ML20212B011

Safety Evaluation Granting Util Request for Exemptions from App R Requirements Re Separation of Cables & Equipment & Associated Circuits

ML20212B011
Person / Time
Site:	Beaver Valley
Issue date:	11/30/1986
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20212A836	List: ML20212A832 ML20212A913 ML20212B011
References
NUDOCS 8612290126
Download: ML20212B011 (14)

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', UNITED STATES P' 7, NUCLEAR REGULATORY COMMISSION

{ $ WASHINGTON, D. C. 20555 4.,,,l SAFETY EVALUATION RY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATIVE TO APPENDIX R EXEMPTIONS RE00FSTED FOR DUQUESNE LIGHT COMPANY REAVER VALLEY POWER STATION UNIT 1 DOCKET NO. 50-334

1.0 INTRODUCTION

By letter dated June 30, 1082, Duquesne Light Company (DLC, the licensee) requested exemptions from Section III.G of Appendix R to 10 CFR Part 50 for Beaver Valley Power Station Unit 1. The requested exemptions were granted on March 14, 1983. By letter dated December 16, 1983, the licensee requested exemptions for nine additional fire areas; eight of those were granted on August 30, 1984 By letter dated January 14, 1985, as supplemented by letters dated October 16, 1985, and October 28, 1986, the licensee requested yet additional exemptions. Information provided in these submittals as well as information gathered during a site visit on ilanuary 22, 1986 has been used in the preparation of this evaluation report.

This safety evaluation is based in part on the attached Technical Evaluation Report (TER) generated by a contractor, Franklin Research Center (FRC). This TER has been reviewed by the staff and it is in agreement with the conclusions reached in this safety evaluation.

Section III.G.1 of Appendix R requires fire protection features to be provided for structures, systems, and components important to safe shutdown and capable of limiting fire damage so that:

a. One train of systems necessary to achieve and maintain hot shutdown conditions from either the control room or emergency control station (s) is free of fire damage; and

b. Systems necessary to achieve and maintain cold shutdown from either the control room or emergency control station (s) can be repaired within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

Section III.G,2 of Appendix R requires that one train of cables and equipmant necessary to achieve and maintain safe shutdown be maintained free of fire damage by one of the following means:

a. Separation of cables and equipment and associated nonsafety circuits of redundant trains by a fire barrier having a 3-hour rating.

Structural steel forming a part of or supporting such fire barriers shall be protected to provide fire resistance equivalent to that required of the barrier.

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b. Separation of cables and equipment and associated nonsafety circuits of redundant trains by a horizontal distance of more than 70 feet with no intervening combustibles or fire hazards. In addition, fire detectors and an automatic fire suppression system shall be installed in the fire area.

c. Enclosure of cable and equipment and associated nonsafety circuits of one redundant train in a fire barrier having a I-hour rating. In addition, fire detectors and an automatic fire suppression system shall be installed in the fire area.

If the above conditions are not met,Section III.G.3 requires that there be an alternative shutdown capability independent of the fire area o' concern. It also reouires that a fixed suppression system be installed in the fire area of concern. These alternative reouirements are not deemed to be equivalent; however, they provide eouivalent protection for those con #igurations in which they are accepted.

Because it is not possible to predict the specific conditions urder which fires may occur and propagate, design basis protective features rather than the desion basis fire are specified in the rule. Plant-specific features may require protection different from the measures specified in Section III.G. In such a case, the licensee must demonstrate by means of a detailed fire hazards analysis that existing protection nr existing protection in con.iunction with proposed modifications will provide a level of safety eouivalent to the technical requirements of Section III.G of Appendix R.

In summary,Section III.G is related to fire protection features for ensuring that systems and associated circuits used to achieve and main-tain safe shutdown are frea of fire damage. Fire protection con #igura-tiens must either 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 station (si is free of fire damage.

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

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

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

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

Two of the exemptions (see Sections 2.0 and 3.0) from Section III.4 of Appendix R requested in the licensee's letter dated January 14, 1985 concern fire area boundaries. The acceptance criteria for fire area boundaries are delineated in Appendix A to PTP APCSB 9.5-1, not in Appendix R to 10 CFR 50. Deviations from Appendix A fire area boundary guidelines do not require exenotions. Accordingly, we have reviewed the two fire area boundary exemptions as deviations from Appendix A guide-lines, rather than as exemptions from Appendix P to 10 CFR 50.

2.0 FIRE DOORS 2.1 Exemptions Reauested Exemptions were requested from Section III.G.2 to the extent that it requires separation of cables and equipment and associated nonsafety circuits of redundant trains by a fire barrier having a 3-hour rating.

The licensee's exemption reouests specifically pertained to fire door assemblies in walls identified as fire area boundaries.

Section III.G.0 of Appendix R to 10 CFR 50 contains requirenents for the protection of hot shutdown components located within the same fire area.

It does not apply to fire area boundaries. Acceptable guidelines for establishment of fire area boundaries are set forth in Section D.1.(j) of Appendix A to BTD APCSB 9.5-1. Therefore, the # ire doors discussed in the licensee's request have been reviewed for conformance with Appendix /

guidelines.

2.2 Discussion The licensee has identified 24 fire areas whose boundaries contain fire door assemblies that do not have a fire resistance rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. A fire door assembly consists of the fire door (s), frame, and hardware.

Some of these assemblies were desianed and constructed as fire-rated assemblies but have been modified for security or flood control purposes, or have not been installed in strict compliance with nationally accepted standards. Other assemF'ies are not fire rated, but are similar to fire rated assemblies.

In all, one fire door and 10 door frames are not labeled, frames in 18 locations have been modified for security purposes, and frames in 8 locations have been otherwise penetrated by pipe or conduit. Several locations contain multiple deviations. A label is the identifying mark i applied to a product as evidence that it complies with the specified standards of the Underwriters Laboratories (UL) or other approval agency.

l Twenty-one of the ?4 fire areas, where these doors are provided, contain I

safe shutdown equipment. Fire door assemblies serving the other three l fire areas -- the PCA shop (Fire Area SR-11, the locker room (Fire Area 58-3), and the clean shop (Fire Area SH-li -- have been modified for security purposes.

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The combustible leading in 17 of these fire areas is 80,000 Rtu per square foot or less, which is eouivalent to a fire severity of up to 60

- minutes based on the ASTM E-119 time-temperature curve. Fire protection in these areas consists of portable extinguishers and manual hose stations.'

, In addition, smoke detectors are installed in the following fire areas:

the intake structure / Fire Areas IS-1 through IS-3), the control room complex (Fire Zones CR-1, -2, and -41, the emergency switchgear roor (Fire Area ES-2), the motor generator room (Fire Area MG-1), and the normal switchgear room (Fire Area NS-11 l The combustible loading in five of the 24 fire areas is between 80,000 and 120,000 Btu per square foot, which corresponds to a fire severity o#

i 60 to 90 minutes. Fire protection in these fire areas consists of portable extinguishers and manual hose stations. In addition, sprinkler systems are installed in the PCA shoo and the clean shop. Detectors are installed in the intake structure and detectors and a total floodino carbon dioxide system are installed in the cable spreading room.

The combustible loading in the remaining two fire areas is between 1?0,000 and 160,000 Btu per square foot, which corresponds to a fire severity of 90 to 120 minutes. Fire protection in these two areas (the east and west cable vaults, Fire Areas CV-1 and CV-?, respectively) consists of portable extincuishers, manual hose stations, heat and smoke ,

detectors, and total flooding carbon dioxide systems.

At the licensee's request, a UL representative visited the plant and inspected typical examples of each identified deviation to evaluate each deviation's impact on the labeling of the doors. On the basis of the UL evaluation, the licensee has made corrective modifications to several of these assemblies.

The licensee has evaluated the affected fire door assemblies (with the corrective modifications) and determined that they provide an adequate margin of fire resistance considering the fire loading on both sides of each of the assemblies. This evaluation is described in Section 11.18 of the licensee's January 14, 1985 submittal.

