ML20235S233
| ML20235S233 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 10/01/1987 |
| From: | Johnson I COMMONWEALTH EDISON CO. |
| To: | Murley T Office of Nuclear Reactor Regulation |
| References | |
| 3656K, NUDOCS 8710080377 | |
| Download: ML20235S233 (36) | |
Text
_ - _ _ - - _ -
O ' Commonwealth Edi
'IA d
.1 j), On3 First N lional Plazi Ch o, Illinois Address RLply to: Post Office Erox 767
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_s Chicago, Minois 60690 - 0767 October 1, 1987-i Mr.. Thomas E. Murley, Director Office of Nuclear Reactor Regulation 3
U.S. Nuclear Regulatory Commission Washington, DC 20555
Subject:
. Quad Cities Station Units.1 and 2
" Transmittal of Additional Appendix R Exemption Requests" NRC Docket Nos. 50-254 and 50-265
Reference:
Letters from I.M. Johnson to T.E. Murley
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dated September 30,-1987
Dear Mr. Murley:
Attached please find a copy of two additional Appendix R-Exemption Requests. These exemptions supplement'those submitted to you and your staff-in the above referenced letters.
The first Appendix R technical exemption pertains to the separation
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of redundant instrumentation. Specifically, this exemption provides l
-l justification for lack of emergency lighting for the suppression pool level instrumentation.
e The second Appendix R technical exemption pertains to hot shutdown repairs and the need to pull fuses to preclude spurious operation of reactor relief valves.
1 Please direct any questions that you may-have regarding this matter to this office.
Ver uly yours, l
I. M. Johns Nuclear Licensing Administrator im Enclosures 1): Appendix A Exemption Request for Separation of Redundant Instrumentation - Suppression Pool Level A
1 Instrumentation 2): Appendix R Exemption Request for Fuse Pulling to D
Preclude Spurious Operation of Reactor Relief Valves - Hot Shutdown Repair (I
3): Remittance: $150.00 Voucher Check cc:
T. Ross - NRR g
0 l
Region III Administrator g
Quad Cities Senior Resident Inspector
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00B0377 973993 p 3656K p
ADOCK 05000254 PDR w
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. QUAD CITIES ~1&2 a
f TABLE OF CONTENTS 4(S)
I PAGE 1
1 11.0 APPENDIX'R EXEMPTION REQUEST FOR SEPARATION-11.0-1 OF REDUNDANT INSTRUMENTATION 1
11.1 JUSTIFICATION FOR SEPARATION OF REDUNDANT' 11.1-1 REACTOR VESSEL. PRESSURE AND LEVEL INDICATING INSTRUMENTATION I
11.1.1 UNIT 1 1
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11.1.1.1 Introduction 11.1-1 11.1.1.2 Fire Protection System 11.1-1
)
I 11.1.1.3.
Fire Hazards Analysis 11.1-2, l
11.1.1.3.1 Fire Zone 1.1.1.2.
11.1-2 11.1.1.3.2 Fire Zone 1.1.1.3 11.1-3 11.1.1.3.3 Fire Zone 11.2.3 11.1-4 l
11.1.1.4 Conclusions
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11.1.2 UNIT 2' 11.1.2.1 Introduction 11.1. 2 Fire Protection System 11.1.2.3 Fire Hazards Analysis 11.1.2.3.1 Fire Zone 1.1.2.2
-11.1.2.3.2 Fire Zone 1.1.2.3 11.1.2.3.3 Fire Zone 11.2.1 11.1.2.4 Conclusions 11.2 JUSTIFICATION FOR SEPARATION OF REDUNDANT 11.2-1 POOL LEVEL INDICATORS 11.2.1 Introduction 11.2-1 11.2.2 Fire Protection System 11.2-1 11.2.3 Fire Hazards Analysis 11.2-1 i f'\\ -
11.2.3.1 Fire Zone 1.1.1.1 11.2-1 V
QUAD CITIES l&2 11.2.3.2 Fire Zone 1.1.1.2 11.2-2
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11.2.3.3 Fire Zone 1.1.1.3 11.2-4 11.2.3.4 Fire Zone l.l.2.1 11.2-4 11.2.3.5 Fire Zone 1.1.2.2 11.2-5 11.2.3.6 Fire Zone 1.1.2.3 11.2-6 11.2.4
' Conclusions 11.2-7 I
11.3 JUSTIFICATION FOR LACK OF 11.3-1 EMERGENCY. LIGHTING FOR I
SUPPRESSION POOL LEVEL INSTRUMENTATION 11.3.1 Introduction 11.3-1 11.3.2 Conclusion 11.3-2 O
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. QUAD CITIES 1&2 111.0
. APPENDIX'R EXEMPTION REQUEST FOR SEPARATION OF REDUNDANT I)
INSTRUMENTATION.
j Per the provision of 10.'CFR 50.12,-Commonwealth Edison.Companyi j
(CECO) requests ~ exemption from.-theirequirementLof.Section III.G.2-
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of Appendix'R for; separation:offredundant.-reactor vessel press'ure and level. indicating 1nstrumentssin-the-UnitL1 reactor building,
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separation ~of1 redundant suppression pool' level' indicating-instruments.in'the Unit'1 and Unit 2 reactor buildings, andilack-E of fixed emergency. lighting for'the suppression.' pool level
' instrumentation.
The just'ification-for these exemptions:are presented!in'the
'following sections':.
d Section Justification For 11.1-Separation of redundant reactor.
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vessel-pressure and level indicating
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instrumentation.
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11.2
. Separation of redun'da'nt suppression I
pool level indicatingL instrumentation.
11.3 Lack of1 emergency lighting for suppression pool level'
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instrumentation.-
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11.0-1 z _1_n_ ___n
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-QUAD CITIES 1&2
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1
.11.1 '
- J STIFICATION FOR' SEPARATION OF' REDUNDANT SEACTOR' VESSEL.
H
- O,
PRESSURE AND. LEVEL INDICATING INSTRUMENTATION
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11.1.1 UNIT 1 i
11.1.1.1 Introduction-
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' Fire Area RB-1 contai'ns cables for the redundant. control room
- l 100 A& B,'
I reactor level.-and_ pressure instrumentation.(LIl-263-101, 106A&B; LR1-263-ll3, LRl-240-26; PRl-640-27A&B)..-In1the' event of a fire in Fire Area RB-1,Elocal instrumentation in the' Unit:1 j
reactor building (Fire Area RB-1) would'be used'to monito'r-reactor' vessel level and pressure.
These locally monitored
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mechanical instruments are located at instrument' racks 2201-5 and 2201-6 on the mezzanine floor (Fire Zone 1.1.l'.3), racks 2201-7 and on rack and 2201-8 on the ground floor (Fire Zone 1.1.1.2),
I in the RCIC room-(Fire Zone 11.2.3) on the torus level.-
2201-58 Instrument racks 2201-5, 2201-6, and 2201-58 have local Instrument indication of both reactor water level and pressure.
racks.2201-7 and 2201-8 have local indication of reactor water u
level'only.
