ML20237C137
| ML20237C137 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 11/27/1987 |
| From: | Murley T Office of Nuclear Reactor Regulation |
| To: | CONNECTICUT YANKEE ATOMIC POWER CO. |
| Shared Package | |
| ML20237C135 | List: |
| References | |
| NUDOCS 8712210060 | |
| Download: ML20237C137 (15) | |
Text
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7590-01 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
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CONNECTICUT YANKEE ATOMIC
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Docket No. 50-213 POWER COMPANY,
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(Haddam Neck Plant)
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EXEMPTION I.
The Connecticut Yankee Atomic Power Company (CYPAC0, the licensee) is the l
holder of Facility Operating License No. DPR-61 which authorizes operation of 1
the Haddam Neck Plant (the facility) at power levels no greater than 1825 megawatts thermal. The facility is a single-unit pressurized water reactor (PWR) located at the licensee's site in Middlesex County, Connecticut.
The License provides, among other things, that the Haddam Neck Plant is subject to all rules, regulations, and Orders of the Nuclear Regulatory Commission (the Commission) now or hereafter in effect.
II.
On November 19, 1980, the Commission published a revised Section 10 CFR 50.48 and a new Appendix R to 10 CFR Part 50 regarding fire protection features of ruclear power plants.
The revised Section 50.48 and Appendix R became effective on February 17, 1981.
Section III of Appendix R contains 15 subsections, lettered A through 0, each of which specifies requirements for a particular aspect of the fire protection features at a nuclear power plant.
Two of these subsections, III.G and III.J are the subjects of the licensee's exemption requests.
8712210060 871127 -
ADOCK05000g3 PDR F
. 7590-01 Section III.G.2 of Appendix R requires that one train of cables and equipment necessary to achieve and maintain safe shutdown be maintained free of fire damage by one of the following means:
a.
Separation of cables and equipment and associated non-safety circuits of redundant trains by a fire barrier having a 3-hour rating.
Structural steel forming a part of or supporting such l
fire barriers shall be protected to provide fire resistance l
l equivalent to that required of the barrier; b.
Separation of cables and equipment and associated non-safety circuits of redundant trains by a horizontal distance of more than 20 feet with no intervening combustible or fire hazards.
i In addition, fire detectors and an automatic fire suppression system shall be installed in the fire area; or c.
Enclosure of cable and equipment and associated non-safety circuits of one redundant train in a fire barrier having a 1-hour rating.
In addition, fire detectors and an automatic fire suppression system shall be installed in the fire area.
Section III.G.3 of Appendix R requires that for areas where alternative or dedicated shutdown is provided, fire detection and a fixed fire suppression system shall also be installed in the area, room, or zone under consideration.
Section III.J of Appendix R requires that emergency lighting units with at least an 8-hour battery power supply shall be provided in all areas needed for operation of safe shutdown equipment and in access and egress routes.
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. 7590-01 III.
By letter dated March 19, 1981, the licensee requested exemptions from Section III.G of Appendix R.
This request, and subsequent submittals, resulted in the NRC granting one exemption from the requirements of Section III.G on November 11, 1981.
On March 1, 1982, the licensee submitted an initial reevaluation of the fire areas and zones identified in previous submittals.
Additional information was submitted on June 18, 1986 and January 6,1987, the licensee submitted additional exemption requests from the requirements of i
l Sections III.G and III.J of Appendix R.
The following is a list of CYAPC0 l
1.
Primary Auxiliary Building (Fire Area A-1).
An exemption was requested from the specific requirements of Section III.G.2a to the extent that this area is not separated by 3-hour fire rated barriers from Fire Area W-1 which contains redundant shutdown system cables.
2.
Primary Auxiliary Building Charging Metering Pump Cubicle (Fire Zone A-ID).
An exemption was requested from the specific requirements of Section III.G.2.a to the extent that this fire zone is not separated by 3-hour rated barriers from fire zone containing redundant shutdown systems, cables, and associated circuits.
3.
Service Building Locker Room (Fire Zone S-38).
An exemption was requested from specific requirements of Section III.G.2.a to the l
extent that this area is not separated by 3-hour rated fire barriers
s
. 7590-01 from adjacent diesel generator rooms (Fire Areas D-1 and D-2) which contain redundant safe si.atdown systems, cables, and associated circuits.
4.
Control Room (Fire Area 5-1).
An exemption was requested from the specific requirements of Section III.G.2.a to the extent that this area is not separated by 3-hour fire-rated barriers from the turbine building (Fire Area T-1) and the mechanical equipment room / instrument shop (Fire Area S-4).
5.
Switchgear Room (Fire Areas S-2), Turbine Building (Fire Area T-1),
and Cable Spreading Area (Fire Zone S-3A).