The licensee chose not to make corrective modifications to the affected door assemblies in the intake structure. The deviations applicable to the fire door assemblies between Fire Areas IS-1 and IS-2, between Fire Areas IS-3 and .IS-4, and from each of these fire areas to the exterior involve the installation of a pipe penetration through the frames.

UL recommended that the interior of all pipes and conduits penetrating fire door frames should be filled with a fire stop material. The pipes through the intake structure door frames convey pressurized air used to activate sliding flood doors located behind the fire door at each open-ing. The exterior of the pipe penetration has been made tight fitting, but the pipes cannot be sealed internally without interrupting the air supply.

Safe shutdown equipment in the intake structure consists of three river water pumps (in separate fire areasi of which only one is required for safe shutdown. In addition, two auxiliary river water pumps located in the separate auxiliary intake structure are available as backup systems.

Two fire pumps are also located in the intake structure in Fire Areas IS-2 ard 15 4 In case of fire in one of Fire Areas IS-1 throuoh IS-4, safe shutdown caoability would not be affected because redundant systems are available in other fire areas. In addition, the solid wall between Fire Areas IS 9 and IS-3 would prevent a fire in Fire Areas IS-1 or IS-P from spreadinc to Fire Areas IS-3 or 15 4 2.3 Evaluation The guidelines of Section D.1.(j) of Appendix A to BTP APCSB 9.5-1 are not met because a fire door is not labeled (1 locationi or because fire door frames are not labeled (10 locations), fire doors have been nodified for security purposes (18 locations), or fire doors have been penetrated by pipe or conduit (8 locations). Several locations contain multiple deviations.

Powever, the equivalent fire severity in each of the affected fire areas is less than 120 minutes and genera 10 'ess than 60 minutes.

The staff har reviewed the licensee's evaluation and concurs with the licensee's assessment that the existing fire door assemblies with the corrective modifications provide an adequate margin of fire resistance compared to the combustible loading in the affected fire areas, with one exception.

The exception to the fire resistance discussed above is the doors located in the intake structure. Due to the functional restrictions, the correc-tive modifications required to upgrade these doors are not possible.

However, these door assemblies, in conjunction with the resistance of the 3-hour fire-rated masonry walls, provide an adequate margin of fire resistance between redundant trains of safe shutdown systems. The staff therefore concludes that the intake structure door assemblies should be acceptable.

2.4 Conclusion Rased on the above evaluation, the staff concludes that the aforenentioned fire door assamblies, combined with the licensee's modifications, provide an acceptable level of protection in accordance with the guidelines of Section D.1(j) of Appendix A to RTP APCSR 9.5-1.

3.0 FIRE DAPPERS 3.1 Exemptions Peauested Exemptions were requested from Section III.G.2.a to the extent that it requires separation of cables and equipment and associated nonsafety circuits of redundant trains by a fire barrier having a 3-hour rating.

The licensee's exemption requests specifically pertained to fire dampers in ducts penetrating floors or walls identified as fire area boundaries.

Section III.G.2 of Appendix R contains requirements for fire protection within fire areas. it does not apply to fire area boundaries. Accept-able guidelines for the establishment of fire area boundaries are set forth in Section D.I.(j) of Appendix A to BTP APCSB 9.5-1. Therefore, the a Uected fire dampers have been reviewed for con'ormance with i Appendix A guidelines.

3.2 Discussion The licensee has identified 13 fire areas whose boundaries contain duct penetrations which are protected by fire dampers whose fire resistance cannot be demonstrated by test data or aporoval by a nationally recognized testing laboratory. The sub.iect fire dampers were shop-fabricated following the construction details of the Sheet Metal and Air Condition-ino Contractors' National Association, Inc. (SPACNA) fire damper program.

The SPACNA progran consists of a set of drawings and specifications for constructing fire dampers eligible to bear UL 1-1/2 hour fire rated damper labels. It also includes instructions for obtaining either UL or SMACNA labels for the damoers. The labels (UL or SMACNA) are the sole means of identifying whether dampers were constructed in accordance with the SMACNA program.

The licensee's submittal indicates that the shop-fabricated dampers do not comply with the SMACNA program because the blades are heavier, the pivot bracket is different, and a closure spring has been omitted from the installed dampers compared with the SMACNA design. Therefore, the dampers do not bear either the UL or SMACNA labels.

All of the affected fire areas contain equipment required for safe shutdown. Fire areas affected include the following:

o Emergency Switchgear Areas (ES-1 and ES-2) o Cable Tray Mezzanine (CS-11 o Main Steam Valve Room and Motor Control Center Room (MS-1) o East and West Cable Vault Areas (CV-1 and CV-2) o Upoer Ventilation Room / Purge Duct Roon and Steam Generator Blew Down Room (SGPD) o Primary Auxiliary Building (PA-1) o Normal Switchgear Roor (NS-1) o Motor Generator Deem (MG-1) o Process Instrument and Pod Position Roon (CR-41 o Pioe Tunnel Area (PT-11 o Auxiliary Feedwater and Quench Sprav Pump Cubicles (QP-1).

3.3 Evaluation The fire protection in the affected areas does not comply with the guidelines of Section D.1.(.1) of Appendix A to BTP APCSB 9.5-1 because duct penetrations are not provided with fire dampers having a fire resistance rating ecual to that required of the penetrated barrier.

The fire dampers are described by the licensee as being functionally eouivalent to the UL-tested ' ire dampers. However, the installed dampers do not bear the UL or SMACNA labels because they differ from the SMACUA design as discussed above. The effects of these differences in the desion of moving parts on damper performance have not been tested.

Therefore, the staff does not have reasonable assurance that the fire dampers will function as intended and that the fire barrier cuidelines of Section D.1.(j) of Appendix A are met.

3.a Conclusion Based on the above evaluation, the staff concludes that the existing fire dampers do not constitute an acceptable deviation from the guidelines of Section D.I.(j) of Appendix A to ETP APCSB 9.5.1. The licensee should provide fire test results for these fire dampers demonstrating that the fire resistance ratings in the configuration installed are equivalent to that required of the barriers in which they are installed. Therefore, the exemotion reouest should be denied.

4.0 CHARGING PUMP CUBICLE A (FIRE ZONE PA-1F), CHARGING PUMD CURICLE B (FIRE ZONE PA 1.01, AND CHARGING PUMP CURICLE C (FIRE ZONE PA-1H) d.1 Exemption Reouested Exemptions were requested fron Section III.G.P.b to the extent that it requires separation of cables and equipment and associated nonsafety circuits of redundant trains by a horizontal distance of more than 20 feet with no intervening combustibles or fire hazards, and to the extent that it requires an automatic fire suppression system to be installed throughout the fire area.

a.? Discussion The licensee has identified the following conditions which do not meet Section III.G.2.b: redundant charging pumps A B, and C are located in individual cubicles which provide at least 70 feet of horizontal separation between pumps. Each cubicle is protected by detectors, but automatic suppression systems are not installed ir the cubicles as required by Section III.G.2.b. One charging pump is required for safe shutdovm of the plant.

The prinary auxiliary building (PAB), Fire Area PA-1, is a single fire l area. It is located north of the fuel building, east of the pipe tunnel I

area / cable vaults and main steam valve area, and south of the service and control buildings. The east side faces the yard areas of the plant.

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4.2.1 Elevation 722 Feet, 6 Inches The charging pump cubicles are adjacent to each other on elevation 7??

feet, 6 inches of the PAB. The walls between the cubicles and the renainder of this level are 2-foot-thick reinforced concrete, except for 8-foot-wide by 3-foot-high ventilation openings from each cubicle to the corridor along the north side and an exhaust duct. The exhaust duct serves all three cubicles, starting in pump A cubicle and terminating in an exhaust shaft east of pump C cubicle.

