ML20237C144
| ML20237C144 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 11/27/1987 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20237C135 | List: |
| References | |
| NUDOCS 8712210067 | |
| Download: ML20237C144 (13) | |
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1 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION CONCERNING FIRE PROTECTION EXEMPTIONS AND RELATED ISSUES CONNECTICUT YANKEE ATOMIC POWER COMPANY DOCKET N0. 50-213 HADDAM NECK PLANT
- 1. 0 INTRODUCTION By letter dated September 16, 1985, the licensee submitted for staff review the results of a revalidation study of the Haddam Neck Plant against the requirements of Sections III.G., J. and L. of Appendix R to 10 CFR Part 50.
Eight new exemptions were requested from these requirements.
The staff reviewed this information and by letter dated December 4, 1985, requested clarification on a number of issues.
Additional questions were transmitted to the licensee on March 25 and April 14, 1986.
By letters dated February 6 and 19, April 30, May 13 and 21, June 10 and 13 (two letters), September 9 and November 24, 1986, and January 6 and May 21, 1987, the licensee provided additional information on the fire protection program.
Included in this information was a request for an additional exemption, revisions to the post-fire safe shutdown methodology and comments on previous staff fire protection safety evaluations.
The staff's evaluation of this information is contained in this report as follows:
Sections 2.0 through 5.0 consist of the evaluation of specific exemption requests; Section 6.0 consists of the evaluation of additional information submitted concerning the fire protection program; and Section 7.0 consists of the
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evaluation of certain comments made by the licensee concerning the staff's November 14, 1984, safety evaluation.
The staff's review of the licensee's revised safe shutdown methodology is continuing and will be the subject of a future safety evaluation.
L 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:
1.
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 fire barriers shall be protected to provide fire resistance equivalent to that required of the barrier; B712210067 871127 PDR ADOCK 05000213 F
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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.
In addition, fire detectors and an automatic fire suppression system shall be installed in the fire area; or 3.
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.
l' If these conditions are not met,Section II.G.3 requires an alternative shutdown capability independent of the fire area of-concern.
It also requires that a fixed fire suppression system be installed in the fire area of concern if it contains a large concentration of cables or other combustibles.
These alternative requirements are not deemed to be equiv-alents, however, they provide equivalent protection for those config-urations in which they are accepted.
Because it is not possible to predict the specific conditions under which fires may occur and propagate, the design basis protective features are specific in the rule rather than a design basis fire.
Plant specific features may require protection different from the measures specified in Section III.G.
In such a case, the licensee must demonstrate by fire hazards analysis, that existing protection in conjunction with proposed modifications will provide a level of safety equivalent to the technical requirements of Section III.G of Appendix R.
In summary, Seccion III.G is related to fire protection features for ensuring'that systems and associated circuits used to achieve and maintain safe shutdown are free of fire damage.
Fire protection configurations must either meet the specific requirements of Section III.G or an alternative fire protection configuration must be justified by a fire hazard analysis.
The staff's general criteria for accepting an alternative fire protection configuration are the following:
The alternative assures that one train of equipment necessary to achieve hot shutdown from either the control room or emergency control stations is free of fire damage.
The alternative assures that fire damage to at least one train of equipment necessary to achieve cold shutdown will be limited such that it can be repaired within a reasonable time (minor repairs with components stored onsite).
Modifications required to meet Section III.G would not enhance fire protection safety above that provided by either existing or proposed alternatives.
Modifications required to meet Section III.G would be detrimental to overall facility safety.
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P 2.0 EVALUATION A.
CHANGING METERING PUMP CUBICLES 1.0 Exemption Requested The licensee requested approval of an exemption from the requirements of Section III.G.2.a of Appendix R to 10 CFR Part 50 to the extent that it requires that redundant shutdown systems be separated by a fire barrier having a 3-hour fire rating.
2.0 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-1A.
The door openings from the cubicles to the common area are formed by a 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.
The fire loading in the cubicles and zone A-1A is negligible.
Existing fire protection includes a smoke detection system at the entrances to the cubicles and in zone A-1A, manual fire fighting equipment, and a partial sprinkler system in zone A-1A.
The licensee has proposed to install a fire damper in the HVAC opening in the west wall of the charging metering pump cubicle and to reroute / protect the shutdown related cables which ex1t this cubicle so as to be free of fire damage.
The licensee justifies the exemption on the basis of the low fire loading, the cubicle configuration, the existing fire protection, and the proposed modifications.