Exemptions were requested from the specific requirements of Section III.G.2.a to the extent that these areas / zones are not separated by 3-hour fire-rated barriers (including structural steel fortning a part of or supporting such fire barriers) from areas containing redundant shutdown systems, cables, and associated circuits.
6.
Turbine Buitying (Fire Area T-1), Switchgear Room (Fire Area S-2),
Service Building Cable Spreading Area (Fire Zone S-3A), and Service Building Locker Room (Fire Zone S-3B).
Exemptions were requested from the specific requirements of Section III.G.2.a to the extent that these areas / zones are not separated by 3-hour fire-rated barriers from areas containing redundant chutdown systems, cables, and associated circuits.
7.
Switchgear Room (Fire Area 5-2).
An exemption was requested from the specific requirements of Section III.G.2.a to the extent that
. 7590-01 8.
Service Building Elevation 21 Feet 6 Inches (Fire Area S-3), Primary Auxiliary Building (Fire Area A-1), Mechanical Equipment Room / Instrument Shop (Fire Area S-4), and Maintenance Shops (Fire Area S-5).
Exemptions were requested from the specific requirements of Section III.G.2 to the extent that these areas are not separated by 3-hour fire-rated barriers from areas which contain redundant shutdown systems, cables, and associated circuits.
9.
Service Building Men's Locker Room & Shower Area (S-9).
The licensee requested an exemption from Section III.G.2 to the extent l
that it requires physical separation and the installation of a smoke detection system to protect redundant trains of 3afe shutdown related cable and equipment.
10.
The licensee requested an exemption from Section III.J to the extent that it requires emergency lighting units with at least an 8-hour battery power supply in all areas needed for operation of safe shutdown equipment and in access and egress routes, in particular, the areas where the licensee cannot meet these requirements are:
(a) A portion of general yard areas for access and egress, (b) in the immediate vicinity of the primary water storage tank (PWST),
(c) for manually operating CD-V-632 located near the demineralized water storage tank (DWST), and l
(d) for manually operating LD-V-221 located near the vent stack.
l o.
. 7590-01 I
The staff has reviewed in detail each of the 10 exemption requests identified above and concluded that the condition or circumstances which exist in exemption requests 1, 3, 4, 6, 7, and 8 are encompassed by the guidance issued in Generic Letter 86-10.
According to the interpretations of Appendix R contained in the generic letter, no exemptions from the requirements of Appendix R are required for these locations.
The staff considers the information presented in support of the exemption requests to constitute the required fire hazards analysis for each location.
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The staff has also reviewed the remaining four exemption requests and l
.has concluded that an acceptable basis for granting these exemptions exists.
These exemptions are discussed below.
1.0 Primary Auxiliary Building Charging Metering Pump Cubicle (Fire Zone A-ID) i An exemption was requested from the specific requirements of Section III.G.2.a to the extent that this fire zone is not separated by 3-hour rated barriers from fire zone containing redundant shutdown systems, cables, and associated circuits.
Discussion One of two charging pumps or the charging metering pump is required to be operable to achieve safe shutdown in the event of a fire in the primary auxiliary building (PAB) area A-1.
The two charging pumps and the charging metering pump are located on elevation 15 ft. 6 in. of the PAB, each within an individual cubicle.
The three cubicles are open to a common area which the licensee has identified as fire zone A-IA.
The door openings from the cubicles to the common area are formed by a l
s e
. 7590-01 partial wall in a " labyrinth" configuration.
The charging metering pump cubicle is bounded on the three sides away from the common area by 3-hour fire rated walls.
The floor and ceiling are also fire rated.
Evaluation The staff was concerned that a fire in any one of the pump cubicles or in the common area (zone A-1A) could damage both of the charging pumps and the charging metering pump.
However, the combustible loading in the i
referenced areas, as represented by the licensee, is negligible.
If all of the combustibles were consumed, the resulting fire would have a duration of less that 4 minutes, as determined by the ASTM E-119 standard time temperature curve.
If a fire should occur, it would be detected by the existing smoke detection system in its formative stage, before significant room temperature rise or flame propagation occurred.
An alarm would be transmitted automatically to the control room.
The fire brigade would be dispatched to the scene and would put out the fire using manual fire fighting equipment.
Pending arrival of the brigade, the construction and Configuration of the cubicles will provide reasonable assurance that at least one charging pump or the charging metering pump would remain free of fire damage.
Therefore, the lack of a complete 3-hour fire-rated barrier at the entrance to the charging metering pump cubicle is not safety significant.
Based on the above evaluation, the staff concludes that the licensee's existing fire protection features provide an equivalent level of fire protection to that which would be achieved by literal compliance with
. 7590-01 Appendix R and, therefore, meets the underlying purpose of the rule.