In order to improve the fire separation between cubicles, the licensee has sealed the ventilation opening between pump B cubicle and the corridor on elevation 72? feet, 6 inches. The pump B cubicle opening is sealed with 12 inches of silicone foam.

The power cables for charging pump B are routed from B cubicle, south nn elevation 722 feet, 6 inches, up to elevation 735 feet, 6 inches where they run west and eventually exit the PAR. These cables are enclosed in 1-hour fire-rated barriers.

The licensee has installed fire dampers in the pump cubicle exhaust duct penetrations. The purpose of the damper installations is to isolate the affected cubicle from other cubicles in case of fire.

Manual hose stations and portable fire extinguishers are located on elevation 722 feet, 6 inches and on each flonr level throughout the PAR.

In addition, smoke detectors are installed within each charging pump cubicle.

Combustibles in each pump cubicle consist of approximately 50 gallons of lube oil. All cables in these cubicles are metal jacketed. The combusti-ble loading in each cubicle is approximately 32,000 Rtu per square foot, which is equivalent to a fire severity of 24 minutes based on the ASTM E-119 time-temperature curve.

Combustibles in the remainder of this level of the PAB consist of cable insulation. The combustible loading outside of the pump cubicles on elevation 722 feet, 6 inches is approximately 11,200 Btu per square foot, which is equivalent to a fire severity of 9 minutes on the ASTP E-119 time-temperature curve. Intervening combustibles in the form of cables in trays are only in the corridor outside of the cubicles.

The horizontal separation between redundant charging pumps A and C is approximately 23 feet (through the corridor north of the cubicles).

Charging pump B is seperated from the other redundant pumps by at least 40 feet of horizontal distance and a total of 25 feet of vertical separa-tion because of the sealing of penetrations for the individual pumps.

4.2.2 Eleva tio.t 735 Feet, 6 Inches Access to the cubicles is provided by hatches on elevation 735 feet, 6 inches. The licensee has installed removable fire barriers in the personnel access hatch openings at the 735-foot, 6-inch level of pump A and C cubicles. Pumps A and C hatch openings are sealed with 4-inch-thick

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l silicone foam slabs in steel frames. The staff concurs with the licensee's analysis that these seals have at least a 1-hour fire rating. The manufacturer's data also indicate that a 4-inch thickness of silicone foon is capable of achieving a 1-hour fire resistance rating.

The combustibles on elevation 735 feet, 6 inches include cable insulation and unbaled waste. The combustible loading is approximately 25,000 Ptu per square foot, which is equivalent to a fire severity of 19 minutes on the ASTM E-119 time-temperature curve.

4.3 Evaluation The fire protection in the charging pumo cubicles does not comp 1v with the technical requirements of Section III.G.2.h of Appendix R because redundant trains of cables and equipment and essociated nonsafety circuits are not separated by 20 feet of horizontal distance free of intervenino combustibles, and an automatic fire suopression system has not been installed.

The primary concern was that even though redundant charging pumps are separatad by a horizontal distance of more than 20 feet, the presence of intervening combustibles in the corridor and the absence of automatic fire suppressinn systems in or around the pump cubicles may result in a loss of safe shutdown capability.

A fire of significant duration or magnitude is not expected to occur on elevation 722 feet, 6 inches because the combustible loading in the pumo cubicles and the surrounding portions of the PAB is moderate to light.

In addition, the intervening combustibles between redundant pumps are only in the corridor outside of the pump cubicles and do not extend into the ventilation openings. Therefore, they do not provide a complete fire propagation path between redundant pumps.

Should a fire occur in a' pump cubicle, it is expected to be detected by the detectors which annunciate in the control room. The operators will dispatch the plant fire brigade to respond and extinguish the fire.

If the detectors do not operate, or if a fire should occur outside of a pump cubicle on the 722-foot, 6-inch level, it is expected that pump B would remain free of fire damage because it is separated from other

. portiens of this level by barriers with at least a 3-hour ' ire resistance l rating and because of the lack of a fire propagation path via intervening combustibles between pumps.

Should a fire occur on the 735 # cot, 6-inch level, it is expected that at least one of the pumps would remain #ree of fire damage because pumps A and C are separated from this portion of the PAB by fire barriers with at least a 1-hour fire resistance rating. In addition, the fire is unlikelv to propagate downward through the pump B cubicle personnel hatch. Pump B power cables are enclosed in 1-hour fire wrap.

Based on this evaluation, the staff concludes that with the installed

! fire protection features and the licensee-committed modifications, there 1

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is reasonable assurance that a fire originating in the PAB building will not prevent the plant from safely shutting down.

4.4 Conclusion Based on the above evaluation, the staff cor.cludes that the existino fire protection for the centrifugal charging pumps (except for the fire dampers discussed in Section 3.?), in conjunction with proposed modifica-tions, provide a level of fire protection equivalent to the technical requirements of Section III.G.2.c of Appendix R. Therefore, the exemp-tion request for the charging pump cubicles should be granted.

5.0 CONTROL ROOM / FIRE ZONES CR-1 AND CR-21 5.1 Exenption Recuested An exemption was requested from Section III.G.2.b to the extent that it requires separation of cables and equipment and associated nonsafety circuits of redundant trains by a horizontal distance of more than 20

feet with no intervening combustibles or fire hazards, and to the extent that it reoufres an automatic fire suppression systen to be installed th cughout the fire area.

5.2 Discussion The Unit I control room (Fire Zone CR-1) is in the control building located ncrth of the PAB, east of the service building, south of the turbine building, and west of the finit ? control room. It is on eleva-tion 735 faet, 6 inches, above the control room HVAC eouipment room (Fire Zone CR-?), the cable spreading room (Fire Area CS-1), and the normal switchgear room (Fire Area NS-1).

Fire Zone CR-1 is separated from the adjacent fire areas by 3-hour Tated fire barriers with all penetrations sealed to a 3-hour fire ratina except for fire doors 035-2 and S35-5, which have been modified as noted below.

Fire Zone CR-1 is not separated from Fire Zone CR-2 by fire-rated barriers 4 because there are no fire dampers in the ducts serving both zones. These ducts are in a masonry shaft.

The combustible contants of Fire Zone CR-1 consist of cable insulation and small amounts of paper. The combustible loading is approximatelv 5,800 Rtu per square foot, which has an equivalent fire severity of 4 minutes based on the ASTM E-119 time-temperature curve.

Fire Zone CR-? is located on elevation 713 feet, 6 inches, adjacent to i the cable spreading room (Fire Area CS-1) on the west and north sides, the process instrument and rod position roon (Fire Area CR-4) on the west side, and the cable tunnel (Fire Area CV-3) on the east side. Fire Zone CR-2 is separated from these fire areas by 3-hour fire-rated barriers, except for fire door S13-4.

The combustible contents of the Fire Zone CP-2 control room consist of cable insulation, lube oil, and charcoal. The combustible loading is

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approximately 39,000 Btu per square foot, which is equivalent to a fire severity of 29 minutes on the ASTM E-119 time-temperature curve.

The fire protection in Fire Zones CR-1 and CR-2 consists of fire detection systems installed throughout each zone, heat detectors in the HVAC system filters in Fire Zone CR-?, manual hose stations, and portable fire extinguishers.

The licensee has identified the following conditions which do not meet Section III.G.2.b: Control circuits for train A emergency diesel generetor are located in the control room, and power cables for train B emergency diesel generator are located in the control room's adjoining HVAC eaufpmant room. One train of emergency diesel generator circuits is required to achieve safe shutdown.

The redundant safe shutdown circuits are separated by a vertical distance of at least 20 feet and a horizontal distance of at least 45 feet (between the duct shaft and the bench board in the control room).

Intervening combustibles consist of cable insulation in the control room and in the control room's HVAC equipment room, but not in the ducts or duct shaft that connect the two rooms.

