ML20244D968
| ML20244D968 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 05/30/1986 |
| From: | Ahmed N CALSPAN CORP. |
| To: | NRC |
| Shared Package | |
| ML20236D338 | List: |
| References | |
| CON-NRC-03-81-130, CON-NRC-3-81-130 TER-C5506-643, NUDOCS 8606170224 | |
| Download: ML20244D968 (27) | |
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1 TECHNICAL EVALUATION REPORT NRC DOCKET NO. 50-331 FRC PROJECT C5506 NRC LICENSE NO. DPR-49 FRC ASSIGNMENT 36 NRC CONTR ACT NO. NRC-03-81 130 FRCTASK 643 I
EVALUATION OF FIRE PROTECTION EXEMPTION REQUESTS FROM 10CFR50.48 AND APPENDIX R TO 10CFR50 l
IOWA ELECTRIC LIGHT AND POWER COMPANY l
DUANE ARNOLD ENERGY CENTER i
TER-C5506-643 l
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Prepared for Nuclear Regulatory Commission FRC Group Leader:
N. Ahmed Washington, D.C. _20555 NRC Lead Engineer:
J. Stang
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May 30, 1986 g
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This report was prepared as an account of work sponsof9d by An egency of the United States Governenent. Neither the United States Government nor any ac,oney thereof, or any of their enifiay teo makes any warranty, expreseed or impIled, or assumes any legal liability or i
tesponcibility for any third party's use, or the results oltuch use, of any information, appa-ratus, product or process disclosed in this report, or represents that its use by'such third party would rot infringe privately owned rights.
1 Prepared by:
Rev[ wed by:
Approved by:
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'epartmenjt ire r
Date:
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Date:
f/3e f 6'6 Date:. 6"50~
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FRANKLIN RESEARCH CENTiiR
,f DIVISION OF ARVIN/CALSPAN 1
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TER-C5506-643 1
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l CONTENTS J
Section Title Page 1
INTRODUCTION 1
1.l' Purpose of Review 1
1.2 Generic Background 1
1.3 Plant-Specific Background 3
1.4 Review Criteria.
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EVALUATION 5
2.1 General 5
2.2 Reactor Building, Elevation 716 Feet, 9 Inches, Torus Area - Fire Zone 1A Reactor Building, Elevation 737 Feet,
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RHR Valve Room - Fire Zone 2D 6 Inches, Reactor Building, Elevation 786 Feet, 0 Inch, Laydown Area and Reactor Water Cleanup (RWCU) Area - Fire Zones 3A/3B 5
2.3 Reactor Building, Elevation 716 Feet, 9 Inches, Torus Area - Fire Zone 1A 11 2.4 Door 202 (Between Fire Zone 1D and Fire Zone 1A)
Door 203 (Between Fire. Zone 1D and Fire Zone 2B) 12 2.5 Equipment Hatch (Between Fire Zone 3B and Fire Zone 4B) 15 2.6 Fire Dampers FD-010 and FD-012 (Between Fire Zone 1A and Fire Zone 1C)
Fire Damper FD-021 (Between Fire Zone 7A and Fire Zone 7C)
Fire Damper FD-111 (Between Fire Zone 3B and Fire Zone 4A) 17
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2.7 Protection of Exposed Structural Steel for l
Rated Barriers 19 l
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2.8 Reactor Building, Elevation 716 Feet, j
-9 Inches, Northeast Corner' Room - Fire Zone 1G
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J Reactor Building, Elevation 735 Feet, 7-1/2 Inches, I
Southwest Corner Room - Fire Zone 1G i
Reactor' Building, Elevation 757 Feet, 6 Inches, North and South CRD Module Areas - Fire Zones 2A/2B l
l Pump House, Elevation 727 Feet, O Inch to.747 Feet, 6 Inches, Sump and Piping. Area -
Fire Zone 16F Fire Dampers Between Fire Zones 7B/7C,.10B/10A, 10B/10E, 10B/11A, and 10D/10F 20 3
CONCLUSIONS 21 23 4
REFERENCES l
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TER-C5506-643 FOREWORD
-This Technical Evaluation Report was prepared by Franklin Research Center.(FRC) under a contract with the U.S. Nuclear Regulatory Commission (Office of Nuclear Reactor Regulation) for technical assistance in support of NRC operating reactor licensing actions.
The technical evaluation was conducted in accordance with criteria established by the NRC.
Mr. Dan. Arnold contributed to the technical preparation'of this report through a subcontract with Rolf Jensen & Associates, Inc.
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TER-C5506-643 1.
INTRODUCTION l
1.1 PURPOSE OF REVIEW I
This technical evaluation report documents an independent review of exemptions or deviations from the fire protection requirements of 10CFR50.48 or Appendix R to 10CFR50 requested for Iowa Electric Light and Power Company's Duane Arnold Energy Center.
This evaluation was performed with the following objectives, To assess if each exemption request demonstrates an I
o equivalent level of overall protection of plant safe shutdown capability following a disabling fire event To determine the bases for acceptance or denial of each o
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1 To recommend the minimum level of fire protection the o
licensee should provide to achieve an equivalent level of fire protection in case a request is denied.
j 1.2 GENERIC BACKGROUND I
i Following a major fire at the Browns Ferry Nuclear Station in l
March 1975, the NRC established a Specicl Review Group which I
initiated an evaluation of the need for improving the fire i
protection programs at all nuclear power plants.
The group found serious design inadequacies regarding fire protection at Browns Ferry, and its report, " Recommendation Related to Browns Ferry Fire" (NUREG-0050, February 1976), contained over 50 recommendations l
regarding improvements in fire prevention and control in existing facilities.
The report also called for the development of specific i
guidance for implementing fire protection regulations, and for a
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comparison of that guidance with the fire protection program at each i
operating plant.
NRC developed technical guidance from the technical recom-mendations in the Special Group's report, and issued those guidelines as Branch Technical Position (BTP) APCSB 9.5-1 [1].
This guidance did not apply to plants operating at that time Guidance to operating plants was provided later in Appendix A to BTP APCSB 9.5-1
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[2), which, to the extent practicable, relies on BTP APCSB 9.5-1.
The guidance in these documents was also published as Regulatory Guide 1.120 [3).
By early 1980, most operating plants had implemented most of j
the guidelines in Appendix A.
However, the fire protection program has had some significant problems with implementation.
To establish a definitive resolution of these problems in a manner censistent with the general guidelines in Appendix A to the BTP and to assure time 3y compliance by licensees, the Commission issued a proposed fire protection rule and its Appendix R, which was described as l
l setting out minimum fire protection requirements for the unresolved i
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The fire protection features addressed included protection 1 q i
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j TER-C5506-643 of safe shutdown capability, emergency lighting, fire barriers, i
associated circuits, reactor coolant pump lubrication system, and alternate shutdown systems.
