Text

Evaluation of Fire Protection Exemption Requests from 10CFR50.48 & App R to 10CFR50,North Anna Power Station Units 1 & 2, Technical Evaluation Rept
	ML20215C001
Person / Time
Site:	North Anna
Issue date:	10/06/1986
From:	Ahmed N; CALSPAN CORP.
To:	Stang J; NRC
Shared Package
ML20213G452	List: ML20213G450; ML20213G467; ML20215C001;
References
	CON-NRC-03-81-130, CON-NRC-3-81-130 TER-C5506-646, NUDOCS 8610100026
	Download: ML20215C001 (45)
	v • d • e

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FRANKLIN RESEARCH CENTER DIVISION OF ARVIN/CALSPAN I

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1 EVALUATION OF FIRE PROTECTION EXEMPT 1sN REQUESTS FROM 10CFR50.48 AND APPENDIX R TO 10CFR50 VIRrfINIA ELECTRIC & POWER COMPANY NORTH ANNA POWER STATION UNITS 1 AND 2 TER-C5506-646 i

TECHNICAL REPORT l

20TH & RACE STREITS PHR.ADELMR PA 19103 TWX 710441989 TEL Q15)4481000 T

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TECHNICAL EVALUATION REPORT i

NRC DOCKET NO. 50-338, 50-339 FRC PROJECT C5506 NRC LICENSE NO. NPF-4, NPF-7 FRC ASSIGNMENT 36 N RC CONTRACT NO. NRC-03-81-130 FRCTASK 646 l.

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EVALUATION OF FIRE PROTECTION EXEMPTION REQUESTS FROM 10CFR50.48 AND APPENDIX R TO 10CFR50 q

VIRGINIA ELECTRIC & POWER COMPANY NORTif ANNA POWER STATION UNITS 1 AND 2 I

TER-C5506-646

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Prepared for q

Nuclear Regulatory Commission FRC Group Leader:

N. Ahmed Washington, D.C. 20555 NRC Lead Engineer:

J. Stang October 6, 1986 This report was prepared as an account of work sponsored by an agency 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

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responsibility for any third party's use, or the results of such use, of any information, appa-i ratus, product or process disclosed in this report, or represents that its use by such third i

party would not Infringe privately owned rights.

f Prepared by:

Reviewe by:

Approved by:

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FRANKLIN RESEARCH CENTER OfVISION OF ARVIN/CALSMN 30ttt & tAtt steeETs.mestAssLpeaa pa stics n._

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TER-C5506-646 CONTENTS i

Section Title Page 1

INTRODUCTION 1

1.1 Purpose of Review 1

1.2 Generic Background 1

1.3 Plant-Specific Background 3

1.4 Review Criteria.

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2 EVALUATION 5

2.1 General 5

2.2 Auxiliary, Fuel, and Decontamination Buildings (Fire Area 11) 5 2.3 Containment Incore Instrument Tunnels (Fire Areas 1-1 and 1-2) 9 F

2.4 Quench Spray Pump Houses (Fire Areas 15-1 and 15-2) 11 2.5 Main Steam Valve Houses (Fire Areas 17-1 and 17-2) 13 J

2.6 Auxiliary Feedwater Pump Houses (Fire Areas 14B-1 and 14B-2) 14 2.7 Charging Pump Cubicles (Elevation 244 Feet, q

6 Inches) 16 1

2.8 4-to 20-mA Signals in Twisted Pair Instrument Cable, Protected From Hot Shorts 3

125-Vdc Circuits in Rigid Metal Conduit, Protected From Hot Short 18 2.9 Separation of Instrumentation Inside the Containments, Intervaning Combustibles With Fire Stops.

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2.10 Auxiliary Building, Ventilation Equipment Area (Fire Area 11) 21 I

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TER-C5506-646 t

l CONTENTS (Cont.)

J Section Title Page 2.11 Emergency Lighting in the Seal Water Filter Area, Use of Portable Lights Emergency Lighting in the Control Room, Use of Diesel Generator Power Supply Emergency Lighting for Exterior Access Routes, 1

Use of Security Lighting and Portable Lights 23 l

6 2.12 Refueling Water Storage Tank, Lack of Level

,i Indication i

26 2.13 Chiller Rooms, Lack of a 3-Hour Rated Barrier.

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2.14 Emergency Switchgear/ Chiller Rooms, No Fire

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Damper (Fire ' Area 6-1) i F

Emergency Switchgear Room, Fire Door Frames 4

(Fire Area 6-2)

Fire Doors, Frames Not Fire Rated (Various Fire Areas)

Fire Doors, Conduits in Door Frames (Various Fire Areas)

Control Room Stairwell / Emergency Switchgear Room Wall Fire Barrier Rating (Fire Area 2)

I Cable Vault / Tunnel and Auxiliary Building Wall Fire Barrier Rating (Fire Area 3-1) i l

Auxiliary / Turbine Buildings' Pipe Tunnel, Lack of Fire Barrier (Fire Area 8)

Control Room / Turbine Building, Bulletproof Doors (Fire Area 2) b Conduits Passing Through Rated Fire Barriers, Lack of Internal Seals (Various Fire Areas) 29 2.15 Withdrawn Exemption Requests 36 3

CONCLUSIONS 37 a

4 ' REFERENCES 40 iv l

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TER-C5506-646 1

FOREWORD I

I This Technical Evaluation Report was prepared by Franklin i

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. Daniel L. Arnold contributed to the technical preparation of this report through a subcontract with Rolf Jensen & Associates, Inc.

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TER-C5506-646

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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 Virginia Electric and Power Company's (VEPCO) North Anna Power Station Units 1 and 2.

This evaluation was performed with the following objectives:

i To assess if each exemption request demonstrates an o

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

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

i Licensee should provide to achieve an equivalent level of I

fire protection in case a request is denied.

r' 1.2 GENERIC BACKGROUND w.

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

,d protection programs at all nuclear power plants.

i The group found serious design inadequacies regarding fire protection at Browns

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Ferry, and its report,

" Recommendation Related to Browns Ferry Fire" (NUREG-0050, February 1976), contained over 50 recom-mandations regarding improvements in fire prevention and control in existing facilities.

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

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i The NRC developed technical guidance from the technical recom-a mandations in the Special Review 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.

i Guidance to operating plants was provided later in Appendix A to lI 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 i

published as Regulatory Guide 1.120 (3].

i By early 1980, the guidelines in Appendix A.most operating plants had implemented most of has had some significant problems with implementation.However, the fire protectio l

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 I

TER-C5506-646 irements for described as setting out minimum fire protection requThe fire pro cy the unresolved issues. included protection of safe sh t

lighting,ication system, and alternate shutdown systems.

pump lubr 1981, the final rule 10CFR50.48 [4] anding the proposed On February 17, l

Appendix R to 10CFR50 [5] became effective, rep acO f such safety l

significance that they should apply to all p an pproved rule.

for which alternative fire protection actions had been aThese item ystems),

previously by the staff.

shutdown capability (including alternate shutdown s lubrication emergency lighting, and the reactor coolant pumpAccord licensed I

l to operate before January 1, 1979, to comply weve tive fire protection system.

rovides three features in these areas.

quire analysis than the proposed rule because Item III.G now p alternative fire protection features which do not reshutdown equipme

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f to demonstrate the protection of redundant sa eand i

l separation

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6-alternative from 50 feet to 20 feet.

initiated by a provides an exemption procedure which can betion feature will P

licensee's assertion that any required fire protecity or that such i,

not enhance fire protection safety in the facil f ty.

modifications may be detrimental to overall sa e t

tion features for ensuring that systems and associ l

g i cuits used to Either fire f damage.

achieve and maintain safe shutdown are free o i

quirements of protection configurations must meet the specif c l

figuration must the staff will be justified by a fire hazards analysis. accept an alt tion t'.

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The alternative ensures that one train of equ pmen l

h ontrol necessary to achieve hot shutdown from either t e c damage.

room or emergency control stations is free of fire o

u least one The alternative ensures that fire damage to at l

h tdown is train of equipment necessary to achieve cold s u ble time 1

o limited so that it can be repaired within a 3

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s Fire-retardant coatings are not used as fire barr er.

t Modifications required to meet Section III.G wou d no o

rovided by either existing or proposed alternative o

d be Modifications required to meet Section III.G woul detrimental to overall facility safety.

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TER-C5506-646 A number of the exemptions from Section III.G of Appendix R requested in the Licensee's submittal concerned fire area boundaries.

The acceptance criteria for fire area boundaries are delineated in Appendix A to BTP APCSB 9.5-1, not in Appendix R to 10CFR50.

Deviations from Appendix A fire area boundary guidelines do not require exemptions.

Accordingly, the fire area boundary i

exemptions have been reviewed as deviations from Appendix A guidelines rather than exemptions from Appendix R to 10CFR50.

Section III.J of Appendix R requires that emergency lighting units with at least an 8-hour battery-powered supply be provided in all areas needed for operation of safe shutdown equipment; and in access and egress routes thereto.

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Guidance to the industry and the NRC's position on certain requirements of Appendix R are covered by various documents, one of g

them being Generic Letter 83-33 [6), which has recently been l1' superseded by Generic Letter 86-10 [7).

"The Interpretations of Appendix R" and "The Responses to Industry Questions," two sections of Reference 7, are written to facilitate industry implementation of Appendix R and represent the NRC's position on all issues

,4 covered.

't Following the promulgation of the final rule, licensees have

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r*qu== tad ax*=ptions 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 1

analyses to ensure each alternative to meeting the requirements of the rule provides an equivalent level of overall protection of 2

plant safe shutdown capability.

Franklin Research Center (FRC) was to provide technical assistance to the NRC within the context of the following scope of work [8):

Subtask 1:

Review each exemption request for information i

deficiencies.

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

Subtask 2:

Review and evaluate each exemption or deviation j

request submitted by the licensees and all additional information provided for conformance r

with acceptance criteria.

Prepare final Technical Evaluation Report (TER) with recommendations, and their basis in support of granting or denying the exemption / deviation request.

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1.3 PIANT-SPECIFIC BACKGROUND l

.By letters dated May 1, 1984, the Virginia Electric and Power Company (VEPCO, the Licensee) submitted a report describing their compliance with Appendix R to 10CFR50.