3.0 Evaluation The technical requirements of Section III.G.2.a. are not met because the charging metering pump and cables are not separated from either of the charging pumps by a complete 3-hour fire-rated barrier.
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 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 than 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 l
room temperature rise or flame propagation occurred.
An alarm would be transmitted automatically to the control room.
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- M 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.
4.0 ' Conclusion i
Based on the above evaluation, the staff concludes that the licensee's alternative fire protection features provide an equivalent level of safety to that achieved by compliance with Appendix R.
Therefore, the licensee's exemption request from the requirements of Section III.G.2.a. in the charging metering pump cubicle should be granted.
B.
UNPROTECTED STRUCTURAL STEEL 1.0 Exemption Requested The licensee requested approval of an exemption from the requirements of Section III.G.2.a. of Appendix R.to 10 CFR Part 50 to the extent that it requires that structural steel which is framed into or supports fire barriers shall be protected to provide fire resistance equivalent to that required by the barrier.
- 2. 0 Discussion The licensee identified the following locations where unprotected steel j.
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:
an automatic halon fire suppression system in the switchgear room; an automatic sprinkler system for cable tray protection in the cable spreading area;
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automatic fire detectors throughout the switchgear and cable spreading areas and in certain special hazards areas of the turbine building; partial automatic sprinkler protection in the turbine building; and manual fire fighting equipment throughout these areas.
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The licensee has committed to install an automatic sprinkler system <where unprotected steel exists in the turbine building, with sprinkler, heat's specifically located to discharge water onto the structural stee'l columns.
The licensee justified the exemption on the basis of the existing level of fire protection and the proposed modification.
3.0 Evaluation i
The technical requirements of Section III.G.2.a. are not met in these l
locations because structural steel which supports certain fire barriers i
are not protected with " fire proofing" material equivalent in fire resistance to the fire-rating of the barrier itself.
The staff was concerned that a fire of significant magnitude could produce room temperatures of sufficient magnitude to cause the steel to fail.
The resulting loss of structural integrity of the fire barrier that is supported by the steel could adversely affect the redundant shutdown systems on either side of the barrier.
However, the locations where significant, fire hazards exist in these areas and/or the locations where unprotected steel are present are now or will be protected by an automatic fire suppression system.
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. -The fire brigade would be dispatched and would put out the fire before room temperatures rose sufficiently to affect the steel.
If rapid fire propagation and room temperature rise 5ccurred before.
l the arrival of the brigade, the automatic fire suppression system would actuate to control the fire, limit temperature rise and protect the steel.
Therefore, coating of the steel with a fire resistant material is not necessary to assure the integrity of the subject barriers.
4.0 Conclusion Based on the above evaluation, the staff concludes that the licensee's existing fire protection and proposed modifications provide an equivalent level of safety to that achieved by compliance with Section III.G.2 of Appendix R.
Therefore, the licensee's request for exemptiori for unprotected steel in the subject areas should be granted.
1 C.
SERVICE BUILDING MEN'S LOCKER ROOM & SHOWER AREA (S-9) 1.0 Exemption Requested The licensee requested an exemption from Section III.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 cable and equipment.
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2.0 Discussion The fire area is enclosed by noncombustible walls, floor and ceiling.
, 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.
y The fire hazard in the area, as represented by the fuel load, in negligible.
All combustible material compile a fuel load of approx 4ntely 14,000 BTU /sq. ft.
which, if totally censumed, would correspond to a fir 9 se. verity equivalent to about 10 minutes on the ASTM E-119 standard time' temperature curve.
The licensee justified the exemption on the contention that the existing fire protection for the cable chase and the room is sufficient and that modifications required to meet Section III.G would not significantly enhance fire safety.
20 Evaluation 7
TM requirements of Section III.G.2 are intended to provide a combination cf passive (separation and/or fire barrier) and active (fire suppression /
- &tection systems) protection to assure safe shutdown capability.
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 one-hour fire-rated barrier.
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This affords an acceptable level of safety in consideration of the low in situ fuel loading identified in the Discussion.
Reinforcing this protection is a complete, automatic sprinkler system that protects the entire men's locker room and shower area.
A vaterflow 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.
It is our opinion that this protection provices reasonable asserance that the shutdown related cables will be free of damage from a fire in the area.
4.0 Conclusion l
i Based on our evaltation, we conclude that addi,tional modifications to meet p'
the requirements of Section III.G.2 would not enhance fire safety above j
that provided by the existing alternative.
Therefore, the licensee's request for exemption should be granted.
D.