5.3 Evaluation The technical requirements of Section III.G.2.b of Appendix R are nnt net in these zones because redundant emergency diesel generator circuits are not separated by a horizontal distance of more than 20 feet free of intervening combustibles or fire hazards, and because an automatic fire suppression system is not installed throughout the fire zones.

The staff's principal concern was that the presence of intervening combustibles between train A emergency diesel generator control circuits and the train B emergency diesel generator power cables, and the lack of fire suppression systems throughout the control room complex may result in a loss o' redundant safe shutdown capability.

However, the combined vertical and horizontal distance between the redundant systems is more than 65 feet. The intervening combustibles in the control room are located above the level of train A control circuits, but not in the ducts or duct shaft. Therefore, it is unlikely that a fire would spread between redundant circuits.

f To spread via the intervening combustibles from the train B power cables

! to the room below, a fire would have to propagato up the duct shaft,

! across the ceiling of the control room, and down to the bench board where the train A circuits are located. This mode of fire spread is unlikely because the combustible loading in these two rooms is light, both are

! protected by fire detectors throughout, there are no combustibles in the

! shaft, and the control room is constantly attended, i

l If a fire were to occur in one of these rooms, the staff has reasonable assurance that it woulci be detected by the fire detectors or the operators.

l Detector actuation would be annunciated in the control room and the l operators would dispatch the plant fire brigade to extinguish the fire.

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5.4 conclusion BaseC .1 the above evaluation, the staff concludes that the above-mentioned fire protection features provide a level of fire protection equivalent to the technical requirements o'Section III.G.2.b of Appendix R. Therefore,

, the exemption reouest for the aforementioned diesel generator circuits and a fire suppression system in the control room complex should be granted.

6.0 MAIN STEAM VALVE POOM (FIRE AREA MS-1) 6.1 Exemption Requested An exemption was requested from Section III.G.2.a to the extent that it requires separation of cables and equipment and associated nonsafety circuits of redundant treins by a fire barrier.having a 3-hour rating.

6.? Discussion The main steam valve room and the adjacent motor control center (MCC),

being part of Fire Area MS-1, are at elevation 752 feet, 6 inches, north of the containment. Fire Area MS-1 is separated from the adjacent areas by 3-hour # ire-rated barriers.

The combustible loading in the area was not ouantified by the licensee, but it was described in a manner as having an equivalent severity of less than 30 minutes based on the ASTM E-119 time-temperature curve. There are no fire detection or automatic fire suppression systems installed in the area. Portable fire extinguishers and manual hose stations are available.

The steam generator atmospheric dump valves (PCV-MS101A, R, and C), main steam isolation valves (TV-MS101A, P and C), steam supply trip valves for the auxiliary feedwater (AFW) pump, MOV-MS105 and TV-MS105A and B, and the residual heat release (RHR) valve (HCV-MS1041 are all located in this fire area and are used for safe shutdown. The RHR valve is used for control of decay heat release in conjunction with the atmospheric steam dump valves.

The RHR valve is redundant to the atmosnheric steam dump valves. Steam supply trip valves TV-MS105 A and B are redundant to each other. The function of these valves and steam supply trip valve MOV-MS105 is to supply the steam-driven AFW pump. On loss of steam supply to this pump, two motor-driven AFW pumps are still available.

6.3 Evaluation The technical requirements of Section III.G.2.a of Appendix R are not met in Fire Area MS-1 because redundant trains of equipment are not separated by a fire barrier having a 3-hour rating.

The staff was concerned that the lack of 3-hour fire rated barriers between redundant valves in this fire area may result in a loss of safe shutdown capability.

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. o The valves in this room perform one of two safe shutdown functions:

o Isolation of the main steam system (main steam isolation valvesi o Control of decay heat release (atmospheric dump valves, steam supply trip valves, RHR valves, and the code safety valves).

The cenbustible loading in Fire Area MS-1 is low (less than 30 minutes).

Redundant valves are separated by at least 5 feet. If a fire were to occur, it is not expected to result in a loss of safe shutdown capability for the following reasons:

o if the steam generator atmospheric dump valves and the RHR valve fail to open, the main steam safety valves would be available.

These valves do not require power or compressed air to operate.

Because of their size and construction and the combustible load in the room, they are not expected to be damaged by a fire, o Should fire damage valve MOV-MS105 and the steam supply trip valves, these valves should fail to the sa'e open position and continue to supply steen to the turbine-driven AFW pump. In addition, two motor-driven AFW pumps are available, o fire damage to electrical controls for the main steam isolation valves can be overcome from outside of this fire area by manually initiatino the " loss of air" condition, which will cause these valves to close safe (the same as the electrical controls).

Therefore, the staff has reasonable assurance that a fire originating in Fire Area MS-1 will not prevent the plant # rom safely shutting down.

6.4 Conclusion Based on the above evaluation, the staff concludes that the above-mentioned fire protection features provide a level of fire protection equivalent to the technical reouirements of Section III.G.2.a of Appendix R. There fore, the exemption request for Fire Area MS-1 should be granted.

7.0

SUMMARY

Based on the evaluation, the staff found that the level of fire 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 exemption in these areas should be granted:

1. Centrifugal charging pump cubicles to the extent that a 20-foot separation free of intervening combustibles between redundant charging pumps is not provided, and automatic fire suppression systems are not installed. For more infonnation, see Section 4.0.

2. Fire Zones CR-1 and CR-2 to the extent that a 20-foot separation without intervening combustibles between trains of redundant emergency

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diesel qenerator cables is not penvided and automatic # ire sunnression systems are not installed. For more in#ormation, see Sectinn 5.0.

3. Fire Area MS 1 to the extent that fire barriers between redundant safe shutdown valves are not 3-hour fire rated. For more information, sae Section 6.0 Rased on the evaluation, the sta#f also concluded that the following is an accentable deviation from the guideliner of Apoendix A to RTP APCSD 9.5-1:

1. Twentv four fire areas es listed in Section 9.? to the extent that fire door assemblies separatino sa'e shutdown areas are not 3-hour rated. For more in#ormation, see Section 7.0.

Rased on the evaluation, the staff found that the followino is not an acceptable deviation from the cuidelines of Aooendix A to RTP APCSD 9.5-1:

1 Thirteen ' ire areas as listad in Section 3.' to the extent that fire dar.pers in ducts between safe shutdown areas are not 3-hour fire-rated. For nnre information, see Section 3.0 P.0 PRINCIPAL CouToinUTOD: .lohn Stano This safety evaluation was orepared and based on a technical evaluation report prepared bv the Franklin Research center ICDCI under a contract with the U.S. Nuclear Deculatorv Commissinn.

Dated: November 1986

TECHNICAL EVALUATION REPORT NRC DOCKET NO. 50-334 FRC PROJECT C5506 NRC LICD;SE NO. DPR-65 FRC ASSIGNMENT 36 NRC CONTRACT NO. N RC-03-81 130 FRCTASK 627 EVALUATION OF FIRE PROTECTION EXEMPTION REQUESTS FROM 10CTR50.48 AND APPENDIX R TO 10 CFR50 DUQUESNE LIGHT COMPANY BEAVER VALLEY POWER STATIO" UNIT 1 TER-C5506-627 Prepared for 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 a0ency of the United States Government. Neither the United States Government nor any agency thereof, or any of their employees, makes any warranty, expressed 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 inf ringe privately owned rl0nts.

Prepared by: eviewed by- Approved by:

7 Y pr '

WfYmm Npartmt. It rectf Princl(hl' Author hDate: 1 Date: 9-3 D Date: 1,/3/f6 e 9 I WthI, ' h pvLO

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J FRANKUN RESEARCH CENTER OtVISION OF ARVIN/CALSPAN m a sau imm.=uwetma = wm

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TER-C5506-627

. CONTENTS Section Title Page 1 INTRODUCTION . . . . . . . . . . 1 1.1 Purpose of Review . . . . . . . . 1 1.2 Generic Background . . . . . . . . 1 1.3 Plant-Specific 1.ackground . . . . . . 3 1.4 Review Criteria . . . . . . . . . 4 2 EVALUATION . . . . . . . . . . . .'