The submittal requested 4

exemptions from Sections III.G and III.J of Appendix R to 10CFR50.

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a TER-C5506-646 By letters dated October 31, 1984; August 21, 1985; and March 21, 1986, the Licensee transmitted revisions to the Appendix R evaluation.

The exemption requests identified in the submittals I

are the subject of this evaluation.

The RFI was deemed unnecessary and none was issued.

no site visit was conducted.

Also, The contents of this TER reflect the information contained in the Licensee's submittals identified above.

This final TER also incorporates / resolves the NRC's comments received to date on the draft version issued on July 2, 1986.

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

1.

Fire Protection Program for Operating Nuclear Power Plants, 10CFR50.48 2.

Appendix R to 10CFR50 l'

3.

Standard Review Plan, NUREG-0800, Branch Technical Position (BTP), CMEB 9.5-1, " Guidelines for Fire Protection for Nuclear Power Plants" d

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Appendix A to BTP APCSB 9.5-1 f

5.

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

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TER-C5506-646 I

2.

EVALUATION 2.1 GENERAL This section presents review and evaluation of exemptions or deviations from 10CFR50.48 or Appendix R to 10CFR50 requested by the Licensee (VEPCO) of North Anna Power Station Units 1 and 2.

Evaluation of exemption requests for each fire area / zone singly or collectively follows a format suggested by the NRC and is arranged in the following subsections:

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o Exemption requested o

Discussion j'

o Evaluation

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o conclusion.

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

ll 2.2 AUXILIARY, FUEL, AND DECONTAMINATION BUILDINGS (FIRE AREA 11) 1 2.2.1 Exemption Requested j

An exemption was requested from the requirements of Section III.G.3 to the extent that it requires fire detection and fixed suppression systems to be provided throughout the fire area, room,

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or zone under consideration.

2.2.2 Discussion

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The Licensee has stated in exemption request 1 that Fire Area 11 does not meet the requirements of Section III.G.3 because fire detection and fixed suppression systems are not provided throughout the area.

North Anna Power Station is a two-unit plant with selected capabilities to allow components from one unit to be used as a means of alternate shutdown for the other unit.

The Licensee has stated that this condition exists for this area.

Therefore, the

)1 requirements of Section III.G.3 apply.

Fire Area 11 consists of the auxiliary, fuel, and decontamination buildings.

1 The buildings are located side by side in a north-south orientation, with the auxiliary buildin'g to the north, the decontamination building to the south, and the fuel building in the center.

This fire area contains the six charging pumps, four component cooling water (CCW) pumps, and associated cabling and valves for all of the pumps.

All barriers separating adjacent fire areas are 3-hour rated with electrical and mechanical penetrations sealed. ;

o TER-C5506-646 e

o The auxiliary building is a four-story structure consisting of the 244-foot, 6-inch; 259-foot, 6-inch; 274-foot, 0-inch; and 291-foot, lO-inch elevations.

The CCW and charging pumps are located on the 244-foot, 6-inen elevation, with the CCW pumps in the main open floor area of this elevation.

Each charging pump is located in a separate cubicle acoessed from the 259-foot, 6-inch elevation.

The fuel and decontamination buildings sections of Fire Area 11 are each a two-story structure.

The fuel building contains the auxiliary monitoring panel (AMP), which is used given a fire in the control room, emergency switchgear rooms, or cable vault / tunnel.

No safe shutdown equipment is located in the decontamination building.

An automatic fire detection system, which annunciates in the control room, is provided in Fire Area 11.

Smoke detectors are

~ provided on each elevation of the auxiliary building, but they do J.

not meet the criteria of full area coverage.

Detectors are installed in all areas with significant amounts of combustibles and near safe shutdown components.

Each charging pump cubicle has one ceiling mounted and one duct mounted smoke detector.

Detection is provided near the CCW

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pumps and their power feeds, charging pump power feeds, and associated valves on the 244-foot, 6-inch and 259-foot, 6-inch a

elevations.

y The fuel building is provided with ceiling mounted smoke detectors and one duct mounted smoke detector, whereas the l

decontamination building is provided with ceiling mounted smoke detectors.

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A sprinkler system is installed over the CCW and charging pumps and their power feeds on the 259-and 244-foot, 6-inch elevations.

Automatic suppression is not provided in either the fuel or decontamination buildings.

Portable extinguishers and i

manual hose stations are provided throughout Fire Area 11 for fire fighting purposes.

Automatic suppression is not provided within i

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the charging pump cubicles.

2.2.2.1 Charging Pump System Configuration and Separation f

There are six charging pumps arranged side by side in individual cubicles on the 244-foot, 6-inch elevation of the auxiliary building.

The charging pump system primarily provides makeup water for the reactor coolant system (RCS).

The three pumps to the east are for Unit 1 and the remaining three are for Unit 2.

A cross-connection is provided between the discharge headers of the two units' charging pumps.

The cross-connection is normally closed, but can be used by opening two manual valves in charging pump cubicles 1C and 2A.

TER-C5506-646 i

I The cubicles are constructed of heavy concrete walls on three sides and the fourth side is a removable wall made of concrete beams.

The walls have an inherent 3-hour fire rating.

See Section i

2.7 for additional details on the capabilities of the removable concrete wall.

The cubicle walls extend from the floor to the ceiling and penetrations through the walls are sealed to a rating of 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months .

There is a single hatch in each cubicle at the floor of the 259-foot, 6-inch elevation to permit personnel entry into the cubicles.

The power feeds for the charging pumps extend up through their respective cubicles and exit at the top of the 259-foot, 6-inch elevation.

There is a minimum of a 20-foot horizontal separation f

between the power feeds for Units 1 and 2 charging pumps as they

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. exit their respective cubicles and head in a northerly direction to the auxiliary building into the cable vault and tunnel of the respective units.

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The charging pump suction valves are located to the east and west of the charging pump cubicles for Units 1 and 2 on the 244-foot, 6-inch elevation.

The valves are not within cubicles, l!

but there is a wall between the valves and the cubicles.

There is a separation distance of at least 100 feet between the two sets of suction valves.

J 2.2.2.2 Component Cooling Water System Configuration and Separation g

t The four CCW pumps are located in a row parallel to the charging pump cubicles, approximately 30 feet to the north on elevation 244 feet, 6 inches.

The CCW system is required to remove heat from the RCS via the residual heat removal (RHR) system loop during cold shutdown.

.-'l' The CCW system includes four pumps and heat exchangers via a common discharge header, which can be aligned to service either or both units.

Only one pump is needed per unit for cold shutdown.

The pumps are mounted on pads that are approximately 15 feet apart on center.

i The distance between the closest Units 1 and 2 CCW pumps is less than 20 feet.

However, the outer two pumps are e-more than 40 feet apart.

The power feeds for the CCW pumps extend up to the 259-foot, 6-inch elevation.

is provided with a 1-hour rated fire wrap until a horizontalThe power feeds for t separation of 20 feet is achieved from the Unit 1 CCW pump power feeds.

Cable trays on the 259-foot, 6-inch elevation pass over the CCW pumps and between associated charging and CCW pumps power t

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TER-C5506-646 feeds.

The trays are provided with fire stops consisting of marinate boards on the top and bottom of the tray.

filled with 10 inches of silicone foam.

The center is j

t 2.2.3 Evaluation Fire Area 11 does not comply with the technical requirements of Section III.G.3 of Appendix R because fire detection and fixed suppression are not installed throughout the area.

There was a concern that because of the absence of area-wide automatic suppression and detection systems, a fire of significant magnitude could develop and damage all four CCW pumps, all charging is pumps, and/or associated cabling and valves.

equivalent fire severity of less than 20 minutes).However, the co For elevation 244 feet, 6 inches, the fire severity is less than 5 minutes and approximately 10 minutgs'on elevation 259 feet, 6 inches.

The combustibles consist primarily of cable insulation and lube oil J

contained in the charging pump cubicles.

and within the charging pump cubicles.In addition, smoke detectors are prov The Licensee has committed to expand the fire detection to areas with large amounts of cable and to areas containing safe shutdown components.

Because of the presence of these detectors, a fire in the CCW pump area or a charging pump cubicle should be detected in its incipient stage.

The alarms from these detectors are annunciated in the main control The fire brigade would be dispatched to extinguish the fire room.

J manually, using hose lines or portable extinguishers.

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A sprinkler system is installed over the CCW and charging pumps and their power feeds on the 259-and 244-foot, 6-inch elevations.

the pumps until the fire brigade arrives.This system should provide fire contro Manual control at the CCW pumps is not required to control the individual CCW pumps

,I-during a fire in this area.

The two most remote CCW pumps are separated by more than 40

F feet.

The center Unit 2 CCW pumps power feeds are provided with a 1-hour fire rated wrap until a horizontal separation of 20 feet is achieved from the Unit 1 CCW pump power feeds.

The spatial separation between the CCW pumps and the protection of the pumps' power feeds provide adequate protection until a fire can:be controlled by the suppression system or the fire brigade.

The six charging pumps are separated by heavy concrete walls that have an inherent fire rating that exceeds 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months .

1 feeds for the charging pumps are separated by a minimum of 20 feetThe power of horizontal separation.

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l TER-C5506-646 The fire stops installed in cable trays effectively reduce the potential of fire spread along the trays.

The installation of area-wide automatic fire suppression and

'i detection systems would not significantly increase the level of fire protection for Fire Area 11..

l 2.2.4 Conclusion l

Based on the above evaluation, it is concluded that the existing fire protection features in conjunction with the j

additional ionization detectors and sprinkler system coverage l

provide a level of fire protection equivalent to the technical requirements of Section III.G.3 of Appendix R.

Therefore, the exemption request for providing area-wide automatic suppression and j

detection systems throughout Fire Area 11 can be granted.

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. 2.3 CONTAINMENT INCORE INSTRUMENT TUNNELS (FIRE AREAS 1-1 AND l-2) l 2.3.1 Exemption Requested An exemption was requested from the requirements of Section III.G.2.d to the extent that it requires redundant cables and equipment to be separated by 20 feet with no intervening combus-tibles.

