Text

Fire Protection Review Rept Evaluation
	ML20245F047
Person / Time
Site:	Susquehanna
Issue date:	06/22/1989
From:	; SCIENCE APPLICATIONS INTERNATIONAL CORP. (FORMERLY
To:	; NRC
Shared Package
ML17156B291	List: ML20245F047;
References
	CON-NRC-03-87-029, CON-NRC-3-87-29 SAIC-89-1122, TAC-59647, TAC-59648, NUDOCS 8906280026
	Download: ML20245F047 (53)
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SUSQUEHANNA UNITS 1 AND 2 FIRE PROTECTION REVIEW REPORT EVALUATION TAC No. 59647/48 l

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SUSQUEHANNA UNITS 1 AND 2 l FIRE PROTECTION REVIEW REPORT EVALUATION j TAC No. 59647/48 I l 4 .

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June 22, 1989 s

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Prepared for:

i U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Contract NRC-03-87-029 Task Order No. 23 1710 Goodndge Dnve. PO. Box 1303, M: Lean. Vorg<nia 22102 (703) 821-4300 ome sac own na ecau, s o,,on two,x se,no, care vi,,a,e a, we , as sege es osa a,oga or,,w rom av o se om serw ro r.csr

s' i 4 L TABLE OF CONTENTS I- Section fagg l

1.0 INTRODUCTION

. . . . . . . . . . . . . . . . . . . . . . I 1.1 PURPOSE OF REVIEW ...................

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1.2 GENERIC BACKGROUND . . . . . . . . . . . . . . . . . . . I 1.3 ' PLANT-SPECIFIC BACKGROUND ............... 2 2.0 EVALUATION . . . . . . . .-. . . . . . . . . . . . . . . 4 2.1 BATTERY ROOM EXHAUST FANS ............... 4 2.2 SUPPRESSION POOL TEMPERATURE INDICATION . . . . . . . . . 6 2.3 NON-RATED FIRE DOORS . . . . . . . . . . . . . . . . . . 7 2.4 WRAPAROUND AREA .................... 9 2.5 PARTIAL RATING OF WALLS AND FLOOR / CEILING ....... 11 2.6 NON-FIREPR00 FED STRUCTURAL STEEL . . . . . . . . . . . . 12 2.7 FIRE SPREAD LIMITATIONS ................ 16 2.8 FIRE AREA D-3 BOUNDARIES . . . . . . . . . . . . . . . . 18 2.9 HVAC PENETRATIONS REACTOR BUILDING FIRE WALLS ..... 19 2.10 FIRE BARRIERS WITHOUT FIRE DAMPERS IN VERTICAL VENTILATION DUCT PENETRATIONS ................- ... 21 2.11 ESSENTIAL REDUNDANT RACEWAY PROTECTION . . . . . . . . . 22 2.12 REACTOR BUILDING FIRE ZONES WITHOUT FIRE DETECTION . . . 24 2,13 FIRE AREAS IN THE CONTROL STRUCTURE WITHOUT FIRE SUPPRESSION ...................... 26 2.14 EMERGENCY SWITCHGEAR ROOM COOLING SYSTEM COMPONENTS -

INSUFFICIENT SPATIAL SEPARATION ............ 27 2.15 KA0 WOOL SYSTEM AS AN ACCEPTABLE l-HOUR BARRIER WRAP .. 28 2.16 INCOMPLETE FIRE SUPPRESSION AND FIRE DETECTION IN DIESEL GENERATOR FIRE AREAS . . . . . . . .......... 29 2.17 PENETRATION SEALS - CONDUITS . . . . . . . . . . . . . . 30 2.18 CONTROL STRUCTURE - FIRE ZONES WITHOUT FIRE DETECTION AND/OR FIRE SUPPRESSION ................ 31 ii

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TABLE OF CONTENTS (Continued) itc.119.D fist 2.19 CONTROL STRUCTURE - FIRE AREA CS-9. PARTIAL FIRE SUPPRESSION ...................... 32 2.20 AUTOMATIC FIRE SUPPRESSION IN FIRE ZONE 2-5D . . . . . . 33 2.21 AUTOMATIC FIRE SUPPRESSION AND INTERVENING COMBUSTIBLES IN FIRE ZONE I-3A ................... 35 2.22 AUTOMATIC FIRE SUPPRESSION AND INTERVENING COMBUSTIBLES IN FIRE ZONE 2-3B-N .................. 36 2.23 NUCLEAR BOILER INSTRUMENTATION IN FIRE ZONE I-5A-S NUCLEAR BOILER INSTRUMENTATION IN FIRE ZONE 2-5A-N . . . 37.

2.24 CATEGORY I COMPONENTS IN FIRE ZONES I-3C-W AND 2-3C-W . 39 2.25 CONTROL STRUCTURE HVAC SYSTEM COMPONENTS - FIRE ZONES l 0-29B AND 0-30A .................... 40 1 2.26 0UTSIDE AREAS - LACK OF SEPARATION OF SAFE SHUTDOWN COMPONENTS AND ELECTRICAL CABLES . . . . . . . . . . . . 42 2.27 REACTOR COOLANT MAKEUP AND DEPRESSURIZATION SYSTEMS .. 43 2.28 CONTROL STRUCTURE CHILLER ESW VALVES - INSUFFICIENT FIRE BARRIER, FIRE ZONE I-3A ................ 44 2.29 CONTROL ROOM RAISED FLOOR AND CONTROL STRUCTURE CABLE CHASE FIRE PROTECTION ................. 45 2.30 SAFE SHUTDOWN ANALYSIS . . . . . . . . . . . . . . . . 47

3.0 CONCLUSION

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1.0 INTRODUCTION

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1.1 PURPOSE OF REVIEW This Technical Evaluation Report (TER) documents an independent review of Revision 3 of the Fire Protection Review Report for Susquehanna Steam Electric Station Units 1 and 2 submitted by Pennsylvania Power & Light i Company, the licensee.

1. To determine if the amendments meet .the guidance established by Appendix A to APCSB 9.5-1 and Appendix R to 10CFR50, and

2. To verify that where the Applicant deviates from staff guidance, an equivalent level of fire protection is provided.

1.2 GENERIC BACKGROUND General Design Criterion 3 (GDC 3), " Fire Protection," of Appendix A to 10CFR50 requires that structures , systems and components important to safety be designed and located to minimize, consistent with other safety requirements, the probability and effects of fires and explosions.

Noncombustible and heat resistant materials are required to be used wherever practical. GDC 3 also requires that fire detection and suppression systems of appropriate capacity and capability be provided and designed to minimize the adverse affects of fires on structures, systems and components important to safety. Additionally, fire fighting systems should be designed to ensure j that their failure, rupture or inadvertent operation does not significantly

. impair the safety capabilities of these structures, systems and components.

Either the staff guidance contained in Branch Technical Position (BTP)

CMEB 9.5-1 of NUREG 0800, " Standard Review Plan," or the combination of staff guidance contained in Appendix A to BTP APCSB 9.5-1 and the technical requirements set forth in Appendix R to 10CFR50 define the essential elements of an acceptable fire protection program at nuclear power plants for demonstrating compliance with GDC 3. The purpose of the fire protection program is to ensure the capability to shut down the reactor and to maintain i 1

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'9 it in a safe shutdown condition and to minimize radioactive releases to the environment in the event of a fire. The above guidance implements the philosophy of defense-in-depth protection against the hazards of fire and its associated affects on safety-related equipment.

Licensees must provide a fire hazards analysis (FHA), which describes plant design and equipment on an area-by-area basis. The FHA should identify fire area boundaries and demonstrate that a fire in any given area will not prevent the plant from safely shutting down. Where any plant design feature deviates from regulatory guidance, it must be identified and demonstrated that the deviation does not adversely affect plant safety.

1.3 PLANT-SPECIFIC BACKGROUND By letter dated June 30, 1988 Pennsylvania Power & Light Company (PP&L) submitted Revision No. 3 to the Susquehanna Steam Electric Station Fire Protection Review Report. The Revision was a result of changes in methodology and physical plant modifications, resulting from the 1985 NRC Appendix R compliance audit. Revision 3 to the Fire Protection Review Report establishes a plant configuration which reflects some modifications which may not yet be fully implemented. The transmittal letter accompanying the revisions identifies the design change packages which must be fully implemented before Susquehanna reflects the fire protection review report.

The letter states that all modifications are scheduled for completion by December 31, 1989.

In addition to describing the general fire protection program and summarizing the safe shutdown analysis, the Fire Protection Review Report also contains a number of requests for deviations from Appendix R to 10 CFR

50. While some of these deviations reflect modifications in safe shutdown methodology from that identified in 1985, many deviations are the same or similar to those requested earlier but have never been formally approved or documented in a plant Safety Evaluation Report (SER).

As a result of the preliminary review of the Fire Protection Review Report, a Request For Additional Information (RAI) was issued on August 26, 1988. A meeting was then held with the representatives of the Licensee on September 8, 1989 to discuss issues of concern. Based on this meeting, 2

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additional information and proposed revisions to the Fire Protection Review )

Report were submitted by letter dated November 22, 1988. l This Technical Evaluation Report provides a review of Revision 3 to the Fire Protection Review Report including deviation requests contained within.

Although the review associated with this TER evaluated deviation -requests associated with compliance with Appendix R, this review did not specifically evaluate the Licensee's safe shutdown methodology.

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i 2.0 EVALUATION ,

2.1 BATTERY ROOM EXHAUST FANS l

2.1.1 Deviation Reauested A deviation was requested from Sections III.J and III.L of Appendix R to 10 CFR 50 to the extent that a repair must be performed to achieve hot shutdown and that a manual action must be performed using essential lighting i rather than 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months battery powered emergency lights.

2.1.2 Discussion !

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A fire in Fire Area CS-9 could damage the circuitry to Battery Room !