The requirements'of Appendix R stipulate that more than 20 feet of horizontal space free of intervening combustibles' should. exist between redundant equipment an'd, in addition,: detection and suppression should be installed throughout'the area.-sThe subsequent analysis provides justification for'an. exemption to the this requirement for the local reactor water level and 1.1.1.3, and l
pressure instrumentation in Fire Zones 1.1.1.2, 11.2.3.- The basis of the justification is that a fire in Fire.
Zones 11.2.3, 1.1.1.2 or 1.1.1.3 would not prevent operators from-locally monitoring the reactor vessel level ~and pressure.
'l 3
l 11.1-1
QUAD CITIES 1&2 11.1.1.2 Fire Protection System Fire Zones 11.2.3, 1.1.1.2, and 1.1.1.3 are provided with complete fire detection with the exception of the regenerative and nonregenerative heat exchanger room, cleanup recirculation pump rooms, and cleanup decant pump phase separator pump room in Fire Zone 1.1.1.3.
Manual hose stations and portable fire extinguishers are located throughout Fire Zones 1.1.1.2 and 1.1.1.3 and just outside the entrance to Fire Zone 11.2.3.
Motor control centers 18-1A, 18-1B, 18-3, 19-1, 19-1-1, 19-4, 19-6 and 18/19-5 are located in Fire Zones 1.1.1.3 and 1.1.1.2 (Fire Zone 1.1.1.2 is the elevation between Fire Zone 1.1.1.3 and 11.2.3).
An inadvertent actuation of any fixed fire suppression system could resu.t in failure of this equipment.
- Also, installation of any other type of suppression such as cardox, halon or foam would be ineffective or inappropriate in these areas because of the large volume and open stairways.
O 11.1.1.3 Fire Hazards Analysis 11.1.1.3.1 Fire Zone 1.1.1.2 This fire zone is the ground floor of the reactor building located above Fire Zone 11.2.3 and below Fire Zone 1.1.1.3.
l Instrument racks 2201-7 and 2201-8 are located in this zone.
Instrument rack 2201-7 is located north of the drywell while instrument rack 2201-8 is located south of the drywell.
In addition, instrument sensing lines to rack 2201-58 (Fire Zone 11.2.3, which are also associated with instruments on racks 2201-5 and 2201-6 (Fire Zone 1.1.1.3), are routed through Fire Zone 1.1.1.2.
O 11.1-2
.. =.. -...
QUAD CITIES 1&2 The combustibles in Fire Zone 1.1.1.2 consist mostly of 151,600 f.-)
V
. feet of cable.
This zone is the ground floor of the reactor building.
It is frequently traveled and occasionally used as a staging area.
Transient combustibles in the fire zone include RWP clothing and limited lubricating and cleaning fluids.
These transient combustibles are controlled to minimal quantities by station administrative procedures.
Lubricating and cleaning fluids are only used in approved containers.
The combustible loading in the fire zone is less than 30,000 Btu /ft2 The worst case postulated fire could involve the transients and cable. insulation material.
Any fire on this elevation would not expose the safe shutdown cables or equipment in Fire Zone 11.2.3 since the heat and products of combustion of the buoyant fire plume will use the ceiling and' floors away from the torus level.
All electrical penetrations are sealed in the floor and ceiling with a noncombustible material.
Available test data found in the FMRC/EPRI test reports,
" Categorization of Cable Flammability" NP-1881, August 1982, provide information describing the burning characteristics of PE/PVC cable in horizontal cable trays.
The heat of combustion of PE/PVC is less than 11,000 Btu /lb.
The l
EPRI tests show that flame spread along horizontal cable trays is very slow.
The test reports for horizontal fire spread in deep l
stacks of horizontal cable trays agree with observations of the rate of fire spread in similar tray arrays in the reactor building at the Browns Ferry fire.
The horizontal spread rate for cable tray fires is about 6 to 7 ft/hr.
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11.1-3
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QUAD CITIES 1&2
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Although the cable-tray. Arrangement in Fire Zone'l.l.l'.-2 is far O
less severe'than that tested in~the'EPRI report,tthe-parameters from those tests can:be used to show a conservative' fire j
These parameters lwould indicate that.only.ab'out.21-
.scenar.io.
1 feet oh-cable would be consumed in a 3-hour' fire. -The heat 1would-i n
- be dissipated into an extremely large room volume.
Heat would' also be lost to the' surrounding enclosureLand: floor above.-
I Convective and radiative heat transfer effects-from:such"a fire
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would obviously not affect cables in Fire 1 Zone-11.2.3 below.
Access to the instruments on the. mezzanine level would be gained.
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L through the' ground. floor.
This can be done either'via the north
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stairwell or th'e south stairwell.
The emergency lights lighting these access _ paths are greater than 100 feet. apart and thus both sets of lights would not be destroyed in'a~ fire since the fire would not spread between the two halves of the. floor'as discussed in the paragraph above.
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Fire detection throughout Fire Zone 1.1.1.2 will provide early l
warning of fire conditions in the zone.
This will' provide ample time for manual firefighting operations tx) control ~ fire spread in the trays to much less than postulated above.
Manual firefighting equipment is available in the fire zone to allow the
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brigade to perform this function.
l Instrument racks 2201-7 and 2201-8 and their associated sensing lines are located in Fire Zone 1.1.l.2 in diametrically opposed positions on either side of the drywell.
A single fire would have to travel more than 60 feet 1around the drywell in order to 1
effect both sets of reactor water level instruments and sensing lines associated with the racks.
Due to the large separation distance, it is not credible to postulate that both instrument racks 2201-7 and 2201-8 will be affected'by a single fire, even though the intervening space is not completely devoid of combustible material.
Therefore, for any credible fire in Fire Zone 1.1.1.2, reactor water level'1ocal indication instrumentation will be available on one of the two instrument
.i 11.1-4
QUAD CITIES 1&2 racks (2201-7 and 2201-8) located in Fire Zone 1.1.1.2.
Reactor
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pressure indication will be available on instrument rack 2201-58 (Fire Zone 11.2.2).
Additionally, except for a fire in the northwest quadrant of Fire Zone 1.1.1.2, local reactor water I
level and pressure indication would also be available on at least one of the two instrument racks (2201-5 and 2201-6) located in Fire Zone 1.1.1.3 and reactor water level indication would be available on rack 2201-58 located in Fire Zone 11.2.3.
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1 11.1.1.3.2 Fire Zone 1.1.1.3 1;
i This fire zone is the mezzanine floor of the reacF.or building.
1 Instrument racks 2201-5 and 2201-6 are located in this zone.
Instrument rack 2201-6 is located east of the drywell while j
instruntent rack 2201-5 is located north of the drywell.
Both of j
i l
these racks contain reactor vessel pressure and level
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indicators.