1 2.3.2 Discussion The Licensee has stated in exemption request 2 that Fire Areas

,P 1-1 and 1-2, both in the incore instrument canals and outside of the canals at the 216-foot, 11-inch elevation, do not meet the requirements of Section III.G.2.d because less than 20 feet of separation exists between redundant excore neutron flux detector cables.

Fire Areas 1-1 and 1-2 are the primary containments for Units

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l and 2, respectively.

Each area is a multi-level structure with floor elevations from 216 feet, 11 inches to 291 feet, 10 inches.

The incore instrumentation canal is located below elevation 231

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feet, 6 inches.

The east, west, and south walls of each canal are of 3-foot-thick reinforced concrete.

The circular wall to the north of each canal is constructed of 4 feet, 6-inch-thick i

reinforced concrete.

The ceiling and floor of each canal are of I

2-foot-thick reinforced concrete.

Access to each canal is through a steel hatch located at elevation 238 feet, 6 inches.

There is a 24-foot-vertical steel ladder within each hatchway that provides access to the canal floor.

The canals contain no exposed combustibles.

All cables in the canal are enclosed in rigid steel conduits.

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TER-C5506-646 i

The incore instrument canal and tunnel for each unit contains cables for four channels of source range neutron flux indication.

Two of the channels were provided as part of the nuclear'instrumen-tation system and two channels were added in 1984-85.

One of the new channels for each unit is used to provide neutron flux indication at the AMP in the fuel' building.

The other three channels provide neutron flux indication in the control room.

The redundant channels for the new excore neutron flux detectors are routed in rigid steel conduit and separated by a 10-foot horizontal distance with no intervening combustibles in the canal.

I Upon exiting the canals, the redundant trains run in opposite directions until a minimum of 20 feet of separation free

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of intervening combustibles exists between the trains.

There is no fixed combustible loading near or within the

. canals.

The potential for transient combustibles is limited since the access hatch is normall'y locked and access is controlled.

2.3.3 Evaluation

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Fire Areas 1-1 and 1-2 at the incore instrument tunnels do not i

comply with the technical requirements of Section III.G.2.d of u

Appendix R because redundant cables and equipment, specifically, excore neutron flux detector cables are not separated by 20 feet with no intervening combustibles.

The combustible loading near the canals is nonexistent.

The 3

canals contain no fixed combustibles.

The potential for transient combustibles to be introduced and stored in the canals is low.

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A major factor that reduces tne potential for damage to 7

redundant source range neutron flux cables is that they are contained in rigid steel conduits.'

,s The conduits provide a level passive protection from the radiant energy of a fire.

The 10-foot separation between redundant cables, A

the nonexistent combustible loading, and the use of rigid conduit provide sufficient passive protection to ensure that one division of source range neutron flux cables would remain free of fire damage.

With the fire protection features as described above, there is reasonable assurance that a fire in the containment incore instrument tunnels will not prevent the plant from safely shutting down.

2.3.4 Conclusion

. Based on the above evaluation, it is concluded that the existing fire protection features provide a level of fire protection. equivalent to the technical requirements of section III.G.2.d of Appendix R.

Therefore, the exemption request from the - - - _. _

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TER-C5506-646 iI requirement of a 20-foot separation between redundant excore

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neutron flux detector cables can be granted.

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2.4 QUENCH SPRAY PUMP HOUSES (FIRE AREAS 15-1 AND 15-2) 2.4.1 Exemption Requested An exemption was requested from the specific requirements of Section III.G.3 to the extent that it requires an automatic fire suppression system throughout the fire areas.

2.4.2 Discussion The Licensee has stated in exemption request 3 that Fire Areas 15-1 and 15-2 do not meet the requirements of Section III.G.3 j

because automatic fire suppression systems are not installed

, throughout each area.

Fire Areas 15-1 and 15-2 include the quench spray pump houses i '

.(QSPHs) and safeguards building for Units 1 and 2.

The Unit 1 QSPH is adjacent to the safeguards area and separated by a reinforced concrete wall with two ventilation duct penetrations.

i i. i The Unit 2 QSPH and safeguards area are separated by approxi-mately 30 feet on grade (elevation 272 feet, O inch), although they do abut at elevation 256 feet, O inch below grade.

Like the Unit 1

,j arrangement, the Unit 2 QSPH and safeguards area are separated by a reinforced concrete wall on the lower elevation and by two concrete

:b walls and a 30-foot-open space on grade.

There are two ventilation duct penetrations between the two areas spanning the 30-foot distance on the exterior between the areas.

Each QSPH contains a quench spray pump, instrumentation racks for the steam generator pressure transmitters, and the recircula-tion spray cooling system and related components.

Alternative shutdown capability is provided in the main steam valve house (Fire i-

!i Area 17).

The safeguards area contains components for the safety injection system, including the low head safety injection pumps and h

valves and components for the recirculation spray system for both pumps and valves.

The safeguards area does not contain any

'1 equipment required for an Appendix R safe shutdown.

Both the QSPMs and safeguards area are equipped with smoke detectors that annunciate in the control room.

The Licensee has committed to install additional smoke detectors in the QSPH to j

provide full area coverage.

Portable extinguishers are provided on each level of both the QSPHs and safeguards area.

Exterior hose l

houses and hydrants are located nearby for fire fighting purposes, i

The combustible loading in the QSPHs and safeguards area is low, consisting primarily of cable insulation with minor amounts of i

grease and lube oil.

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TER-C5506-646 2.4.3 Evaluation The fire protection in the QSPHs and safeguards area does not comply with the technical requirements of Section III.G.3 of Appendix R because an automatic fire suppression system is not installed throughout each area.

There was a concern that because an area-wide automatic suppression system is not installed, a fire of significant magnitude could develop and damage redundant steam generator pressure transmitters.

However, the combustible loading in the areas are low, consisting primarily of cable insulation with minor amounts of i

grease and lube oil.

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

'i in room temperature.

j Each QSPH and safeguards area is protected by a fire detection system consisting of ionization smoke detectors.

The Licensee has committed to provide additional detectors in each QSPH to provide full area coverage.

Because of the presence of these detectors, a fire in these areas should be detected in its incipient stage.

The

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alarms for these detectors are annunciated in the main control i

room.

The fire brigade would be dispatched to extinguish the fire i

manually, using the hose lines or portable extinguishers.

Instrumentation rackr, for the steam generator pressure transmitters are located in these fire areas, specifically each

!-]

QSPH.

The Licensee has committed to provide alternative shutdown capability for the transmitters in Fire Area 17.

This fire area is separated from the QSPHs and safeguards area by qualified 3-hour rated fire barriers.

'[~N Based on the fire protection features described above, the installation of an area-wide automatic fire suppression system i

would not significantly increase the level of fire protection for U

these areas.

With the fire protection features as described above, there is reasonable assurance that a fire in the QSPHs and safeguards area will not prevent the plant from safely shutting down.

r 2.4.4 Conclusion Based on the above evaluation, it is concluded that the existing fire protection in conjunction with additional' ionization detectors provide a level of fire protection equivalent to the i

technical requirements of Section III.G.3 of Appendix R.

Therefore, the exemption request from providing area-wide automatic l

suppression for Fire Areas 15-1 and 15-2 can be granted.

. l l

TER-C5506-646

I r

MAIN STEAM VALVE HOUSES (FIRE AREAS 17-1 AND 17-2) 2.5 2.5.1 Exemption Requested An exemption was requested from the specific requirements of Section III.G.3 to the extent that it requires automatic fire suppression systems throughout each of the fire areas.

2.5.2 Discussion The Licensee has stated in exemption request 4 that Fire Areas 17-1 and 17-2 do not meet the requirements of Section III.G.3 because automatic fire suppression systems are not installed throughout each area.

Fire Areas 17-1 and 17-2 are the main steam valve houses for L

.l Units 1 and 2, respectively.

Each fire area is located in a i

separate structure north of and adjacent to the containment buildings (Fire Areas 1-1 and 1-2), to the QSPHs (Fire Areas 15-1 and 15-2), and to the cable vaults and tunnels (Fire Areas 3-1 and 3-2).

Fire Areas 17-1 and 17-2 are multi-level structures consisting i

of the 272, 282, 297, and 307-foot, 6-inch elevations.

The fixed combustible loading in these areas is low,

,J consisting primarily of cable insulation and grease.

Ionization smoke detectors are provided in each of the fire i

{q areas at the upper elevation.

The detectors alarm in the control In addition, portable fire extinguishers and exterior hose room.

j stations are available for manual fire fighting.

3 Fire Areas 17-1 and 17-2 contain the main steam code safety valves, the power-operated relief valves (PORVs), and the steam supply valves to the turbine-driven auxiliary feedwater (AFW) pump.

The steam supply valves for the turbine-driven pump fail open and the PORVs fail closed.

A fire in either of these areas has the potential to damage control of the PORVs from the control room.

This will result in the opening of the code safety valves.

The steam supply valves tn the turbine-driven AFW pump fail open and no manual operation of steam supply is required from these fire areas.

Alternate shutdown capability is available by manually opening the PORVs by turning the handwheels.

i 2.5.3 Evaluation The fire protection in the main steam valve houses does not comply with the technical requirements of Section III.G.3 of i

Appendix R because an automatic fire suppression system is not installed throughout each area.

' l

q TER-C5506-646 I

1 '

Fire Areas 17-1 and 17-2 contain the main steam code safety valves, PORVs, and the steam supply valves for the turbine-driven AFW pump.

The combustible loading in these areas is low, consisting primarily of cable insulation and grease.

it is expected that it would develop slowly.If a fire were to occur, Ionization smoke detectors are provided in each of the areas at the upper elevation.

The alarms for the detectors are annunciated in the main control room.

The fire brigade will be dispatched and will extinguish the fire manually using the hose lines or portable extinguishers.

Until the fire is extinguished by the fire brigade, the low combustible loading, the use of code safety valves, the fire

,f, detection, and the ability to manually operate the PORVs all will

- provide sufficient protection to ensure that a fire in the above fire areas will not prevent a safe plant shutdown.

2.5.4 Conclusion r

Based on the above evaluation, it is concluded that the existing fire protection features provide a level of fire protection equivalent to the technical requirements of Section III.G.3 of Appendix R.

Therefore, the exemption request for J'

providing automatic fire suppression throughout Fire Areas 17-1 and 17-2 can be granted.