2.1 General . . . . . . . . . . . 5 2.2 Fire Doors . . . . . . . . . . 5 2.3 Fire Dampers. . . . . . . . . . 8 2.4 Charging Pump Cubicle A (Fire Zone PA-lf) ,

Charging Pump Cubicle B (Fire Zone PA-19), and Charging Pump Cubicle C (Fire Zone PA-lh) . . 10 2.5 Control Room (Fire Zones CR-1 and CR-2) . . . 13 2.6 Main Steam Valve Room (Fire Area MS-1) . . . 15 3 CONCLUSIONS . . . . . . . . . . 18 4 REFERENCES . . . . . . . . . . 19 J

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. . TER-C5506-627 FOkBWORD This Technical Evaluation Report was prepared by Franklin Research Center (FRC) under a contract with the U.S. Nuclear 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. Jacob B. Klevan contributed to the technical preparation of this report through a subcontract with Rolf Jensen &

Associates, Inc.

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TER-C5506-627

1. INTRODUCTION 1.1 PURPOSE OF REVIEW This technical evaluation report documents an independent review of exemptions or deviations from the fire protection requirements of 10CFR50.48 or Appendix R to 10CFR50 requested for Duquesne Light Company's (DLC) Beaver Valley Power Station Unit

1. This evaluation was performed with the following objectives:

o To assess if each exemption request demonstrates an equivalent level of overall protection of plant safe shutdown capability following a disabling fire event o To determine the bases for acceptance or denial of each exemption request o To recommend the minimum level of fire protection the Licensee should provide to achieve an equivalent level of

fire protection in case a request is denied.

1 i 1.2 GENERIC BACKGROUND

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 fcund serious design inadequacies regarding fire protection at Browns Ferry, and its report, " Recommendation Related to Browns Ferry l Fire" (NUREG-0050, February 1976), contained over 50 recom-I mandations regarding 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 1.120 (3).

By early 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 protection rule and its Appendix R, which was described as setting out minimum fire I

T TER-C5506-627 I

! protection requirements for the unresolved issues. 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) and Appendix 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 safe shutdown capability (including alternate j 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 i because Item III.G now provides three alternative fire protection features which do not require analysis to demonstrate the i

protection of redundant safe shutdown equipment, and reduces the l 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 that such modifications may be detrir. ental 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 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 damage to at least one train of equipment necessary to achieve cold shutdown is limited so that it can be repaired within a reasonable time (minor repairs using components stored on the site).

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

l' o Modifications required to meet Section III.G would not

" enhance fire protection safety levels above those provided by either existing or proposed alternatives.

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TER-C5506-627 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 are covered by various documents, one of them being Generic Letter 83-33 (6), which has recently been superseded by Generic Letter 86-10 [7). "The interpretations of Appendix R" and "the responses to industry questions," two sections of Reference */, 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 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 analyses 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):

I Subtask 1: Review each exempt:on 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 letter dated June 30, 1982, Duquesne Light Company (DLC, the Licensee) requested exemptions from Section III.G of Appendix R to 10CFR50. By letters dated January 14 and October 16, 1985, the Licensee provided additional information in support of these requests. Information provided in these submittals as well as information gathered during a site visit on January 22, 1986 has

been used in the preparation of this evaluation report.

l The Request for Information (RFI) required in satisfaction of Subtask 1 was transmitted to the NRC on December 17, 1985 [9].

The contents of this final TER reflect the information -

contained in the Licensee's submittals identified above. This TER also reflects resolution / incorporation of the NRC comments made todate on the draft version.

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. o TER-C5506-627

. 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, 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.

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TER-C5506-627

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2. EVALUATION

, 2.1 GENERAL This section presents review and evaluation of exemptions from Appendix R to 10CFR50 requested by the Licensee (DLC) of Beaver Valley Power Station Unit 1. 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 subsectior.s:

o Exemption requested o Discussion o Evaluation o Conclusic:.

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

2.2 FIRE DOORS 2.2.1 Exemptions Requested Exemptions were requested from Section III.G.2.a to the extent that it requires separation of cables and equipment and

) associated nonsafety circuits of redundant safe shutdown trains i by a fire barrier having a 3-hour rating.

The Licensee's exemption requests specifically pertained to fire door assemblies in walls identified as fire area boundaries.

j Section III.G.2 of Appendix R to 10 CFR 50 contains requirements for the protection of hot shutdown components.

located within the same fire area. It does not apply to fire area boundaries. Acceptable guidelines for establishment of fire area boundaries are set forth in Section D.l. (j) of Appendix A to BTP APCSB 9.5-1. Therefore, the fire doors discussed in the

Licensee's request have been reviewed for conformance with Appendix A guidelines.

I 2.2.2 Discussion The Licensee has identified 24 fire areas whose boundaries contain fire door assemblies that do not have a fire resistance rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. A fire door assembly consists of the fire door (s), frame, and hardware. Some of these assemblies were designed and constructed as fire rated assemblies but have been modified for security or flood control purposes, or have not been installed in strict compliance with nationally accepted l

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! TER-C5506-627 standards. Other assemblies are not fire rated, but are similar to fire rated assemblies.

In all, one fire door and 10 door frames are not labeled, frames in 18 locations have been modified for security purposes, and frames in 8 locations have been otherwise penetrated by pipes

, or conduits. Several locations contain multiple deviations. A label is the identifying mark applied to a product as evidence that it complies with the specified standards of the Underwriters Laboratories (UL) or other approval agency.

Twenty-one of the 24 fire areas, where these doors are provided, contain safe shutdown equipment. Fire door assemblies serving the other three fire areas -- the PCA shop (Fire Area SB-1), the locker room (Fire Area SB-3), and the clean shop (Fire Area SH-1) -- have been modified for security purposes.

The combustible loading in 17 of these fire areas is 80,000 Btu per square foot or less, which is equivalent to a fire severity of up to 60 minutes based on the ASTM E-119 time-temperature curve. Fire protection in these areas consists of portable extinguishers and manual hose stations. In addition, smoke detectors are installed in the following fire areas: the intake structure (Fire Areas IS-1 through IS-3), the control room complex (Fire Zones CR-1, -2, and -4), the emergency switchgear room (Fire Area ES-2), the motor generator room (Fire Area MG-1) ,

and the normal switchgear room (Fire Area NS-1).

The combustible loading in five of the 24 fire areas is between 80,000 and 120,000 Btu per square foot, which corresponds to a fire severity of 60 to 90 minutes. Fire protection in these fire areas consists of portable extinguishers and manual hose.

stations. In addition, sprinkler systems are installed in the 4 PCA shop and the clean shop. Detectors are installed in Fire Area IS-4 of the intake structure and detectors and a total l flooding carbon dioxide system are installed in the cable j spreading room.

The combustible loading in the remaining two fire areas is between 120,000 a..d 160,000 Btu per square foot, which l

corresponds to a fire severity of 90 to 120 minutes. Fire protection in these two areas (the east and west cable vaults, Fire Areas C/-l and CV-2, respectively) consists of portable extinguishers, manual hose stations, heat and smoke detectors, and total flooding carbon dioxide systems.

At.the Licensee's request, a UL representative visited the plant and inspected typical examples of each identified deviation to evaluate each deviation's impact on the labeling of the doors.

On the basis of the UL evaluation, the Licensee has made corrective modifications to several of these assemblies.