These racks are more than 40 feet apart.
In
.l addition, reactor water level instrument sensing lines to racks gg 2201-7, 2201-8, and 2201-58 are. routed in this zone.
Redundant l
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trains of the sensing liries are more than 30 feet apart.
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The combustibles in Fire Zone 1.1.1.3 consist mostly of 75,700 feet of cable.
This fire zone is normally not heavily traveled during operation.
Transient combustibles are controlled to minimal quantities by station administrative procedures.
The combustible loading in the fire zone is less than 20,000 Btu /ft2, Fire detection is provided throughout the fire zone with the f
1 exception of the regenerative and nonregenerative heat exchanger
' room and the cleanup decant pump phase separator pump room.
This j
detection system will provide early warning of fire conditions l
which will allow the fire brigade ample time for manual suppression operations using available firefighting equipment in l
the fire zone.
11.1-5 l
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QUAD CITIES 1&2 3
Any-fire on this elevation would notexposefthe: safe shutdown' H
I O-equipment'or cables in. Fire, Zones 1.1.1.2:-or 11.2.3 since:the,
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heat and products of combustion.of the buoyant fire plume will be j
carried to the levels above Fire 1 Zone 1.1.1. 3.
Water level instrument sensing lines.to the instrument racks located in Fire Zones l. l. l. 2 and 11. 2. 3' are touted ' in Fire Zone 1.1.1. 3.
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-However, due to the low fire loading in Fire Zone 1.1.1.3, the l
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fact that the sensing lines are located below the significant hazard.in the' zone,li.e.,' cable in cable tray, and the. distance of-over 30 feet between redundant trains of sensing lines, it :is j
not credible to postulate that'both sets'of redundant sensing
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lines will be damaged by a single f' ire' in Fire Zone 1.1.1.3, even l
L though the intervening space is not completely-devoid of j
combustible material.
Therefore, for any credible fire in Fire-d Zone 1.1.1.3, reactor' water level local indication instrumentation will be available.at a minimum on instrument rack 2201-58 in Fire Zone 11.2.3 and on one of the two racks 2201-7 and 2201-8 located in Fire Zone 1.1.1. 2.
If'the fire is j
at or near.MCC 18-1A-1, valve-M01-1301-16 could possible' spuriously close this rendering the reactor vessel pressure indicator at panel 2201-58 inoperable.- In this event, reactor vessel pressure can be read at pressure indicator. 1-262-10B located on instrument rack 2201-10 which is in the RER Division II pump room (Fire Zone 11.2.2).
Instrument rack 2201-10 is separated from the rest of reactor building as discussed in Section 3.2 of the Unit 1 Reactor Building Appendix R Exemption Requests.
11.1.1.3.3 Fire Zone 11.2.3 This fire zone is in the basement level of the reactor i
a building.
Instrument rack 2201-58 is located in this zone.
In addition, instrument sensing lines associated with-instrumentation on racks 2201-5 and 2201-6, in Fire Zone 1.1.1.3, l
are-routed through the zone.
O-i 11.1-6
__-____-______-__-__-_-_a_-_-_-_-
QUAD CITIES 1&2
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Any fire on this elevation would not expose the safe shutdown
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equipment or cables in Fire Zones 1.1.1.2 or 11.2.3 since the heat and products of combustion of the buoyant fire plume will be carried to the levels above Fire Zone 1.1.1.3.
Water level instrument sensing lines to the instrument racks located in Fire j
Zones 1.1.1.2 and 11.2.3 are routed in Fire Zone 1.1.1.3.
However, due to the low fire loading in Fire Zone 1.1.1.3, the fact that the sensing lines are located below the significant hazard in the zone, i.e.,
cable in cable tray, and the distance of over 30 feet between redundant trains of sensing lines, it is not credible to postulate that both sets of redundant sensing lines will be damcged by a single fire in Fire Zone 1.1.1.3, even though the intervening space is not completely devoid of combustible material.
Therefore, for any credible fire in Fire Zone 1.1.1.3, reactor ater level local indication instrumentation will be available at a minimum on instrument rack 2201-58 in Fire Zone 11.2.3 and on one of the two racks 2201-7 and 2201-8 located in Fire Zone 1.1.1.2.
If the fire is
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at or near MCC 18-1A-1, valve M01-1301-16 could possible spuriously close this rendering the reactor vessel pressure indicator at panel 2201-58 inoperable.
In this event, reactor l
vessel pressure can be read at pressure indicator 1-262-10B l
located on instrument rack 2201-10 which is in the RER Division II pump room (Fire Zone 11.2.2).
Instrument rack 2201-10 is separated from the rest of reactor building as discussed in l
Section 3.2 of the Unit 1 Reactor Building Appendix R Exemption Requests.
11.1.1.3.3 Fire Zone 11.2.3 l
This fire zone is in the basement level of the reactor building.
Instrument rack 2201-58 is located in this zone.
In l
addition, instrument sensing lines associated with instrumentation on racks 2201-5 and 2201-6, in Fire Zone 1.1.1.3-are routed through the zone.
11.1-6
y
. QUAD: CITIES 1&2 The' combustibles in Fire' Zone:11.2.3 consist of 1568 feet'of-i O
ceb1e, 10 ee11one or 1ube 011 in the RCIC pump, turbine, drein tank and oil reservoir and the core spray: pump, and 33 pounds of internal duct insulation.
The average-combustible loading in J
this zonefis less than 10,000' Btu /ft2, e-i LTheEcelling.is a-2-foot.4-inch thick reinforced concrete wall containing removable concrete-slabs that. allow equipment-access.
Mechanical penetrations.through the ceiling are. sealed with a noncombustible' material.
H The fire detection present throughout the zone will provide.early
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. warning.of fire conditions.
This will allow the' fire' brigade ample time for manual-suppression operations using.firefighting equipment located just outside the entrance'to the zone in Fire
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Zone 1.1.1.1.
The low fire loading and construction of the ceiling would confine the' fire to this zone and not present a hazard to the reactor' water level instruments or associated sensing lines on the ground floor (Fire Zone 1.1.1.2).
Reactor l
pressure would be available orJ instrument' racks 2201-5 or 2201-6, which are located on the mezzanine floor. level (Fire Zone 1.1.1.3).
However, to prevent'the fire in Fire' Zone 11.2.3 from l
affecting the pressure readings at those racks,~two isolation valves per rack, located on'the sensing lines going down to the RCIC room would'need to be manually closed.
11.1.1.4 Conclusions The previous analysis justifies an exemption request from the requirements of total area suppression and more than 20 feet of horizontal intervening space free from combustibles between the redundant instruments.
The technical bases that justify the exemption request are summarized below.
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O 11.1-7
=_--_x-
i QUAD CITIES 1&2 1.
The 5'different local indication-instrument racks and
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associated sensing lines are diversely located on three floors of the reactor building with large separation distances between redundant components, ensuring'that at
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least one train of reactor water level and pressure instruments will be free of fire damage.