9 2.6 AUXILIARY FEEDWATER PUMP HOUSES (FIRE AREAS 14B-1 AND 1 2.6.1 Exemptions Requested ii.

Exemptions were requested from the requirements of Section i

III.G.3 to the extent that it requires an automatic fire suppres-sion system throughout each of the identified fire areas and from Section III.L.2.d to the extent it requires direct readings of l:

process monitoring variables necessary to perform and control required functions.

2.6.2 Discussion The Licenses has stated in exemption requests 5 and 23 that l7 the AFW pump house for each unit does not meet the requirements of l

Section III.G.3 because area-wide automatic fire suppression is not installed.

In addition, level monitoring of the energency conden-i sate storage tank (CST) does not meet the requirements of Section l

III.L.2.d because of potential fire damage to redundant level l

transmitters and cables.

North Anna Power Station is a two-unit plant with selected capabilities to allow components from one unit to be used as a means of alternate shutdown for the other unit.

The Licensee has 1

i !

i

+

1 TER-C5506-646 I

i stated that this condition existn for this area.

Therefore, the requirements of Section III.G.3 apply.

1 In addition, the Licensee has provided alternative shutdown capability for emergency condensate storage tank level indication.

i Fire Areas 14B-1 and 14B-2 contain the motor-driven AFW pumps for Units 1 and 2.

In addition, the AFW pump discharge valves and level transmitters for each unit's emergency CST are also located in these areas.

Each fire area is located in a separate structure which is ll distinct from all other plant structures and dedicated solely to l

the AFW pump system.

The walls and roofs of Fire Areas 14B-1 and t

145-2 are constructed of 24-inch-thick reinforced concrete.

All penetrations of the north wall into the turbine-driven AFW pump

{

fire area are sealed to a 3-hour fire rating.

A fire in Fire Area 3 R-1 or 14B-2 has the potential to damage both motor-driven AFW pumps, AFW pump discharge valves, and the i

level transmitters for each unit's emergency CST.

If the motor-driven pumps become inoperable, the turbine-driven pumps can be used.

t.

Loss of the level indicators for the emergency CST would

}

require that the pump suction pressure indicator located in the j

turbine-driven pump fire area to be used as an indication of i

emergency CST levelT The Licensee has committed to provide i

procedures detailing the use of AFW pump suction pressure as a means to determine adequate emergency CST level.

l The fixed combustible loading in each area is low, consisting of grease and lubricating oil.

4 Ionization smoke detectors, which alarm in the control room, are provided throughout Fire Areas 14B-1 and 14B-2.

Portable extinguishers and exterior hose stations are available for manual fire fighting purposes.

2.6.3 Evaluation i

The fire protection in the AFW pump houses does not comply

r with the technical requirements of Sections III.G.3 and III.L.2.d of Appendix R because an autor.atic fire suppression system is not installed throughout each area and because a fire can damage i

1 redundant emergency CST level transmitters.

i Both motor-driven AFW pumps, redundant level transmitters for each unit's emergency CST, and AFW pump discharge valves are I

located in these fire areas.

Due to the lack of an automatic j

suppression system, there was concern that a fire of significant magnitude could develop and damage both pumps and redundant level j

transmitters. 4 l

I i

TER-C5506-646 i

However, the combustible loading in Fire Areas 14B-1 and 14B-2 is low, consisting primarily of grease and lubricating oil within equipment.

In addition, smoke detectors are provided throughout these fire areas.

Because of the presence of the detectors, a fire in i

the motor-driven AFW pump fire areas should be detected in its incipient stage.

the main control room.The alarms from the detectors are annunciated in The fire brigade would be dispatched to extinguish the fire manually using hose lines or portable t

extinguishers.

l l

The Licensee has provided alternative shutdown capability for emergency CST level by reading the turbine-driven AFW pump suction pressure indicator located in a separate fire area.

The Licensee has stated that procedures exist detailing the use of the turbine-driven AFW pump suction pressure indicator in the turbine-driven AFW pump fire area as an alternative means of determining emergency CST level.

! L A fire in these areas will not affect the availability of the turbine-driven AFW pumps.

The turbine-driven AFW pump fire a eas j

are separated from the motor-driven AFW pump fire areas by 3_ our rated fire barriers.

i I

With the fire protection features as described above and alternative shutdown procedures, there is reasonable assurance that a fire in the motor-driven AFW pump areas will not prevent the t

plant from safely shutting down due to loss of redundant I

motor-driven ATW pumps and valves cr emergency CST level transmitters.

2.6.4 Conclusion Based on the above evaluation, it is concluded that the

(

existing fire protection features provide a level of fire l

t i

protection equivalent to the technical requirements of sections III.G.3 and III.L.2.d of Appendix R.

Therefore, the exemption requests from the requirements for providing automatic suppression in the motor-driven AFW pump houses and from direct reading of emergency CST level can be granted.

2.7 CHARGING PUMP CUBICLES (ELEVATION 244 FEET, 6 INCHES) 2.7.1 Exemption Requested An exemption was requested from the specific requirements of l

Section III.G.2.a to the extent that it requires the separation of cables, equipment, and associated nonsafety circuits of redundant trains by a fire barrier having a 3-hour fire resistance rating.

I i 4

TER-C5506-646 g

2.7.2 Discussion The Licensee has stated in exemption request 7 that Units 1 and 2 charging pump cubicles do not meet the requirements of Section III.G.2.a because of the removable concrete wall.

e The charging pump cubicles are located on the 244-foot, 6-inch elevation of the auxiliary building.

The cubicles are approxi-mately 9 feet, high.

6 inches wide by 24 feet, 6 inches long, and 14 feet Three of the four walls of each charging pump cubicle are i I constructed of 3-hour rated reinforced concrete.

The fourth wall is constructed of close-fitting, interlocking reinforced concrete ties.

The ties are 1-foot-thick and have a protective steel plate on all interlocking surfaces.

The ends of the ties fit in between jj the flanges of the beams to provide stability.

i The combustible loading on elevation 244 feet, 6 inches of the auxiliary building is low, consisting primarily of cable insula-tion.

The area immediately adjacent to the subject wall is a i

corridor and is free of fixed combustibles.

The combustible loading within the. charging pump cubicles consists of approximately 30 gallons of lube oil contained in each There are no fixed combustibles near the subject wall.

pump.

'b An ionization smoke detection system is provided in the auxiliary building and includes one ceiling mounted and one duct

. p?

mounted detector in each charging pump cubicle.

The smoke i

detection system provides separate alarms for each cubicle and for each elevation of the auxiliary building in the control room.

Portable extinguishers and fire hose stations are provided for l-fire fighting purposes.

i 2.7.3 Evaluation The charging pump cubicles located on the 244-foot, 6-inch elevation of the auxiliary building do not comply with the technical requirements of Section III.G.2.a of Appendix R because i

the north wall of each cubicle is not a 3-hour rated fire barrier.

The north wall is a removable concrete wall.

building and within each charging pump cubicle is low.The combustible The principal combustibles consist of cabic insulation and lube oil contained within the charging pumps.

There is no combustible material in contact with or penetrating the removable wall.

' Ionization smoke detectors are provided in the auxiliary building and, within each charging pump cubicle.

i The alarms from the detectors are annunciated in the main control room.

Upon 1 a

t l

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l-TER-C5DJ6-646 I

i detection of a fire, the fire brigade would be dispatched and would extinguish the fire with the hose lines or portable extinguishers.

A major factor that reduces the risk of fire propagation through the removable wall is that its thickness exceeds a typical 3-hour rated wall and all joints and seams are tight-fitting.

Until the fire is extinguished, the separation and inter-mediate barriers between the charging pumps, the lack of intervening combustibles, and the low combustible loading of the auxiliary building corridor near the walls and the charging pump cubicles will provide sufficient passive protection to ensure that one shutdown division would remain free of fire damage.

]

2.7.4 Conclusion

"{

Based on the above evaluation, it is concluded that the existing fire protection features provide a level of fire protection equivalent to the technical requirements of Section j

III.G.2.a of Appendix Jt.

Therefore, the exemption request for the removable wall in each charging pump cubicle can be granted.

[

2.8 o

4-TO 20-MA SIGNALS IN TWISTED PAIR INSTRUMENT CABLE, i t PROTECTED FROM HOT SHORTS

]

o 125-VDC CIRCUITS IN RIGID METAL CONDUIT, PROTECTED FROM HOT j

SHORTS I

2.8.1 Exemptions Requested g

Exemptions were requested from the specific requirements of

)

Section III.G.2 to the extent that it requires the protection of I

low current instrument circuits and 125-Vdc circuits that could prevent operation or cause maloperation due to hot shorts.

2.8.2 Discussion p;

The Licensee has requested, in exemption requests 19 and 20, exemption from Appendix R for 4-to 20-mA signals carried by i l instrument cables which are routed in raceway with other instrument I L.

cables and for 125-Vdc circuits serving high/ low pressure inter-faces that are routed in dedicated rigid steel conduits.

One or i"

more of these circuits are installed in the cable vault and tunnel, j

main control room, containment, emergency switchgear room, and main 1

steam valve house.

i The Licensee states that the condition of all four conductors

~

of two adjacent low current level instrument circuits, which are routed in raceway with other instrument cables, fusing together in

.the correct polarity with low impedance is not credible.

In addition, a direct short (positive and negative conductors contact-ing each other) or short to ground will cause a zero signal output.

i '.-..

i TER-C5506-646 4

The 125-Vdc circuits that are routed within a cable tray and

}

provide motive power to high/ low pressure boundaries that are

{

susceptible to hot shorts must be protected in accordance with Section III.G.2 of Appendix R.

The Licensee has committed to route l

these circuits in dedicated steel conduit.

In addition, there are I

procedures requiring the circuits' to be deenergized in the event of a fire.

1 The Licensee has committed to provide a new isolation switch in the emergency switchgear room to ensure that the circuits can be deenergized from either the control room or from the emergency switchgear rooms.

J 2.8.3 Evaluation 1

i Sections III.G.2 and III.L.7 of Appendix R define circuit j

failure modes as hot shorts, open circuits, and shorts to ground.

t For consideration of spurious actuations, all possible functional failure states must be evaluated, i.e.