The Licensee has evaluated the affected fire door assemblies (with the corrective modifications) and determined that they provide an adequate margin of fire resistance considering the

TER-C5506-627 fire loading on both sides of each of the assemblies. This evaluation is described in Section 11.18 of the Licensee's January 14, 1985 submittal. ,

The Licensee chose not to make corrective modifications to the affected door assemblies in the' intake structure. The deviations applicable to the fire door assemblies between Fire Areas IS-1 and IS-2, between Fire Areas IS-3 and IS-4, and from each of these fire areas to the exterior involve the installa-tion of a pipe penetration through the frames.

UL recommended that the interior of all pipes and conduits penetrating fire door frames should be filled with a fire stop material. The pipes through the intake structure door frames convey pressurized air used to activate sliding flood doors located behind tne fire door at each opening. The exterior of the pipe penetration has been made tight fitting, rut the pipes cannot be sealed internally without interrupting tne air supply.

Safe shutdown equipment in the intake structure consists of three river water pumps (in separate fire areas) of which only one is required for safe shutdown. In addition, two auxiliary river water pumps located in the separate auxiliary intake structure are available as backup systems. Two fire pumps are also located in the intake structure in Fire Areas IS-2 and IS-4.

In case of fire in one of Fire Areas IS-1 through IS-4, safe shutdown capability would not be affected because redundant systems are available in other fire areas. In addition, the solid wall between Fire Areas IS-2 and IS-3 would prevent a fire in Fire Areas IS-1 or IS-2 from spreading to Fire Areas IS-3 or IS-4.

2.2.3 Evaluation The guidelines of Section D.1. (j) of Appendix A to BTP APCSB 9.5-1 are not met because a fire door is not labeled (1 location) or because fire door frames are not labeled (10 locations), fire doors have been modified for security purposes (18 locations), or fire doors have been penetrated by pipes or conduits (8 locations). Several locations contain multiple deviations.

However, the equivalent fire severity in each of the affected fire areas is less than 120 minutes and generally less than 60 minutes.

Review of the Licensee's evaluation indicates that the existing fire door assemblies with the corrective modifications provide an adequate margin of fire resistance compared with the combustible loading in the affected fire areas, with one exception.

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TER-C5506-627 The exception to the fire resistance discussed above is the doors located in the intake structure. Due to the functional restrictions, the corrective modifications required to upgrade these doors are not possible. However, these door assemblies, in conjunction with the resistance of the 3-hour fire rated masonry walls, provide an adequate margin of fire resistance between redundant trains of safe shutdown systems. It is, therefore, concluded that the intake structure door assemblies should be acceptable. gg 2.2.4 Conclusion Based on the above evaluation, it is concluded that the aforementioned fire door assemblies, combined with the Licensee's modifications, provide an acceptable level of protection in accordance with the guidelines of Section D.1. (j) of Appendix A to BTP APCSB 9.5-1. Therefore, the fire door exer.ptions can be granted.

2.3 FIRE DAMPERS 2.3.1 Exemptions Requested Exemptions were requested from Section III.G.2.a to the extent that it requires separation of cables and equipment and associated nonsafety circuits of redundant trains by a fire barrier having a 3-hour rating.

The Licensee's exemption requests specifically pertained to fire dampers in ducts penetrating floors or walls identified as fire area boundaries.

Section III.G.2 of Appendix R contains requirements for fire protection within fire. areas. It does not apply to fire area boundaries. Acceptable guidelines for the establishment of fire area boundaries are set forth in Section D.1. (j) of Appendix A to BTP APCSB 9.5-1. Therefore, the affected fire dampers have been reviewed for conformance with Appendix A guidelines.

2.3.2 Discussion The Licensee has identified 13 fire areas whose boundaries contain duct penetrations which are protected by fire dampers whose fire resistance cannot be demonstrated by test dsta or approval by a nationally recognized testing laboratory. The i

subject fire dampers were shop-fabricated following the construction details of the Sheet Metal and Air conditioning

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Contractors' National Association, Inc. (SMACNA) fire damper program.

The SMACNA program consists of a set of drawings and specifications for constructing fire dampers eligible to bear UL 1-1/2 hour fire rated damper labels. It also includes instructions for obtaining either UL or SMACNA labels for the

TER-C5506-627 dampers. The labels (UL or SMACNA) are the sole means of identifying whether dampers were constructed in accordance with the SMACNA program.

The Licensee's"' submittal indicates that the shop-fabricated dampers do not comply with the SMACNA program because the blades are heavier, the pivot bracket is different, and a closure spring has been omitted from the installed dampers compared with the SMACNA design. Therefore, the dampers do not bear either the UL or SMACNA labels.

All of the affected fire areas contain equipment required for safe shutdown. Fire areas affected include the following:

o Emergency Switchgear Areas (ES-1 and ES-2) o Cable Tray Mezzanine (CS-1) o Main Steam Valve Room and Motor Control Center Room (MS-1) o East and West Cable Vault Areas (CV-1 and CV-2) o Upper Ventilation Roem/ Purge Duct Room and Steam l Generator Blow Down Room (SGPD) o Primary Auxiliary Building (PA-1) j o Normal Switchgear Room (NS-1) o Motor Generator Room (MG-1) o Process Instrument and Rod Position Room (CR-4) o Pipe Tunnel Area (PT-1) o Auxiliary Feedwater and Quench Spray Pump Cubicles ,

(QP-1).

2.3.3 Evaluation i The fire protection in the affected areas does not comply I with the guidelines of Section D.1. (j) of Appendix A to BTP APCSB 9.5-1 because duct penetrations are not provided with fire dampers hacing a fire resistance rating equal to that required of the penetrated barrier.

Th'e fire dampers are described by the Licensee as being ,

functionally equivalent to the UL-tested fire dampers. However,,

i the installed dampers do not bear the UL or SMACNA labels because j they differ from the SMACNA design as discussed above. The effects of these differences in the design of moving parts on damper performance have not been tested.

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TER-C5506-627 Therefore, there is no reasonable assurance that the fire dampers will function as intended and that the fire barrier guidelines of Section D.1. (j) of Appendix A are met.

2.3.4 Conclusion Based on the above evaluation, it is concluded that the existing fire dampers do not constitute an acceptable deviation from the guidelines of Section D.1. (j) of Appendix A to BTP APCSB 9.5.1. The Licensee should provide fire test results for these fire dampers demonstrating that the fire resistance ratings in the configuration installed are equivalent to that required of the barriers in which they are installed. Therefere, the fire i damper exemptions are denied.

2.4 CHARGING PUMP CUBICLE A (FIRE ZONE -PA-lF) , CHARGING PUMP CUBICLI B (FIRE ZONE PA-lG) , AND CHARGING PUMP CUBICLE C (FIRE ZONE PA-lH) i 2.4.1 Exemption Requested Exemptions were requested from Section III.G.2.b to the extent that it requires separation of cables and equipment and associated nonsafety circuits of redundant trains by a horizontal distance of more than 20 feet with no intervening combustibles or fire hazards, and to the extent that it requires an automatic fire suppression system to be installed throughout the fire area.

i 2.4.2 Discussion The Licensee has identified the following conditions which do

, not meet Section III.G.2.b: Redundant charging pumps A, B, and C are located in individual cubicles which provide at least 20 feet

of horizontal separation between pumps. Each cubicle is protected by detectors, but automatic suppression systems are not installed in the cubicles as required by Section III.G.2.b. One

(

charging pump is required for safe shutdown of the plant.

The primary auxiliary building (PAB), Fire Area PA-1, is a i single fire area. It is located north of the fuel building, east  ;

of the pipe tunnel area / cable vaultn and main steam valve area, and south of the service and control buildings. The east side faces the yard areas of the plant.

2.4.2.1 Elevation 722 Feet, 6 Inches I

i The charging pump cubicles are adjacent to each other on elevation 722 feet, 6 inches of the PAB. The walls between the. l

[ cubicles and the remainder of this level are 2-foot-thick reinforced concrete, except for 8-foot-wide by 3-foot-high

( ventilation openings from each cubicle to the corridor along the north side and an exhaust duct. The exhaust duct serves all three cubicles, starting in pump A cubicle and terminating in an exhaust shaft east of pump C cubicle.