Exhaust Fans OV116A and OV116B and therefore allow for the accumulation of hydrogen to unacceptable levels. By switching the battery charger from- the

" Equalize" mode to the " Normal" mode, the amount of hydrogen production can be reduced. With this manual action performed within two hours of the 1 damage, the Licensee has calculated that the hydrogen concentration would ;

not exceed 2' percent until 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months from the time of the fan failure. The lower explosive limit (LEL) of hydrogen is 4 percent, however, the Licensee has chosen to use 2 percent for the purpose of conservatism. Repair of one of the redundant fans prior to 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months would maintain the hydrogen concentration below 2 percent. Restoration of a fan after the circuitry has been damaged by fire would consist of lifting leads, replacing a fuse and installing a jumper. The Licensee has also identified that the manual action associated with the battery charger would be performed using the essential lighting on the battery room elevation (771') and that no 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months battery lights are in the immediate vicinity. -The Licensee has established that the fan circuitry and the essential lighting circuitry are located in areas such that no fire disabling the fans and requiring the manual action, would also disable the essential lighting.

2.1.3 Evaluation The safe shutdown plan for SSES is not in compliance with Section III.G of Appendix R to the extent that the battery room exhaust fan circuitry may 4

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not remain free of fire damage, and with Section III.L to the extent that 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months emergency lights.are not provided in the area of the required manual action of switching the battery chargers from " Equalize" to " Normal".

The first action regarding the battery rooms associated with a control room fire would be to switch the battery chargers from " Equalize" to

" Normal". This is a routine action connected with the plants technical specifications. Although 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months emergency lights are not in the area of the- i battery chargers, lights powered from the essential emergency switchgear are throughout the area and would provide adequate lighting to perform the manual action. Circuits associated with the emergency switchgear do not run through the Control Room and therefore would be expected to operate in the event of a Control Room. fire that could cause damage to the Battery Room Exhaust Fans. 'It is also stated by the Licensee that this manual action should take place within two hours of a control room fire. Based on the relative routine nature of the manual action, two hours is considered sufficient time to perform the manual action. Considering the nature of the !

essential lighting in the area, there is also reasonable assurance that there would be adequate light to perform the action even given the lack of dedicated 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months emergency lights.

The Licensee has also identified that with the manual action previously described, a repair of the fan circuitry must be made within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months of the fire to ensure that hydrogen concentrations remain within acceptable levels.

The Licensee based their calculations on maintaining the hydrogen levels )

below 2 percent by volume. Since the lower explosive limit of hydrogen is 4 I percent by vol ume, the Licensee's calculations are considered to be conservative. The time available to perform the repair can be considered adequate and sufficiently long to allow the plant to be brought into a

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stable condition. Although this repair is necessary to maintain. a stable j hot shutdown condition and therefore is not in compliance with Appendix R, j there is reasonable assurance that the repair can be performed in the l l necessary time and therefore ensure a safe plant condition. l l

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Based on the evaluation above, there is reasonable assurance that the lack of emergency lighting in the area requiring a manual acticn and the 5

f, 1 t necessary repair of the fan circuitry, do not significantly affect plant safety. Therefore the deviation request associated with the Battery Room Exhaust Fans can be granted.

2.2 SUPPRESSION POOL TEMPERATURE INDICATION 2.2.1 Deviation Reauested A deviation is requested from Section III.L of Appendix R to the extent that Suppression Pool temperature indication may not be available for shutdown outside of the Control Room.

2.2.2 Discussion Suppression Pool temperature indication is available on the remote shutdown panel for each unit with indication provided from the Suppression Pool Temperature Monitoring System (SPOTHOS). However, a fire in the Control Room may cause the failure of both redundant temperature indicators for each unit and therefore loss off suppression pool monitoring capability at the remote shutdown units. By letter dated April 28, 1989 the Licensee provided a detailed discussion of this issue.

Procedure E0-100-009, Plant Shutdown From Outside Control Room, provides direction to the operators to ensure that RHR and _ RHRSW flows are established and proper flow rates maintained. Based on the flow rates of 9,000 GPM for RHRSW and 10,000 GPM for RHR as stated in the procedure, adequate suppression pool cooling is maintained.

2.2.3 Evaluation The potential exists for loss of indication associated with suppression pool temperature instrumentation on the remote shutdown panel and therefore the Licensee is not in compliance with Section III.L of Appendix R.

There was a concern that if temperature indication was lost, there would be no assurance that suppression pool temperature would be maintained within an acceptable range. However, the Licensee has demonstrated that flow indications for both RHRSW and RHR would remain available and that 6

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1 verification of the appropriate flows will ensure that adequate suppression pool cooling is taking place. The procedure for plant shutdown was reviewed and it was confirmed that operators are directed to establish appropriate flow rates to ensure suppression pool cooling and to monitor these flow rates to ensure that an acceptable temperature is maintained. Therefore, there is reasonable assurance that the potential for loss of suppression pool temperature indication will not adversely affect safe plant shutdown.

2.2.4 Conclusion Based on information provided in the April 28, 1989 letter from the Licensee, there is reasonable assurance that adequate suppression pool cooling will be maintained even if suppression pool temperature indication was lost. Therefore, this deviation can be granted.

2.3 NON-RATED FIRE DOORS 2.3.1 Deviation Recuested A deviation is requested from Section III.G of Appendix R to the extent that fire doors in barriers requiring a 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rating are not rated or are rated for less than 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months .

2.3.2 Discussion Table DR 3-1 of the Fire Protection Review Report identifies doors within the Reactor Building which are not in compliance with the requirements of Appendix R. These doors are identified as Type I, II, or III which corresponds to watertight doors, pressure doors and hollow steel doors respectively.

Factory Mutual Corporation reviewed the plants watertight doors in reports dated January 1985 and August 1987. It was concluded in these reports that the watertight doors could be expected to provide at least 1-1/2 hours of fire resistance. Factory Mutual evaluated the subject pressure resistance doors in reports dated August 1985 and June 1986 and concluded that these doors could be expected to provide a fire resistance rating of at least 1-1/2 hours. In the same reports, the hollow steel doors in question 7

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. 4 were evaluated and determined to provide a fire resistance of at least 1-1/2 hours.

The combustible loadings in the Reactor Building fire areas containing the non-rated doors are low. In all cases the loadings are less than 1-1/2 hours and generally significantly lower. The Licensee also programmatically monitors the loadings in these areas to verify that the loadings remain less than 1-1/2 hours and that the concentrated loading immediately adjacent to the doors in question also remains less than 1-1/2 hours.

2.3.3 Evaluation Fire Areas identified in Table DR 3-1 in Revision 3 of the Fire Protection Review Report are not in compliance with section III.G of Appendix R because fire barriers separating redundant safe shutdown components within fire areas are not rated due to non-rated fire doors. All of the doors in question have been reviewed by Factory Mutual and have been determined to provided a fire resistance of at least 1-1/2 hours. The fire loading within the fire areas of the Reactor Building are low as identified in the Fire Hazards Analysis. In all cases, the fire loadings are less than the 1-1/2 hours. In addition, the Licensee has implemented administrative controls to ensure that combustible loadings in the fire zones adjacent to the non-rated doors do not exceed 1-1/2 hours and that loadings in the immediate vicinity of the doors are maintained at less than the fire resistance equivalent that the door could be expected to provide. Therefore there is reasonable assurance that the doors would provide the necessary protection to ensure the operation of safe shutdown components in the event of fire.

2.3.4 Conclusion i

. 1 Based on the evaluation above, it can be concluded that replacing the non-rated doors referenced in Table DR 3-1 in Revision 3 to the Fire:

Protection Report, with doors having a 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rating would not significantly .)

increase the level 'of fire safety and therefore, this deviation can be !

granted.

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i 2.4 WRAPAROUND AREA 1

2.4.1 Deviation Recuested A deviation is requested from Section III.G.2 of Appendix R to the extent that a three hour barrier is not provided between redundant shutdcwn l trains in the Reactor Building. ,

l I 2.4.2 Discussion The Reactor Building is not in compliance with Section III.G.2 of Appendix R because separation of redundant shutdown trains is not accomplished by one of the methods identified in Appendix R. In lieu of providing a three hour barrier between redundant trains, the Licensee proposes to establish the " Wraparound Area" as providing adequate separation between redundant trains.

The Wraparound area is an area designated within the Reactor Building to provide at least 50 feet of spatial separation between the north and south sides of the Reactor Building which contain the majority of the redundant shutdown trains. In order to ensure that 50 feet of separation has been maintained, a 66 foot wide area was actually designated to accommodate drawing tolerances of i8 feet for conduit locations. Although f

some redundant cable is located within the Wraparound Area, protection for I these cases is provided with 3-hour rated fire wrap where no suppression is provided or 1-hour wrap where automatic sprinkler protection is provided.

The Wraparound area is comprised of four zones for each unit with the ;

designations 1-38-W, 1-3C-W, 1-4A-W and 1-5A-W for Unit I and 2-3B-W, 2-3C- I

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W, 2-4A-W and 2-5A-W for Unit 2. Within these zones, three configurations have been identified.

Fire Zones 1-3B-W, 2-3B-W, 1-4A-W, 2-4A-W and 2-5A-W are all provided with automatic sprinkler protection and all have combustible loadings calculated to be less than 45 minutes of equivalent fire duration as compared with the ASTM E119 Time Temperature Curve.

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., . j Fire Zones 1-3C-W and 2-3C-W are not provided with automatic suppression. These zones are designated as high radiation areas and access j is limited. In addition, these areas contain a number of valves, piping and l platforms which would hamper the accumulation of any significant combustible l material. These zones also contain a space approximately 25 feet wide ,

dividing the zones, which contain. no cable trays and therefore no l intervening combustibles between opposite sides.

Fire Zone 1-5A-W comprises the third configuration. This zone is not provided with automatic suppression. This zone includes two elevated q mezzanine areas and a 50 feet by 11 feet aisle. There are no in-situ j combustibles in the mezzanine areas and only two non-safety related cable trays above the aisla. A fire propagating across this zone must travel 50 )

feet horizontally along a cable tray containing only IEEE 383 cable.