Therefore, the licensee's exemption request from the requirements of Section III.G.2.a in the charging metering pump cubicle should be granted.
2.0 Switchgear Room (Fire Areas S-2), Turbine Building (Fire Area T-1), and Cable Spreading Area (Fire Zone S-3A).
Exemptions were requested from the specific requirements of l
Section III.G.2.a to the extent that these areas / zones are not separated by l
l 3-hour fire-rated barriers (including structural steel forming a part of or supporting such fire barriers) from areas containing redundant shutdown systems, cables, and associated circuits.
Discussion The licensee identified the following locations where unprotected steel exists:
inside the switchgear room where steel supports the floor of the control room; inside the turbine building, where steel supports the control room floor; and inside the cable spreading area where steel supports the switchgear room floor.
The combustible loading in these locations consists of significant quantities of cables and lube oil, but the hazard associated with these materials has been mitigated by automatic fire suppression systems.
Existing fire protection includes: (1) an automatic halon fire suppression system in the switchgear room; (2) an automatic sprinkler system for cable tray protection in the cable spreading area; (3) automatic
. 7590-01 Existing fire protection includes: (1) an automatic halon fire suppression system in the switchgear room; (2) an automatic sprinkler system for cable tray protection in the cable spreading area; (3) automatic fire detectors throughout the switchgear and cable spreading areas and in certain special hazards areas of the turbine building; (4) partial automatic sprinkler protection in the turbine building and (5) manual fire fighting equipment throughout these areas.
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Conclusions l
l The locations where significant fire hazards exist in these areas and/or the locations where unprotected steel are present are now protected by automatic fire suppression systems.
Under any credible fire scenario in these locations, a fire would be detected in its incipient stages by the existing fire detection systems or by operating personnel.
In support of the in situ fire suppression systems, the fire brigade would be dispatched and would put out the fire before. room temperatures rose sufficiently to affect the steel.
Rapid fire propagation and room temperature rise is not expected to occur before the arrival of the brigade because the automatic fire suppression system would actuate to control the fire, limit temperature rise, and protect the steel.
Therefore, coatir.g of the steel with a fire resistant material is not necessary to assure the integrity of the subject barriers.
Based on the above evaluation, the staff concludes that the licensee's existing fire protection as well as additional proposed modifications l
provides an equivalent or superior level of fire protection and safety to that which would be achieved by literal compliance with Section III.G.2 of
. 7590-01 Appendix R and, therefore, meets the underlying purpose of the rule.
Therefore, the licensee's request for exemption for unprotected steel in the subject areas should be granted.
3.0 Service Building Men's Locker Room & Shower Area (S-9).
The licensee requested an exemption from Section 111.G.2 to the extent that it requires physical separation and the installation of a smoke detection system to protect redundant trains of safe shutdown related l
{
l cable and equipment.
Discussion The fire area is enclosed by noncombustible walls, floor and ceiling.
I Existing fire protection for the area consists of an automatic sprinkler system, manual hose stations, and portable fire extinguishers.
Safe shutdown components located within the area consist of service water pump power cables.
Cabling from both divisions are located within a single cable chase with no divisional separation. The cable chase is enclosed on three sides by two layers of gypsumboard and on the fourth side by concrete block.
The fire-hazard in the area, as represented by combustible materials, is negligible.
All combustible materials compile a fuel load of approxi-mately 14,000 BTU /sq. ft. which, if totally consumed, would correspond to a fire severity equivalent to about 10 minutes on the ASTM E-119 standard time temperature curve.
Conclusion l
The existing fire protection for the area consists of both passive and active safety features.
The gypsumboard and concrete block enclosure around the cable chase represents at least a one-hour fire-rated barrier.
. 7590-01 This affords an acceptable level of safety in consideration of the low in situ fuel loading stated in the discussion above.
Reinforcing this protection is a complete, automatic sprinkler system that protects the entire men's locker room and shower area.
A water flow alarm from the sprinkler system is annunciated in the control room.
In addition, portable fire extinguishers and hose stations are available for manual fire fighting.
f It is our opinion that this protection provides reasonable assurance that l
the shutdown related cables will be free of damage from a fire in the area.
l Based on our evaluation, we conclude that any additional modifications to meet the literal requirements of Section III.G.2 would not enhance fire 1
safety above that provided by the existing fire protection systems.
Therefore, the staff concludes that the licensee's existing fire protection meets the underlying purpose of the relevant section of Appendix R and the licensee's request for exemption should be granted.
4.0 Emergency Lighting The licensee requested an exemption from Section 111,J to the extent that it requires emergency lighting units with at least an 8-hour battery power supply in all areas needed for operatico of safe shutdown equipment and in access and egress routes.