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• TER-C5506-627 In order to improve the fire separation between cubicles, the Licensee has sealed the ventilation opening between pump B cubicle and the corridor on' elevation 722 feet, 6 inches. The pump B cubicle opening is sealed with 1; inches of silicone foam.

The power cables for charging pump B are routed from E

. cubicle, south on elevation 722 feet, 6 inches, up to elevat;on

735 feet, 6 inches where they run west and eventually exit the PAB. These cables are enclosed in 1-hour fire rated barriers.

The Licensee has installed fire dampers in the pump cubicle 4

exhaust duct penetrations. The purpose of the damper installations is to isolate the affected cubicle from other cubicles in case of fire.

Manual hose stations and portable fire extinguishers are i located on elevation 722 feet, 6 inches and on each floor level throughout the PAB. In addition, smoke detectors are installed

within each charging pump cubicle.

Combustibles in each pump cubicle consist of approximately 50 gallons of lube oil. All cables in these cubicles are metal jacketed. The combustible loading in each cubicle is 4 approximately 32,000 Btu per square foot, which is equivalent to i a fire severity of 24 minutes based on the ASTM E-119

! time-temperature curve.

Combustibles in the remainder of this level of the PAB consist of cable insulation. The combustible loading outside of i the pump cubicles on elevation 722 feet, 6 inches is i approximately 11,200 Btu per square foot, which is equivalent to

! a fire severity of 9 minutes on the ASTM E-119 time-temperature

! curve. Intervening combustibles in the form of cables in trays i- are only in the corridor outside of the cubicles.

! The horizontal separation between redundant charging pumps A and C is approximately 23 feet (through the corridor north of the cubicles). Charging pump B is separated from the other redundant

pumps by at least 40 feet of horizontal distance and a total of 25 feet of vertical separation because of the sealing of ,

penetrations for the individual pumps.

l 2.4.2.2 Elevation 735 Feet, 6 Inches i

l Access to the cubicles is provided by hatches on elevation 735 feet, 6 inches. The Licensee has installed removable fire j barriers in tne personnel access hatch openings at the 735-foot, j 6-inch level of pump A and C cubicles. Pumps A and C hatch openings are sealed with 4-inch-thick silicone foam slabs in steel frames. It is concluded that these seals have at least a*

l-hour fire rating. The manufacturer's data also indicate that a 4-inch thickness of silicone foam is capable of achieving a 1-hour fire resistance rating.

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TER-C5506-627 The combustibles on elevation 735 feet, 6 inches include cable insulation and unbaled waste. The combustible loading is approximately 25,000 Btu per square foot, which is equivalent to a fire severity of 19 minutes on the ASTM E-119 time-temperature curve.

2.4.3 Evaluation The fire protection in the charging pump cubicles does not j comply with the technical requirements of Section III.G.2.b of Appendix R because redundant trains of cables and equipment and associated nonsafety circuits are not separated by 20 feet of horizontal distance free of intervening combustibles, and an automatic fire suppression system has not been installed.

1 The primary concern was that even though redundant charging pumps are separated by a horizontal distance of more than 20 feet, the presence of intervening combustibles in the corridor and the absence of automatic fire suppression systems in or around the pump cubicles may result in a loss of safe shutdown capability.

A fire of significant duration or magnitude is not expected to occur on elevation 722 feet, 6 inches bercuse the combustible

loading in the pump cubicles and the surrounding portions of the PAB is moderate to light. In addition, the intervening combustibles between redundant pumps are only in the corridor outside of the pump cubicles and do not extend into the ventilation openings. Therefore, they do not provide a complete fire propagation path between redundant pumps.

,, should a fire occur in a pump cubicle, it is expected to be i detected by the detectors which annunciate in the control room.

The operators will dispatch the plant fire brigade to respond and extinguish the fire.

If the detectors do not operate, or if a fire should occur outside of a pump cubicle on the 722-foot, 6-inch level, it is expected that pump B would remain free of fire damage becaust it

is separated from other portions of this level by barriers with 1

at l'ast e a 3-hour fire resistance rating and because of the lack of a fire propagation path via intervening combustibles between pumps.

Should a fire occur on the 735-foot, 6-inch level, it is expected that at least one of the pumps would remain free of fire damage because pumps A and C are separated from this portion of the PAB by fire barriers with at least a 1-hour fire resistance.

rating. In addition, the fire is unlikely to propacate downward through the pump B cubicle personnel hatch. Pump B power cables are enclosed in 1-hour fire wrap. l i

TER-C5506-627 Based on this evaluation, it is concluded that with the installed fire protection features and the Licensee-committed modifications, there is reasonable assurance that a fire

originating in the PAB will not prevent the plant from safely shutting down.

2.4.4 Conclusion Based on the above evaluation, it is concluded that the existing fire protection for the centrifugal charging pumps (except for the fire dampers discussed in Section 2.3.2), in conjunction with proposed modifications, provides a level of fire protection equivalent to the technical requirements of Section III.G.2.c of Appendix R. Therefore, the exemption for the charging pump cubicles can be granted.

2.5 CONTROL ROOM (FIRE ZONES CR-1 AND CR-2) i 2.5.1 Exemption Requested

) An exemption was requested from Section III.G.2.b to the

! extent that it requires separation of cables and equipment and associated nonsafety circuits of redundant trains by a horizontal distance of more than 20 feet with no intervening combustibles or fare hazards, and to the extent that it requires an automatic fire suppression system to be installed throughout the fire area.

2.5.2 Discussion The Unit 1 control room (Fire Zone CR-1) is in the control building located north of the PAB, east of the service building, i south of the turbine building, and west of the Unit 2 control

room. It is on elevation 735 feet, 6 inches, above the control room HVAC equipmer.t room (Fire Zone CR-2), the cable spreading room (Fire Area CS-1), and the normal switchgear room (Fire Area NS-1).

I Fire Zone CR-1 is separated from the adjacent fire areas by 3-hour rated fire barriers with all penetrations sealed to a 3-hour fire rating except for fire doors 035-2 and S35-5, which have been modified as noted below.

Fire Zone CR-1 is not separated from Fire Zone CR-2 by fire

! rated barriers because there are no fire dampers in the ducts serving both zones. These ducts are in a masonry shaft.

)

The combustible contents of Fire Zone CR-1 consist of cable i insulation and small amounts of paper. The combustible loading.

! is approximately 5,800 Btu per square foot, which has an

equivalent fire severity of 4 minutes based on the ASTM E-119 j time-temperature curve.

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TER-C5506-627 Fire Zone CR-2 is located on elevation 713 feet, 6 inches, adjacent to the cable spreading room (Fire Area CS-1) on the west and north sides, the process instrument and rod position room (Fire Area CR-4) on the west side, and the cable tunnel (Fire Area CV-3) on the east side. Fire Zone CR-2 is separated from these fire areas by 3-hour fire rated barriers, except for fire

door S13-4.

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I The combustible contents cf the Fire Zone CR-2 control room I consist of cable insulation, lube oil, and charcoal. The combustible loading is approximately 39,000 Btu per square foot, which is equivalent to a fire severity of 29 minutes en the ASTM E-119 time-temperature curve.

't l The fire protection in Fire Zones CR-1 and CR-2 consists of fire detection systems installed throughout each zone, heat detectors in the HVAC system filters in Fire Zone CR-2, manual hose stations, and portable fire extinguishers.

t The Licensee has identified the following conditions which do l not meet Section III.G.2.b: Control circuits for train A i emergency diesel generator are located in the control room, and

, power cables for train B emergency diesel generator are located l in the control room's adjoining HVAC equipment room. One train

, of emergency diesel generator circuits is required to achieve j safe shutdown.