On February 17, 1981, the final rule 10CFR50.48 (4) and Appendix R to 10CFR50 [5] became effective, replacing the proposed rule.
Only three of the 15 items in Appendix R were of such safety significance that they should apply to all plants, including those for which alternative fire protection actions had been approved previously by the staff.
These items are protection of safe shutdown capability (including alternate shutdown systems),
emergency lighting, and the reactor coolant pump lubrication system.
Accordingly, the final rule required all reactors licensed to operate before January 1, 1979, to comply with these three items even if the NRC had previously approved alternative fire protection features-in these areas.
However, the final rule is more flexible than the proposed rule because Item III.G now provides three alternative fire protection features which do not require analysis to demonstrate the protection of redundant safe shutdown equipment, and reduces the acceptable distance in the physical separation alternative from 50 feet to 20 feet.
In addition, the rule now provides an exemption procedure which can be initiated by a licensee's assertion that any required fire protection feature will not enhance fire protection safety'in the facility or that such modifications may be detrimental to overall safcty.
In summary,Section III.G is related to fire protection features to ensure that systems and associated circuits used to achieve and maintain safe shutdown are free of damage.
Either fire protection configurations must meet the specific requirements of Section III.G or an alternative fire protection configuration must be justified by a fire hazards analysis.
Generally, the staff will accept an alternative fire protection configuration if:
The alternative ensures that one train of equipment o
necessary to achieve hot shutdown from either the control room or emergency control stations is free of fire damage.
The alternative ensures that fire damage to at least one o
train of equipment necessary to achieve cold shutdown is limited so that it can be repaired within a reasonable time (minor repairs using components stored on the site).
Fire-retardant coatings are not used as fire barriers.
o Modifications required to meet Section III.G would not o
enhance fire protection safety levels above those provided by either existing or proposed alternatives.
Modifications required to meet Section III.G would be o
detrimental to overall facility safety.
Guidance to the industry and the NRC positions on certain requirements of Appendix R is covered by various documents, one of them being Generic Letter 83-33 [6] which has recently been
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TER-C5506-643 superseded by Generic Letter 86-10 [7).
"The interpretations of Appendix R" and "the responses to industry questions," two sections of Reference 7, are written to facilitate industry implementation of Appendix R and represent NRC position on all issues covered.
Following the promulgation of the final rule, licensees have j
requested exemptions and deviations from Appendix R to 10CFR50.
The exemptions and deviations are in the form of a fire hazards analysis.
The NRC is to review exemption requests and associated
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analysis to ensure that each alternative meets the requirements of j
the rule by providing an equivalent level of overall protection of l
plant safe shutdown capability.
Franklin Research Center (FRC) provides technical assistance to the NRC within the context of the following scope of work [8]:
Subtask 1:
Review each exemption request for information deficiencies.
Provide Request for Information (RFI) to resolve such deficiencies.
Subtask 2:
Review and evaluate each exemption or deviation request submitted by the licensees and all additional information provided for conformance with acceptance criteria.
Prepare final Technical Evaluation Report (TER) with recommendations, and their basis in support of granting or denying the exemption / deviation j
request.
1.3 PLANT-SPECIFIC BACKGROUND By letter dated September 28, 1984, the Iowa Electric Light and 3
Power Company (the Licensee) requested exemptions from Section III.G of Appendix R to 10 CFR Part 50 and provided clarifications to exemption requests previously granted.
By letter dated October 31, 1984, the Licensee provided additional information concerning the protection of structural steel in support of their exemption requests.
These exemption requests are the subject of this i
evaluation.
The exemptions, which were previously granted by the NRC and now found unnecessary, are discussed in Section 2.8 of this report.
NRR and Region III fire protection engineers along with the FRC team visited the site on March 12, 1986, to review the areas where the exemptions from Appendix R were requested and to gather additional information requested in the RFI.
The RFI required in satisfaction of Subtask 1 was transmitted to the NRC on February 6, 1986 [9].
The draft TER was transmitted to the NRC on May 1, 1986
[10].
The contents of this final TER reflect the information contained in the Licensee's submittals identified above as well as information collected or provided during the site visit.
It also incorporates / resolves the NRC comments made to date and takes into account additional clarification that the Licensee provided in response to the RFI. - _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _
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TER-C5506-643.
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1 1.4 REVIEW CRITERIA The criteria used in reviewing:the Licensee-submitted exempt' ion
-i requests are based on the following documents:
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Fire Protection Program.for Operating Nuclear Power Plants, 10CFR50.48 H
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Appendix R to 10CFR50 j
- 3.. Standard Review Plan, NUREG-0800, Branch Technical Position (BTP), APCSB 9. 5-1,
" Guidelines.for Fire' Protection for j
Nuclear Power. Plants" 4.
Appendix A to BTP APCSB 9.5-1 I
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Generic Letter 86-10, " Implementation of Fire Protection-
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Requirements," dated April 24, 1986.
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2.
EVALUATION I
2.1 GENERAL This section presents the. review and evaluation of exemptions or deviations from 10CFR50.48 or Appendix R to 10CFR50 requested by the Licensee (Iowa Electric Light and Power Company).
Evaluation of i
exemption requests for each fire area / zone singly or collectively follows a format suggested by the NRC and is arranged in the following subsections:
o Exemption requested o
Discussion o
Evaluation o
Conclusion.
The fire area / fire zone numbering used in this section corresponds to that used in the Licensee's submittal.
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REACTOR BUILDING, ELEVATION 716 FEET, 9 INCHES, TORUS l
AREA - FIRE ZONE 1A l
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o REACTOR BUILDING, ELEVATION 757 FEET, 6 INCHES, RHR VALVE
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l ROOM - FIRE ZONE 2D l
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o REACTOR BUILDING, ELEVATION 786 FEET, O INCH, LAYDOWN AREA i
AND REACTOR WATER CLEANUP (RWCU) AREA - FIRE ZONES 3A/3B i
1 2.2.1 Exemptions Requested l
Exemptions were requested from the specific requireme.nts of I
Section III.G.2.a to the extent that it requires separation of l
cables, equipment, and associated non-safety circuits of redundant 1
safe shutdown trains by a fire barrier with a 3-hour rating.
l 2.2.2 Discussion The Licensee has identified the following fire zones which do not meet the requirements of Section III.G.2.a due to the leck of fire barrier enclosures for safe shutdown valves and valve motor operators and the installation of flexible conduit wrap in an l
l untested configuration.