EMERGENCY LIGHTING 1.0 Exemption Requested i
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e The licensee requested approval of an exemption from the technical requirements of Section III.J. of Appendix R to 10 CFR Part 50 to the
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extent that it requires 8-hour' battery powered emergency light:Ing in areas 4
needed for safe shutdown and-in access anj egress routes to lhese areas.
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.n 2.0 Discussion r
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.Q Upon completion of the post-fire safe shutdowt aathodology, the licessee -
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identified all locations where manual actions att required and detennned g
f the optimum travel paths for operating personneP tc ad from these, areas.
1 With the exception of the following locatigs, the'licensei hd in's'talled
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8-hour battery powered lighting units per the requirements of Ed.tfon III.J.
T These locations'are:
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.a portion of general yard areas for access and egress; for danually N tf
' operating LD-V-221 located near the vent stack;
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in the immediate vicinity of the primary water storage tank (PWST); (
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4 for manually operating CD-V-632 located near the demineralized waten V
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$t 3) storage tank (DWST).
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lt The licensee proposes to' utilize the su:urity perimeter lighting T$r a e YJ portion of the outside egress routes snd one outside task and portable a
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' hand-held lighting units for the re d ning tasks and routes of travel. i' 9 p The licensee justified the exemptioin 09 the basis of the adequacy of the alternative lighting to satisfy the+ underlying purpose of the regulation. " T[
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- g 3.0 Evaluation A
e n III.J. are not met in th above-ThetechnicalrequirementsofSectip'batterypoweredemergencylighting' cf reterenced locations because 8-hour s
units have not been provided where mante.41 actions are required for sefe '
shutdownandinroutesoftraveltdandfgomtheseareas.
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- ,i The staff had several concerns with,the licensee's proposal to use,o6rtab k r
lights.
The first was that the fla'shlight would not be maintained (n an" operable condition 1or use in an emergency.
However, the licensee comitted to control access to and to maintain the flashlights so as to be assured of their availability and operability when needed.
The staff was also concerned that there%ight be obstructions or tripping hazards in the route of travel that might not be revealed with the beam of
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.a flachlight.
Based on past observations of the proposed reate, v i such ~
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conditions exist.
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s' Finally, the staff was concerned that in proceeding across the yard area or in performing shutdown tasks, the operator would be required to use both hands, which would effectively prevent him from usinej t.he flashlight However, the licensee has indicated that no such actions at e ne:essary..
On this basis, the' staff considers the licensee % hse of flashlight's to be acceptable.
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Tile staff also had several concerns with the licensee's proposal to rely upon security lighting.
The first was that the same fire which resulted in the need to go to the areas covered by the security lighting would cause the loss of this capability.
The security lighting is supplied power from the security dies'el and is, therefore, not vulnerable to fire loss under the r)ostulated fire scenario.
J Anotner concern was that the level of illumination vould be sufficient to prceid the staff with reasonable assurance that the safe shutdown function cou W be achieved. :~The licensee conducted a wa.1kdorn of the yard areas y
where the alternating lighting configuration was previded.
This walkdown a
- 7 confirmed that an ahquate level of illumination had been provided.
The naff was also concerned that the' security lighting would not be s
maintained.
However, this lighting is inspected and maintained as part of the plant security requirements.
The staff finds this acceptable.
T 4.0 Conclusion O
tt Based on the abovk evaluation, the staff considers the. licensee's alternate lighting configuration to be equissient to that achieved by'conformance
. with Appe6 dix R to 10 CFR Part 50. Therefore, the licensee s request for i xemptiydfrom the requirements of secticn III.J. in the subject locations e
should on granted.
t 3.0 FIRE A1EA BOUNDARY CONSTRUCTION s sA( c
, 3.1 Enuptions Reauested Tbs %.6nSea; requested approval of six exemptions from the technical reotdrements oi'Section III.G.2.a. to the extent that it ret,uires that s
freoundant shut *wn-related systems be separated by 3-hour fire-rated
, barriers; i
/33.2 Dir.ussion A
7 7.n cor pnction with the Appendix R reappraisal, the licensee redefined fire a. seas for the purpose of assessing safe shutdown capaldlity separation /
" protection.
During this effort, the licensee indicated that within certain waM o and floor / ceiling assemblies which define the perimeter of these n
arees, there exists certain non-fire-rated features. These are:
a sheet
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metal wall, HVAC penetrations without fire dampers, security modified fire
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9. sors, non-fire rated door frames, and unprotected steel. The licensee e
F 31so identified a portion of the fire barrier between the service and turdine buildings as being less than 3-hours. The specific locations and f
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description of these conditions are contained in the licensea's September 16,
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1985, submittal in exemption request numbers 1.0, 3.0, 4.0, 6.0, 7.0, and 8.0.