2.4.3 Evaluation l Fire zones separated by the Wraparound Area are not in compliance with Section III.G.2 of Appendix R because separation is not provided with 3-hour barriers or 20 foot separation with detection and suppression. However, spatial separation of at least 50 feet is' provided and automatic sprinklers are provided in the majority of Wraparound fire zones. The zones not containing sprinkle-s have limited combustibles and the accumulation of ;

transient combustibles is limited by either restricted personnel access or the physical arrangement of the zone. Redundant cables located within the Wraparound Area are protected in accordance with Appendix R Section III.G.2.

The spatial separation provided by the Wraparound Area in addition to sprinkler protection in zones where any significant combustibles are located, provides reasonable assurance that a fire would not propagate across the Wraparound Area and affect redundant shutdown trains.

2.4.4 Conclusion Based on the evaluation above, it is concluded that the Wraparound Area provides adequate separation of fire zones within the Reactor Building which ;

contain redundant shutdown trains. Therefore, the use of the Wraparound Area provides separation equivalent to the requirements of Section III.G.2 of Appendix R and this deviation can be granted.

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4 2.5 PARTIAL RATING OF WALLS AND FLOOR / CEILING 2.5.1 Deviation Reauested A deviation is requested from Section III.G.2 of Appendix R to the extent that fire boundaries required between fire areas need only be rated for the portion of the wall or floor / ceiling common to the two areas.

2.5.2 Discussion The Licensee is requesting a deviation to allow for the partial rating of a fire rated assembly. This deviation request is based on the interpretation that this type of partial rating is not normally used in

" classical fire protection practice". Partial rating would allow for a portion of a wall or floor / ceiling assembly that was not separating fire areas containing redundant shutdown components or cables, to be treated as unrated.

2.5.3 Evaluation While the Licensee is correct in stating that partial rating of assemblies is not normally found in general industry, the requirements of Appendix R are only concerned with the separation of redundant shutdown trains. Portions of a wall or floor / ceiling assembly not required to meet Appendix R are out of the scope of that document and therefore there.is no basis for granting a deviation. The Licensee should be aware that fire rated assemblies not required for Appendix R may be necessary to conform to guidelines in Appendix A to BTP APCSB 9.5-1 and therefore must be properly evaluated.

.' 2.5.4 Conclusi20 Based on the discussion above, there is no basis for granting a deviation for partial rating of walls or floor / ceiling assemblies and therefore this deviation request should be withdrawn.

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, o 2.6 NON-FIREPR00 FED STRUCTURAL STEEL-2 .' 6.1 Deviation Reauested A deviation is requested from Section III.G.2.a of Appendix Rc to the extent that' structural steel forming a part of or supporting a~ required fire barrier is not protected to provide. fire resistance equivalent to th'at required of the barrier.

2.6.2 Discussion A number of. fire zones contain unprotected structural steel -supporting 3-hour floors separating redundant shutdown divisions. Table 6.1' in Revision 3 to'the Fire Protection Review Report, contains - a comprehensive list of affected areas. In addition, the deviation request contains ~a complete set of drawings identifying locations of . unprotected structural steel. These drawings are cross-referenced with the zones of concern, on Table 6.1.

This deviation request was originally submitted to the NRC in September of 1985. After preliminary review, the NRC requested additional justification. Based on this request, the Licensee submitted the Structural Steel Action Plan on February 10, 1986. After a meeting was held on July 30,- 1986 the NRC requested that the submittal be_ revised to account for consideration of the effects of slab. openings and the use of 100% live load criteria and specific details of the areas required to be fire rated. As a result of this request, the Licensee modified 'their analysis and responded to these issues in the Summary Report' For Structural. Steel Evaluation included in the Fire Protection Review Report.

." The methodology used in the structural steel evaluation was established to determine if the maximum fire that t.ould.be anticipated within a fire area, would jeopardize the integrity of the structural steel significantly to cause barrier failure. Within the analysis, the minimum structural steel necessary to support the barrier was established. 'This was done because-substantially more steel is provided than necessary under' normal conditions to account for loadings under various design basis accidents.'Since Appendix R does not require that fire be analyzed coincident with other accidents, 12

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this additional steel could fail and not jeopardize the integrity of the barrier provided the failure of the steel itself did not damage'the barrier in question. The analysis established that the reinforced . concrete slab must be able to support 100%'of the allowable live load.shown. on existing l structural framing plan drawings and that the loss of structural continuity as a result of hatch openings and penetrations must. be _ considered. In addition, the selected structural steel framing beams must'be. capable of-carrying any. increased loadings caused by the elimination of adjacent members to the building girders and/or columns.

The analysis concluded that any required structural steel framing member with a maximum of two horizontal cable trays in the vicinity was evaluated as acceptable. This is based on calculations provided in the report which attempt to establish that the heat of. combustion resulting from -

a fire in the cable contained in two or less trays would not be sufficient to cause the failure of the steel member.

The analysis also concluded that.any structural steel framing members in areas protected by an NFPA 13 sprinkler system were acceptable. This-was based on the premise that sprinkler protection provided adequate cooling j capability to maintain the steel below its failure. point. A discussion- of l installed configurations versus the requirements established in NFPA 231C,

" Standard for Rack Storage of Materials" is provided in-the summary report. '

NFPA 231C is used for a comparison because the sprinkler performance requirements established in this code were developed, based on live fire tests, to ensure that structural steel integrity was maintained given the significant heat loads potentially present in a rack storage configuration.

.l For steel members which were not considered acceptable for any of the .

l previously mentioned reasons,-an analysis was performed to determine i f. a l

postulated fire in the vicinity of the steel would raise the_ member above !

10000 F, This threshold was chosen because it is used as acceptance criteria !

in NFPA 251 for evaluating structural steel fireproofing. In addition, the American Institute of Steel Construction Manual states that steel maintains '

approximately 63% of its yield strength at 10000F. The allowable bending stress as stated in the manual is between 60%'and 66% of the members yield strength. Therefore, it is concluded in the analysis, that if the steel is 13 L_-___-__-____________-__-___________-_-__-_-_____________.__. _ - - . _ _ _ . _ _ _ . ___ ___ :__ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ - _ _ _ _ _ _ _ - _ _ _ _ _ . - _ _ .

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determined to remain below 1000 F, it will remain within its design limits and therefore will not fail.

Combustibles considered in the evaluation included in-situ and {

transient combustibles within a fire area. The presence of combustible oil in the HPCI and RCIC Turbines was also reviewed to determine the impact of an oil fueled fire on steel integrity. The turbines contain a total of 155 gallons of oil. The Licensee determined that if this oil was spilled on the floor along with an equivalent amount assumed to be in the area during replacement, a resulting fire would not raise room temperatures sufficiently to damage the steel. This calculation also assumed that the floor drains did not remove any spilled oil. In addition the possibility of an oil spray fire was reviewed. The oil in the turbines has a maximum flow rate of 60 GPM at 110 psi, however, the piping containing the oil is seismically qualified making the possibility of a leak remote. In addition, the turbines are protected with open head water deluge systems. The Licensee concluded that in the unlikely event of an oil spray fire, the deluge systems would control the fire.

The maximum fire postulated from transient combustibles was not considered to have an impact on steel integrity. This conclusion was based on testing performed at Sandia Laboratory which demonstrated that the heat output from transient combustible fires is generally low and presents more of a problem as an ignition source rather than a fuel source. In addition, charcoal contained in filter banks was reviewed. Since the filters are contained in steel housings and each filter is provided with a manual deluge j system, a charcoal fire was determined not to have an impact on structural steel integrity. The combustible review concluded that the only fuel source substantial enough to potentially affect structural steel was cable j

insulation.

An energy balance was used to determine the maximum heat rise in steel

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based on a fire consuming the combustibles within the vicinity of the steel.

Only heat absorption of steel and concrete were used in the calculations.

Heat release rates for cable were based on testing performed at Sandia. The tests were performed using polyethylene cable in a loose packed !

configuration. It is stated in the analysis that this would provide for i conservative results since the cable at the plant is (EPR)/hypalon and is 14 i

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l generally tightly packed in cable trays. Using an energy balance method described in the Summary Report, structural steel members were analyzed using the heat outputs calculated for cable tray fires exposing the steel member.

Based on the calculations performed, the Licensee concluded that no additional fireproofing of steel was required to prevent structural steel j failure, i

2.6.3 Evaluation The Licensee is not in compliance with Section III.G.2.a of Appendix R because the majority of structural steel supporting fire rated barriers is not protected equivalent to that barrier. The structural steel supporting j the roof of the Reactor Building Switchgear Rooms is provided with 3-hour fireproofing.

The Licensee performed an analysis to determine if the combustibles in the vicinity of vital steel members could produce a fire sufficient enough to cause the steel member to reach 1000 0F, which was considered the maximum temperature that steel would maintain its load carrying capacity. The Licensee discounted combustible liquids and transient fuel sources based on the determination that they could not provide sufficient heat to cause steel failure. These assumptions were reviewed and found to be acceptable. The Licensee also discounted charcoal as a fuel source since it is confined in steel and provided with manual deluge protection. This conclusion is also considered appropriate. ,

The analysis provided calculations demonstrating that steel in areas 1 provided with automatic suppression or subject to a cable fire from two or ;

less cable trays, could not be raised to its failure point. These calculations were reviewed and found to provide adequate justification for these conclusions.

The heat generated by cable combustion was based on actual data from testing at Sandia Laboratory. These figures are considered conservative since the type and configuration of cable used can be considered worst case.

These heat outputs were then used to calculate maximum predicted temperature 15

. t l

i rise for steel members. The calculations used to predict steel temperature rise were reviewed and found to be conservative.