3 energized or deenergized'by one or more, the component could be of the above failure modes.

i Guidance concerning which circuit failure mode must be considered in identifying circuits associated by spurious actuation

'a is provided in Generic Letter 86-10, which states that for ungrounded de circuits, if it can ba shown that only two shorts of p

the proper polarity without grounding could cause spurious y

operation, no further evaluation is necessary, except for circuits involving high/ low pressure interfaces.

The Licensee has routed circuits involving high/ low pressure interfaces in dedicated rigid steel conduits.

In addition, there are procedures that require the circuits to be deenergized in the

'f event of a fire.

The circuits can be deenergized from the main iL control room and the emergency switchgear rooms.

i The probability of getting a hot short of the proper polarity

.}

without grounding two independent de circuits (one circuit within a j-dedicated conduit and one circuit from outside the conduit) is considered sufficiently low as not to require evaluation.

This guidance is contained in Section 5.3.1 of Generic Letter 86-10.

Based on the above guidance contained in Generic Letter 86-10, the exemption requests for the above circuits are not required.

tr 2.8.4 Conclusion Based on the above evaluation, it is concluded that'the 4-to

{

20-mA instrument cables and the 125-Vdc circuits identified in the Licensee's submittals meet the guidance contained in Generic Letter j

86-10.

Therefore, the exemption requests from protecting the circuits from hot shorts are not required.

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e-TER-C5506-646 1

2.9 SEPARATION OF INSTRUMENTATION INSIDE THE CONTAINMENTS, INTERVENING COMBUSTIBLES WITH FIRE STOPS j

j 2.9.1 Exemption Requested I

An exemption was requested from the requirements of Section

{

III.G.2.d to the extent that it requires redundant cables and equipment separated by 20 feet or by radiant energy shields to be free of intervening combustibles.

I 2.9.2 Discussion The Licensee has stated in exemption request 27 that primary 4

and alternate trains of cabling for primary plant instrumentation inside the containment are separated by more than 20 feet or by

't radiant energy shields, but intervening combustibles exist in certain areas.

The instrumentation of concern are the RCS hot and cold leg temperatures, steam generator level, excore neutron flux monitoring, and RCS pressure and pressurizer level.

Fire Areas 1-1 and 1-2 are the primary containments for Units 1 and 2, respectively.

Primary and alternate trains of instrumen-T tation are routed through two different penetration areas within

4 each containment.

There is an electrical penetration area into 1

each unit's cable vault / tunnel area and a second electrical g

penetration area for each containment is provided into the fuel

, g building.

The two penetration areas are each separated by more than 20 feet horizontally and 30 feet vertically for each unit.

1 Radiant energy shields have been placed between primary and alternate instrumentation or components located less than 20 feet i e apart.

Fire rated conduit wraps have been provided where there is less than 20 feet of horizontal separation, regardless of the open vertical exposure.

The wraps are provided until a distance of 20 i

feet of horizontal separation is achieved or until a barrier constructed of heavy concrete is encountered.

Intervening combustibles in the form of cables trays exist between primary and alternate trains of instrumentation separated by more than 20 feet or by radiant energy shields.

In order to mitigate the potential of fire spread along these trays, the Licensee has committed to install vertical and horizontal fire stops where the cable trays constitute a potential intervening combustible.

I I The horizontal fire stops are 36-inch-long marinate boards on the top and bottom of the tray, with 10 inches of silicone foam in between.

The fire stops are located in various areas selected to prevent fire propagation between redundant safe shutdown' components or circuits along the intervening cable trays.

!l

. Cable tray covers have been installed on trays near the cable vault / tunnel penetration areas.

In addition, a cable tray bottom has been installed on the lowest horizontal cable tray, i

l 't l

l i

. ~..

TER-C5506-646 Heat and smoke detectors, which alarm in the control room, are located in thc primary containment.

Also, there are portable fire extinguishers located inside of the containment.

Dry standpipes are available for use by the fire brigade.

2.9.3 Evaluation The fire protection for Fire Areas 1-1 and 1-2 does not comply with the technical requirements of Section III.G.2.d of Appendix R because intervening combustibles, specifically, cables in trays exist between primary and alternate trains of cabling for primary plant instrumer.tation, which is separated by more than 20 feet or

{

by radiant energy shields.

The Licensee has committed to provide fire stops between redundant instrumentation components or cabling i

to mitigate the consequences of intervening combustibles.

t!

l"

~

The location and design of the fire stops will inhibit fire propagation along the cable trays between redundant safe shutdown circuits or components.

t With the fire protection features described above, there is 1

reasonable assurance that a fire within the containments will not prevent the plant from safely shutting down due to the loss of primary and alternate trains of identified instrumentation cabling resulting from fire propagation along intervening combustibles.

2.9.4 Conclusion __

Based on the above evaluation, it is concluded that the 9

existing fire protection features combined with the proposed cable tray fire stops provide a level of fire protection equivalent to the technical requirements of Section III.G.2.d of Appendix R.

Therefore, the exempti:n requcet from the specific requirements of Appendix R requiring no intervening combustibles can be granted.

2.10 AUXILIARY BUILDING, VENTILATION EQUIPMENT AREA (FIRE AREA 11) 2.10.1 Exemption Requested l

An exemption was requested from the requirements of Section III.G.2.b to the extent that it requires full area detection and suppression throughout Fire Area ll.

2.10.2 Discussion The Licensee has stated in exemption request 28 that Fire Area 11 for each unit does not meet the requirements of Secti6n III.G.2.b because full area detection and suppression are not provided.

Fire Area 11 consists of the auxiliary, fuel, and decontam-ination buildings for Units 1 and 2.

The buildings are located side by side in a north-south orientation, with the auxiliary 1 -.

o TER-C5506-646 t

{'

building to the north, the decontamination building to the south, j

and the fuel building in the center.

Additional details concerning i

Fire Area 11 are provided in Section 2.2.

i The Licensee has installed new ventilation fans in the I

auxiliary building and has ensure'd that fan locations and redundant trains of cabling are separated by more than 20 feet.

The two new ventilation fans are installed on the roof of the auxiliary i

building, elevation 319 feet, 4 inches.

l-The fans are installed to ensure that ventilation for the charging pumps and the CCW pumps will be available following a fire in the auxiliary building or in other areas.

The fans are i

installed on a concrete slab located above the CCW heat exchanger cubicle.

Elevation 291 feet, 6 inches of the auxiliary building con-tains the normal auxiliary building exhaust fans, containment purge supply fans, miscellaneous supply and exhaust fans, and ventilation j

system charcoal filters.- The new ventilation fans are located on the roof so that approximately 40 feet of separation is maintained.

1 l

2.10.3 Evaluatien

L:

The fire protection for Fire Area 11 does not comply with the technical requirements of Section III.G.2.b of Appendix R because

~

1 automatic fire suppression and detection systems are not installed throughout Fire Area 11.

1 There was a concern that because of the absence of area-wide automatic suppression and detection systems, a fire of significant magnitude could develop and damage the normal building exhaust fans and the new ventilation fans in the auxiliary building.

However, the combustible loading in Fire Area 11 is low (an equivalent fire savarity of less than 20 minutes).

l In addition, an automatic fire detection system is installed l

in all areas with significant amounts of combustibles and areas J

containing safe shutdown components.

Because of the presence of the detectors, a fire should be detected in its incipient stage.

l The alarms from the detectors are annunciated in the main control room.

The fire brigade would be dispatched to extinguish the fire

.e manually, using hose lines or portable extinguishers.

i The new ventilation fans are located on the roof so that approximately 40 feet of separation is maintained from the old fans.

Once the duct is inside the auxiliary building, h'ard and flexible ducts are routed down to the CCW pump area to charging 1 -

pump cubicles and penetration areas.

The flexible duct is con-tained in a fireproof enclosure and stored in an area that will not be affected by a fire in Fire Area 11.

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TER-C5506-646 t

At the roof elevation, the two trains are separated by more than 20 feet horizontally with no intervening combustibles.

The cables are routed in separate fire areas, except at the fan location.

A fire in the normal switchgear room may disable the new ventilation fans in the auxiliary building, but the existing ventilation vould not be affected.

4 The installation of area-wide automatic fire suppression and

}

detection systems would not significantly increase the level of fire protection for Fire Area 11.

j 2.10.4 Conclusion i

Based on the above evaluation, it is concluded that the existing fire protection features combined with the new ventilation j

system in the auxiliary building provide a level of fire protection equivalent to the technical requirements of Section III.G.2.b of i

Appendix R.

Therefore,,the exemption request from the requirement i

i of full area suppression and detection in Fire Area 11 can be granted.

!Il 2.11 o

EMERGENCY LIGHTING IN THE SEAL WATER FILTER AREA, USE OF PORTABLI LIGHTS EMERGENCY LIGHTING IN THE CONTROL ROOM, USE OF DIESEL

-'j o

GENERATOR POWER SUPPLY

f EMERGENCY LIGHTING FOR EXTERIOR ACCESS ROUTES, USE OF o

j ' s SECURITY LIGHTING AND PORTABLE LIGHTS

' l 2.11.1 Exemptions Requested 1

Exemptions were requested from the requirements of Section j,-

III.J to the extent that it requires all areas needed for operation

l-of safe shutdown equipment; and in access and agress routes thereto i

to be provided with emergency lighting units with at least an 8-hour battery supply.

2.11.2 Discussion

y The Licensee has stated in exemption requests 31, 32, and 33 that the above areas 13 not meet the requirements of Section III.J of Appendix R because 8-hour battery-powered emergency lighting is not installed.

The seal water filter area (SWFA) is located south of the charging pump cubicles on the 244-foot, 6-inch elevation of the 4

auxiliary building.

The SWFA consists of a series of concrete i

cubicles approximately 6 feet deep and 10 feet wide.

They contain i

seal water filters, heat exchangers, and injection filters.

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TER-C5506-646 t-The auxiliary building is part of Fire Area 11, which is described in more detail in section 2.2.

