evaluation of redesignated fir 3: area boundaries for five (5) plant.

-areas containing safe shutdown eduipment. These redesignated fire "

areas are a change from th'e licensee's designation of fire area.

boundaries identified as fire areas 1 through 74 in the original Fire Hazard Analysis Report dated in 1977 which were required to be maintained by th'd licensee through amendment no.19 of Facility Operating-License No. DPR-54 issued February 28, 1978. The redesignation of fire area boundaries reflects the licensee's re-evaluation..of fire area boundaries for compliance with 10 CFR 50, Appendix R and makes a request for relief from certain provision of amendment no.19 of Facility Operating License No. OPR-34.

Notice of Consideration of Issuance of Amendment to License and Proposed No Significant Hazards Consideration Determination and Opportunity for Hearing related to-t,he requested action was '

published in the Feder(l_ Register on . No com:nents or, requests for hearing were received.

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0703020328 870219 PDR P ADOCK 05000312 PDR 3

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B. 1 BACKGROUNO INFORMATION. -

- Follaingafirea't>the[ Brown'sFerryNuclearStationLin-March 1985, W. 'the staff initiated. an evaluation of the need foriimproving the fire  ;

-protection programs _at all: licensed nuclear. power plants.'-As a.

- result' of this- evaluation,- Amendment No.18_ to the. Operating License for the, Rancho Seco Nuclear _ Generating l Station (the facility) wash

, - issued'on. feb'ruary 14,E 1978.' This amendment added interim Limitin'g 4 - Conditionsz for Operation,Surveillan'e, c and Administrative -

6 _ -requirements for fire protection, tolthe facility technical z e > < -

specifications. ' These interim requirements were subsequently .

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modified by Amendment No. 35, dated August 20, 1981. 'Among other-4 . _

items, this' amendment revised the interim. specifications to~ reflect 1', -

the, completion of: plant modifications designed to' enhance fire

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'a InMbruary1981,.theCommissionreviseditsregulation'sby' adding ~

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Section'50.48 and Appendix R to 10 CFR 50. These new regulations 7

i formally defined;the administrative;and facility requirements .

necessary to satisfy Generalq Design, Criterion 3 (Fire Protection) of Appendix A to 10 CFR 50! As a' result of issuance ~of 10 CFR 50.48,.

the licensee' prepared an u'pdated, fire hazard analysis of the facility;to determinesif modif.ica'tions were necessary to provide

' conformance with the revised guidance. l Based on'information a; developed by this up' dated' analysis;in 1985, the. licensee determined

, that a number of fire' area boundaries could be revised such that a

-number of fire doors, fire dampers and penetration seals-included in

the. Limiting. Conditions-for Operations set forth in. facility

_ Technical Specifications > required by License Amendment No. 19 are no

• longer-requi. red.' '

e C. Discbssion - "

.s .m The licensee's. Updated Fire Hazard Analysis Report (UFHAR) contained in proposed amendment no. 137.to the FSAR re-evaluates fire area

a. boundaries identified in1the licensee's original (1977) Fire Hazard

Analysis Report (FHAR) (10 CFR 50 Appendix A review process) and re-defines-these fire areas' boundaries based on-fire hazard analysis

-performed in~accordance with NRC. guidance contained in Generic Letter 86-10 for110.CFR 50, Appendix; R compliance.

The<UFHAR deletes some.of the original:1977 FHAR fire area

, boundaries'and re-designate the area boundaries so that the original FHAR fire: area boundary" forms a part of the re-designated fire area and is identified as a sub-fire area within the re-designated fire area. The methodology used in'the UFHAR re-designated. fire areas-rely ,on design basis protective features as specified in section III.G. ~of Appendix R to 10 CFR 50 or analysis demonstrating

,. technical equivalency in accordance with the guidelines contained in x ' Generic Letter No._86-10. For Example:

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a 1 The UFHAR analysis for a given re-designated fire area considers the:

.. potential fire hazards.of the fire area and adverse consequences of

- " fire damage that'could be imposed on safe shutdown equipment:in the

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.. Jarea'. . Measures for mitigation of the adverse fire damage include

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distance between redundant safe shutdown trains, reliance on-K s installed fire detection and suppression hardware, installation-of additional . fire barriers or providing alternative. shutdown-capability that it, independent of the re-designated' fire area of Concern.-