Based on the analysis provided in the request for-deviation, the ,

Licensee has provided adequate justification that fireproofing of structural i steel would not significantly increase the level of fire protection in the j plant. ]

2.6.4 Conclusion 1 i

Based on the evaluation above, th'e lack of structural - steel l fireproofing as defined in Deviation Request No. 6 contained in Revision 3 of the Fire Protection Review Report and as updated by letter dated November j 26, 1988 has been found to be an acceptable deviation from the requirements of Appendix R Section III.G.2.a and therefore, should be granted, l

2.7 FIRE SPREAD LIMITATIONS i

2.7.1 Deviation Reauested i

A deviation from Section III.G.2 of Appendix R is requested to the extent that certain areas designated as " buffer zones" can be considered _,

equivalent to fire area boundaries. :

I 2.7.2 Discussion I

The Licensee has designated the following fire zones as buffer zones !

between Fire Areas R-1A and R-1B in Unit 1: 1-68, 1-6C, 1-6D, 1-6F, 1-7A 0- i i

6G, 0-6H and 0 8A. In Unit 2, the following zones have been designated as

~

buffer zones between Fire Areas R-2A and R-2B: 2-6B,2-60, 2-6E, 2-6F, 2-7A and 0-8A. l l

The Licensee has established the buffer zone concept to demonstrate compliance with-Appendix R in the Reactor Building. These buffer zones are I areas in the upper elevations of the Reactor Building that contain minimal j safe shutdown components or cable and have low combustible loading. The Licensee is proposing that these areas' would prevent the propagation of fire from fire areas on opposite sides of the buffer zone.

16

-m____ -__:__.:___m______ _m- _ _ _ . .m___.-._ ____m-_-___mm_._--__.___

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

. 4 The Fire Areas separated by the buffer zones, R-1A and R-1B for Unit I and R-2A and R-2B for Unit 2, are separated by a minimum distance of 50 feet horizontally. All of the buffer zones have detection except the Spent Fuel l Pools (1-6F and 2-6F), the Cask Storage Pit (0-6F) and the Recirculation Fan i Room (1-78). Combustible loading in the buffer zones is low or negligible.

The walls bounding the buffer zones are not fire rated, however, they are constructed of heavy concrete and doors are of heavy metal construction.

Manual fire extinguishers and hoses are located throughout the buffer zones. j 1

Safe shutdown cables and components within the buffer zones were treated as if they were located in each of the adjacent fire Areas.

Therefore, both shutdown trains located in the buffer zones were protected per the requirements of Appendix R Section III.G.2.

l 2.7.3 Evaluation i

g The Reactor Building is not in compliance with Section III.G.2 of Appendix R because fire areas containing redundant trains of shutdown cables and components are not separated by a rated fire barrier.

The physical design and layout of the plant includes areas in the upper

. elevations of the Reactor Building which are essentially free of )

combustibles. These areas or buffer zones are located between fire areas containing the majority of shutdown cables and components. The Licensee has protected both trains of shutdown cables and components which are located I within the buffer zones. The majority of the buffer zones contain fire detection which could be expected to alert the Control Room Operators of a fire in its incipient stages. The Operators would then dispatch the fire brigade to control the fire. Three of the four zones not containing j detection contain only pools of water and therefore present no fire hazard and would not propagate fire from one side to the other. The fourth is the Recirculation Fan Room which contains negligible combustibles and is in a configuration which could only impede fire travel. A minimum of 50 feet horizontally separates fire areas and in many cases, a fire would have to travel through several buffer zones.

Based on review of the plant configuration, and given the low l combustible loadings, and presence of detection in most zones, there is 17 a___-_____-___________- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

reasonable assurance that a fire would not propagate from one fire area across the buffer zone and affect the redundant shutdown component in the other fire area.

2.7.4 Conclusion i

Based on the evaluation above, the addition of fire rated barriers between Fire Areas R-1A and R-1B and R-2A and R-2b would not significantly increase the level of fire safety. Therefore, the deviation requesting the use of buffer zones in lieu of fire rated barriers in the Reactor Building can be granted.

2.8 FIRE AREA D-3 BOUNDARIES 2.8.1 Deviation Recuested .

l 1

A deviation is requested from Section III.G.2 of Appendix R to the {

extent that the combustible loading in the Emergency Diesel Generator Bay

]

'or the C diesel (Fire Area D-3) may exceed the 3-hour rating of the fire area boundary.

2.8.2 Discussion A modification was made to the C diesel bay which added a 2200 gallon waste oil tank. The licensee states that if both the new and the old dirty ;

oil tanks are assumed full and a fire consumes all of the oil, a fire with an equivalent severity of over 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months could be predicted.

2.8.3 Evaluation While this type of analysis is considered prudent, NRC guidelines and requirements do not consider the installation of fire rated barriers in excess of 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months . Also, considering that the oil would be contained in tanks and that the diesel bay is protected with automatic suppression, it would not be likely that a fire would actually last longer than 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months .

18 1

2.8.4 Conclusion Since Appendix R nor other NRC requirements or guidelines do not call for the installation of fire barriers in excess of 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated, this requested for deviation is not necessary and should be withdrawn.

2.9 HVAC PENETRATIONS REACTOR BUILDING FIRE WALLS 2.9.1 Deviation Reauested A deviation is requested from Section III.G.2 of Appendix R to the extent that fire dampers are not installed in certain HVAC penetrations in Reactor Building Walls.

2.9.2 Discussion Deviation Request No. 11 in Revision 3 of the Fire Protection Report identifies 10 HVAC penetrations in the Unit 1 Reactor Building and 9 in the Unit 2 Reactor Building, which do.not have fire dampers installed in them.

The Licensee has performed an analysis which demonstrates that the combustibles in the fire zones on either side of the HVAC opening would not cause a fire of sufficient magnitude to actuate a damper if it were installed in the opening. In addition the analysis reviewed the affects of the heat which would be transmitted through the unprotected duct, on safe shutdown components in the adjacent fire zone.

The analysis initially reviewed the fire resistance that would be provided by the ductwork itself. Data was provided from a test conducted at Underwriter's Laboratory which demonstrated that a galvanized steel (0.022

. inch) duct would provide a fire resistance of approximately one hour. The analysis states that all ductwork in question is 0.048 inch galvanized steel. In addition, it is stated that all ductwork in question is seismically qualified.

Based on a request from the NRC, resulting from the preliminary review of this issue, the Licensee has provided information relating to the affects of heat transfer through the opening on the sprinkler systems in the adjacent fire zone. The concern was that heat passing through the ductwork 19

l

-r

.1 might operate the sprinkler in the non-affected fire zone and could impact ;

the operation of the un-damaged shutdown train. The Licensee calculated that in the worst case configuration, the resultant maximum air temperature in the adjacent fire zone would be 146 0F. The temperature rating of the sprinkler heads in the Reactor Building is 212 0F and therefore the heads would not operate.

1 2.9.3 Evaluation l

The Reactor Building is not in compliance with Section III.G.2 of ;

Appendix R because W!AC penetrations in fire barriers separating redundant trains are not provided with fire dampers. ,

I However, the combustible loading in all fire zones of concern is less f than 1-1/2 hours with localized loading in the area of the ductwork less than I hour. The ductwork in question is seismically rated and substantially heavier than the ductwork demonstrated by Underwriter's l Laboratory to provide a fire resistance rating of I hour. Temperature calculations performed by the Licensee demonstrated that the temperature of i the air being transmitted to the adjacent room would be less than 150 F. 0 This temperature would - not be sufficient to directly damage shutdown components in the adjacent room or cause the operation of sprinklers in the unaffected fire zone. In addition, all fire zones on either side of an unprotected opening are provided with fire detection. It would be expected that Control Room Operators would be notified of a fire while in its l incipient stages. The Operators would notify the fire brigade who would control the fire.

1 i

Based on the low combustible loading in the vicinity of the ductwork, i I the substantial steel construction of the ductwork itself, and fire !

l detection in all zones of concern, there is reasonable assurance that l installing fire dampers in the Reactor Building HVAC penetrations identified l in Deviation Request No.11 would not significantly increase the level of '

plant fire safety. !

l l

20

.. , .i j

1 l

2.9.4 Conclusion I Based on the evaluation above, the lack of fire dampers in HVAC l

penetrations identified in Deviation Request No.11 in the Fire Protection l l Review Report is considered acceptable and therefore, this deviation can ~be granted.

2.10 FIRE BARRIERS WITHOUT FIRE DAMPERS IN VERTICAL VENTILATION DUCT PENETRATIONS i I

2.10.1 Deviation Reouested l A deviation is requested from Section III.G.2 of Appendix R to the extent that nine vertical ventilation duct penetrations in the Reactor Building do not contain fire dampers.

2.10.2 Discussion This request for deviation from Appendix R is similar to that described in Deviation Request No. 11 submitted by the Licensee, however, unprotected penetrations in this deviation are located in floor / ceiling assemblies in the Reactor Building rather than walls. In addition the deviation request states that all of the zones located beneath the penetrations in question are protected by an automatic fire suppression system. The " worst case" temperature of air transmitted to the adjacent fire zone of 146 0F, calculated in Deviation Request No.11, remains valid. Additionally, for vertical penetrations, impact to the adjacent zone from elevated temperatures would be limited since the duct either has no openings in either fire zone or on either side of the fire barrier or, the supply duct to a sprinklered fire zone has no openings in the fire zone with the postulated fire or, the fire zone with the postulated fire is sprinklered and in the event of a fire in that zone, the fire would be controlled before the duct could be heated sufficiently to impact the adjacent fire zone.

2.10.3 Evaluation Fire zones identified in Deviation Request No. 12 in Revision 3 of the Fire Protection Report, are not in compliance with Section III.G.2 of 21

l l Appendix R because floor / ceiling fire rated assemblies do not contain fire dampers in the penetrations.

!.ack of dampers in vertical penetrations is generally a more significant concern than lack of dampers in horizontal penetrations.

However, in all cases covered by this deviation request, the fire zone

! l beneath the unprotected HVAC penetration is protected by automatic sprinklers. There would be reasonable assurance that the fire in the

, " lower" sprinklered zone would be controlled prior to the " upper" zone being impacted by heat passing through the unprotected barrier. In several cases, no openings exist in the ductwork in one or both of the zones, further l reducing the impact potential. In addition, the Licensee has performed calculations which demonstrate the limited combustibles in the vicinity of the unprotected openings would not generate enough heat inside of the l

ductwork to impact the adjacent zone. Therefore, there is reasonable assurance that providing fire rated dampers in the vertical penetration l openings identified in Deviation Request 12 would not significantly increase the level of fire safety.