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1 Exemptions from the specific requirements of Appendix R to I
provide automatic suppression and detection throughout these fire
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l zones were previously requested and granted.
As part of the l
previous exemption requests, the Licensee had committed to provide l
l-hour rated fire wraps on cables in conjunction with spot automatic suppression systems to protect safe shutdown valves.
The proposed modifications were deemed adequate for these zones and the previous exemptions were granted by the NRC.
TER-C5506-643 The Licensee hac proposed to change the previously approved designs to incorporate the use of 3-hour rated cable wrapping for rigid conduit and junction boxes, flexible cable fire wrap for flexible conduit, and to eliminate.the spot automatic suppression systems.
The proposed design change incorporates the use of 3-hour rated cable wrap for rigid conduit and junction boxes.
The material selected is 3-hour rated Thermolag, manufactured by TSI, Inc.
In accordance with Section III.G.2.a of Appendix R, automatic suppression is not required when 3-hour fire rated separation is provided between redundant safe shutdown systems.
Therefore, the specific requirements of Appendix R are met for the 3-hour wrapped circuits for rigid conduit and junction boxes in the identified zones.
The aforementioned 3-hour rated fire wrap is not provided for cables in flexible conduits, the motor operators, or the valves.
Due to the rigid characteristics of the 3-hour rated Thermolag material, the Licensee proposed to protect flexible conduit using a flexible fire wrap manufactured by B&B Insulators under the trade name "Hemyc".
The flexible conduits (varying from 6 to 18 inches in length) are located near the motor operators.
The "Hemyc" material compensates for slight movement or vibration that may cause cracking or failure of the Thermolag fire barrier system.
The "Hemyc" material has been tested and approved for a fire resistance rating of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> based on a given thickness of the wrap.
The "Hemyc" material is installed on the flexible conduits in excess of the thickness of the 1-hour system.
The thickness installed was analyzed by the manufacturer as equivalent to a 3-hour barrier but no testing was performed.
The fire zones for which the above protection is proposed are described below.
2.2.2.1 Reactor Building, Elevatier 716 feet, 9 inches, Torus Area - Fire Zone 1A Fire Zone 1A incorporates the entire torus area on elevation 716 feet, 9 inches.
The area contains safe shutdown equipment from Division I and Division II.
Redundant functions are, with one exception, located on opposite ends of the room and are separated by at least 50 feet.
Refer to Section 3.0 for additional information on the separation of redundant functions within the torus area.
The exception to the separation described above is a pair of Division I RHR valves located near Division II safe shutdown equipment.
Valves MO-2005, MO-2006, and MO-2007 are Division I RHR valves that provide suppression pool cooling water.
They are located in the northwest part of Fire Zone 1A in an area that is primarily a Division II area.
The redundant Division II valves, MO-1932, MO-1933, and MO-1934 are located in the southwest corner of Fire Zone 1A.
There is approximately a 30-foot separation free of intervening combustibles between the redundant trains of valves. _ _ - _ _ _ _ _ - - - _ _ _ _ -
I TER-C5506-643 Division I valves MO-2005 and MO-2007 are required to maintain j
hot shutdown conditions.
Valve MO-2006 is not required to operate for safe shutdown; however, the electrical portion of the valve circuit that provides an interlock signal is required to prevent maloperation of valves MO-2005 and MO-2007 and is protected with 3-hour fire wrap.
If the safety relief valves are used for plant shutdown, suppression pool cooling would be required to achieve and maintain hot shutdown.
The Licensee has stated that suppression pool cooling would not be required before it is possible to manually open the RHR flow path to the pool.
Fire Zone 1A has a floor area of approximately 10,815 square feet.
The fixed combustible loading for Fire Zone 1A is approximately 836 Btu per square foot, which equates to an equivalent fire severity of 0.67 minutes based on the ASTM E-119 time-temperature curve.
Nearly one-half of the combustible loading is assumed to be 500 pounds of wood scaffolding that has since been removed from the zone.
General area fire detection and automatic fire suppression systems are not provided for Fire Zone 1A.
Portable extinguishers and manual hose stations are provided in adjacent zones.
2.2.2.2 React e Building, Elevation 757 feet, 6 inches, RHR Valve Room - Fire Zone 2D Fire Zone 2D is the RHR valve rt m on elevation 757 feet, 6
inches of the reactor building.
The room contains safe shutdown equipment from both divisions.
Division I RHR valves MO-2003 and MO-2004 are required to operate to achieve and maintain cold shutdown.
The valves electrical circuits are protected to assure that spurious oepration will not interfere with safe shutdown.
This protection is provided by the 3-hour rated cable wrap and flexible fire barrier material described previously.
The Licensee has determined that in the event of a fire, the manual closing mechanism for the required valves would remain operable and that the valves would not be required before it would be possible to manually open the RHR flow path during a fire, based on the combustible loading.
By letter dated June 22, 1982, the Licensee indicated that valves MO-1908 and MO-1909, which provide high-low pressure interface isolation for the RHR letdown line, are disconnected during normal plant operation by locking open the MCC power breakers.
Subsequently, the Licensee determined that a fire would not affect both valves and that locking open the MCC power breakers during normal plant operation is not necessary.
In the same letter, the Licensee proposed a procedural change to lock open the MCC power breakers for valves MO-1900 and MO-1902.
These valves provide the high-low pressure interface for the RHR reactor head spray line.
Subsequently, the Licensee has stated that the high-low pressure interface will be maintained by an existing in-line check valve and that locking open the MCC power breakers during normal plant operation is not necessary. _ _ _ _ _ _ - _ - _ _ - _
s TER-C5506-643 I
The combustible loading in this fire zone is low, approximately 425 Btu per square foot, which is equivalent to a fire severity of 0.33 minutes based on the ASTM E-119 time-temperature curve.
The combustibles consist of cable insulation located in two trays at least 10 feet above and to the side of valves MO-2003 and MO-2004.
One cable tray is protected by a 3-hour rated fire wrap which further reduces the combustible material available in the zone.
The other cable tray is located at least 24 feet to the side of MO-2003 and MO-2004.
There is significant spatial separation between the trays, conduit, and motor operators for Division I valves MO-2004 and MO-2005 and the Division II redundant valves MO-1904 and MO-1905.
General area fire detection or automatic fire suppression is not provided for Fire Zone 2D.
Portable extinguishers and manual hose stations are available in adjacent Fire Zones 2A/2B.
2.2.2.3 Reactor Building, Elevation 786 feet, O inch, Reactor Water Cleanup (RWCU) Area - Fire Zones 3A/3B-Fire Zones 3A/3B incorporate the laydown area and the reactor water cleanup (RWCU) area of the reactor building on elevation 786 feet, O inch.