The Licensee's procedures for Appendix R safe shutdown for certain fire areas require an operator to enter each SWFA to verify the position of valves and, if needed, to open or close any that are not aligned.

lights in the SWFA.There are currently no battery-powered energency Portable constant recharge lanterns are installed directly outside of the SWFA for use by the operator during emergency shutdown procedures, The SWFA cubicles are locked, high radiation areas.

e The general area dose rate is normally 2 rem /hr.

The operator only needs to be in the cubicles long enough to verify valve alignment and to manually operate any valve not aligned.

This procedure only needs to be verified once.

in the SWFA will be needed. No other entries or constant attendance L-No gauges or instruments need to be observed in the SWFA.

Access and egress routes to the SWFA cubicles have fixed 8-hour battery-powered emergency lights.

Normal 8-hour emergency lighting is provided in the area outside of the SWFA so the portable lanterns will be illuminated.

l' (d

The portable lights are contained in locked metal cases with a break-away lock.

The lights are visually checked periodically and incorporated into the emergency lighting periodic test program.

d The control room emergency lighting units are diesel powered as opposed to an 8-hour battery-powered supply.

The Licensee's lq basis for the use of diesel-backed emergency lighting in the i,

control room includes the following:

1.

I The plant emergency diesel generators have a fuel capacity in excess of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

.I 2.

Power feeds are routed such that no single fire outside the control room could affect both power supplies for the control room lights.

3.

The lights are arranged in a configuration such that the lights from each unit's diesel cover both sides of the control room.

F 4.

An illumination test has been performed to verify the adequacy of the lighting level to perform required operations when powered from either diesel, s

During the short transition from loss of offsite power to diesel generator power, lights having a battery power supply will be illuminated within the control room complex.

j Operator access routes to various safe shutdown components may require travel outside of the buildings.

Lighting for these exterior routes is provided by station security lighting and _ _ _ _ _ _ _ _.

TER-C5506-646 portable lights.

The security lighting is powered by the station security diesel in the event of the loss of offsite power.

Safe shutdown components are located within several buildings that require exterior access.

These buildings are the main steam valve house, AFW pump house, QSPH, fuel oil pamp house, SW pump i

house, and auxiliary SW pump house and yard vault pit.

Shutdown procedures for the exterior buildings require the operator to assemble at the Appendix R locker area and acquire portable lights.

The inventory of the Appendix R locker is checked periodically to ensure that adequate lights are available and that J

the batteries are functional.

2.11.3 Evaluation 1

i The fire protection in the above areas does not comply with the technical requirements of Section III.J of Appendix R because 8-hour battery-powered emergency lighting is not installed in all l

areas needed for operation of safe shutdown equipment and in access and egress routes therato.

The Licensee has provided an acceptable level of emergency t-lighting to ensure access and egress to emergency control stations.

1 i ', '

These include the following:

i t

d Dedicated, controlled, and maintained portable lights o

i located at pre-designated locations.

i fi security perimeter lighting powered by the security diesel o

generator.

Redundant diesel-backed emergency lighting provided for the o

control room.

The location and control of the emergency lighting should ensure access and egress to areas required to achieve and maintain safe shutdown.

With the features described above, there is reasonable assurance that adequate lighting for all required areas is provided and that the lack of 8-hour battery-powered emergency lighting units in the areas above will not prevent the plant from i

safely shutting down.

I 2.11.4 conclusion Based on the above evaluation, it is concluded that the i

existing security lighting and control room lighting combined with the location and controls of dedicated portable lights provide a i

level of fire protection equivalent to the technical requirements of Section III.J of Appendix R.

Therefore, the exemption requests from'the requirement for 8-hour battery-powered emergency lighting in the above areas can be granted.

l i

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TER-C5506-646 t

2.12 REFUELING WATER STORAGE TANK, IACK OF LEVEL INDICATION 2.12.1 Exemption Requested An exemption was requested from the requirements of Section III.L.2.d to the extent that it requires process monitoring to be capable of providing direct readings of process variables necessary to perform and control required functions.

4 j

2.12.2 Discussion iI The Licensee has stated in exemption request 34 that the level 4

(.

monitoring of the refueling water storage tank (RWST) does not meet the requirements of section III.L.2.d because a fire occurring in any one of several fire areas such as the control room or the

't emergency switchgear room may result in the loss of RWST level

,j indication.

An RWST is provided for each unit.

,m water to the RCS via the charging pumps for reactor coolantThe RWST provides makeu inventory and reactivity control.

Level indication for the RWST is provided in the control room for normal operations.

A fire in the i

control room and either unit's emergency switchgear room or cable

,,L vault / tunnel could cause the loss of this indication.

No redundant or alternate method is provided for obtaining either a direct or indirect level indication.

1 Plant technical specifications require that 1

475,058 gallons of water be available in the RWST of each unit that is operating. L 1

The percent of the volume of the RWST is required to attain cold shutdown.

{

i The discharges of the charging pumps for the two units are cross-connected and provide alternate shutdown capability to each

~

other.

! {

unit's RWST.Each unit's charging pumps take auction from the respective

)

3, There are administrative controls to ensure that if one unit il' is not operating, there will be sufficient volume in that unit's h.

RWST to safely shut down the operating unit should the operating unit's charging pumps become disabled.

using the charging pumps' discharge cross-connection. Shutdown would be achieved 2.12.3 Evaluation 1

The fire protection for the RWST does not comply with the i

technical requirements of Section III.L.2.d of Appendix R because i

fire can damage RWST level indication and no alternate means of j

process monitoring is provided.

Therefore, direct readings of the j

process variables necessary to perform and control required functions at the control room and the remote shutdown panel are not 1

)

provided.

I 1 3

1 l

TER-C5506-646 The amount of water taken from the RWST for RCS makeup during an Appendix R safe shutdown is less than 10 percent of the minimum RWST volume allowed by the Licensee's technical specifications.

j Administrative controls are'provided to ensure that there is sufficient quantity of water available in the RWST of a unit that unit if necessary.is not operating to supply the charging pumps for the opera i

l There is a sufficient margin of RWST volume to achieve Appendix R safe shutdown.

j 2.12.4 Conclusion i

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

existing RWST inventory combined with the administrative controls

~

and the quantity of water available in the RWST of a unit that is not operating provide a icvs1 of fire protection equivalent to the requirements of Section III.L.2.d of Appendix R.

Therefore, the i

exemption request from^ direct reading of process variables, o

specifically, the RWST level, can be granted.

, l 2.13 CHILLER ROOMS, LACK OF A 3-HOUR RATED BARRIER i

2.13.1 Exemption Requested i

)J

.An exemption w'a's requested from the requirements of Section

(

III.G.2.a to the extent that it requires the separation of cables, I},{,

a fire barrier having a 3-hour fire resistance rating. equipmen 2.13.2 Discussion venti a i n open ngs ex st bet e n ts 1 a d ch 1 er r ons nto 4

the turbine building basement (Fire Area 8).

1 i

elevation of the service building.Both units' chiller rooms are located on the The chiller rooms are both i

bounded to the south by the respective unit's emergency switchgear

{ ;'

and air conditioner rooms.

rated.

The wall between these areas is 3-hour j

building basement, elevation 254The north wall of each chiller room is adjacent to feet, o inch.

This wall.is a minimum of 12-inch-thick concrete.

The doors between these areas i

are 3-hour rated installed in channel steel frames similar to those i

described in Section 2.14.2.3.

openings in this wall for each chiller room.There are also two ventilation Each opening is approximately 4 feet by 4 feet.

I are the only unsealed penetrations between the two chiller roomsThe openings i '

i

TER-C5506-646 and the turbine building.

Each opening is protected with a missile barrier consisting of three rows of 1/4-inch-thick steel beams.

i Elevation 254 feet, O inch of the turbine building has an area-wide sprinkler system.

Automatic deluge systems protect the major lube oil components located on this elevation.

Both chiller rooms are provided with smoke detectors which annunciate in the control room.

i 6-There is a masonry wall between Units 1 and 2 side of the turbine building, dividing the basement and mezzanine levels.

This wall separates the ventilation openings to each unit's chiller One chiller room is capable of maintaining sufficient cool-room.

ing to keep the control room tenable for over 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

i

' -l Fire extinguishers are located throughout both areas and hose i

stations are located in the turbine building adjacent to the chiller rooms.

;i JU 2.13.3 Evaluation

~

?

Units 1 and 2 chiller rooms, located on elevation 254 feet, 0

) ll inch of the service building, do not comply with the technical requirements of Section III.G.2.a of Appendix R because unrated l

ventilation openings exist into the turbine building basement.

i L

smoke detectors are provided in each unit's chiller room adjacent to each of the ventilation openings.

Because.of the i 1 detectors, a fire within the chiller room will be detected in its i L incipient stage.

The alarms from the detectors are annunciated in the main control room.

The fire brigade will be dispatched and

'r would extinguish the fire manually using the hose lines or portable extinguishers provided.

l Areas in the turbine building adjacent to the openings are provided with full area sprinkler systems.

Automatic deluge spray i

,1 systems are installed on major lube oil components located on this elevation.

There are no combustibles which pass through the venti-lation openings.

1 l

~

A full height masonry wall on elevation 254 feet, 0 inch of the turbine building separates the ventilation openings of Units 1 r.

4 and 2 chiller rooms.

A single chiller room will provide sufficient l

cooling to keep the control room tenable for over 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

Until the fire is extinguished by the fire brigade 'er automatic suppression systems, the spatial separation and intervening ansonry wall in the turbine building, the general area i

fire suppression system in the turbine building, the fire detection system in the chiller rooms, and the lack of intervening combusti-bles will provide sufficient protection to provide reasonable assurance that a chiller room would remain free of fire damage. i

=

TER-C5506-646 2

4 Also, there is reasonable assurance that a fire in the area will not prevent the plant from safely shutting down.

2.13.4 Conclusion Based on the above evaluation, it is concluded that the existing fire protection features provide a level of protection equivalent to the technical requirements of Section III.G.2.a of Appendix R.

Therefore, the exemption request for the unrated ventilation openings from each unit's chiller room into the turbine building basement can be granted.

2.14 o

EMERGENCY SWITCHGEAR/ CHILLER ROOMS, NO FIRE DAMPER (FIRE j'.