I 2.10.4 Conclusion Based on the evaluation above, the lack of fire dampers in nine vertical penetrations in the Reactor Building is considered an acceptable deviation from Appendix R Section III.G.2 and can therefore be granted.

2.11 ESSENTIAL REDUNDANT RACEWAY PROTECTION 2.11.1 Deviation Reauested

. A deviation is requested to the extent that; (a) protection of redundant safe shutdown cables in a fire zone may be accomplished through the use of one or a combination of methods identified in Appendix R Section III.G.2a, b, and c; (b) the safe shutdown cables required to ensure availability of a safe shutdown path in a particular fire zone need only be protected within that fire zone; and (c) all raceways are protected by the use of a 1-hour fire rated barrier where automatic suppression / detection exists or by the use of a 3-hour fire rated barrier where automatic 22

suppression does not exist. This deviation request is intended to apply to all fire areas in the Unit I and 2 Reactor Buildings.

2.11.2 Discussion l This deviation request was submitted to apply the criteria established in Deviation Request No.4, Wraparound Areas and Deviation Request No. 7, l Fire Spread Limitations. With the application of criteria in those deviation requests, protection of essential raceways would be accomplished by application of a number of methods identified in Appendix R Section III.E. In addition, where suppression was required per Appendix R, the suppression may only be in the zone and may not be provided "throughout" the area as specified in NRC guidance.

2.11.3 Evaluation Protection of essential redundant raceways in the Reactor Building is accomplished by employing various alternatives as defined in Appendix R Section III.G.2a, b, and c. These are established as options in Appendix R, and using a combination of these methods is not restricted by the document.

Therefore, part (a) of the request is not considered a deviation from Appendix R and is not required.

The request for protecting cables only within the zone being considered incorporates the concepts defined in Deviation Requests No. 4 and No.7.

These have been previously reviewed in this report and have been found to be acceptable. Therefore, if the concepts discussed for the Wraparound Area and Limited Fire Spread are applied as defined in their respective deviation I requests, no additional deviation is necessary for part (b) of this request.

Part (c) of this request is intended to define that detection and suppression are provided for redundant trains where called for by Appendix R, however, the suppression may only be provided in the fire zone and therefore, the fire area could be considered to have partial suppression.

At the interface of a zone with suppression and a zone without suppression, the protection of cables would change from 1-hour wrap to 3-hour wrap. The Licensee has verified that no significant combustibles exist for 20 feet on either side of the zone boundaries. Determination of the acceptability of 23

partial suppression was considered during the evaluation of Deviation Requests No. 4 and No. 7. During this review it was found acceptable based on limited combustibles and the protection provided for redundant cables, to have partial suppression in Reactor Building fire areas. Therefore, the lack of total area suppression and the application of Appendix R on a " zone" basis, is considered an acceptable deviation from Appendix R provided that the evaluations for Deviations No. 4 and No. 7 remain valid.

2.11.4 Conclusion Based on the evaluation above, the lack of area-wide automatic suppression in the Reactor Buildings is considered an acceptable deviation from Appendix R and therefore can be granted.

2.12 REACTOR BUILDING FIRE ZONES WITHOUT FIRE DETECTION 2.12.1 Deviation Reauested A deviation is requested for lack of detection in certain fire zones within fire areas requiring detection per Appendix R Section III.G.2.

2.12.2 Discussion 4

The following fire zones have been identified as having no detection:

Fire Area Fire Zone R-1A 1-2C 1-4E 0-6E 1-78 1-6F R-1B l-lJ 1-6F 0-6H R-2A 2-2C 24 l

Fire Area Fire Zone 2-4E 2-11 2-6F R-2B 2-lJ 2-6F With the exception of Fire Zones 1-2C and 2-2C, none of the zones listed contain safe shutdown components. Zones 1-2C and 2-2C are the railroad airlock and access shaft for Units 1 and 2 and contain limited safe shutdown

! components. Although detection is not provided, sprinkler automatic protection is provided throughout the zones. Combustible loading in all of l the zones is minimal.

2.12.3 Evaluation ]l All of the zones contain minimal or negligible combustible loading. It would not be expected that a fire in any of the zones could impact safe shutdown components in adjacent zones. The two zones with safe shutdown components within the zone contain only minimal equipment and are provided with automatic suppression. Based on this, it is concluded that the addition of detection in the specified zones would not significantly increase the level of plant fire safety.

2.12.4 Conclusion Based on the above evaluation, the lack of detection in the specified fire zones is considered an acceptable deviation from Appendix R Section III.G.2 and therefore, this deviation can be granted.

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2.13 FIRE AREAS IN THE CONTROL STRUCTURE WITHOUT FIRE SUPPRESSION l 2.13.1 Deviation Reauested A deviation is requested from Section III.G.2.c of Appendix R to the extent that automatic suppression is not provided in addition to 1-hour wrap in Fire Areas CS-11 and CS-20.

2.13.2 Discussion Fire Areas CS-11 and CS-20 contain safe shutdown cables within conduits protected by 1-hour rated fire wrap. Fire Area CS-20 also contains two 125V DC distribution panels which are enclosed in 1-hour rated material. The combustible loading in the areas is less than 30 minutes. Both areas are provided with ionization type smoke detection. No cable trays are located in either fire area.

2.13.3 Evaluation Fire Areas CS-11 and CS-20 are not in compliance with Appendix R Section III.G.2.c because automatic suppression is not provided in addition to 1-hour wrap and detection. However, the combustible loading in both areas is low, less than 30 minutes. It could be expected that the detection would alert Control Room Operators of any fire while in its incipient stage.

The Control Room would then notify the fire brigade who could respond and control the fire. In addition, the protection of safe shutdown cables inside conduit and electrical panels coupled with the low loading, provides reasonable assurance that a fire would not affect the shutdown capability of the plant. It should also be noted that these areas are of similar

. configuration to Fire Zones 0-28B-I and 0-28B-11 which were granted a deviation for lack of suppression by the NRC in Supplement 4 to the plant Safety Evaluation Report (SER).

2.13.4 Conclusion Based on the above evaluation, the lack of suppression in Fire Areas CS-Il and CS-20 are found to be an acceptable deviation from Appendix R Section III.G.2.c and therefore, this deviation can be granted.

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2.14 EMERGENCY SWITCHGEAR ROOM COOLING SYSTEM COMPONENTS -

INSUFFICIENT SPATIAL SEPARATION l 2.14.1 Deviation Reouested A deviation from Section III.G.2.b of Appendix R is requested to the extent that Emergency Switchgear Room Copling System Components are separated by less than 20 feet.

2.14.2 Discussion Fire Zones 1-4A-S and 2-4A-S contain redundant fans, damper actuators, flow switches and temperature switches separated by less than 20 feet. The minimum separation is associated with the redundant flow and temperature switches which are located 3'-4" apart on either side of the air duct.

Both zones are provided with detection and automatic suppression.

In-situ combustibles in the zones is low with the potential for transient combustibles limited by room configuration. The safe shutdown equipment is located in a mezzanine approximately 20 feet off the main floor with access provided only by a ladder. The only intervening combustible is cable tray E2PJ in Unit 2 which has been wrapped with 1-hour fire rated material. The fan motors are located within their respective supply plenums. The damper actuators and switches are contained within metal housings.

2.14.3 Evaluation The Emergency Switchgear Room cooling components located in Fire Zones 1-4A-S and 2-4A-S are not in compliance with Section III.G.2.b of Appendix R because they are not separated by at least 20 feet. However detection and l automatic suppression are provided. The in-situ combustibles are low and the configuration of the zones makes it unlikely that significant transient combustibles would accumulate. Since the fan motors _ are located within separate plenums and the actuators and switches are located on opposite sides of the ducts, a single fire could not expose both trains of redundant components. Based on this, there is reasonable assurance that a fire in either Fire Zone 1-4A-S or 2-4A-S would not damage both trains of cooling components and affect the ability of the plant to achieve safe shutdown.

27

4 a

2.14.4 Conclusion Based on the evaluation above, the lack of separation of Emergency Switchgear Cooling System Components is found to be acceptable and therefore, the deviation from Section III.G.2.b of . Appendix A can

granted.

2.15 KA0 WOOL SYSTEM AS AN ACCEPTABLE 1-HOUR BARRIER WRAP l

2.15.1 Deviation Reauested l

A deviation from Section III.G.2.c of Appendix R is requested to the ;

extent that Kaowool has been used in some areas as a 1-hour rated barrier and the NRC identified in Generic Letter 85-01 that Kaowool does not meet the 1-hour criteria.

2.15.2 Discussion The Licensee has identified that Kaowool was used as a 1-hour fire rated wrap in some areas to meet Appendix R requirements, prior to fuel load for Unit 1, in July of 1982. Every area where Kaowool was used is also 1 provide with an automatic suppression system.

2.15.3 Evaluation NRC Generic Letter 85-01 stated that the product Kaowool did not meet the 3250 F acceptance criteria and therefor should not be considered as a 1-hour rated barrier. However, the letter continued to state that if this system had been installed and approved by the NRC prior to the new guidance, it need not be replaced. Since the Kaowool installed in Unit I was j previously approved by the NRC, the Kaowool can be considered to meet the 1- i hour criteria required by Appendix R.

2.15.4 Conclusion Based on the discussion above, the existence of Kaowool installed prior to the issuance of Generic Letter 85-01 is an acceptable deviation from Appendix R and therefore, this deviation can be granted.

28

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l' 2.16 INCOMPLETE FIRE SUPPRESSION AND FIRE DETECTION IN DIESEL GENEPATOR FIRE AREAS 2.16.1 Deviation Reouested A deviation is requested from Section III.G.2 of Appendix R to the extent that suppression and detection are not provided throughout Fire Areas l D-1 and D-3.

l 2.16.2 Discussion Fire Areas D-1 and D-3 contain emergency diesel generators and are not provided with suppression and detection for their upper levels. Although these fire areas are separated from other fire areas by 3-hour barriers, redundant trains of shutdown equipment are located within the areas and therefore suppression and detection is required per Appendix R. Fire Areas l D-2 and D-4 do not contain redundant equipment and are therefore not included in the deviation request.