Divisions I and II redundant core spray isolation valves are j
located in Fire Zones 3A/3B.
Each core spray line has a normally open outboard valve and a normally closed inboard valve.
Both valves are located outside of the dry well.
The valves are MO-2135 and MO-2137 for Division II and MO-2115 and MO-2117 for Division I.
Core spray injection valve MO-2137 is required to operat a for safe shutdown, and valve MO-2135 is required to remain in its normally open position.
The valve, motor operator, conduits, and i
cable trays associated with MO-2137 are protected by a enclosure using Thermolag 3-hour rated material.
The conduit to the motor operator for valve MO-2137 is protected by 3-hour rated cable wrap and flexible fire barrier material as previously described.
The electrical circuits for valve MO-2135, including flexible conduit, are also protected to preclude spurious closing of the valve during safe shutdown.
The Licensee has stated that the valve and valve motor operator are not required during shutdown because the valve does not need to change position to support safe shutdown.
The Division II core spray valves are located on the north side of the fire zone, and Division I valves are on the south side.
They are approximately 75 feet apart with several intervening barriers, such as the drywell.
Fire Zone 3A has a fixed combustible loading of approximately 27,000 Btu per square foot, which equates to an equivalent fire severity of 23 minutes based on the ASTM E-119 time-temperature curve.
Fire Zone 3B has a combustible loading of approximately 20,500 Btu per square foot, the equivalent fire severity is approximately 16 minutes.,
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TER-C5506-643 There are 37 ionization smoke detectors on the ceilings throughout Fire Zones 3A/3B.
General area fire suppression is not provided.
Portable extinguishers and manual hose stations are provided within the zones.
2.2.3 Evaluation The above fire zones do not comply with the technical requirements of Section III.G.2.a of Appendix.R due to the lack of fire barrier enclosures for the motor operators of the safe shutdown valves and the installation of flexible conduit wrap which has not been tested for a 3-hour fire resistance rating.
1 Fire Zone 1A contains redundant trains of RHR valves that provide suppression pool cooling.
If the safety relief valves are ever used for plant shutdown, suppression pool cooling would be required to achieve and maintain hot shutdown.
The combustible loading in this fire zone is low, approximately 830 Btu per square foot.
There are no intervening combustibles between the redundant valves which are separated by approximately 30 feet.
The Licensee has stated that suppression pool cooling would not be required before it would be possible to manually open the RHR flow path to the pool, based on the combustible loading in the zone, and that the i
manual closing mechanism for the required valves would remain operable.
Based on the protection of the valve circuits, the low combustible loading, the lack of intervening combustibles between redundant valves, and the capability for manual operation at a time exceeding the duration of a fire, sufficient passive protection exists for Fire Zone 1A to ensure the ability to achieve and maintain safe s.hutdown.
Fire Zone 2D contains safe shutdown equipment for both divisions, specifically Division I RHR valves MO-2003 and MO-2004, which are only required to operate to achieve and maintain cold shutdown.
They are not required to achieve or maintain hot shutdown.
The electrical portion of the valves is protected to assure that spurious operation would not interfere with safe shutdown.
The combustible loading in this fire zone is low, approximately 425 Btu per square foot.
There is significant spatial separation between the redundant Division I and Division II valves.
The Licensee has determined that if a fire occurred in this area, the manual closing mechanisms for the required valve would remain operable.
Based on the protection of the valve circuits, the low combustible loading, the spatial distance between redundant valves, and the capability for manual operation at a time exceeding the duration of an expected fire, sufficient passive protection exists for Fire Zone 2D to ensure the ability to achieve and maintain safe shutdown.
Fire Zones 3A/3B contain Division I and Division II redundant core spray isolation valves.
core spray injection valve MO-2137 is required to operate for safe shutdown, and valve MO-2135 is required to remain in its normally open position.
As described in Section 2.2.3, the valve, motor operator, conduits, and cable trays associated with MO-2137 are protected by a 3-hour rated enclosure.
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TER-C5506-643 j
Th m fere, the specific requirement of Section III.G.2.a of l
Appendix nas been met for this valve, except for the flexible j
conduit tt the motor operator, which is protected by the flexible fire barrier material.
The electrical circuits for valve Mo-2135 are protected to preclude spurious closing of the valve during safe shutdown.
This protection is provided by 3-hour cable fire wrap and flexible fire barrier material as described previously.
Ionization smoke detectors are provided throughout Fire Zones 1
3A/3B.
These detectors alarm in the main control room.
Line-type j
heat detectors are provided in cable trays protected with 3-hour fire wrap.
If a fire occurs, it should be detected in its incipient stage and alarmed in the main control room.
The fire brigade will be dispatched to the fire zone to extinguish the fire using the portable extinguishers and manual hose stations provided.
Until the i
fire is extinguished, the 3-hour rated cable wrap, the flexible J
cable wrap material, the spatial separation between redundant valves, and the ionization smoke detectors all provide sufficient
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protection to ensure the ability to achieve and maintain safe i
shutdown.
2.2.4 Conclusion Based on the above evaluation, it is concluded that the
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existing fire protection combined with the proposed modifications
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provide a level of fire protection equivalent to the technical i
requirements of Section III.G.2.a of Appendix R.
Therefore, the exemption requests for the aforementioned valve motor operators and j
flexible conduit wrap can be granted.
i 2.3 REACTOR BUILDING, ELEVATION 716 FEET, 9 INCHES, TORUS AREA - FIRE ZONE 1A 2.3.1 Exemption Rectuested An exemption was requested from the specific requirements of Section III.G.2.b to the extent that it requires an automatic fire l
suppression and fire detection system throughout the fire zone.
l 2.3.2 Discussion i
i The Licensee has identified Fire Zone 1A as not meeting the requirements of Section III.G.2.b because automatic fire suppression j
and detection systems are not installed throughout the zone.
Fire Zone 1A incorporates the entire torus area on elevation f
716 feet, 9 inches.
The torus area contains Division I and Division l
II safe shutdown equipment.
Redundant functions are located on cpposite sides of the room except for safe shutdown valves and 1
circuits described in Section 2.2.
The divisions of cables and equipment are generally segregated within Fire Zone 1A such that Division II occupies the northwest half of the zone and Division I occupies the southeast half.
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TER-C5506-643 is over 50 feet of spatial separation between the divisions with 4
large noncombustible equipment in between the redundant areas.
Fire Zone 1A has a floor area of approximately 10,815 square feet.
The fixed combustible loading of Fire Zone 1A is approximately 836 Btu per squa 1 foot, which is equivalent to a fire severity of 0.67 minute.
Nea; y one-half of the combustible loading is assumed to be 500 pounds of wood scaffolding that has since been removed from the zone.