AREA 6-1)

I o

EMERGENCY SWITCHGEAR ROOM, FIRE DOOR FRAMES (FIRE AREA 6-2)

FIRE DOORS, FRAMES NOT FIRE RATED (VARIOUS FIRE AREAS) o o

FIRE DOORS, C6NDUITS IN DOOR FRAMES (VARIOUS FIRE AREAS)

CONTROL ROOM STAIRWELL / EMERGENCY SWITCHGEAR ROOM WALL, o

1 FIRE BARRIER RATING (FIRE AREA 2)

CABLE VAULT / TUNNEL AND AUXILIARY BUILDING WALL FIRE o

J BARRIER RATING (FIRE AREA 3-1)

F AUXILIARY / TURBINE BUILDING PIPE TUNNEL, LACK OF FIRE o

BARRIER (FIRE AREA 8) o CONTROL ROOM / TURBINE BUILDING, BULLETPROOF DOORS (FIRE AREA 2)

CONDUITS PASSING THROUGH RATED FIRE BARRIERS, LACK OF o

INTERNAL SEALS (VARIOUS FIRE AREAS) i

{

2.14.1 Exemptions Requested I

Exemptions for the following configurations were requested I

from Section III.G.2 of Appendix R to the extent that it requires

)

separation of redundant safe shutdown components by 3-hour rated i r-fire barriers.

i l

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 establishing fire area boundaries are set forth in Appendix A to BTP APCSB 9.5-1 in Section D.1. (j).

i Therefore, these areas have been reviewed for conformance with

{

Appendix A. guidelines.

}

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

,-_----_-,_.n-

n

TER-C5506-646 l

2.14.2 Discussion 2.14.2.1 Emergency Switchgear/ Chiller Rooms, No Fire Damper (Fire Area 6-1)

The Licensee has stated in exemption request 14 that the 12-inch diameter schedule 40 pipe penetration between the air conditioning room (Fire Area 6-1) and the chiller room (Fire Area j

8) is not provided with a fire damper.

The penetration arrangement was identified in the 1979 Fire Protection Safety Evaluation Report issued by the NRC staff.

Subsequently, the arrangement was found acceptable by the NRC staff as stated in a letter dated July 9, 1979.

As indicated in Generic Letter 86-10, "if a fire area boundary has been specifically identified and justified in the fire hazards analysis performed in

!l',

the Appendix A process and evaluated and accepted by the staff, the fire area boundary need not be reviewed as part of the reanalysis for compliance with section III.G of Appendix R."

Therefore, the

<{'

subject penetration remains acceptable for continued use in the fire area boundary as aescribed.

)

n-i I f 2.14.2.2 Emcreency Switchgear Room, Fire Door Frames (Fire l

Area}!)

2 The Licensee has stated in exemption request 15 that two door

-.!j assemblies in the emergency switchgear fire area boundary are not fire rated.

The two door assemblies are oversized door openings used for equipment accesa during construction.

The door openings

' It have been reduced to a standard double door frame by a steel structure.

The first door (Fire Door S54-8) is located between Fire Areas i

6-1 and 6-2.

The second door (Fire Door 554-11) is located between Fire Areas 6-2 and the turbine building fire area.

The emergency switchgear rooms are protected by smoke detec-tors which annunciate in the main control room.

In addition, a total flooding Halon fire suppression system has been installed.

The turbine building basement has an automatic sprinkler sys-tem installed throughout the area.

i 1 r-There are several fire extinguishers located throughout both i

areas.

Hose stations are located in or near both areas.

The Licensee has performed an analysis evaluating the capability of these doors to perform in these fire area boundaries based on the installed fire protection systems, combustible j

quantity, and configuration and found them comparable to Under-writer's Laboratories (UL) labeled doors.

i

..-_-------_..,,,--_-.---y.-__,..-

,,---.ww.--+.m.,

TER-C5506-646 r

2.14.2.3 Fire Doors, Frames Not Fire Rated (Various Fire Areas)

The Licensee has stated in exemption request 16 that several door assemblies in fire area boundary walls have frames which do not have a label from a recognized testing laboratory.

The subject doors include:

o Door 854-5 Unit 1 emergency switchgear room (ESGR) to Unit 1 cable tunnel

)

o Door S54-9 Unit 2 ESGR to Unit 2 cable tunnel l

o Doors S71-16, 17, All four amargency diesel c

18, and 19 generator rooms to the turbine 3

building

~

o Door 71-19A Door from technical support center l

i..,

HVAC room to the turbine building o

Doors S76-25 and 26 Units 1 and 2 control rooms to the

{

turbine building I

l o

Doors S94-7, 8, 9, Battery rooms 1-I, 1-XII, 2-I, and and 10 2-III to the cable spreading room l

o Doors A80-1 and 2 Rod drive room to the auxiliary J

building, both units.

R The frames consist of steel channels which are an integral

..l part of a poured concrete wall.

The. Licensee' has performed an 1

analysis which shows that the frames'are equivalent to labeled frames due to their construction.

The analysis considered the 2

combustible quantity, configurations,,and fire protection systems 3

j on each side of such doors.

'~

l All of the above areas are equipped with rate compensated i

and/or smoke detectors.

The cable spreading room, cable tunnel, rod drive area, and diesel generator rooms are equipped with a total ~ flooding Co$re equipped with a manually actuated Halon fire suppression system.

The emergency j

switchgear rooms system.

In addition, the cable tunnel has a backup deluge system r

and a closed-head sprinkler system which are manually activated.

t Fire extinguishers are located throughout all of the areas and hose stations are located nearby.

2.14.2.4 FireDoors,ConduitsinDoorFrames(VarioushireAreas) l The Licensee has stated in exemption request 17 that several door' assemblies in fire boundary walls have. conduits penetrating into the door frames.

The conduits carry, cable for security

TER-C5506-646 i

devices such as card readers or door monitoring.

This type of conduit. penetration has not been tested for a 3-hour fire rating.

The fire doors involved include:

o Door S54-5

' Unit 1 emergency switchgear room (ESGR)> to Unit 1 cable vault / tunnel o

Door S54-6 Unit 1 ESGR to the control room stairwell o

Door S54-7 Unit 2 ESGR to the control room stairwell o

Door S54-8 Door between Units 1 and 2 ESGRs I

\\

o Door S54-9 Unit 2 ESGR to Unit 2 cable vault / tunnel o

Door S54-11 Unit 2 ESGR to the turbine building f

l o

Door S76-25

[

Unit 2 control room to the' turbine building o

Door S76-26 Unit 1 control room to the turbine

-J building o

Doors S71-16, 17, Doors between'each emergency diesel 1

18, and 19 generator room and the turbine building o

Doors S94-7, 8,

9, Battery rooms 1-I, 1-III, 2-I, and l

and 10 2-III in the cable spreading rooms.

Detection is provided in all areas adjacent to the above doors.

Il The conduits penetrate enly one side of the frame (where the conduits and frame meet) and all connections are tight.

I The Licensee has evaluated the affected fire door assemblies and determined that they provide an adequate margin of fire resistance I

considering the fire loading on both sides of each of the door r

assemblies.

2.14.2.5 Control Room Stairwell / Emergency Switchgear Room Wall Fire Barrier Rating (Fire Area 2)

The Licensee has stated in exemption request 21 that the stairwell wall between the control room complex (Fire Area 21) and the Unit 2 emergency switchgear room (Fire Area 6-2) is not fire rated for 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months .

TER-C5506-646 The stairwell between the control room complex and the Unit 2 emergency switchgear room is considered part of the control room

(

complex fire area (Fire Area 2).

The wall between the stairwell and the Unit 2 ESGR is constructed of 8-inch-thick masonry blocks.

The Licensee has performed an analysis to evaluate the capability of the wall to perform in this fire area boundary based on the installed fire protection systems and adjoining spaces, the combustible loading configuration within these areas, and comparison with masonry walls of known fire resistance rating.

The evaluation concluded that the 8-inch-thick masonry wall provides an adequate margin of fire resistance based on the NRC staff guidance.

2.14.2.6 Cable Vault / Tunnel and Auxiliary Building Wall Fire Barrier Rating (Fire Area 3-1)

The Licensee has stated in exemption request 22 that there is an i

8-inch-thick masonry block wall between sections of the 259-foot, 0-inch elevation of the cable vault / tunnel (Fire Areas 3-1 and 3-2) and the auxiliary building (Fire Area 11) that is not rated for 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months .

t The Licensee has stated that the subject wall is rated for a minimum of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

In addition both the cable vaults and tunnels j

and the auxiliary building are eq,uipped with smoke detectors which annunciate in the control rect.

The cable vault and tunnel are equipped with an automatic total flooding CO, fire suppression system and a closed-head manual

J sprinkler sistem. JL partial sprinkler system is installed on the 259-and 244-foot, 0-inch elevations of the auxiliary building, reducing the probability of fire exposure to the subject wall.

The B-inch-thick masonry wall combined with the fire protection rl features described above provide an adequate margin of fire resistance based on the NRC staff guidance.

J 2.14.2.7 Auxiliary / Turbine Building Pipe Tunnel, Lack of Fire

]

Barrier (Fire Area 8)

The Licensee has stated in exemption request 24 that a pipe tunnel is located below the ground floor of the service building and provides a routing from the turbine building to the auxiliary building for various pipes.

A rated barrier or seal does not exist at either and of the tunnel.

'l The tunnel has a negligible combustible loading in the form of pipe insulation on chilled water lines.

1 into the turbine building at the floor level.The tunnel opens vertically This elev_ation of the turbine building is equipped with an area-wide automatic ~ sprinkler system and deluge systems protect major lube oil components.

'The combustible loading in the auxiliary building is low to moderate.

The 244-foot elevation where the tunnel exits into the wuxiliary bu'ilding contains small cable runs and only small amounts --_

,..-.,,g r

w--

-w--

--v-

TER-C5506-646 I

I of lube oil in pumps.

The area near the tunnel in the auxiliary building is also protected by automatic sprinklers.

There are smoke i

detectors on the auxiliary building side of the pipe tr.rnel.

There is a 3-foot-wide dike around the turbine building tunnel opening which prevents flammable liquids from entering the tunnel.

2.14.2.8 Control Room / Turbine Building, Bulletproof Doors (Fire Area 2)

The Licensee has stated in exemption request 26 that two door assemblies in the fire area boundary wall between the control room i

and the turbine building have been modified by installing 1/4-inch-thick steel plates on the exterior of the door for bulletproof resistance.