The fire areas in question contain automatic suppression and detection in the basement and on the ground floor. The top floors, containing only fan equipment are the only areas not provided with detection or suppression.

No safe shutdown equipment is located in the areas lacking suppression and detection.

2.16.3 Evaluation l

Fire Areas D-1 and D-3 are not in compliance with the requirements of i Section III.G.2 of Appendix R because suppression and detection is not provided throughout an area containing redundant -trains of shutdown equipment.

The top elevation of each diesel bay, which contains only fan q equipment, is not provided with suppression and detection. The lower two !

levels, which contain the redundant equipment are provided with full area detection and suppression coverage. The combustible loading on the upper elevation is minimal. There is reasonable assurance that any fire that could start in the unprotected area, would not affect safe shutdown i 29 l l

l

L .. .

l e

i L equipment in the adjacent lower levels. Since redundant diesels are provided, a fire potentially affecting operability of a diesel would not affect safe shutdown. In addition the detection and suppression in the lower levels provides further assurance that a fire would be detected and controlled within the areas containing safe shutdown equipment.

2.16.4 Conclusion Based on the evaluation above, there is reasonable assurance that tthe l addition of detection and suppression in the top elevations of Fire Areas D-1 and D-3, would not significantly increase the level of fire safety and therefore this deviation can be granted.

2.17 PENETRATION SEALS - CONDUITS 2.17.1 Deviation Reauested A deviation from Section III.G.2 of Appendix R is requested to the extent that conduits will be provided with an internal non-combustible seal on one side, to maintain fire barrier integrity.

2.17.2 Discussion Generic Letter 86-10 states that " Openings inside conduit larger than 4 inches in diameter should be sealed at the fire barrier penetration.

Openings inside conduit 4 inches or less in diameter should be sealed on each side of the fire barrier and sealed either at both ends or at the fire barrier with non-combustible material to prevent the passage of smoke and hot gas."

The Licensee has identified that conduits passing through fire barriers will be provided with a seal consisting of non-combustible material on one side at the first accessible opening.

2.17.3 Evaluation The Identified conduit sealing methodology differs from NRC staff guidance provided in Generic Letter 86-10 since only one seal is being 30

provided rather than a seal on each side as stated in NRC guidance.

However, many of the conduits at the plant terminate in closed junction boxes on one or both sides. Recent tests have determined that this would provide equivalent protection to a rated seal. In addition, many of the conduits are located in areas with automatic suppression which .would reduce the potential of fire traveling through an open conduit to the adjacent fire area. The conduit sealing program as identified in Deviation Request No.20 q provides reasonable assurance that redundant trains of shutdown components I would not be affected by fire or smoke and hot gases traveling through conduits.

2.17.4 Conclusion Although not 'specifically a deviation, the method identified for ;

sealing conduits in Deviation Request No. 20 is found to provide adequate I protection against fire and is acceptable when used in barriers required by Appendix R Section III.G.2.

2.18 CONTROL STRUCTURE i FIRE ZONES WITHOUT FIRE DETECTION AND/OR FIRE SUPPRESSION 2.18.1 Deviation Reouested A deviation is requested from Section III.G.2 of Appendix R to the extent that fire suppression and/or detection is not provided throughout Fire Area CS-3 in the Control Structure.

2.18.2 Discussion

, Fire Area CS-3 is divided into eight fire zones. The redundant safe

~

shutdown raceway within this fire area is protected by 1-hour rated wrap and suppression and detection is provided in areas containing the raceway.

Suppression and detection has been provided for the zones as follows:

31

e Z2Dg Detection Sucoression Redundant Raceway 0-21A No Sprinklers (Partial) No 0-22A Partial Sprinklers (Partial) No !

0-22C No No No 0-23 Partial No No 0-24A Yes CO 2 Yes 0-24B Yes CO2 (Partial) Yes l 0-24C Yes CO 2 No I 0-24F Yes CO2 (Partial) Yes 2.18.3 Evaluation Fire Area CS-3 is not in compliance with Section III.G.2 of Appendix R because suppression and/or detection is not provided throughout an area containing redundant safe shutdown cables.

However, the redundant cables are protected by 1-hour rated wrap.

Suppression and detection is also provided in all areas in the vicinity of the redundant raceway. The combustible loading in areas lacking suppression and/or detection is low. There is reasonable assurance that a fire in the area would not damage the redundant cables and affect plant shutdown.

2.18.4 Conclusion Based on the present plant features, including suppression and i detection in the vicinity of the redundant raceway, and considering that the raceway is also protected with 1-hour rated wrap, there is reasonable {'

assurance that a fire would not affect the ability of the plant to achieve safe shutdown and therefore this deviation can be granted. j 1

2.19 CONTROL STRUCTURE - FIRE AREA CS-9, PARTIAL FIRE SUPPRESSION l 2.19.1 Deviation Reouested I

l A deviation from Section III.G.3 of Appendix R is requested to the :

i extent that partial fire suppression is provided in an area relying on a dedicated shutdown method. i 32 1

l l I !

e 2.19.2 Discussion I

Fire Area CS-9 is the Control Room including adjacent vestibules and offices. Fire Zones 0-26K and 0-26L-(Technical Support Center and Conference Room) are provided with automatic sprinkler protection. Other suppression in the Fire Area consists of manual CO2 in raised floor areas.

Detection is provided throughout the fire area. In addition, extinguishers are located throughout the area.

2.19.3 Evaluation The Control Room is not provided with automatic suppression throughout !

the area and therefore is not in compliance with Section III.G.3 of Appendix l R. !

However, manual 2C0 is provided for raised floor areas and sprinkler protection is provided for two zones adjacent to the actual Control Room.

Detection is provided throughout the area and in addition, the Control Room is constantly manned. It would be expected that any fire would be detected early and extinguished using the installed portable fire extinguishers. If necessary, dedicated shutdown capability has been provided independent of the Control Room area. There is reasonable assurance that the addition of automatic suppression throughout the Fire Area CS-9 would not significantly increase the level of plant fire safety.

2.19.4 Conclusion Based on the evaluation above, the lack of automatic fire suppression throughout Fire Area CS-9 is considered acceptable and therefore this deviation from Section III.G.3 of Appendix R can be granted. !

2.20 AUTOMATIC FIRE SUPPRESSION IN FIRE ZONE 2-5D 2.20.1 Deviation Reouested j A deviation is requested from Section III.G.2.b to the extent that I automatic suppression is not provided for an area where redundant shutdown components are located.

l 33 i

2.20.2 Discussion I

Fire Zone 2-5D contains RCWU Outboard Isolation Valve HV-G33-2F004.

This valve is normally open and would require closing to achieve post fire safe shutdown. The Inboard Isolation Valve HV-G33-2F001 could be closed if l the outboard valve is not available due to damage by fire. Although the-inboard valve is located in the Containment, control and power cables pass l through fire zones adjacent to Fire Zone 2-5D in the same Fire Area. No suppression is provided in Fire Zone 2-5D.

The minimum separation of the outboard valve and the closest cable for the redundant valve is approximately 50 feet. The only combustibles in Fire Zone 2-5D consist of five gallons of oil, one gallon in each of five cleanup System Recirculation Pumps, and four cable trays at the east end of the fire zone. The cable trays are located 49 feet from the outboard valve.

Fire detection is provided in Zone 2-5D which is also considered a high radiation area and therefore has limited access.

2.20.3 Evaluation Fire Zone 2-5D is not in compliance with Section III.G.2.b of Appendix R because automatic suppression is not provided for an area containing redundant safe shutdown components.

However, the minimum separation of the redundant components is 50 feet.

Combustibles in the zone are minimal. The small amounts of oil, are contained in pumps and segregated by partial concrete walls. The only cable trays present are at the opposite end of the zone to the redundant valve.

It would not be probable for a fire to travel 50 feet from one end of the

. zone to the other given the limited combustibles. Since the zone is designated a high radiation area, personnel access is limited and the potential for accumulation of transient combustibles is low. In addition, the zone is provided with fire detection which would alert the Control Room of any fire while in its incipient stages. The Control Room would then noti fy the plant fire brigade to control the fire. Therefore, there is reasonable assurance that a fire would not damage both the Outboard Isolation Valve and cables to the redundant Inboard Isolation Valve.

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1 2.20.4 Conclusion I

Based on the evaluation above, the addition of automatic fire :l suppression in Fire Zone 2-5D woul1 not significantly increase the level of )

fire protection and therefore this deviatica can be granted. .)

1 2.21 AUTOMATIC FIRE SUPPRESSION AND INTERVENING COMBUSTIBLES IN FIRE ZONE 1-3A' i 2.21.1 Deviation Reauested A deviation is requested from Section III.G.2.b of Appendix R to the extent that partial suppression is provided and some intervening -]

combustibles exist in Fire Zone 1-3A. :i I

2.21.2 Discussion Fire Zone 1-3A contains redundant trains of safe shutdown equipment.

Several different redundant components are in the area, however, the minimum separation exists between Core Spray System flow instruments for Division 2 (FIS-E21-IN006B and FT-E21-IN003B) and the redundant Division 1 instruments (FIS-E21-IN006A and FT-E21-IN003A). The separation of these redundant !

instruments is 45 feet horizontally.

Automatic sprinkler protection is provided in all areas of Zone 1-3A except between column lines 23.5 and 25. Although the sprinkler coverage provided is not "throughout" the zone, a minimum of 25 feet of the 45 feet of redundant train separation is covered by sprinklers. Smoke detection is provided throughout the zone.

In addition to the lack of full area coverago, several cable trays traverse the separation area and therefore can be considered intervening combustibles. The cable trays are fully enclosed by sheet metal in the 25 foot area where suppression is provided. The total combustible loading of-the area is approximately one hour. The accumulation of transient combustibles is limited since the area in question has a three feet wide passage way which provides limited floor space for material.