2.
Because the instruments are mechanically operated, there is no electrical cabling whose failure could affect operation of l
the instruments.
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3.
Emergency lights are available at these instruments.
The I
lighting in Fire Zones 1.1.1.2, 1.1.1.3 and 11.2.3 would not l
be affected by a fire for the same reason the instruments in the zones would not be simultaneously affected by a fire.
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11.1-8
QUAD CITIES 1&2 11.1.2 UNIT 2 k_)
11.1.2.1 Introduction Fire Area RB-2 contains cables for the redundant control room-reactor level and pressure instrumentation (LI2-263-101, 100A&B, 106A&B; LR2-263-113, LR2-240-26; PR2-640-27A&B).
In the event of a fire in Fire Area RB-2, local instrumentation in the Unit 2 reactor building (Fire' Area RB-2) would be used to monitor reactor vessel level and pressure.
These locally monitored mechanical instruments are located at instrument racks 2202-5 and 2202-6 on the mezzanine floor (Fire Zone 1.1.2.3), racks 2202-7 and 2202-8 on the ground floor (Fire Zone 1.1.2.2), and rack l
2202-58 in the RCIC' room (Fire Zone 11.3.1) on the torus level.
Instrument racks 2202-5, 2202-6, and'2202-58 have local indication of both reactor water level and pressure.
Instrument racks 2202-7 and 2202-8 have local indication of reactor water l
level only.
The requirements of Appendix R stipulate that more than 20 feet of horizontal space free of intervening combustibles should exist between redundant equipment and, in addition, detection and s
suppression should be installed throughout the area.
The subsequent analysis provides justification for an exemption to the this requirement for the local reactor water level and pressure instrumentation in Fire Zones 1.1.2.2, 1.1.2.3 and 11.3.1.
The basis of the justification is that a fire in Fire Zones 11.3.1, 1.1.2.2, or 1.1.2.3 would not prevent operators from locally monitoring the reactor vessel level and pressure.
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O 11.1-9
)
I QUAD CITIES 1&2 i
11.1'.2.2 Fire' Protection System 1
Fire Zones 11.3.1, 1.1.2.2, and 1.1.2.3 are provided with J
complete fire detection with the. exception of the regenerative l
and nonregenerative heat exchanger room, cleanup recirculation pump rooms, and cleanup decant pump phase separator pump room'in
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Fire Zone 1.1.2.3.
Manual hose stations and portable fire
-l extinguishers are located throughout Fire Zones 1.1.2.2 and I
1.1.2.3 and just outside the entrance to Fire Zone 11.3.1.
l l
Motor control centers 28-1A, 28-1B, 28-3, 29-1, 29-1-1, 29-4, 29-6 and 28/29-5 are located in Fire Zones 1.1.2.3 and 1.1.2.2 (Fire Zone 1.1.2.2 is the elevation between Fire Zone 1.1.2.3 and 11.3.1).
An inadvertent actuat' ion of any fixed fire suppression system could result in failure of this equipment.
.Also, 1
1 installation of any other type of suppression such as cardox, halon or foam would be ineffective or inappropriate in these areas because of the large volume and open stairways.
p) u-11.1.2.3 Fire Hazards Analysis 11.1.2.3.1 Fire Zone 1.1.2.2
)
This fire zone is the ground floor of the reactor building location above Fire Zone 11.3.1 and below Fire Zone 1.1.2.3.
Instrument racks 2202-7 and 2202-8 are located in this zone.
Instrument rack 2202-7 is located north of the drywell while instrument rack 2202-8 is located south of the drywell.
In addition, instrument sensing lines to rack 2202-58 (Fire Zone 11.3.1), which are also associated with instruments on racks 2202-5 and 2202-6 (Fire Zone 1.1.2.3), are routed through Fire Zone 1.1.2.2.
O 11.1-10
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QUAD CITIES.1&2' l
The combustibles in Fire. Zone 1.1.2.2. consist'mostly of 126,200 b)s feet of cable.
This zone is the ground floor of the reactor is frequently traveled and occasionally used as a building.
It Transient. combustibles in the-fire zone include staging area.
These-RWP clothing and limited lubricating and cleaning fluids.
transient combustibles are controlled to minimal quantities by station administrative procedures.
Lubricating and' cleaning fluids are only used in approved containers.
The combustible 2,
loading in the fire zone is less than 20,000 Btu /ft 1
The worst case postulated fire could involve the transients and cable insulation material.
Any fire on this elevation would not expose the safe shutdown cables or equipment in' Fire Zone:11.3.l' since the heat and products of combustion of.the buoyant fire plume will use the ceiling and floors away from the torus level.
All electrical penetrations are sealed in the floor and ceiling with a noncombustible material.
Available test data found in the FMRC/EPRI test reports, (g
" Categorization of Cable Flammability" NP-1381. negust 1982, q
provide information describing the burning characteristics of l
PE/PVC cable in horizontal cable trays.
[
The heat of combustion of PE/PVC is less than 11,000 Btu /lb.
The EPRI tests show that flame spread along horizontal cable trays is very slow.
The test reports for horizontal fire spread in. deep stacks of horizontal cable trays agree with. observations of the rate of fire spread in similar tray arrays in the reactor building at the Browns Ferry fire.
The horizontal spread rate for cable tray fires is about 6 to 7 ft/hr.
Although the cable tray arrangement in Fire Zone 1.1.2.2 is far less severe than that tested in the EPRI report, the parameters from those tests can be used to show a conservative fire scenario.
These parameters would indicate that only about 21 feet of cable would be consumed in a 3-hour fire.
The heat'would
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be dissipated into an extremely large room volume.
Heat would 11.1-11
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QUAD CITIES 1&2 y
also be lost to the surrounding enclosure and floor above.
O Convective and radiative heat transfer effects from such a fire would obviously not affect cables in Fire' Zone 11.3.1 below.
Access to the instruments on the mezzanine level would be gained through the ground floor.
This can be done eit.her via the north stairwell or the south stairwell.
The.energency lights light.ing these access paths are greater than 100 feet apart and thus both sets of lights would not be destroyed in a fire since the fire would not spread between'the two halves of the floor as discussed in the paragraph above.
Fire detection throughout Fire Zone 1.1.2.2 will provide early warning of fire conditions in the zone.
This will provide ample time for manual firefighting operations to control fire spread in the trays to much less than postulated above.
Manual firefighting equipment is available in the fire zone to allow the brigade to perform this function.
O Instrument racks 2202-7 and 2202-8 and their associated sensing lines are located in Fire Zone 1.1.2.2 in diametrically opposed positions on either side of the drywell, north and south of the l
b drywell, respectively One sensing line for the local reactor water level indication on rack 2202-7 is routed from near rack 2202-8 around the eastern boundary of the drywell to rack 2202-7.
Inaddition,tworedundantpairofreactorwater.-levej l
sensing lines to rack 2202-58 (Fire Zone 11. 3.1) are routed through the southern portion of Fire Zone 1.1.2.2.