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The licensee has justified these conditions on the following bases:
low fire loading; the presence of automatic smoke detection and fire suppression systems; the availability of manual fire fighting equipment; significant spatial separation between redundant shutdown systems on either side of the walls and floor / ceilings or no redundant systems on either side of the barrier; and the ability of the existing barrier to limit fire spread.
3.3 Evaluation The above-referenced conditions exist within fire area boundaries and, therefore, are encompassed by the guidance issued in Generic Letter (G.L.)
86-10.
According to the interpretations of Appendix R contained in the generic letter, no exemptions are required for these conditions.
- However, the staff considers the information presented in the exemption requests as constituting the required fire hazards analysis.
The staff's principal concern was that a fire of significant magnitude could occur in one area and spread to another because of these features.
With regard to the sheet metal wall between the waste disposal and primary auxiliary building; the fire door assemblies; the unprotected steel; and the 2-hour fire-rated wall between the service and turbine buildings, the staff's concern was significantly mitigated by the fact that these features still maintain a continuous noncombustible barrier against the passage of smoke, hot gases, and radiant energy from one side of the barrier to another.
Because of the substantial nature of these features, a fire of i
significant magnitude and duration would be necessary to adversely affect their integrity.
Because of the existing fire detection and suppression systems, it is the staff's judgment that any potential fire would be detected early and controlled by the suppression systems and/or extinguished by the fire brigade before damage to the barrier would be sustained.
l Therefore, the lack of a 3-hour fire rating is not significant from a fire safety standpoint.
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With regard to the HVAC penetrations without fire dampers, the staff's j
l concern is mitigated by the substantial construction of the ducts and by industry tests which demonstrate that, under certain fire exposures, i
ventilation ducts are capable of remaining intact and limiting fire propagation through an opening which is not protected by a fire damper.
The fire loading within the affected areas of the plant and the existing automatic manual fire fighting equipment would result in a fire of significantly less intensity and duration than the exposure fire in the above-mentioned tests.
The staff, therefore, has reasonable assurance L
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that the subject ducts would be capable of withstanding the effects of a postulated fire and remain intact.
Nevertheless, quantities of smoke and hot gases may propagate from one area to another through the ductwork.
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However, upon exiting from exhaust grilles outside of the fire area, the j
smoke would be so diffused and the hot gases cooled so as to represent no j
significant threat to redundant shutdown systems that are present.
l Therefore, the presence of fire dampers in the ducts are not necessary to j
assure that one division of shutdown systems is free of fire damage.
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3.4 Conclusion l
The licensee's fire hazard's analyses of non-3-hour rated features within fire area boundaries conform with the guidance issued in Generic Letter 86-10 and is, therefore, acceptable.
4.0 RELATE 3 FIRE PROTECTION ISSUES 4.1 Introduction During the review of the licensee's exemption requests and Appendix R revalidation study, the staff had a number of questions and concerns regarding certain aspects of the fire protection program.
Requests for additional information were transmitted to the licensee on December 4, 1985, March 25 and April 14, 1986.
The licensee responded in letters dated February 19, May 13, and September 9, 1986.
The staff's evaluation of this information is as follows.
4.2 Discussion / Evaluation The staff expressed concern that where certain cables were to be rerouted and/or protected in the primary auxiliary building the modification would not be in accordance with Section III.G.2. of Appendix R.
The licensee responded in the February 19, 1986, submittal that these modifications will be implemented so as to assure that at least one division will remain free of fire damage.
On the basis that the separation / protection of redundant systems is in accordance with Section III.G. of Appendix R or an approved exemption, this issue is considered closed.
The staff expressed concern regarding the licensee's justification for the non-fire-rated features in fire area boundaries.
Specifically, the staff requested additional information about: the location of redundant shutdown systems on either side of these features; technical specification surveillance of fire protection systems that the licensee referenced, and the details of construction of some of the features.
This information was provided by the licensee in the February 19, May 13, and September 9,1986, letters and has been addressed in the staff evaluation in Section 3.0 of this SE.
The staff also expressed concern regarding the adequacy of fire barrier penetration seals.
The licensee responded in the September 9, 1986, letter that penetration seals either:
(1) meet the acceptance criteria of the
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standard fire test for fire barrier penetration seals with conservative margin; or (2) meet the criteria of Generic Letter 86-10; or (3) are not required to satisfy the requirements of Appendix R to 10 CFR Part 50.