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2.21.3 Evaluation Fire Zone 1-3A is not in compliance with Section III.G.2.b of Appendix R because automatic suppression is not provided throughout the area. and intervening combustibles exist between redundant trains.

However, automatic suppression is provided for approximately 25 feet of the 45 feet of separation between redundant trains of Core Spray instruments. In addition detection is provided in the zone which alarms in the Control Room and would alert the plant operators and fire brigade of any fire in the zone. Given the combustible loading of approximately one hour, it would not be probable that a fire would span the 25 feet of protected area between redundant trains. Although cable trays do span the separation area, the intervening combustibles are fully enclosed in metal covers for 25 feet in the area of automatic suppression. There is reasonable assurance that a fire would not travel in the cables across the 25 feet of enclosed cable tray and sprinklered area. It should also be noted that NRC Generic Letter 86-10 Section 3.6.2 states that enclosing cable trays fully in metal.

covers in an area that is sprinklered and provided with' detection, would be an appropriate way to deal with intervening combustibles. l 2.21.4 Conclusion Based on the evaluation above, the partial sprinkler coverage and intervening combustibles have not been found to adversely affect plant safety and therefore this deviation can be granted.

l 2.22 AUTOMATIC FIRE SUPPRESSION AND INTERVENING COMBUSTIBLES IN FIRE ZONE 2- 1 38-N l 2.22.1 Deviation Reouested i

A deviation is requested from Section III.G.2.b of Appendix R to the extent that intervening combustibles in the form of cable trays exist in an i area between redundant shutdown components.

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8 lj 2.22.2 Discussion 1

The configuration of this area is similar to that of Fire Area 1-3A j evaluated in Section 2.21 of this report. The differences are that the "

redundant Core Spray instruments are separated by slightly less, 41 feet versus 45 feet, although the combustible loading is also less, 45 minutes ,

versus one hour. In addition, the 41 feet of separation is completely covered be automatic suppression. The intervening combustible cable trays are fully enclosed in metal covers for 25 feet in the separation area where suppression and detection are also provided.

2.22.3 Evaluation As determined in evaluation 2.21 of this report, there is reasonable assurance that a fire would not propagate across the area of separation between redundant trains of Core Spray instruments based on the presence of automatic suppression and detection and the enclosure of the intervening cable trays in metal covers for at least 25 feet.

2.22.4 Conclusion Based on the evaluation above and in Section 2.21 of this report, the intervening cable trays between redundant trains of safe shutdown components in Fire Zone 2-3B-N has been determined to not adversely affect plant safety and therefore this deviation can be granted.

2.23 NUCLEAR BOILER INSTRUMENTATION IN FIRE ZONE l-5A-S NUCLEAR BOILER INSTRUMENTATION IN FIRE ZONE 2-5A-N 2.23.1 Deviation Reouested A deviation is requested for Fire Zone 1-5A-S in Unit I and 2-5A-N in Unit 2, to the extent that redundant trains of Nuclear Boiler Instrumentation are not separated be at least 20 feet as defined in Section III.G.2.b of Appendix R.

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I 2.23.2 Discussion The minimum separation provided in either of the zones for ECCS interlock components is 14 feet. In Fire Zone 1-5A-S, redundant safe shutdown vessel indication components are separated by a minimum of 6 feet.

l l Both zones are provided with automatic suppression and detection 1

throughout the zones. Cable trays within the vicinity of the redundant components are provided with metal covers. Combustible loading in both zones is low. In addition, a plant procedure has been implemented to prevent the accumulation of transient combustibles in the zones. ?

Within Fire Zone 1-5A-S, Division II safe shutdown cables have been ]

wrapped and Division I cables have been wrapped in Zone 2-5A-N. In order to !

ensure the integrity of at least one division of instrumentation within each zone, Division I cables in Zone 1-5A-S and Division II cables in Zone 2-5A-N i have been protected with 1-hour rated wrap for 10 feet'in the vicinity of l the redundant instrumentation.

2.23.3 Evaluation i l

Fire Zones 1-5A-S and 2-5A-N are not in compliance with Section )

III.G.2.b of Appendix R since separation of at least 20 feet is not provided between redundant trains and cable trays act as intervening combustibles.

However, automatic suppression and detection are provide throughout each zone. Given the low loading in the area, it is not likely' that a fire !

of significant magnitude could develop. Transient combustibles are controlled in the area by plant administrative procedures and are not a

significant hazard. The intervening combustible cables within trays are )

enclosed in metal covers. The combination of these covers and the automatic suppression, provides reasonable assurance that a fire would not propagate through the trays from one train to the other.

i Although one division of cables is protected within each zone, cables for the second division.have been protected within the vicinity of the redundant instrumentation. This provides additional assurance that a single 38

I i .

i fire would not jeopardize the operability of redundant trains of. I instrumentation. j l

l 2.23.4 Conclusion Based on the evaluation above, the lack of 20 feet of separation between redundant trains of instrumentation and the presence of intervening q combustibles in Fire Zones 1-5A-S and 2-5A-N has not been found to significantly reduce the level of fire safety and therefore this deviation -

can be granted.

2.24 CATEGORY I COMPONENTS IN FIRE ZONES 1-3C-W AND 2-3C-W 2.24.1 Deviation Reouested I A deviation is requested from Section III.G.2.b of Appendix R to the extent that a minimum separation of 20 feet is not provided between j

' redundant trains of safe shutdown components and automatic suppression is not provided.

2.24.2 Discussion

)

Fire Zones I-3C-W and 2-3C-W contain redundant trains of valves and temperature instrumentation associated with the RHR system of Unit I and Unit 2 respectively. The minimum separation of 13 feet is connected with the RHR Heat Exchanger Outlet Temperature Element. All other redundant components are separated by greater than 20 feet.

Combustible loading in the zones is low and the accumulation of transient combustibles is limited since the zones are designated high radiation areas and personnel access is restricted. No intervening l combustibles exist between the redundant components.

Detection is provided throughout the zones and manual fire fighting i equipment in the form of hoses and portable extinguishers are located in the area, i

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2.24.3 Evaluation The fire zones in question are not in compliance with Appendix R because a minimum separation of 20 feet is not provided between redundant shutdown components. In addition, automatic suppression is not provided in the zone.

However, combustible loading in the zones is low and no intervening combustibles exist between the redundant components. The accumulation of substantial transient combustibles is unlikely since the zones are high radiation areas and access is restricted. The low loading in the area and lack of ignition sources makes a fire in the area not probable. However, if a fire were to occur, the installed detection would be expected to notify the Control Room of a fire while in its incipient stages. The Control Room Operators would then notify the plant fire brigade who could control the fire using the available hoses and portable extinguishers.

Therefore, there is reasonable assurance that the installation of-automatic suppression within the zones and the separation of the temperature elements by more than 13 feet, would not significantly increase the level of plant fire safety.

2.24.4 Conclusion I

Based on the evaluation above, the lack of automatic suppression and 20 i feet of separation between redundant trains of components in Fire Zones 1-3C-W and 2-3C-W, is found to be an acceptable deviation from Appendix R Section III.G.2.b and therefore this deviation can be granted.

2.25 CONTROL STRUCTURE HVAC SYSTEM COMPONENTS - FIRE ZONES 0-29B AND 0-30A 2.25.1 Deviation Recuested A deviation from Section III.G.2.b of Appendix R is requested to the extent that Control Structure HVAC System components are not separated by a minimum of 20 feet in Fire Zones 0-29B and 0-30A.

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.. i 2.25.2 Discussion Multiple redundant HVAC components associated with the Control Structure HVAC System are located in Fire Zones 0-29B and 0-30A. A complete list of these components is included as Table DR30-1 in Deviation Request No. 30. Many of these components are separated by less than 20 feet.

The combustible loading in both zones is low with the exception of charcoal inside a filter plenum. However, this charcoal is provided with detection and a manual deluge system and is contained inside a rigid steel housing. Administrative procedures are provided to restrict the accumulation of transient combustibles in the zones. Both zones are provided with automatic suppression and detection throughout. The- physical layout of the zones including large HVAC components and partial walls prevents a single fire from exposing many redundant components.

2.25.3 Evaluation Fire Zones 0-298 and 0-30A are not in compliance with Appendix R Section III.G.2.b because redundant components are located closer than 20 feet. However, both zcnes are protected by automatic suppression and detection. The in-situ combustibles are low with the exception of charcoal filters which are provided with detection and manual deluge. Specific administrative procedures restrict the accumulation of transient combustibles in areas where redundant trains might be exposed. Because of the low combustible loading, automatic suppression and geometry of the zones, there is reasonable assurance that a tire would not damage redundant trains of HVAC components. In addition, the detection in the zones would alert the Control Room of any fire in the area who in turn could notify the fire brigade.

2.25.4 Conclusion Based on the evaluation above, the lack of 20 foot separation between redundant trains of Control Structure HVAC components in Fire Zones 0-29B and '0-30A is considered acceptable and therefore the deviation can be granted.

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/

2.26 0UTSIDE AREAS - LACK OF SEPARATION OF SAFE SHUTDOWN COMPONENTS 'AND ELECTRICAL CABLES 2.26.1 Deviation Reauested A deviation is requested from Section III.G.2.b of Appendix R to 'the extent that outside manholes and' underground duct banks are not separated by-greater than 20 feet and are not provide with detection or suppression.

l 2.26.2 Discussion l

The electrical manholes are seismically designed and constructed to be water tight. The manholes extend 12 inches above grade and are constructed of concrete with a minimum thickness of six inches. The manholes are not directly adjacent to any significant hazards and are designed such that-a fuel oil spill could not run down into the manholes and expose cables.

In addition to the manholes, this deviation request also includes the-Emergency Diesel Generator Fuel Oil Storage Tank Transfer Pumps and the RHR Service Water Spray Pond Valves. The transfer pumps are- submerged inside-the fuel oil tanks. The electrical cables are enclosed in conduit and located in a vault above the diesel generator tanks. The vault is 1 seismically designed and provided with a missile protective cover.