An exemption was previously requested and granted from the j
requirements to provide automatic suppression and detection 1
throughout Fire Zone 1A.
The exemption was approved based on the extremely low fire loading and significant spatial separation with no intervening combustibles between the redundant divisions.
As i
part of the previously approved exemption request, the Licensee committed to provide 1-hour rated fire wrap in conjunction with spot i
automatic suppression system to protect certain valves.
Changes to this commitment are discussed in Sections 2.2.2.1 and 2.2.3.
I 2.3.3 Evaluation The fire protection for Fire Zone 1A does not comply with the technical requirements of Section III.G.2.b of Appendix R because automatic fire suppression and detection systems are not installed l
throughout the area.
l Fire Zone 1A contains both Division I and Division II safe shutdown equipment.
A major factor that reduces the fire risk in this zone is that passive protection is afforded for the redundant divisions by over 50 feet of spatial separation between the divisions, by the central placement of the drywell, and by the existence of large noncombustible equipment.(torus) between the redundant cables.
Until the fire it extinguished, the separation and intermediate barriers between safe shutdown systems, the lack of intervening combustibles, and the low combustible loading of Fire Zone 1A all would provide sufficient passive protection to ensure that one shutdown division would remain free of fire damage.
2.3.4 Conclusion Based on the above evaluation, it is concluded that the existing fire protection in conjunction with modifications described in Section 2.2 provide a level of fire protection equivalent to the technical requirements of Appendix R.
Therefore, the exemption request from the requirement for fixed fire suppression and detection systems throughout the fire zone can be granted. - _ _ _ _ _ _ _
1 TER-C5506-643 i
2.4 o
DOOR 202 (BETWEEN FIRE ZONE 1D AND FIRE ZONE 1A) o DOOR 203 (BETWEEN FIRE ZONE 1D AND FIRE ZONE 2B)
I 2.4.1 Exemption Requested J
Exemptions were requested from the requirements of Section III.G.2.a to the extent that it requires the separation of cables, l
equipment, and associated non-safety circuits of redundant trains by i
a fire barrier with a 3-hour fire resistance rating.
2.4.2 Discussion l
The Licensee has identified that Fire Zones 1A, 1D, and 2B do not meet the requirements of Section III.G.2.a because unlabeled watertight doors are installed in the zones' boundaries.
Each fire zone is located on elevation 716 feet, 9 inches of the reactor l
l building.
Fire Zone 1A is the torus room, Zone 1D is the RHR corner l
l room, and Zone 2B is stair 4.
The boundariec between these zones serve as III.G.2.a fire barriers.
Doors 202 and 203 are watertight doors in the boundaries I
separating these fire zones.
In a letter dated January 10, 1783, l
the Licensee stated that door 202 did not have a fire rated label, i
that the manufacturer currently manufactures an identical door with a steel flange, which is rated as a 3-hour fire door, and that the existing door would be modified in accordance with the manufacturer's instructions to upgrade the door to be 3-hour rated.
In the same letter, door 203 was characterized as a 1-1/2 hour rated l
stairwell door between Zone 1D and Zone 2B.
An exemption was previously requested and granted for door 203 as being sufficiently rated for the boundary between Fire Zone 1D and Fire Zone 1B.
However, it is the same as door 202 and is unlabeled.
Therefore, the Licensoe decided to modify both watertight doors to upgrade them to 3-hour rated doors.
Subsequent to this decision, it was discovered that the modification required to upgrade the doors to 3-hour rated would degrade the watertight capability.
The 3-hour rated door was fire tested with a gasket; however, the fire test resulted in flame propagation through the door via the gasket material at 21 minutes into the test.
Because of the flame propagation, the door would not be approved for a 3-hour rating if the gasket material is used.
Therefore, to upgrade the doors to 3-hour ratings would require removal of the gaskets, thereby degrading the watertightness of the door.
Door 202 separates the RHR corner room (Zone 1D) from the torus I
room (Zone 1A).
Door 203 separates the RHR corner room (Zone 1D) from stair 4 (Zone 2B).
The overall combustible loading for the torus room (Fire Zone 1A) is low, corresponding to an equivalent fire severity of 4 - _ _ _ _ _ _ _ _ _ _ _
TER-C5506-643 j
)
minutes.
The closest installed combustibles to door 202 in the torus room are cable trays located 25 feet west of the door and more than 20 feet above the floor.'
Door 202 is normally locked and is not used for access.
Transient combustibles are found near the door.
The equivalent fire severity for the RHR corner room (Fire Zone 1D) is approximately 11 minutes.
The combustibles consist of approximately 32 gallons of lube oil contained in equipment at the floor level and 440 pounds of cable insulation.
The closest fixed i
combustible to doors 202 and 203 in Fire Zone 1D is a cable tray-along the south wall of the zone, approximately 8 feet away from i
door 202 and 13 feet above the floor.
The lube oil is located in pumps approximately 25 feet east of door 202 and is separated from i
door 203 by an 8-foot-high shield wall.
Transient combustibles associated with a dressout area are typically located within the I
i shield wall area adjacent to door 203 in Fire Zone 1D.
i l
There are no combustibles on Fire Zone 2B's side of door 203 l
since stair 4 is devoid of fixed combustibles and is maintained free 1
of transient combustibles.
l The RHR corner room (Fire Zone 1D), which accesses both doors, is provided with ionization smoke detectors which alarm in the main control room.
i i
The original gasket material provided for the watertight doors was manufactured of neoprene and ignited 21 minutes into the fire test.
This material was replaced by the Licensee with fire-retardant gasketing material which does not react to immediate f)ame or burn freely, and is capable of maintaining the required watertight integrity.
l 2.4.3 Evaluation The above fire zones' boundaries do not comply with the technical requirements of Section III.G.2.a of Appendix R bec ause 3-hour rated fire doors are not installed.
Watertight doors are installed in lieu of 3-hour rated fire doors.
The combustible loading in areas adjacent to each of the installed watertight doors is low.
The combustibles consist of cable insulation, lube oil contained in equipment, and transient combustibles associated with a dressout area.
Ionization smoke detectors are provided in Fire Zone 1D which is adjacent to the watertight doors.
These detectors will detect a l
fire in Zones 1D, lA, or 2B that challenges the watertight doors' boundaries.
The alarms for these detectors are annunciated in the main control room.
The fire brigade will be dispatched and would extinguish the fire manually using the hose lines or portable f
extinguishers provided.
Based on their similarity 'o tested and approved fire t
doors, watertight door 202 and 203 exhibit substantial fire ___
TER-C5506-643 resistance characteristics.