These latter two lines are also associated with two local reactor water level indicators and pressure instrumentation on racks 2202-5 and 2202-6 (Fire Zone 1.1. 2. 3).
Where any two of three level indicators
/
(two on rack 2202-58, one on rack 2202-7) have sensing lines routed together, the third remaining level indicator has sensing lines separated from them by at least 30 feet.
Given this separation, it is not credible to postulate that the reactor water level instrumentation at racks 2202-58 and 2202-7 will be I
O af fected by a single fire in Fire Zone 1.1.2.2, even though the 11.1-12
i g
l QUAD CITIES 1&2 1
-j i
intervening spaces are not completely devoid of ' combustible h
' material.
Reactor pressu:e is available on' instrument rack 2202-58 (Fire Zone'11.3.3)'.
The'line from which p essuke indication j
will not be..affNbted by b fire in Fire is taken on rack 2202-58 Zone.l.1.2.2, except for spurious c1bstp[e of M0ld1301-16 or M01-1301-17.
M ese can be opened if they spuriously close.
L1 11.1,.2.% 2 Fire Zone 1.ls2,.3
.s s
4
.i This fire zone is the mezzanine floor of the reactor building.
)
f g ('
instrument racks 2202-5 and 2202-6 are located in this zone.
Instrueent rack 2202-6 is located east of-the drywell while instrument rack 2202-5 is located north of the drywell.,
pcthof these racks contain reactor vessel pressure and level indicatdrs.
These racks are more'than 30 feet apart.
In addition, reactor water level inscrument sensing lines to racks 2202-7, 2252-8, and 2202-58 are routed in this zone.
Redundant
.l j
trains of the sensing lines are more than 30 feet apart.
]
O a
The combustibles in Fire, Zone 1.1.2.3 consibt mostly of 76,100 feetodcable.
This fi'reJzene is normally not heavily traveled during operation.
Transient combustibles are controlled to l
minimal quantities by station administrative procedures.
The combustible loading in the fire zone is less than:20,000 Stu/ft2, Fire detection is provided throughout the fire zone with the j
exception of the regenerative and nonregenerative heat exchanger j
room and the cleanup decant pump phase separator pump room.
This l
detection system will provide early warning of fire conditions which will allow the fire brigade ample time for manual l
suppression operations using available firefighting' equipment in the fire zone.
Any fire on this elevation would not expose the safe shutdown equipment or cables in Fire Zoncs 1.1.2.2 or 11.3.1 since the heat and products of combustion of the buoyant fire plume will be O
carriea to tne 1 eve 1e above rire zone 1.1.2.3-water 1 eve 1 w
l 11.1-13 g.
-w. w
o,~r.
c
'I QUAD CITIES'l&2
^
y'
.t
' instrument sensing lines to the ins'trument. racks.l'ocated?fn' Fire Zones'l.1.'2.2 and 11.3.1 are routed in Fire Zone 1.1.2.3.
.However,-due to the low fire loading in. Fire Zone 1.1.2.3,-the
~
fact that st: sensing lines-are located below the'significant hazard in-the zone, i.e.,
cable in cable tray, and the distance <
-of over 30-feet between. redundant trains of; sensing lines', it!is not credible to. postulate.that both sets of redundantLsensing
' lines will be damaged by a singlezfire~1n Fire Zone;1.1.2.3, even though the intervening, space is'not' completely devoid of combustible material.
Therefore, for any credible fire;in-Fire Zone 1.1.2.3, reactor water' level local. indication j
instrumentation'will be available!at'a minimum cn. instrument rack 2202-58.in Fire Zone 11.3.1 and'on one of'the two racks.
(2202-7 and 2202-8) located in1 Fire Zone l.l.l.2.-
If the fire is ll6'could possibly.
J at or'near MCC 28-1A-1 valve M02-130l spuriously close thus rendering the reactor vessel pressure.
indicator at Panel 2201-58 ~ inoperable.
In this event, reactor vessel pressure can be read at pressure indicator 2-262-10B
()
located on instrument rack 2202-10 which is in the RHR Division II pump' room (Fire Zone 1123.2).
Instrument' rack-2202-10 is separated from the rest of the reactor buildinguas discussed in l
'Section 4.2 of the Unit'2 Reactor Building Appendix R' Exemption j
i i
Requests.
11.1.2.3.3 Fire Zone 11.3.1 This fire zone'is in the basement level of the reactor building.
Instrument rack 2202-58 is located in this zone.
In addition, instrument sensing lines associated.with instrumentation on racks 2202-5 and 2202-6, in Fire Lone 1.1.2.3,.
l are routed through the zone.
O 11.1-14
OUAD CITIES 1&2
.The combustibles in. Fire Zone 11.3.1 consist of-6200 feet of-cable, 10 gallons'of lube oil in the.RCIC pump, turbine,.. drain
~
tank'and oil reservoir and'the core' spray pump, and133 poundsfof internal duct insulation.
The average combustible loading i'n1 this zone is less than 20,000 Btu /ft2, The ceiling is a 2-foot 4-inch thick reinforced ~ concrete wall-
~
containing removable concrete slabs that allow-equipment Mechanical penetrations through'the. ceiling ~are sealed
. access.
with a noncombustible material.-
The fire detection present throughout the zone will. provide early warning of fire conditions.
This wil11 allow'the fire brigade ample time for manual suppression-operations using firefighting.
equipment located just outside the entrance to the zone in Fire Zone.l.1.2.1.
The low fire loading and construction of the
~
ceiling would confine the fire to this zone and'not present a hazard to the reactor water level instruments or associated sensing lines on the ground floor (Fire Zone ~1.1.2.2).
Reactor.
l pressure would be available on instrument racks 2202-5 or 2202-6,-
which are located on the mezzanine floor level (Fire Zone 1.1.2.3).
However, to prevent the fire in Fire Zone 11.3.1 from l
affecting the pressure readings at those racks,'two isolation valves per rack, located near their respective' racks, would need to be manually closed.
11.1.2.4 Conclusions The previous analysis justifies an exemption request from the requirements of total area suppression and more than.20 feet of horizontal intervening space free from combustibles between the redundant instruments.
The technical bases that' justify the exemption request are summarized below.
l
(}
j 4
11.1-15 l
QUAD CITIES 1&2 local indication instrument racks and 1.
The 5 different r~
\\-
associated sensing lines are diversely located on three floors.of the reactor building with large separation distances between redundant components, ensuring that at least one train of reactor water level and pressure instruments will be free of fire damage.
Because the instruments are mechanically operated, there is
[
2.
no electrical cabling whose failure could affect operation of the instruments.
This Emergency lights are available at' these instruments.
3.
1.1.2.3 and 11.3.1 would not lighting in Fire Zones 1.1.2.2, be affected by a fire for the same reason the instruments.in the zones would not be simultaneously affected by a fire.