Where 3-hour rated fire barriers were required by Appendix R and the original:(1977) FHAR for separation of redundant safe shutdown trains, the licensee's UFHAR' identifies and justifies the lack'of:

these^ protective features i by the results of analysis of expected

, fire potential ~on'either side of the barrier.with particular focus on the localiz' ed heating affects of. the ' lowest or non-rated '

= Lcomponent in the~ fire' barrier., Where the intensity and duration of-

'e s the analyzed fire potential exceeded the_ lowest rated or non-rated .

component in the fire barrier, the analysis assumes that redundant safe' shutdown trains located in adjacent fire areas could be damaged

', by.a fire in the area of concern'and requires upgrading of_the fire barrier, relocat J

'_i barrier wrap mate;on of additional:

rials or safe shutdown equipment, automatic additional detection and fire

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suppression..etc.,xin order to provide an equivalent. level of protection for-the safe shutdown equipment.

II. EVALUATION The fire hazard.analys'1E for'each of the re designated fire areas considers the fixed'and maximum expected transient fire potential'for the, area. The fire potentials'are calculated on the basis of the total fir'e

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potential of the re-designated fire area, as well as the_ fire potential'

_ contained in sub-fire' areas-within the re-designated fire areas. This was done to assure that'any;1ocalized higher fire potential within a sub-firetarea was recognized and evaluated individually rather than

< ^ analyzed as spread over.the total square footage of:the re-designated-fire area. The calculations used in the licensee analysis (Impell-  %

Corporation calc. no.: 142.-7-109/SMUD' calc. no. 2-FPP-M1846) were referenced in section 7,, item no. 27 of,the licensee's January 16,:1986f

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submittal to the NRC.

The licenseeirequested the staff's review of redesignat'ed fire are'as RG1, RG3, RT1, RBl~and RB2. By letter dated. November 4,1986, Region V was L , informed that NRR had concluded its: review of the licensee's requested

exemptions for fire areas:RB1,'RB2 and RG1. In addition to granting the licensee's exemption request for these fire areas, the staff also found'

the fire area boundaries for these areas acceptable. The fire hazard' analysis for redesignated fire areas-RG3 and RT1 have similar conditions-

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l-as those described.for re-designated fire areas RB1, RB2 and RG1 and are

[ described in the~UFHAR that is still under review by NRR.

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III. CONCLUSIONS: _

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Environmental ~ Consideration

,E This'amendmenkinvolvesachange'intheinstallationoruseofafacilityL 1

componentDlocated within the restricted area as defined in-10 CFR Part

'20. 1The staff has' determined that the amendment. involves no significant

. increase ~-in'the' amounts ~of any' effluents that may be-released offsite, and,that ~the're lis no significant increase 'in individual 'or ' cumulative occupational; radiation exposure. The Commission.has previously issued a proposed; finding that this. amendment involves no.significant hazards consideration:and there has been no public~ comment on such finding.

~Accordingly, this amendmentJmeets 'the eligibility criteria for. .

categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental

' assessment need be prepared in connection with the issuance of this amendment.

Based'on the above referenced. ongoing evaluation by the NRC,stdff, we:

conclude that the fire protection features and physical arrangements of re-designated fire areas RB1, RB2, RG1, RG3 and RT1 provide a level of protection equivalent to1the technical requirements of section III.G.2.a.

of' Appendix R.' Therefore, the licensee's request for relief ~from maintaining those fire barriers in sub-fire arear as= required by amendment no. 19 of Facility Operating License No..DPR-54 should be granted, provided the re-designated fire; area boundaries described in.the UFHAR containing the sub-fire areas covered.by Amendment No. 19 are ~

- maintained.in-accordance with the Technical Specification Operability

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requirements of . Technical Specification No. 3.14.6.

. Conclusion We have concluded, based on the considerations discussed above, that (1) there is reasonable assurance that the health and safety.of.the public will not be endangered by operation in the proposed manner, and (2) such activities will be conducted in compliance with the Commission's regulations, and the issuance of the amendment will not be-inimical to common defense and security or to the health and safety of the public.