The doors have been modified in accordance with the manufacturer's instructions to upgrade them to be 3-hour rated, except for the provision of the gasket material.
The gasket material originally supplied with the door has been replaced with gasket material with improved flame / heat resistance characteristics.
There are no combustibles on both sides of either door that would present a flame propagation path through the boundary.
The' substantial fire resistance of the doors, the lack of combustibles near both sides of each watertight door, the low combustible loading of adjacent fire zones, and the fire detection provided in Fire Zone 1D will provide sufficient protection to ensure that one shutdown division would remain free of fire damage.
Also, there is reasonable assurance that a fire in the above zones would not propagate through doors 202 or 203.
2.4.4 Conclusion Based on the above evaluation, it is concluded that the existing fire protection provides a level of protection equivalent to the technical requirements of Section III.G.2.a of, Appendix R.
Therefore, the exemption request for the aforementioned watertight doors can be granted.
2.5 EQUIPMENT HATCH BETWEEN FIRE 20NE 3B AND FIRE ZONE 4B 2.5.1 Exemption Requested An exemption was requested from the requirements of Section III.G.2.a to the extent that it requires the separation of cables, equipment, and associated non-safety circuits of redundant trains by a fire barrier with a 3-hour fire resistance rating.
2.5.2 Discussion The Licensee has identified that the fire barrier between Fire Zone 3B and Fire Zone 4B does not meet the requirements of Section III.G.2.a because of an open hatch.
Fire Zone 4A, on elevation 812 feet, O inch, contains both trains of control room heating, ventilation, and air conditioning (HVAC) chillers.
This equipment is located in the northern portion of Fire Zone 4A.
Fire Zone 4A is connected to Zone 4B by a narrow corridor.
Fire Zone 4B does not contain any safe shutdown equipment or cables.
However, Zone 4B does communicate with combined Fire Zones 3A/3B, on elevation 786 feet, O inch, through a large open vertical equipment hatch in the floor of Zone 4B.
Fire Zones 3A/3B contain alternate shutdown capability (ASC) panels and equipment that is used should a control room evacuation be required.
Fire Zone 4A is separated from Fire Zone 3A by a 3-hour fire rated floor / ceiling assembly.
Fire Zone 4B is open to Fire Zone 3B through the 19-foot by 19-foot open equipment hatch.
The equipment hatch is bounded on the north and south by concrete block and metal - _ _ _ _ - - _ _ _ _ _ - _ _ _
1 TER-C5506-643 siding walls which form part of the radioactive laundry area.
The west side of the equipment hatch is bounded by the reactor building wall, which leaves the east side of the hatch as the only communication path from Zone 3B to Zone 4B.
l An autcmatic deluge spray system is installed over the hatch at the ceiling of Fire Zone 3B.
The system automatically actuates from L
detectors at the hatch's perimeter.
The deluge system can be manually actuated in Fire Zone 3B.
J In addition, a partial wet-pipe sprinkler system is installed l
in Fire Zone 4B covering the radioactive laundry areas and corridor adjacent to the hatchway.
Sprinkler protection is also provided in 1
the area of the redundant HVAC chillers.
The total fire load for Fire Zone 4B, including transient combustibles, is 4,307 Btu per square foot, which is equivalent to a fire severity of 3.2 minutes.
l The total combustible load for Fire Zone 4A is 7,381 Btu per j
i square foot, resulting in an equivalent fire severity of 5.4 i
minutes.
The distance from the equipment hatch to the cables and 3
equipment used for alternate shutdown in Fire Zone 3A exceeds 70 feet.
There are no combustibles which pass through the hatch's opening.
Approximately 25 feet of the distance between the chillers and the hatch is protected by automatic sprinklers.
Detection is available throughout Zones 3A/3B and 4A/4B.
The Licensee previously requested and was granted an exemption from the full zone suppression requirement regarding protection of the redundant control room HVAC equipment in Zone 4A, considering there is a fire in Zone 4A.
Subsequently, the Licensee has i
identified the following scenario:
A fire starts in Zones 3A/3B and disables auxiliary shutdown capability.
This is acceptable since no control room evacuation is required and shutdown can be accomplished fro.3 the control room.
l The fire propagates through the open hatch to Zone 4B, then propagates to the HVAC area in the northern part of Zone 4A, disabling the main control room HVAC chillers, thereby potentially affecting shutdown from the control room.
The Licensee has requested an exemption for this scenario due to the open hatch.
2.5.3 Evaluation The fire zone boundary between Zone 3B and Zone 4B does not meet the requirements of Section III.G.2.a because of the open hatch..
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TER-C5506-643 l
l With the open hatch, a fire could damage ASC panels / equipment in Fire Zone 3B and the control room chillers in Fire Zone 4A if it l
propagated through the hatch.
However, the combustible loading in these zones is low, consisting primarily of cable insulation in trays.
There are no combustibles which pass through the hatch's opening.
l Smoke detectors are provided throughcut Zones 3A/3B and 4A/4B.
I Because of the detectors, a fire in these areas will be detected in its incipient stage.
The alarms from the detectors are annunciated in the main control room.
The fire brigade will be dispatched and will extinguish the fire manually using hose lines or portable extinguishers provided.
Areas in these fire zones containing significant' combustibles, l
and the area adjacent to the hatch opening and the redundant control room chillers are provided with partial wet-pipe sprinkler systems.
An automatic deluge spray system is installed over the hatch at the ceiling of Zone 3B.
There are no combustibles which pass l
through the hatch's opening.
Until the fire is extinguished by the fire brigade or automatic l
l suppression systems, the spatial separation between the control room I
chillers and the ASC area, low intervening combustibles, the low combustible loadings, the deluge water spray and wet-pipe sprinkler systems, and the general area fire detection will provide sufficient protection to ensure that the control room chillers or the ASC equipment area would remain free of fire damage.
There is also reasonable assurance that a fire in the above fire zones will not prevent a safe plant shutdown.
2.5.4 Conclusion Based on the above evaluation, it is concluded that the l
existing fire protection features provide a level of protection I
equivalent to the technical requirements of Section III.G.2.a of Appendix R.
Therefore, the exemption request for the aforementioned l
hatch between Fire Zone 3B and Fire Zone 4B can be granted.
2.6 o
FIRE DAMPERS FD-010 AND FD-012 (BETWEEN FIRE ZONE 1A AND FIRE ZONE 1C) o FIRE DAMPER FD-021 (BETWEEN FIRE ZONE 7A AND FIRE ZONE 7C) o FIRE DAMPER FD-lli (BETWEEN FIRE ZONE 3B AND FIRE ZONE 4A) l l
2.6.1 Exemption Requested Exemptions were requested from the requirements of Section III.G.2.a to the extent that it requires the separation of cables, equipment, and associated non-safety circuits of redundant trains by a fire barrier with a 3-hour fire resistance rating.