The redundant safe shutdown circuits are separated by a

! vertical distance of at least 20 feet and a horizontal distance 1 of at least 45 feet (between the duct shaft and the bench board

! in the control room). Intervening combustibles consist of cable insulation in the control room and in the control room's HVAC

!. equipment room, but not in the ducts or duct shaft that connect t

the two rooms.

2.5.3 Evaluation I

I The technical requirements of Section III.G.2.b of Appendix R are not met in these zones because redundant emergency diesel generator circuits are not separated by a horizontal distance of more than 20 feet free of intervening combustibles or fire [

hazards, and because an automatic fire suppression system is not installed throughout the fire zones.

I The principal concern was the presence of intervening combustibles between train A emergency diesel generator control circuits and the train B emergency diesel generator power cables, I and the lack of fire suppression systems throughout the control

! room complex may result in a loss of redundant safe shutdown -

l capability.

l However, the combined vertical and horizontal distance  !

between the redundant systems is more than 65 feet. The  !

intervening combustibles in the control room are located above ,

, ~14-l 1 _ _ _ _ _ _ _ _ _ .

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

i TER-C5506-627 i

the level of train A control circuits, but not in the ducts or duct shaft. Therefore, it is unlikely that a fire would spread between redundant circuits.

To spread via the intervening combustibles from the train B power cables to the room below, a fire would have to propagate up the duct shaft, across the ceiling of the control room, and down to the bench board where the train A circuits are located. This

! mode of fire spread is unlikely because the combustible loading '

in these two rooms is light, both are protected by fire detectors throughout, there are no combustibles in the shaft, and the

control room is constantly attended.

If.a fire were to occur in one of these rooms, there is

reas.onable assurance that it would be detected b'y the fire 1' detectors or the operators. Detector actuation would be annunciated in the control room and the operators would dispatch i the plant fire brigade to extinguish the fire.

1 2.5.4 Conclusion Ba' sed on the above evaluation, it is concluded that the above-mentioned fire protection features provide a level of fire protection equivalent to that of Appendix R. Therefore, the exemption for the control room complex can be granted.

2.6- MAIN STEAM VALVE ROOM (FIRE AREA MS-1) 2.6.1 Exemption Requested An exemption was requested from Section III.G.2.a to the extent that it requires separation of cables and equipment and  !

associated no9 safety circuits of redundant trains by a fire l, barrier.having a 3-hour rating.

I 2.6.2 Dp cussion l

Tho tain steam valve room and the adjacent motor control center (MCC) , being part of Fire Area MS-1, are at elevation 752 feet, 6 inches, north of the containment. Fire Area MS-1 is separated from the adjacent areas by 3-hour fire rated barriers.

l

, The combustible loading in the area was not quantified by tne Licensee, but was described as having an equivalent severity of less than 30 minutes based on the ASTM E-119 time-temperature curve. There are no fire detection or automatic fire suppression systems installed in the area. Portable fire extinguishers and manual hose stations are available.

The steam generator atmospheric dump valves (PCV-MS101A, B, and C); main steam isolation valves (TV-MS101A, B, and C); steam supply trip valves for the auxiliary feedwater (ATW) pump, MOV-MS105 and TV-MS105A and B; and the residual heat release (RHR) valve (HCV-MS104) are all located in this fire area and are

TER-C5506-687 1

, used for safe shutdown. The RHR valve is used for control of decay heat release in conjunction with the atmospheric steam dump valves.

The RNR valve is redundant to the atmospheric steam dump I valves. Steam supply trip valves TV-MS105A and B are redundant l

. to each other. The function of these valves and the steam supply trip valve MOV-MS105 is to supply the steam-driven AFW pump. On

' loss of steam supply to this pump, two motor-driven AFW pumps are still available.

2.6.3 Evaluation ,

The technical requirements of Section III.G.2.a of Appendix R i

l, are not met in Fire Area MS-1 becausa redundant trains of equipment are not separated by a fire barrier having a 3-hour rating.

The concern was that the lack of 3-hour fire rated barriers between redundant valves in this fire area may result in a loss of safe shutdown capability.

The valves in this room perform one of two safe shutdown functions:

o Isolation of the main steam system (main steam

{ isolation valves) j o control of decay heat release (atmospheric dump valves, ,

i steam supply trip valves, RHR valves, and the code safety valves).

4 j, The combustible loading in Fire Area MS-1 is low (less than

30 minutes). Redundant valves are separated by at least 5 feet.

i If a fire were to occur, it is not expected to result in a loss

! of safe shutdown capability for the following reasons:

l o if the steam generator atmospheric dump valves and the RHR valve fail to open, the main steam safety valves would

! be available. These valves do not require power or compressed air to operate. Because of their size and '

I construction and the combustible load in the room, they i are not expected to be damaged by a fire.

o Should fire damage valve TV-MS101A and the steam supply j trip valves, these valves' fail-safe open position will continue to supply steam to the turbine-driven AFW pump.

In addition, two motor-driven AFW pumps are available.

l. .

o Fire damage to electrical controls for the main steam

- isolation valves can be overcome from outside of this fire

! area by manually initiating a " loss of air" condition, a

J f I

, - - _ - _ , . . . , , - - .-.,-_-c -----------.N

r

• *

• TER-C5506-627 which will cause these valves to close safe (the same as the electrical controls).

Therefore, there is reasonable assurance that a fire originating in Fire Area MS-1 will not prevent the plant from safely shutting down.

2.6.4 Conclusion Based on the above evaluation, it is concluded that the above-mentioned fire protection features provide a level of fire protection equivalent to the technical requirements of Section III.G.2.a of Appendix R. Therefore, the Fire Area MS-1 exemption can be granted.

1

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. 4 o TER-C5506-627

3. CONCLUSIONS This section is provided to consolidate the results of the evaluation contained in Section 2 concerning the exemptions requested by the Licensee from the requirements of Section III.G of Appendix R to 10 CFR 50 for Beaver Valley Power Station Unit

1. It is not meant as a substitute for the specific conclusions ,

reached in the various subsections of Section 2 for which the i reader is referred to specific subsections.

Based on the evaluation, the existing fire protection and/or proposed fire protection modifications provide a level of fire l protection equivalent to the technical requirements of Section III.G of Appendix R; therefore, the following exemptions from the requirements of Section III.G of Appendix R can be granted.

1. Fire Zones PA-1f, PA-1g, and PA-lh to the extent that a 20-foot separation free of intervening combustibles between redundant charging pumps is not provided and automatic fire suppression systems are not installed pursuant to III.G.2.b. For more information, see Section 2.4.2.

2. Fire Zones CR-1 and CR-2 to the extent that a 20- '

foot separation without intervening combustibles between trains of redundant emergency diesel generator cables is not provided and automatic fire suppression systems are not installed pursuant to III.G.2.b. For more information, see Section 2.5.2.

3. Fire Area MS-1 to the extent that fire barriers between redundant safe shutdown valves are not 3-hour fire rated pursuant to III.G.2.a. For more information, see Section 2.6.2. ,

Based on the evaluation, the level of fire safety in the areas listed below is an acceptable deviation from the guidelines of Appendix A to BTP APCSB 9.5-1:

i 1. Twenty-four fire areas to the extent that fire door

! assemblies separating safe shutdown areas are not 3-hour l rated pursuant to III.G.2.a. For more information, see i Section 2.2.2.

i i Based on the evaluation, the level of fire safety in the

' areas listed below is not an acceptable deviation from the guidelines of Appendix A to BTP APCSB 9.5-1:

i

1. Thirteen fire areas to the extent that fire dampers in. '

ducts between safe shutdown areas are not 3-hour fire ,

rated pursuant to III.G.2.a. For more information, see j

Section 2.3.2.

l .

-1s-l ,

i

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e o e TER-C5506-687

4. REFERENCES

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

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

3. Regulatory Guide 1.120, " Fire Protection Guidelines for Nuclear Power Plants," November 1977

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 Certain 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

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

July : 1986 e

19-1