4 The doors of concern are S76-25 and S76-26.

Door S76-25 is a double-leaf door between the Unit 2 side of the control room and the turbine building.

Door S76'-26 is a single-leaf door between the Unit i

1 side of the control room and the turbine building.

\\

n Smoke detectors are installed on the ceiling of the control room i

and in the subfloor area.

An automatic Halon fire suppression syster l,

is also installed in the subfloor area.

The turbine building has an automatic sprinkler system through-out the building, except over the operating floor.

There are fire J

extinguishers located throughout both areas and the hose stations are located outside of the control room.

's The subject doors are UL labeled and 3-hour fire rated.

In order to satisfy security requirements, 1/4-inch-thick steel plates were added to each leaf of the doors.

The doors were then certified for a bullet resistance rating in accordance with UL-752.

At the time of the modification, acceptable 3-hour rated bullet resistant doors were not available.

The Licensee has performed an analysis which demonstrates the acceptability of the doors for service in a fire area boundary.

The technical basis for the evaluation considered installed fire protection systems, configuration of the turbine building and control room doors, transient combustibles, and administrative procedures.

I 2.14.2.9 Conduits Passing Through Rated Fire Barriers, Lack of Internal Seals (Various Fire Areas)

The Licensee has stated in exemption request 35 that several conduit penetrations through 3-hour rated fire barriers between fire areas containing redundant safe shutdown components are not sealed internally with a fire stop material providing a penetration seal equivalent to the rating of the fire barrier.. -._-- - _

TER-C5506-646 l

Generic Letter 86-10 provides guidance on conduit and cable tray penetrations through fire barriers.

This guidance states that openings through fire barriers which separate fire areas should be sealed or closed to provide a fire resistance rating at least equal to the barrier.

Openings inside conduits larger than 4 inches should be sealed at the barrier penetration.

Openings inside conduits 4 inches or less in diameter should be sealed at the fire' barrier unless the conduit extends at least 5 feet on each side of the barrier and is sealed at both ends or at the barrier with noncombustible material to prevent the passage of smoke and hot gases.

I As an alternative to the above guidance, the Licensee has proposed the following configurations for the internal sealing of conduit penetrations.

The following list of criteria are an acceptable deviation from the guidelines.

t 1.

Conduits are sealed internally at the fire barrier to the rating of the fire barrier.

2.

The conduits are sealed on at least one side of the fire barrier and both areas have fire detection near the l:

penetration.

3.

When the conduits penetrate a fire barrier and are unsealed, fire detection is installed near the conduit penetration on d

both sides of the barrier.

In addition, fixed suppression is installed on at least one side of the barrier near the p

conduit penetration or the fire loading on both sides of the L.

barrier is 20 minutes or less.

2.14.3 Evaluation The guidelines of Section D.l. (j) of Appendix A to BTP APCSB l

9.5-1 are not met for the above fire area boundaries as described.

r l

There was a concern that a fire in any of these areas would penetrate the subject fire barriers, resulting in loss of safe shutdown capability.

i I~

Because of the fire protection features provided, it is not expected that a fire of significant magnitude or duration will occur in any of the fire areas.

If a fire does occur, it would be detected by the ionization detectors and extinguished by the plant fire brigade or automatic suppression systems before spreading through the barriers to another fire area.

The Licensee's analysis demonstrates that the integrity of the fire area boundaries is not jeopardized.

2.14.4 Conclusion Based on the above evaluation, it is concluded that the existing fire protection features provide an adequate level of fire protection

~ ;

~

TER-C5506-646 and, therefore, they are acceptable deviations from the guidelines of Section D.l. (j) of Appendix A to BTP APCSB 9.5-1 2.15 WITHDRAWN EXEMPTION REQUESTS In various revisions of the Licensee's report describing compliance with 10CFR50, Appendix R exemptions were requested for the areas listed below.

The exemptions were to the extent that Appendix R requires 20 feet of separation, 3-hour rated boundaries, 3-hour rated fire dampers in boundaries, or 8-hour emergency lighting.

I Subsequently, the Licensee elected to protect the necessary safe shutdown equipment with alternate modifications or determined that the equipment was not necessary.

The Licensee has committed that the alternatives are in compliance with Appendix R.

Therefore, the following exemption requests are no longer necessary.

~

Unit 2 RHR Pumps, Less Than 20 Feet of Separation o

Control Room / Emergency Switchgear Rooms, Fire Damper Rating o

Control Room / Battery Rooms, Fire Damper Rating o

Control Room / Turbine Building, No Fire Damper o

Control Room / Cable Spreading Rooms, Fire Damper Rating o

J Quench Spray Pump House and Safeguards Area, Nonrated Damper o

E Emergency Switchgear/ Chiller Rooms, No Fire Damper o

Fire Doors, Security Modifications to Latch Keepers o

Emergency Lighting in Containment, Use of Portable Lights o

o Establishing Letdown, Using Nonshift Personnel

=.

1 TER-C5506-646 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 10CFR50 for North Anna Power Station Units 1 and 2.

It is not meant as a substitute for the specific conclusions reached in the various subsections of Section 2 for which the reader is referred to spacific subsections.

Based on the evaluation, it is found that the level of fire i

safety in the areas listed below is equivalent to that achieved by compliance with the technical requirements of Section III.G of Appendix R and, therefore, the Licensee's request for exemption in the following areas can be granted:

1.

Auxiliary, Fuel, and Decontamination Buildings, Fire Area 11.

l Lack of fixed automatic fire suppression and detection systems throu,ghout the fire area.

See section 2.2 for i

additional information.

2.

Containment Incore Instrument Tunnels, Fire Areas 1-1 and 1-2.

Lack of 20 feet of separation between redundant excore neu-W tron flux detector cables.

See Section 2.3 for additional information.

9 3.

Quench Spray Pump Houses, Fire Areas 15-1 and 15-2.

Lack of fixed automatic suppression systems throughout each fire area.

See Section 2.4 for additional information.

4.

Main Steam Valve Houses, Fire Areas 14B-1 and 14B-2.

Lack of fixed automatic suppression systems throughout each i

main steam valve house.

See section 2.5 for additional information, t i t

5.

Auxiliary Feedwater Pump Houses, Fire Areas 14B-1 and 14B-2.

r-Lack of direct readings of process monitoring variables i

necessary to perform and control required functions.

See Section 2.6 for additional information.

6.

Charging Pump Cubicles, Elevation 244 Feet, 6 Inches Lack of 3-hour rated fire barriers separating redundant safe shutdown equipment.

See Section 2.7 for additional information.

l 1

TER-C5506-646 7.

Separation of Instrumentation, Containment.

Redundant cables and equipment separated by 20. feet or.by radiant energy shields with intervening combustibles.

See Section 2.9 for additional information.

8.

Auxiliary Building, Ventilation Equipment Area, Fire Area 11.

Lack of automatic fire suppression and detection systems throughout the fire area.

See Section 2.10 for additional information.

I 9.

Chiller Rooms, Elevation 254 Feet, O Inch.

Lack of 3-hour rated fire barriers between redundant safe I

shutdown equipment. See Section 2.13 for additional information.

i Based on the evaluation, it is 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.J of Appendix R and, therefore, the Licensee's request for exemption in f

these areas can be granted.

4 o

Emergency Lighting in the Seal Water Filter Area, Use of j

Portable Lights o

Emergency Lighting in the control Room, Use of Fuel Generator 9

Power Supply a

Emergency Lighting for Exterior Access Routes, Use of o

Security Lighting and Portable Lights.

Lack of emergency lighting units with at least an 8-hour battery supply in all areas needed for operation of safe

,,,.j shutdown equipment and access and egress routes thereto.

a Based on the evaluation, it is found that the level of fire safety in the areas listed below meets the guidance provided for compliance with Section III.G of Appendix R and, therefore, the l

Licensee's request for exemption from Section III.G.2 is not l

required.

o 4-to 20-mA Signals in Twisted Pair Instrument Cable o

125-Vdc Circuits in Rigid Metal Conduit Protection of low current instrument circuits and 125-Vdc circuits that could prevent operation or cause maloperation due to hot shorts.

See Section 2.8 for additional information.

l

TER-C5506-646 s

i 1.

Based on the evaluation, it is found that the level of fire safety for the following fire area boundaries is equivalent to that achieved by conformance with the guidelines of Section D.l. (j) of Appendix A to BTP APCSB 9.5-1 and are therefore acceptable.

Emergency Switchgear/Chil.ler Rooms, No Fire Damper (Fire o

Area 6-1)

Emergency Switchgear Room, Fire Door Frames (Fire Area 6-2) o Fire Doors, Frames Not Fire Rated (Various Fire Areas) o o

Fire Doors, Conduit in Door Frames (Various Fire Areas)

Control Room Stairwell / Emergency Switchgear Room Wall Fire o

Barrier Rating (Fire Area 2)

I o

Cable vault / Tunnel and Auxiliary Building Wall Fire Barrier Rating (Fire Area 3-1)

Auxiliary /Turbin'e Buildings' Pipe Tunnel, Lack of Fire o

Barrier (Fire Area 8) f'.

Control Room / Turbine Building, Bulletproof Doors (Fire o

Area 2)

Conduits Passing Through Rated Fire Barriers, Lack of o

Internal Sells (Various Fire Areas)

P.

Based on the evaluation, the level of fire safety in the area listed below meets the guidance provided for compliance with Section III.G of Appendix R and, therefore, the Licensee's request for exemption from section III.L.2.d can be granted:

1.

Refueling Water Storage Tank, Lack of Level Indication.

Lack of direct readings of process monitoring variables necessary to perform and control required functions.

See Section 2.12 for additional information.

f'

,1 o

o TER-C5506-646 4.

REFERENCES 1.

Standard Review Plan, NUREG-0800, BTP CMEB 9.5-1, " Fire Protection Program," July 1981 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 o-Power Plants," November 1977 l

4.

10CFR50, " Fire Protection Program for Operating Nuclear Power l

Plants," November 19, 1980 rr 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 i

i P

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 Dated October 6, 1986 E

E r

T -

.--

ML20215C001

Text

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