TER-C5506-643 2.6.2 Discussion The Licensee has identified the following duct penetrations which do not meet the requirements of Section III.G.2.a because tho installation of 3-hour rated fire dampers are not in accordance with the manufacturer's installation instructions.
For clarity, fire damper numbers used in the Licensee's submittal are used in this discussion.
2.6.2.1 Fire Dampers FD-010 and FD-012 Fire dampers FD-010 and FD-012 are installed on the surface of the fire barrier wall between Fire Zone 1A and Fire Zone 1C.
The dampers are two section, vertical-type dampers with a mullion separating the sections.
The surface mounted installation consists of a 3-hour rated fire damper installed in an 8-inch channel frame attached to the perimeter of the penetration.
The frame is protected with 3-hour rated fire resistive material (Thermolag).
Proper expansion clearances are provided between the fire damper, the 8-inch channel frame, and the damper retaining angles.
Since the duct transition penetrates the wall at an angle, the conventional fire damper installation within the wall is not feasible.
The Licensee has stated that single-section dampers have been successfully tested in a surface mounted configuration similar to that used for the two-section dampers.
2.6.2.2 Fire Dampers FD-021 and FD-111 Fire dampers FD-021 and FD-111 are installed within fire barriers in accordance with the manufacturer's installation instructions.
The dampers are retained within the fire barrier by retaining angles installed on the fire damper sleeve.
Due to the close proximity of a perpendicular wall on one side of each of the fire damper penetrations, the installation of one of the eight specified retaining angles is not possible.
The Licensee states that testing of this situation has been performed successfully according to the manufacturer's report.
However, it is not clear that testing for the specific physical configurations of fire dampers FD-021 and FD-111 has been performed.
2.6.3 Evaluation The aforementioned fire dampers do not comply with the technical requirements of Section III.G.2.a of Appendix R because the dampers are not installed in accordance with the manufacturer's installation instructions.
Successful fire tests of similar configurations to those used by the Licensee have been performed by the damper manufacturer.
The duct that contains these dampers is of substantial stee:t construc- - _ _ _ _ _ - _ _ _
TER-C5506-643 tion which reduces the probability of fire propagation through the penetrations.
There is also reascnabla assurance that a fire would not propagate between fire zones through the referenced fire damperc and prevent a safe plant shutdown.
Review of the damper installations indicates that the installed dampers provide protection equivalent to dampers installed in accordance with the manufacturer's instructions.
2.6.4 Conclusion Based on the above evaluation, it is concluded chat the existing fire protection features provide a level of protection equivalent to the technical requirements of Section III.G.2.a of Appendix R.
Therefore, the exemption requests for fire dampers FD-010, -012, -021, and -111 can be granted.
2.7 PROTECTION OF EXPOSED STRUCTURAL STEEL FOR RATED BARRIERS 2.7.1 Exemptions Requested Exemptions were requested from Section III.G.2.a to the extent that it requires structural steel forming part of or supporting required fire barriers be protected to provide a fire resistance equivalent to that of the required barrier.
2.7.2 Discussion The Licensee has identified several areas which do not meet the requirements of Section III.G.2.a because structural steel forming part of or supporting required fire barriers is not fireproofed.
The Licensee met with the NRC staff on September 5, 1984, to discuss several exemptions from the requirement to protect structural steel forming part of or supporting required fire barriers.
The basis for the proposed exemptions was that the peak temperature of the structural steel would not exceed 1100 F when exposed to fires postulated in the Licensee's fire hazards analysis.
The structural and steel associated with the fire barriers and found g
to exceed 1100 F has been fireproofed.
During the meeting, the NRC staff indicated that the peak temperature calculations performed should explicitly model local temperature effects due to the spatial relationship of combustible materials and structural steel, flame plume effects, and fire zone ventilation.
By letter dated October 31, 1984, the Licensee submitted an evaluation of the temperature response of structural steel based on peak temperature calculations.
The evaluation uses a mathematical model to calculate the potential time-temperature profile of fires in each fire zone.
Two fire modeling. methodologies are employed in the analysis.
A fully developed enclosure fire model is used to evaluate the average gas mixture temperature in the enclosure; _ _ _ _ _ _ _ _ _ _
TER-C5506-643 secondly, local heating effects on steel members are as sessed by flame and fire plume impingement calculations.
These medels formed the basis of the structural steel evaluation.
It the peak temperature calculations show that ghe time-temperature profile in an area will exceed 1100 F within 3
)
hours, additional evaluation is performed to calculate the corresponding temperature response of the supgorting structural steel.
If the steel temperature exceeda 1100 F within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, the Licensee has committed to protect the steel with 3-hour ratgd fireproofing.
If the steel temperature does not reach 1100 F, an exemption from the requirements to provide structural steel fireproofing is requested.
The results of the analysis performed indicated that several specific structural steel membe55 did n t f*il> i * < did " t "tt*in the failure temperature of 1100 F when analyzed under the localized neating effects model and the enclosure fire model.
Those that l
failed would be fireproofed.
The results of the analysis are summarized on Tables 1 and 2 of the Licensee's October 31, 1984 letter.
The peak steeg temperature attained in certain fire zones was reduced below 1100 F by reducing or controlling the combustible loading within the area.
The Licensee has committed to institute operational procedures to ensure that the combustible load limit assumed by the calculations is not exceeded.
2.7.3 Evaluation The fire zones' boundaries identified in Table 1 of the Licensee's October 31, 1984 letter do not comply with the technical requirements of Section III.G.2.a of Appendix R because structural steel forming part of or supporting fire barriers is not fireproofed.
The Licensee has performed peak temperature calculations that model local temperature effects due to the spatial relationship of combustible material to structural steel, flame plume effects, and fire zone ventilation.
The overall approach described and implemented by the Licensee is technically sound.,
The fire models employed have been documented, and the methodology employed represents a compromise between accuracy in a real fire environment simulation and practicality of implementation.
The review indicates that this compromise results in a conservative evaluation.
The approach used by the Licensee is based on Limerick's methodology, which has been previously submitted on.other dockets and approved.
The principal concern was that, because of the lack of fireproofing on structural steel, a fire could lead to the structural failure of the steel and subsequently the required fire barrier.
However, based on the Licensee's evaluation, there is - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - - _. __
m t
TER-C5506-643 l
l 0
reasonable assurance that a fire in the identified fire zones would i
not affect required structural steel fire zones' boundaries and
{
prevent a safe plant shutdown.
l Q
2.7.4 Conclusion j
t Based on the above evaluation, it is concluded that the results i
of the structural steel analysis provide a level of fire protection equivalent to the technical requirements of Section III.G.2.a of l
Appendix.R.