On this basis, the staff considers this issue closed.
Finally the staff noted that the licensee had made no definitive conclusion regarding the results of the Appendix R revalidation study.
In response to this concern, the licensee, in the September 9, 1986 letter, identified four conditions in the plant that are different from what had been described in previous. licensee submittals and staff safety evaluations.
These relate to:
fire pump' circuits; yard hydrants; fire protection for the lube oil reservoir and hydrogen seal oil unit; and fire door frames.
The staff has reviewed these conditions and conclude that they are not signifi-cant from a fire safety standpoint.
No other deviations from staff fire protection guidelines and requirements have been identified.
4.3 Conclusion Based on the above evaluation, the staff concerns / questions regarding the fire protection aspects of the licensee's Appendix R revalidation study are considered resolved.
5.0 SER REVISIONS 5.1 Discussion / Evaluation By. letter dated November 14, 1984, the staff granted a number of exemptions to the technical requirements of Section III.G. of Appendix R to 10 CFR Part 50 and evaluated' aspects of the licensee's alternate shutdown capability.
By letters dated September 16, 1985, February 6 and June 10, 1986, the licensee recommended that certain revisions / corrections be'made to the staff's safety evaluation.
The staff evaluated these recommendations and has concluded that the following changes are warranted.
In the SE the staff stated that the licensee has developed alternate shutdown methods under two assumptions:
(1) a fire in the control room will cause loss of function of the entire main control console, but cause damage to only two adjacent sections, and (2) a fire will cause a simultaneous loss of function and complete damage to all auxiliary control panels.
In fact, the assumptions were taken as separate occurrences and were not analyzed simultaneously.
In the November 14, 1984 SE the staff indicated that all openings in the control room are protected by fire-rated doors, dampers or penetration seals.
In fact, certain non-fire-rated features exist in the control room perimeter as delineated in the licensee's September 16, 1985, letter.
These features have been evaluated in Section 3.0 of this safety evaluation.
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_ 12 In the description of fire protection to be provided in the control room, the staff indicated that a halon fire suppression' system was to be installed within the main control board.
In fact, a total flooding halon fire suppression system has been installed to provide protection for the entire
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control room.
'The staff described the boundary construction of the switchgear room as consisting of reinforced concrete walls, floor and ceiling.
This should read as follows:
"The switchgear room is enclosed by sheet metal siding on the north and east walls, concrete blocks on the south wall, part reinforced concrete and part sheet steel backed by concrete block on the west wall, and reinforced concrete for the floor and ceiling." The staff's evaluation of tuon-fire-rated boundary construction is contained in Section 3.0 of this SE.
The staff identified safe shutdown equipment in the switchgear room as including MCC's 51 and 61.
These MCC's are in fact identified as 5-1 and 6-1.
The staff indicated that all cables are coated with a fire retardant material.
In fact, IEEE-383 qualified cables have not been coated.
In the switchgear room, the staff stated that one of the station barriers would be relocated.
This should read one of the station batteries would be relocated.
In the screenwell pumphouse the staff described the boundary construction as consisting of reinforced concrete walls, floor and ceiling.
This should read.as follows:
"The fire area is enclosed by walls and floor of concrete construction below grade and is enclosed by walls and ceilings of sheet metal siding over structural steel framework above grade."
The staff stated that in the residual heat removal (RHR) pump area, safe shutdown systems consist of division A and B RHR pumps, heat exchangers and related cabling.
It should be noted, however, that the licensee has rerouted cable for the B division RHR pump outside of the A division pump cubicle.
Several of the licensee's comments pertain to the safe shutdown and alternate shutdown capabilities and will be specifically addressed in a future staff safety evaluation on these issues.
6.0
SUMMARY
Based on the above evaluation, the staff recommends that the following exemption requests should be granted:
1.
The absence of 8-hour battery powered emergency lighting units in certain outdoor plant locations;
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.The absence of a complete 3-hour fire-rated enclosure around the charging metering pump cubicle; 3.
The absence of fire resistant material for structural steel which supports or is framed ~into certain fire barriers; and t
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The absence of complete separation between power cables in the cable chase located in Fire Area S-9 of the service building (men's locker room).
The staff also concludes that the licensee's exemption requests for.
certain conditions within fire area boundaries are not necessary.
The t
fire hazards. analyses which justify these conditions conform with
. (GL) 86-10 and are,.therefore, acceptable.
7.0 ACKNOWLEDGEMENT Principal Contributor:
D. Kubicki, NRR.
Dated: November 27, 1987 w-_____.-____-___
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