O C) 11.1-16
QUAD CITIES 1&2 11.2 JUSTIFICATION FOR SEPARATION OF REDUNDANT SUPPRESSION POOL LEVEL INDICATORS 11.2.1 Introduction Fire Areas RB-1 and RB-2 in the Unit 1 and Unit 2 reactor buildings contain the suppression pool level sight glass 1(2)-
1602-10 and level transmitter.s 1(2)-1626, 1(2)-1641-5A and 1(2)-
1641-5B along with the cables that provide power and connect these transmitters to control room level indicators 1(2)-1602-3, 1(2)-1640-10A and 1(2)-1640-10B.
One of these indicators must be j
The i
available to provide suppression pool level indication.
requirements of Appendix R stipulate that more than 20 feet of horizontal space free of intervening combustibles should exist between redundant equipment and, in addition, detection and Since the suppression should be installed throughout the area.
power for the transmitters is from the MCC's located on the mezzanine floor, the sight glass would have to be used to monitor suppression pool level for a fire in the northern half cf the torus level and all levels above.
1 1
The subsequent analysis provides justification for an using the j
/
level sight glass in the event of a fire in the northern half of the torus level.
The basis of the justification is that a fire in the north end of Fire Zone 1.1.1.1(1.1.2.1) would not prevent operators from monitoring the suppression pool level.
11.2.2 Fire Protection System Fire Zones 1.1.1.1 and 1.1.2.1 are protected by detection and suppression systems.
Linear thermal detectors have been installed in each cable tray and below the bottom treyr in these fire zones.
As added protection, portions of the Division I and II trays, where they are routed within 20 feet of each other, are wrapped with a 1-hour rated fire resistive material.
An automatic sprinkler system has been installed at the south wall 11.2-1
. QUAD CITI'ES 1&2 of th'ese fire zones in'the.immediate vicinity of the cable risers-()
that pass through the ceiling.
The' rest of the zone is protected.
L by manual suppression, consisting of portable CO2 extinguishers.
'and hose stations.
Fire Zone's 1.1.1.2 andil.l.2.2Lare also. protected by~ detection and suppression systems.
Smoke detectors.have been installed throughout these-fire zones and. ionization detectors are installed above the.drywell/ torus.aP'-compressors, 480V'MCC's 18/19-5 and 28/29-5, and the ACAD air compressors.. Manual.
suppression is provided in the fire zones, consisting of portable CO2' extinguishers and.bose. stations.
g 11.2.3 Fire Hazards Analysis 11.2.3.1 Fire Zone 1.1.1.1 This fire zone is the Unit 1 torus level area.of the reactor
(])
building.
Level sight glass 1-1602-10 is located'in this. fire zone on the north side of the torus.
The combustibles in Fire Zone 1.1.1.1 consist mostly of 41,515 feet of cable.
Transient combustibles and ignition sources'in the torus are strictly controlled and cannot be practically introduced due to access limitations.
The average combustible loading is less than 8000 Btu /ft2, The ceiling of Fire Zone 1.1.1.1 is constructed of minimum 2-foot 0-inch thick' concrete'with all electrical penetrations sealed-with noncombustible material.
The linear fire detectors located in and adjacent to the cable trays will provide early warning of a fire..
This will allow the' fire brigade ample time for manual suppression operations using-available firefighting' equipment in this. fire' zone.- The-suppression pool' level needs to be checked when torus water
{")
cooling is initiated.
This occurs, at the latest, 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />'into 11.2-2
_ ____ __ = _ ____ _. _
i l
QUAD CITIES 1&2 l
the event, at which time the fire will have been been
~3
.;*d.
extinguished and the operators will have access to the sight glass.
11.2.3.2 Fire Zone 1.1.1.2 This fire zone is the ground floor level of the reactor building.
151,600 The combustibles in Fire Zone 1.1.1.2 consist mostly of This zone is the ground floor of the reactor feet of cable.
is frequently traveled and occasionally used as a building.
It Transient combustibles in the fire zone include staging area.
These RWP clothing and limited lubricating and cleaning fluids.
transient combustibles are controlled to minimal quantities by station administrative procedures.
Lubricating and cleaning j
fluids are only used in approved containers.
The combustible 2,
loading in the fire zone is less than 30,000 Btu /ft The worst case postulated fire could involve the transients and
()
Any fire on this elevation would not cable insulation material.
expose the safe shutdown cables or equipment in the south half of the torus below since heat and products of combustion of the fire plume will use the ceiling and floors away from the buoyant All mechanical, hatch, and stairwell openings in'the torus.
southern portion of the floor in Fire Zone 1.1.1.2 (south of column line 16) are sealed liquid-tight with noncombustible material or curbed to prevent a liquid spill from flowing into All electrical penetrations are scaled in the the torus below.
floor and ceiling with a noncombustible material.
Available test data found in the FMRC/EPRI test reports,
" Categorization of Cable Flammability" NP-1881, August 1982, provide information describing the burning characteristics of PE/PVC cable in horizontal cable trays.
3 11.2-3
QUAD CITIES 1&2 The The heat of combustion of PE/PVC is less than 11,000 Btu /lb.
flame spread along horizontal cable trays is O-tests show that EPRI reports for horizontal fire spread in deep The test very slow.
stacks of horizontal cable trays agree with observations of the rate of fire spread in similar tray arrays in the reactor The horizontal spread rate building at the Browns Ferry fire.
for cable tray fires is about 6 to 7 ft/hr.
Although the cable tray arrangement in Fire Zone 1.1.1.2 is far the parameters less severe than that tested in the EPRI report, from those tests can be used to show a conservative fire These parameters would indicate that only about 21 scenario.
The heat would feet of cable would be consumed in a 3-hour fire.
Heat would be dissipated into an extremely large room volume.
also be lost to the surrounding enclosure and floor above.
Convective and radiative heat transfer effects from such a fire would obviously not affect cables in Fire Zone 1.1.1.1 below.
the operators will have access to level sight glass
- Thus,
()
2-1602-10.
Fire detection throughout Fire Zone 1.1.1.2 will provide early This will provide ample warning of fire conditions in the zone.
time fo$ manual firefighting operations to control fire spread {n Manual the trays to much less than postulated above.
is available in the fire zone to allow the firefighting equipment brigade to perform this function, 11.2.3.3 Fire Zone 1.1.2.1 This fire zone is the Unit 2 torus level area of the reactor building.
Level sight glass 2-1602-10 is located in this fire zone on the north side of the torus.
O 11.2-4
QUAD CITIES 1&2 r-K The combustibles in Fire Zone 1.1.2.1 consist mostly of 22,456 l
ks) i feet of cable.
Transient combustibles and ignition sources in the torus are strictly controlled-and cannot be practically introduced due to access limitations.