Date:

~ Principal Contributor:

C.'.Ramsey, Region V l-.. <

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Attachment No. 2 >

l D-R-A-F-T F

Docket *No. 50-312

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-Mr. John. E. Ward '

Deputy General Manager, Nuclear Sacramento, Municipal Utility District-

-6201 S Street '

P.'0. Box 15830

. Sacramento, California 1 95813

SUBJECT:

AMENDMENT NO. TO FACILITY OPERATING-LICENSE N0. DPR-54 1 REDEFINED FIRE. AREA B0UNDARIES The Commission has^ issued the enclosed Amendment No. to Facility Operating License No. DPR-54 for Rancho Seco Nuclear Generating Station. This amendment revises the facility fire area boundaries in response to your application dated January 16, 1986.

The amendment revises the operability requirements for the fire' areas identified as RBI,-RB2, RG1, RG3 and RT1 as described in the Updated Fire Hazard. Analysis Report (UFHAR) as' proposed in Amendment No. 137 to the FSAR.

A copy of the Safety Evaluation is also enclosed. Notice of-Issuance will be included in the Commission's next regular bi-weekly Federal-Register notice.

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Sincerely, PWR Project Directorate No. 6 Division of Pressurized Water Reactor Licensing-B, NRR

Enclosures:

1.  ; Amendment No. to DPR-54

2. Safety Evaluation ,

cc w/ enclosures:

see next page 4.

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. Attachment.No.'3- -

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n,o ,j SACRAMENTO MUNICIPAL UTLITY' DISTRICT - ~

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DOCKET'NO. 50-312 e .,

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' AMENDMENT TO'FR ILITY'0PERATING'LICEN'SE.- s b -

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Amendmerit No. .

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- . . License No. DPR-54:

J 1. The Nuclear. Regulatory Commission (the . Commission);h'as found that: '

? - A .' ;The application'for amendment 1by Sacramento Municipal Utility-District (the licensee) dated January 16, 1986,. complies with the W '

standards andlrequirementsrof.the Atomic Energy:Act of.1954~,'as. . + m amended (the Act), an'd the Commission's rules.and r'egulations set ,

'forth-in 10 CFR Chapter I;.

B. The facility will operate-in conformity with therapplication':the ,

provisions of.the Act, and the rules-~and.. regulations-of the. '

-Commission; t .

C. 'There;isreasonabeassurance(i)thattheactivitiesauthorizedby.

this amendment:can be conducted without endangering the health and

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safety 1of the public, and (ii).--that such activities will be > '

conducted in compliance ~with?the' Commission's regulations;

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'n~ -D. ' The issuance oftthis amendment.'will not be. inimical to the common

' . -defense _land's'ecuri.ty'or tolthe' health.and safety ofzthe public; 2 '

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E.*:Theisdu'anceYofthisamendmentis-inaccordancewith'~10CFRPart51' ofsthe' Commission's ' regulations and"all applicable' requirements have~ >

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'2..Thislicenseameddment"iseffective'asEf;its.dateofissuance. -

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1 FOR THE NUCLEAR REGULATORY ~ COMISSION

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. -PWR Project Directorate No. 6 Division ~of Pressurized Water Reactor.

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Licensing-B, NRR i' ' .

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Attachment:

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l Changes to Plant Fire Area Boundaries Required by Appendix R to 10 CFR 50 L,-

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Date of Issuance:

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t Attachment No. 4 RANCHO SECO UNIT 1 TECHNICAL SPECIFICATION Limiting Conditions for Operation J 3.14.6 Fire Rated Assemblies Specification

.3.14.6.1 All fire rated assemblies (walls, floor / ceilings, cable tray enclosures and other fire barriers) separating safety-related' fire areas or separating portions of redundant systems important to safe shutdown within a fire area and all sealing-. devices in fire rated assembly (fire doors, fire windows, fire dampers, cable, piping, and ventilation duct penetration seals) shall be OPERABLE.

-3.14.6.2 With one or more of the above required fire rated assemblies and/or sealing devices inoperable, within one hour either establish ~a continuous fire watch on at least one side of the affected assembly, or verify the OPERABILITY of fire detectors on at least one side of the inoperable assembly and establish an hourly fire watch patrol.

' Restore the inoperable fire rated assembly and sealing device to OPERABLE within 7; days or, in lieu of any other reports required by Specification 6.9, prepare and submit a Special Report to the Commission pursuant to Specification 6.9.5.E within the next 30 days outlining the action ~taken, the cause of the inoperable fire rated assembly and/or sealing device and plans and schedule for restoring the fire assembly and sealing device to OPERABLE status.