In particular, the areas where the licensee cannot meet these requirements are:
(a) A portion of general yard areas for access and egress, (b) in the immediate vicinity of the primary water storage tank (PWST),
(c) for manually operating CD-V-632 located near the demineralized water storage tank (DWST), and (d) for manually operating LD-V-221 located near the vent stack.
R-' i
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1 7590-01 l
I
. Discus sion' l
Upon completion of the post-fire shutdown methodology, the licensee identified all locations where manual actions are required and determined the optimum travel paths for operating personnel to and from these areas.
With the exception of the locations identified above, the licensee has installed 8-hour battery powered lighting units per the requirements of Section III.J.
The licensee proposes to utilize the security perimeter lighting for a portion of the outside egress routes and one outside task and portable hand-held lighting units for the remaining task and routes of travel.
Conclusion Based upon our review of the information, the staff has concluded:
(1) that there are no obstructions or tripping hazards in the routes of travel; (2) that operators would not be required to perform shutdown tasks using both hands; and (3) that the licensee has a program to assure both the availability and operability of the flashlights, when needed.
The staff has also concluded that, given that the security lighting is powered from a separate diesel generator, the security lighting is not vulnerable to fire loss.
The licensee has confirmed for the staff that an adequate level of illumination in the yard areas exists.
Based on the above, the staff considers the licensee's alternative lighting configuration to be equivalent to that achieved by literal conformance with Appendix R to 10 CFR Part 50 and, therefore, meets the 1
. 7590-01 underlying purpose of Section III.J of Appendix R.
Therefore, the licensee's request for exemption from the requirements of Section III.J. in the subject locations should be granted.
10 CFR 50.12 Determinations i
Pursuant to 10 CFR 50.12(a)(2), the Commission will not consider granting an exemption unless special circumstances are present.
Item (ii) of the j
subject regulation includes special circumstances where application of the subject regulation would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule.
The underlying purpose of Section III.G is to provide adequate protection of redundant components of safety-related equipment by limiting damage in the event of a fire at one safety-related component location so that the performance of the other redundant safety-related component is not affected.
The licensee has installed automatic detection and suppression systems to prevent fire propagation and limit fire damage in lieu of separation of the components as prescribed by Appendix R.
As described in the evaluation section of each exemption request, the staff has concluded that the existing fire protection systems provide equivalent or superior fire protection to that which would be provided by meeting the literal separation requirements of Section III.G of Appendix R.
The underlying purpose of Section III.J is to provide adequate illumina-tion to assure the capability of performing all necessary safe shutdown functions as well as provide illumination for required movements into and out of the plant.
In lieu of the 8-hour battery units specified by Appendix R, the licensee has proposed using security lighting and hand-held
. 7590-01 portable flashlights.
The staff has reviewed the proposed alternative and has concluded, as described in the conclusion section of exemption number four that the security lightir,g system would be a reliable alternative and would provide an adequate level of illumination to perform all required safe shutdown functions.
In summary, the staff has concluded that the alternative fire protection provided in support of the exemptions meets or exceeds the l
l fire protection which would otherwise occur if literal compliance with the separation requirements of Appendix R were required.
In addition, the staff has concluded that the alternative use of security lighting and portable flashlights would meet the underlying purpose of Section III.J by providing acceptable levels of illumination to assure that required safe shutdown functions and required personnel movements can be performed.
Therefore, the staff concludes that "special circumstances" exist for the licensee's requested exemptions in that imposition of the literal require-ments of the regulation in these particular circumstances is not necessary -
to achieve the underlying purposes of Appendix R to 10 CFR Part 50.
IV.
Accordingly, the Commission has determined that, pursuant to 10 CFR 50.12(a)(2)(ii), special circumstances exist in that existing levels of emergency lighting and fire protection systems satisfy the underlying sections of Appendix R l
to 10 CFR Part 50.
Further, the staff has concluded that the requested exemptions are authorized by law and will not endanger life or property or the common
. 7590-01 defense and security and are otherwise in the public interest.
Therefore, the Commission hereby grants the exemption requests from the requirements of Section III.G and III.J of Appendix R to 10 CFR Part 50 described in Section III above.
Pursuant to 10 CFR 51.32, the Commission has determined that the issuance of this exemption will have no significant impact on the environment (51 FR 17696, May 14, 1986; 51 FR 24456, July 3, 1986; and 52 FR 5509 February 23,1987).
A copy of the Commission's concurrent Safety Evaluation related to this action and the above referenced submittals by the licensee are available for public inspection at the Commission's Public Document Room, 1717 H Street, N.W.,
Washington, D.C. and at the local public document room located at the Russell Library, 123 Broad Street, Middletown, Connecticut 06457.
FOR THE NUCLEAR REGULATORY COMMISSION Thomas E. Murley, Director Office of Nuclear Reactor Regulation Dated at Bethesda, Maryland this 27th day of November 1987
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