The average combustible Joading in the fire zone is less than 5000 Btu /ft2, The ceiling of Fire Zone 1.1.2.1 is constructed of minimum 2-foot j
0-inch thick concrete with all electrical penetrations sealed
]
with noncombustible materials.
i
- l The linear fire detectors located in and adjacent to the cable l
trays will provide early warning of a fire.
This will allow the fire brigade ample time for manual suppression operations using available firefighting equipment in this fire zone.
The i
I suppression pool level needs to be checked when torus water i
cooling was initiated.
This occurs, at the latest, 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> into j
the event, at which time the fire will have been extinguished and the operators will have access to the sight glass.
)
11.2.3.5 Fire Zone 1.1.2.2 This fire zone is the ground floor level of the Unit 2 reactor building.
The combustibles in Fire Zone 1.1.2.2 consist mostly of 126,200 feet of cable.
This fire zone is the ground floor of the reactor l
building.
It is frequently traveled and occasionally used as a staging area.
Transient combustibles in the fire zone include anticontamination clothing and limited lubricating and cleaning fluids.
These transient combustibles are controlled to minimal quantities by station administrative procedures.
Lubricating and cleaning fluids are only used in approved containers.
The l
average combustible loading in the fire zone is less than 25,000 Btu /ft2, 11.2-5 i
i
i QUAD CITIES 1&2 The worst case postulated fire could involve the transients and
()
cable insulation mate "al.
Ar.y fire on this elevation would not expose the safe shutdown cables or equipment'in the southern half of the torus below since heat and products of combustion of the buoyant fire plume will rise to the ceiling and away from the torus.
All mechanical, hatch, and stairwell openings in the southern portion of the floor in Fire Zone 1.1.2.2 (south of column line 10) are sealed liquid-tight with noncombustible material or curbed to prevent a liquid spill from flowing into the torus below.
All electrical penetrations are sealed'in the floor and ceiling with a noncombustible material.
]
Available test data found in the FMRC/EPRI test reports,
" Categorization of Cable Flammability" NP-1881, August 1982, provide information describing the burning characteristics of j
I PE/PVC cable in horizontal cable trays.
The heat of combustion of PE/PVC is less than 11,000 Btu /lb.
The EPRI tests show that flame spread along horizontal cable trays is very slow.
The test reports for horizontal fire spread in deep stacks of horizontal cable trays agree with observations of the rate of fire spread in similar tray arrays in the reactor building at the Browns Ferry fire.
The horizontal spread rate for cable tray fires is about 6 to 7 ft/hr.
Although the cable tray arrangement in Fire Zone 1.1.2.2 is far less severe than that tested in the EPRI report, the parameters from those tests can be used to show a conservative fire scenario.
These parameters would indicate that only about 21 feet of cable would be consumed in a 3-hour fire.
The heat would be dissipated into an extremely large room volume.
Heat would also be lost to the surrounding enclosure and floors above.
Convective and radiative heat transfer effect from such a fire would not affect cables in Fire Zone 1.1.2.1 below.
Thus, the operators will have access to level sight glass 2-1602-10.
OV 11.2-6
QUAD CITIES 1&2 Fire detection throughout Fire Zone 1.1.2.2 will provide early O
werning of fire conditione in the fire zone.
This wi11 grovide ample time for manual firefighting operations to control fire spread in the trays to much less than that postulated above.
Manual firefighting equipment is available in the' fire zone to allow the brigade to perform this function.
11.2.4 Conclusions The previous analysis justifies an exemption request from the requirements of total area suppression and more than 20 feet of horizontal intervening space free from combustibles between the redundant instruments.
The technical bases that justify the exemption request are summarized below.
1.
The level sight glass on the torus level would not be damaged by a fire in the torus level due to the low combustible loading in the area of the sight glass.
2.
Torus level monitoring is not required until 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> into the event when RHR torus cooling is initiated.
At this time the fire will have been extinguished and the operators will have access to the sight glass.
3.
A fire that begins on the ground floor cannot spread to the torus level since the heat and products of combustion will rise to higher elevations.
4.
Portable lighting will be utilized to illuminate the sight glass when it is being read.
11.2-7
QUAD CITIES 1&2 11.3 JUSTIFICATION FOR LACK OF EMERGENCY LIGHTING FOR
,_(-)
SUPPRESSION POOL LEVEL INSTRUMENTATION 11.3.1 Discussion As described in Section 11.2, for'a fire in the northern porticne of Fire Zones 1.1.1.1 (Unit 1 Torus Area) and 1.1.2.1 (Unit 2 Torus Area) and all Reactor Building floor levels above the torus level, suppression pool level will be determined by locally reading sight glasses LG1-1602-10 for Unit 1 and LG2-1602-10 for Unit 2.
Section III.J of Appendix R would require that battery-powered emergency lighting be available to illustrate the sight glasses in the torus area when they are utilized as safe' shutdown instrumentation.
Therefore an exemption to the requirement is required for the particular instance of the suppression pool sight glasses.
I The two sight glasses (one per unit) are located on top of their respective torus structures.
The torus areas contain a large
()
concentration of piping and supports which would severely restrict the usefulness of any fixed lighting sources for illumination of the sight glasses, in addition to making reinstallation of such a fixed light source unwarrantedly difficult and complex.
Operators will utilize portable, handheld light sources to illuminate the sight glasses when their use is required.
Such light sources can be obtained by the operators in the control room and the Appendix R Safe Shutdown Procedures call for them to be issued to operators when they are required to leave the control room to perform manual safe shutdown activities.
The portable light sources provide sufficient lighting levels to easily read the sight glasses.
l 0
11.3-1
= _ _ _ _ - _ - _ - - _ _ _ _ _ _ _ _ _ -
QUAD CITIES 1&2 11.3.2 Conclusion 3(V As described in the proceeding discussion, lack of fixed emergency lighting in the torus areas for illumination of the suppression pool level sight glasses will'not interfere with timely performance of safe shutdown activities.
The bases for exemption from the requirement for fixed emergency lighting in this instance are summarized as follows:
1 1.
The high concentration of piping and support structures in the torus areas would severely limit the effectiveness of fixed emergency lighting in those areas.
1 l
2.
Portable, handheld light sources will provide sufficient illumination of the sight glasses for them to be easily read.
]
I l
3.
Installation of fixed emergency lighting in the congested
]
torus areas would be unwarrantedly difficult.
1 I
l 1
l l
l l
11.3-2
i i
1 I
("])
Quad Cities 1 & 2 l
TABLE OF CONTENTS i
PAGE
)
i 12,0 APPENDIX R EXEMPTION REQUEST FOR FUSE PULLING 12.0-1.