Bases

'0PERABILITY of all fire detection instrumentation ensures that adequate warning capability is available.for the prompt detection of fires. This capability is required'in order to ' detect and locate fires in their early stages. Prompt detection of fires will reduce the potential for damage to safety-related equipment or' redundant systems important to safe shutdown and is an-integral element in the overall facility fire protection program.

In the event that a portion of the fire detection instrumentation is inoperable, the establishment of frequent fire patrols in the affected areas is required tol provide detection capability until the inoperable instrumentation is returned to service.

The OPERABILITY of the fire suppression systems ensures that adequate fire suppression capability is available to confine and extinguish fires occurring in any portion of the facility where safety-related equipment or redundant systems important to safe shutdown is located. The fire suppression system consists of the water system, spray and/or sprinklers, CO2, and fire hose stations. The collective capability of the fire suppression systems is adequate to minimize potential damage to safety related equipment or redundant systems important to safe shutdown and is a major element in the facility fire protection program.

2 In the event that portions of the fire suppression systems'are inoperable, alternate. backup fire fighting equipment is required to be made available in the affected areas until t,he affected equipment can be restored to service.

In the event that the fire suppression water system becomes inoperable,

..immediate corrective measures must be taken since this system provides the major fire suppression capability of the plant. The requirement for a twenty-fourf(24) hour report to the Commission provides for prompt evaluation of the acceptability of the corrective measures to provide adequate fire suppression capability for-the continued protection of the nuclear plant.

The integrity of fire rated assemblies ensures that fires will be confined or adequately retarded from' spreading to adjacent portions of the facility. This design feature minimizes the possibility of a single fire rapidly involving several areas of the facility prior to detection and extinguishment. The fire rated assemblies are.a passive element in the facility fire protection program and are subject.to periodic inspections. During periods of time when the fire rated assemblies are inoperable, an hourly or continuous fire watch, as appropriate, is required to be maintained in the vicinity of the affected assembly until the assembly is restored to operable status.

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, RANCH 0LSECO UNIT 1 TECHNICAL ~ SPECIFICATIONS

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Surveillance Standards

'Once perf312 days byfvisual inspection of the station to assure

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all equipment-is_available at the station.

b. $0nceper18'm'onthsin'spect.andreplaceallgasketsinthe -

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' couplings.that-are degr'aded, and remove the hose for inspection

'r; and re-racking. .

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Once'per three (3)_ years, partially open hose station valves to verify valv,e operability and have no valve blockage.

, d. -0nce per three (3) years by removing and replacing all hose with new hose that meets or exceeds NFPA guidelines or

> recommendations.

4.18.6 - Fire Rated Assemblies 4.18.6.1 Each of the fire rated assemblies specified in Section 3.14.6.1 shall be verified to be functional:-

i a. At least once per 18 months by a visual inspection.

b. Prior to returning a fire rated ~ assembly to functional status following' repairs or maintenance by performance.of a functional ~

test of the non passive' components of the affected fire rated assembly (s).

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Attachment No. 5-4 ATTACHMENT T0'LIC'ENSE AMEN 0 MENT NO. 1 ,

l FACILITY OPERATING ~ LICENSE ~NO. DPR-54 F DOCKET NO. 50-312-

, . TABLE.OF REDEFINED FIRE AREA BOUNDARIES

'Reyise designated fire area boundaries required by-Amendment No! 19 to Facility Operating' License No. DPR-54.to be redefined as follows:

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' Redefined. Amendment No. 19 '

Fire Area ' Designated Fire' .  : Room' LNo. Description Area (Sub-Fire = Area)' Numbers AUXILIARY BUILDING The following are sub-fire areas of Appendix R fire area RB1:'

RBl . West Containment Penetration' 49 '052 Valve Area ,

RB1 -East Containment Penetration' 50 045, 051-Valve Area RB1 .Radwaste Air Supply. Fan Room 51l- 050

- RBl . Seal' Return Cooler Room 52 046[049 RB1 Makeup Pump Room' ~58 044 RB1 Spent Resin Tank Room 60 047, 048 The following are sub-fire areas'of-Appendix R fire area RB2:

RB2' . Waste Gas Compressor Room 40' 022 J7 RB2 -Waste Gas Decay Tank Room- 41 018 RB2 Miscellaneous Waste Gas < _ 42- 021 Condensate Tank Room RB2  ::Deboration' Ion' Exchange and ' 43 019, 059