Therefore, the exemption requgsts from fireproofing i
structural steel which does not reach 1100 F can be granted.
2.8 o
REACTOR BUILDING, ELEVATION 716 FEET, 9 INCHES, NORTHEAST CORNER ROOM - FIRE ZONE 1C i
)
o REACTOR BUILDING, ELEVATION 735 FEET, 7-1/2 INCHES, SOUTHWEST CORNER ROOM - FIRE ZONE 1G o
REACTOR BUILDING, ELEVATION 757 FEET, 6 INCHES, NORTH AND l
SOUTH CRD MODULE AREAS - FIRE ZONES 2A/2B o
PUMP HOUSE, ELEVATION 727 FEET, O INCH TO 747 FEET, 6 l
INCHES, SUMP AND PIPING AREA - FIRE ZONE 16F o
FIRE DAMPERS BETWEEN FIRE ZONES 7B/7C, 10B/10A, 10B/10E, i
10B/11A, AND 10D/10F 2.8.1 Discussion By letters dated December 19, 1983, and April 26, 1983, exemptions were granted from the requirements of Appendix R,Section III.G for the above zones.
The exemptions were to the extent that Appendix R requires full zone automatic suppression, 1-hour fire protection of redundant cable and equipment, or 3-hour fire dampers in boundaries between fire s.ones.
Subsequently, the Licensee elected to protect the necessary safe ' shutdown equipment with alternative modifications.
The Licensee has stated that the alternative modifications are in full compliance with Appendix R,Section III.G.2.
Therefore, the exemption requests previously granted are no longer, necessary.
2.8.2 Evaluation and Conclusion According to the Licensee's statement, the above zones meet the requirements of Appendix R; therefore, no evaluation is necessary.
TER-C5506-643 3.
CONCLUSIONS i
This section is provided to consolidate the results of the evaluation contained in Section 2 concerning the exemptions requested by the Licensee from the requirements of Section III.G of
]
Appendix R to 10CFR50 for Duane Arnold Energy Center.
It is not meant as a substitute for the specific conclusions reached in the various subsections of Section 2 for which the reader is referred to specific subsections.
Based on the evaluation, the level of fire protection in th-areas / zones listed below is equivalent to the technical requireme.,ts of Section III.G of Appendix R; therefore, the Licensee's request for exemption in these areas / zones can be granted:
1.
o Reactor Building, Elevation 716 feet, 9 inches, Torus Area - Fire Zone 1A o
Reactor Building, Elevation 757 feet, 6 inches, RER Valve Room - Fire Zone 2D o
Reactor Building, Elevation 786 feet, O inch, Laydown Area and Reactor Water Cleanup (RWCU) Area - Fire Zones 3A/3B Lack of fire barrier enclosures for valves and valve motor operators in the untested installation of flexible conduit wrap.
Refer to Section 2.2 for additional details.
2.
Reactor Building, Elevation 716 feet, 9 inches, Torus Area - Fire Zone 1A Lack of automatic fire suppression systems throughout the zone.
Refer to Section 2.3 for additional details.
3.
o Door No. 202 (Between Fire Zone 1D and Fire Zone 1A) o Door No. 203 (Between Fire Zone 1D and Fire Zone 2B)
Ncn-rated watertight doors installed in barriers between redundant trains of cables and equipment.
Refer to Section 2.4 for additional details.
4.
Equipment Hatch Between Fire Zone 3B and Fire Zone 4B Open hatch exists between redundant safe shutdown trains of cables and equipment.
Refer to Section 2.5 for additional details.
5.
o Fire Dampers FD-010 and FD-012 (Between Fire Zone 1A and Fire Zone 1C) o Fire Damper FO-021 (Between Fire Zone 7A and Fire Zone 7C). _ _ _ - _ _ - _ _ _ _ - _ - _ _ -
I TER-C5506-643 4
o ' Fire Damper'FD-111 (Between Fire Zone 3B and Fire Zone 4A)
Installation of 3-hour rated fire dampers are not in accordance with the manufacturer's installation instructions.
Refer to Section 2.6 for additional details.
1 1
6.
Protection of Exposed Structural Steel for Rated Barriers l
I Lack of fireproofing for structural steel forming a part of or supporting fire barriers between redundant trains of cables and equipment.
Refer to Section 2.7 for additional information.
1 The level of fire safety in the zones listed below complies l
with the technical requirements of Section III.G of Appendix R.
l l
Therefore, the previously approved exemption requests for these zones are no longer required.
Refer to Section 2.8 for additional information.
1 o
Reactor Building, Elevation 716 feet, 9 inches, Northeast Corner Room - Fire Zone 1C o
Reactor Building, Elevation 735 feet, 7-1/2 inches, Southwest Corner Room - Fire Zone 1G o
Reactor Building, Elevation 757 feet, 6 inches, North and South CRD Module Areas - Fire Zones 2A/2B
~
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o Pump House, Elevation 727 feet, O inch to 747 feet, 6 l
l inches, Sump and Piping Area - Fire Zone 16F o
Fire Dampers Between Fire Zones 7B/7C, 10B/10A, 10B/10E, i
10B/llA, and 10D/10F l
l
. i
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1 TER-C5506-643 I
I l
4.
REFERENCES l
1.
BTP APCSP 9.5-1 " Fire Protection Program," July 1981 (Standard
]
Review Plan, NUREG-0800).
]
2.
Appendix A to BTP APCSP 9.5-1, " Guidelines for Fire Protection-
)
for Nuclear Power Plants Docketed Prior to July 1, 1976,"
August 23, 1976.
3.
RegOlatory Guide 1.120, " Fire Protection Guidelines for Nuclear Power Plants," November 1977.
j 4,
10CFR50, " Fire Protection Program for Operating Nuclear Power Plants," November 19, 1980.
5.
Appendix R to 10CFR50, " Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979," November 19, 1980.
l i
6.
Generic Letter 83-33, "NRC Position on Certain Requirements of 1
Appendix to 10CFR50," October 19, 1983.
7.
Generic Letter 86-10, " Implementation of Fire Protection Requirements," April 24, 1986.
8 Final Work Assignment No. 36, transmitted by M.
Carrington l
(NRC) to Dr.
S.
Pandey (FRC) on July 17, 1985.
9.
Requests for Information (RFI), transmitted by N. Ahmed (FRC) to J.
Stang (NRC) on February 6, 1986.
10.
Draft TER, transmitted by N. Ahmed (FRC) to J.
Stang (NRC) on May 1, 1986.
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