)
TO ELIMINATE SPURIOUS OPERATION CONCERNS 12.1 JUSTIFICATION FOR FUSE PULLING TO PRECLUDE 12.1-1 SPURIOUS EQUIPMENT OPERATION
]
1 J
12.1.1 Discussion 12.1-1 l
l 1
12.1.2 Conclusion-12.1-2 i
I 12.2 JUSTIFICATION FOR FUSE PULLING TO PRECLUDE 12.2-1 J
SPURIOUS OPERATION OF REACTOR RELIEF VALVES 12.2.1 Discussion 12.2-1 12.2.2 Conclusion 12.2-2 l
l l
I O
QUAD CITIES 1 & 2
()
12.0 APPENDIX R EXEMPTION REQUEST FOR FUSE PULLING TO ELIMINATE SPURIOUS OPERATION CONCERNS Per provision of 10 CFR 50.12, Commonwealth Edison Company (CECO) request exemption from the. requirement of Section III.G.1 of Appendix R that one train of systems needed for hot shutdown be
)
free of fire damage, in so far as this is interpreted as i
disallowing the use of repairs to implement hot' shutdown (SECY-83-269, Section 1.2.1).
CECO specifically requests an exemption request be granted to allow the pulling of fuses to preclude the possibility of spurious operation of safe shutdown equipment and reactor relief valves.
I Justification for this exemption request is provided in the I
following section.
Section Justification for
(
12.1 Fuse Pulling to Preclude j
1 Spurious Equipment Operation i
1 12.2 Fuse Pulling to Preclude I
Spurious Operation of Reactor Relief Valves l
l 1
O i
12.0-1
QUAD CITIES 1 & 2
(~h j
12.1 JUSTIFICATION FOR FUSE PULLING TO PRECLUDE SPURIOUS EQUIPMENT OPERATION 12.1.1 Discussion In the event of a fire in the Fire Areas TB-I (Turbine Building Northern Zone Group) or'TB-III (Turbine Building Southern Zone Group), RHR system logic cables associated with safe shutdown equipment could possibly be damaged by a fire.
This. damage could potentially result in spurious operation of safe shutdown equipment including RHR pumps and valves, diesel generator auxiliary equipment, safety relief valves, and. 4-kV breakers.
In order to prevent the possibility of spurious operation, the power to the RHR logic circuits must be deenergized.
For fires in other areas of the plant where this problem exists, the circuits are deenergized by tripping the breakers in the de distribution panel rooms in the turbine building (Fire Zones 6.1.A, 6.1.B,
( ))
6.2.A and 6.2.B).
These rooms, however, are located in the l
Northern and Southern Zone Groups and, therefore, could be inaccessible.
In order to deenergize the circuit for a fire in l
the Northern Zone Group, eight fuses in panel 902-32 located in the auxiliary electric equipment room (Fire Area SB-I) would be removed.
For a fire in the Southern Zone Group, eight fuses in panel 901-32, also located in the auxiliary electric equipment room would be pulled.
All of the fuses are in control circuits and are rated 15 amperes or less.
Actual load currents are considerably less, therefore, no personal safety equipment is needed.
The operators have been I
trained at pulling similar fuses for routine testing and i
l maintenance operations.
The pulling of fuses is considered a repair for the purpose of Appendix R, therefore, an exemption to Appendix R is necessary for the use of this procedure to achieve and maintain hot 1
shutdown.
)
12.1-1 l
J
QUAD CITIES'l & 2
()
12.1.2 Conclusion Based on this analysis, the intent of Appendix R is met, because the pulling of these fuses will not interfere with the timely per formance of other safe ' shutdown operations.
The justification l
for removal of these fuses is summarized as follows:
~
1.
This procedure will be used to guard against possible spurious operation for fires in either of only two fire l
areas.
1; 1
'2 The fuses are easily identified and removed.
l 1
3.
All of the fuses required to be removed for each of these fire areas are located-in one panel in the auxiliary electric equipment room.
}
i I
l 4
()
12.1-2
QUAD CITIES 1 & 2
()
12.2 JUSTIFICATION FOR FUSE PULLING TO PRECLUDE SPURIOUS OPERATION OF REACTOR RELIEF VALVES i
l l
12.2.1 Discussion I
For fires occurring in Fire Areas SB-I, RB-1, RB-2, TB-I, TB-II, or TB-III, it is possible that damage to electrical circuits I
could occur, e.g.,
shorts in power or control cables, which would result in spurious operation of a Unit 1 and/or Unit 2 reactor I
relief' valve (203-3A, 203-3B, 203-3C, 203-3D, or 20 3-3E).
To l
ensure against such spurious operation, it will be necessary in some cases to manually disable the relief valve circuitry.
Generally, this involves removing power to the valves and is commonly accomplished by opening breakers at electrical distribution panels.
However, for a fire in Fire Area TB-I or TB-III, it will be necessary to remove control power fuses to deenergize the valve circuits.
The removal of fuses to achieve
()
or maintain hot shutdown is considered a repair for the purposes of Appendix R, and thus is not permissible without specific exemption.
There are 10 fuses per unit which will need to be removed in order to deenergize the circuits to each unit's five relief valves.
The Unit 1 fuses are located in electrical panel 1-2201-32 in Fire Zone 1.1.1.3 (Unit 1 Reactor Building Mezzanine Floor Level) in Fire Area RB-1.
The Unit 2 fuses are located in electrical panel 2-2201-32 in Fire Zone 1.1.2.3 (Unit 2 Reactor Building Mezzanine Floor Level) in Fire Area RB-2.
For a fire in Fire Area TB-I (Turbine Building Northern Zone l
Group), only the Unit 2 fuses, located in Fire Area RB-2, will need to be removed, since such a fire will not affect the Unit 1 relief valve circuitry.
A fire in Fire Area TB-I will not affect Fire Area RB-2 and the panel containing the fuses will be readily accessible.
()
For a fire in Fire Area TB-III (Turbine Building Southern Zone Group), only the Unit 1 fuses, located in Fire Area RB-1, will 12.2-1
QUAD CITIES 1 & 2
()
need to be removed, since such a fire' will not affect the Unit 2 relief valve circuitry.
A fire in Fire Area TB-III will not affect Fire Area RB-1 and the panel containing the fuser will be readily accessible.
The 20 fuses (10 per unit) under consideration are cartridge-type fuses and are rated at 20 amperes.
No personal safety equipment is needed for their removal and the station operators are trained and experienced in removing such fuses for routine testing'and maintenance.
l 12.2.2 Conclusion As demonstrated in the preceding discussion, the removal of fuses' to prevent spurious operation of the reactor relief valves would a
not interfere with timely performance of safe shutdown I
operations.
Justification for the acceptability of removing the fuses as part of postfire hot shutdown operations is summarized as follows:
1.
The number of fuses under consideration is limited to 10 for each unit.
All 10 fuses for a given unit are
)
located on a single panel in the reactor building.
l l
2.
Removal of the fuses will be incorporated into the plant Appendix R Safe Shutdown Procedures.
3.
The fuses are located at panels in fire areas dif ferent from those fire areas in which the postulated fire occurs that requires removal of the fuses.
4.
The fuses under consideration are easily identifiable, low amperage fuses, which are easily removed without threat to operator safety.
12.2-2
- - _ _ - _ - _ -