. Miscellaneous ~ Waste Condensate '

'Demine'ralizer Room ,

-RB2- Miscellaneous Waste ,

44 023, 024

' Concentrator Room RB2 Bor,ic Acid Evaporator Room 45 025

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Redefined , Amendment No. 19 Fire Area e Designated Fire Room No. Description Area (Sub-Fire Area) Numbers-RB2 Main Corridor --Below Grade '46 011, 012, 013, 015, 016, 020, 036, 057, 058, 107, 111 RB2 Ion Exchange Valve Area 53 027-035

-RB2 Miscellaneous Waste Filter 54 026 Room RB2' Tank Rooms - Below Grade 55 037-042 RB2- Train B High Pressure- 59 043 Injection Pump Room RB2 Miscellaneous Waste Tank Room 66 014, 017 The following are sub-fire areas of Appendix R fire area RG1:

RG1 Air Conditioning Equipment Room 22- 202, 204, 228 RG1 Electrical Penetration Area / 34 106, 109, Chemical Storage Balcony 110, 114, 117, 118, 133, 136 RG1 Hot Machine Shop 35 134 RG1 Waste Solidification Area 39 112 RG1 Makeup Tank Room 65 113 The following are sub-fire areas of Appendix R fire area RG3:

RG3 Elevator No. 2 63 129, 221, 346 RG3 Elevator Machinery Room 70 128 The following are sub-fire areas of Appendix R fire area RM1:

RM1. Sample Cooler Chiller Room 23 225

.RM1 North Communication Room 24 224N, 227 RM1 South Communication Room 25 224S RM1 Storage Room 26 223 RM1 Main Corridor - Mezzanine Level 29 206, 207, 226

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' Redefined'

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Amendment No. 19 Fire Area ~ Designated Fire- Room No. Description -Area (Sub-Fire Area) . Numbers- -

The following are sub-fire areas 1of- Appendix R fire area RT1:

RT1: Health Physics Office 3 330,'331, 332'-

RT1-- Clean Locker Room 4- .304, 308,

', _ 305, 306, 353'

. c RT1 Conference Room 5 349, 352 RT1 Storage Room 7 325

. , RT1 ' Chemical Laboratory 8 327, 328.

.RT1 Radiological Chemistry 9- 319, 320, 321 Laboratory

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= RT1' Calibration and Source 10 324

' Storage Room -

a RT1 . Chemical Storage Room. 11 -323

t iRT1' Fuel Storage Building Access 11 2 322W

- ' Corridor .

RT1 Reactor Building Access Area 13 309, 314, 316, 317, 350,'351,

-322E RT1 Main Corridor - Turbine Deck 14 302, 303, 329 1

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Attachment No. 6 SALP INPUT FOR COMPLETED SER Organization Preparing SALP Input: Region V Facility: Rancho Seco Docket Number: 50-312.

Phase: Outage SER

Subject:

Redefined Fire Area Boundaries TAC Number: 61485 Licensing Activities Functional Area:

Evaluation Criteria

1. Management Involvement in Assuring Quality The licensee's submittal was extremely thorough, complete and accurate.

It therefore appears there was sufficient management involvement to assure submission of a quality application for license amendment.

Rating: Category 1

2. Approach to Resolution of Technical Issues from a Safety Standpoint The licensee applied conservative criteria in resolving technical questions involving safety.

Rating: Category 1

3. Responsiveness to NRC Initiatives The licensee's request for evaluation of redefined fire area boundaries as a result of completing an upgraded fire hazard analysis indicates a high degree of responsiveness to NRC guidance. The licensee was also responsive to a staff request for additional submittals.

Rating: Category 1

4. Reporting and Analysis of Reportable Events The licensee has promptly reported inoperable fire rated assemblies through numerous special reports and LERS. The licensee analyzed each fire rated assembly component and initiated the limiting conditions for operation required by technical specification no. 3.14.6.

Rating: Category 1

5. Staffing (Including Management)

The quality of the licensee's submittal indicates ample staffing was available to perform this task.

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Trainihg.andQualification'Effectivene'ss

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_ . , e The~high, quality of.the;11ce'nsee's. submittal indicates the training and.- ~

'...- Squalifications;of> the= individuals '

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' 's Rating:-Category;1.' ' ' -

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