The six RHR service water spray pond valves are located in a valve pit. l Redundant Valves are separated from each other by a 3 foot thick concrete j wall with no penetrations. All safe shutdown power and control cables are located in conduit. .!

l; 2.26.3 Evaluation ,

i i

The electrical manholes and vaults containing fuel oil transfer pump cables- and RHR spray pond valves and cables are not in compliance with ;

Appendix R because redundant components and cable are-located closer than 20.

feet and no suppression and detection is provided.-

l However, the substantial construction of the manholes and vaults would prevent the components inside from being exposed to an exterior fire. !

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Within the structures, combustible loading is negligible and there 'are no f ignition sources. The structures would also be protected from an exterior j combustible liquid fire by raised sides and/or tight fitting covers.

Therefore, there is reasonable assurance that the addition of detection and suppression and increased separation would not significantly . increase the level of fire safety.

2.26.4 Conclusion Based on the evaluation above, the lack of separation, detection 'and suppression for exterior manholes and components identified in deviation request No. 32 is considered acceptable and therefore this deviation can be granted.

2.27 REACTOR COOLANT MAKEUP AND DEPRESSURIZATION SYSTEMS 2.27.I Deviation Recuested A deviation is requested from Section III.G to the extent that reactor coolant process variables will vary from those normally predicted for loss of normal a.c. power.

2.27.2 Discussion The shutdown methodology defined for the plant utilizes Core Spray / ADS, alternate shutdown cooling and suppression pool cooling. With this method, the reactor level may go lower than normally predicted for loss of offsite power and the depressurization rate may be faster. However, the Licensee states that the safe shutdown analysis has demonstrated that under these

, conditions, there will be no fuel clad damage, rupture of any primary coolant boundary or rupture of the containment boundary. In addition, the reactor coolant makeup function will be capable of maintaining the reactor coolant level above the top of the core. The performance goals for the 1 reactivity control function, the reactor heat removal function, the process monitoring function and other support functions, are unaffected.

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_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ ]

2.27.3 Evaluation Section III.L of Appendix R (as it applies to compliance with Section-III.G.3 of Appendix R) states that "during the post fire shutdown, the ;

reactor coolant system process variables shall be maintained within those i predicted for a loss of normal a.c. power, and the fission product boundary

! integrity shall not be affected; i.e. there shall be no fuel clad. damage, rupture of any primary coolant boundary, or rupture of the containment -]

boundary". While the process variables differ from those achieved under normal conditions, the performance criteria as defined in Appendix R are all met.. In addition, the analysis ensures that the level of . coolant will always be maintained above the top of the core.

I 2.27.4 Conclusion i

Based on information provided in Deviation Request No. 11 in Revision 3 of the Fire Protection Review Report, the difference in reactor coolant process variables as defined in Section III.L of Appendix R is found to be an acceptable deviation and therefore can be granted.

2.28 CONTROL STRUCTURE CHILLER ESW VALVES - INSUFFICIENT FIRE BARRIER, FIRE ZONE I-3A i

2.28.1 Deviation Reouested A deviation is requested from Section III.G.2.c of Appendix R to the l extent that a I-hour barrier is not provided for the Control Structure

)

Chiller ESW Valves.

2.28.2 Discussion ,

. .\

The valves in question have a minimum separation of 9' 6" and are not provided with a I-hour barrier between them. The valves are located in Fire j Zone I-3A which is provided with automatic suppression and detection. In f addition, directional water spray around one of the valves acts as a water curtain separating the two valves. Cable trays in the immediate vicinity of the valves are provide with metal covers. Design of the valves and operator i i

44 ;

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1 ao ..,

i have been reviewed to ensure that operation of the water spray would not adversely affect their operation. ;

2.28.3 Evaluation Separation of the Control Structure Chiller ESW Valves is not in compliance with Appendix R because a 1-hour barrier has not been provided ;

between the valves. I However, suppression and detection exists throughout the fire zone. i Additionally, water spray directional nozzles have been provided to form' a '

water curtain between the redundant valves. Combustible loading in the area is. low. Although some cable trays do exist in the immediate vicinity of the valves, they have beer, provided with metal covers and therefore would not present an exposure hazard to the valves.

Based on the presence of a water spray system between the valves and 3 detection and suppression in the fire zone, the lack of 20 feet separation is found to be an acceptable deviation from Appendix R.

2.28.4 Conclusion Based on the evaluation above, the present configuration of the Control Structure Chiller ESW Valves is found to be acceptable and therefore the deviation for lack of separation can be granted.

2.29 CONTROL ROOM RAISED FLOOR AND CONTROL STRUCTURE CABLE CHASE FIRE PROTECTION 2.29.1 peviation Reouested A deviation from Sections III.G.2.a. b, c is requested to the extent that separation and detection and suppression is not in compliance for cable routed under the main control room raised floor and cable shafts and chases within the Control Structure.

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2.29.2 Discussion Redundant trains of shutdown cable are routed under the Control Room raised floor. This area is provided with detection and manual CO2 . Three electrical cable chases extend from Elevation 698'-0" to Elevation 783'-0" in the Control Structure. Each chase is enclosed by fire rated construction

]

on all sides. An automatic total flooding 002 system protects the entire !

length of the chases except at the Control Room elevation where a manual C02 system is insta11eci. In addition to the cable chases, the Control Room has two cable shafts under the north and south soffits. The cable shafts are enclosed by 3-hour fire rated concrete walls at the north and south sides of )

the Control Room and by 2-hour rated construction inside the Control Room. ]

Each cable shaft is provided with detection and Manual 002 suppression. j 2.29.3 Evaluation l This deviation request applies to Fire Areas CS-6, CS-7 and CS-9.

Since CS-9 is the Control Room and dedicated shutdown has been provided, this area falls under the requirements of Section III.G.3 of Appendix R rather than III.G.2. Therefore, the issue of lack of suppression and/or manual suppression in lieu of automatic suppression is the concern. This ;

issue has previously been evaluated under Section 2.20 of this report and found to be acceptable.

Fire Areas CS-6 and CS-7 are the electrical cable chases. Section 6.2 of the Fire Protection Review Report states that safe shutdown path 3 cables contained in these chases have been protected in a fire rated envelope. In addition automatic CO 2 suppression has been provided accept in zones adjacent to the Control Room in which manual 002 suppression has been installed. All zones within the fire areas of concern have been provide with detection. Therefore the deviation from Appendix R criteria relates to the manual CO 2 protection versus automatic suppression throughout.

Only the zones adjacent to the Control Room are provided with manual suppression. Because of the proximity to the Control Room and the presence of detection that would alert the Control Room Operators to a fire in the chases, it would be expected that immediate action could be taken to investigate a cable chase fire. If necessary, the Operators could activate 46

l the manual suppression systems. Based on this, the addition of automatic suppression in the cable chase areas that currently have manual suppression, would not significantly increase the level of plant fire safety.

2.29.4 Conclusion Based on the above evaluation, the' presence of manual C02 suppression iin the Control Building cable chases is considered acceptable and therefore this deviation can be granted.

2.30 SAFE SHUTDOWN ANALYSIS In addition to deviation requests, the Fire Protection Review Report I

contains a general description of the plant fire protection program including discussions of the various installed fire protection features.

The Review Report also provides a summary of the safe shutdown analysis which defines the methodology used to comply with Appendix R. Although the methodology was not specifically evaluated as part of this review, the sub-section dealing with multiple high impedance faults on page 3.3-9 of the report was determined not to be in compliance with Appendix R and subsequent NRC guidance.

The Licensee stated in the Review Report that " multiple high impedance faults are considered to be an extremely low probability event and were not considered a design criteria". This is in conflict with guidance provided in Generic Letter 86-10 which states " simultaneous high impedance faults for all associated circuits located in the fire area should be considered in the evaluation of the safe shutdown capability". The guidance also states

" clearing such faults on associated circuits which may affect safe shutdown !

may be accomplished by manual breaker trips governed by written procedures", i The Licensee stated in a response to a RAI, dated November 22, 1988 that no f specific written procedures existed for clearing such faults. Ay letter I dated April 28, 1989 the Licensee committed to performing an analysis of I high impedance faults. If necessary, the Licensee also comitted to provide f written procedures for clearing possible faults. The Licensee stated in the l 1etter that a schedule for completion of any possible modifications or !

development of procedures will be provided to the NRC upon completion of the analysis.

47 I

3.0 CONCLUSION

S Based on the evaluations in this report, the following deviations from Appendix R to 10 CFR 50 have been found acceptable.and therefore can be granted:

l- Section in l this reoort lillt 1 2.1 BATTERY ROOM EXHAUST FANS i l 2.2 SUPPRESSION POOL TEMPERATURE INDICATION 2.3 NON-RATED FIRE DOORS 2.4 WRAPAROUND AREA 2.6 NON-FIREPR00 FED STRUCTURAL STEEL '

2.7 FIRE SPREAD LIMITATIONS 2.9 HVAC PENETRATIONS REACTOR BUILDING FIRE WALLS 2.10 FIRE BARRIERS WITHOUT FIRE DAMPERS IN VERTICAL VENTILATION DUCT PENETRATIONS 2.11 ESSENTIAL REDUNDANT RACEWAY PROTECTION !

2.12 REACTOR BUILDING FIRE ZONES WITHOUT FIRE DETECTION 2.13 FIRE AREAS IN THE CONTROL STRUCTURE WITHOUT FIRE SUPPRESSION 2.14 EMERGENCY SWITCHGEAR ROOM COOLING SYSTEM COMPONENTS -

INSUFFICIENT SPATIAL SEPARATION I 2.15 KA0 WOOL SYSTEM AS AN ACCEPTABLE 1-HOUR BARRIER WRAP 2.16 INCOMPLETE FIRE SUPPRESSION AND FIRE DETECTION IN DIESEL !

GENERATOR FIRE AREAS 2.17 PENETRATION SEALS - CONDUITS 2.IB CONTROL STRUCTURE - FIRE ZONES WITHOUT FIRE DETECTION AND/OR FIRE SUPPRESSION 2.19 CONTROL STRUCTURE - FIRE AREAS CS-9, PARTIAL FIRE SUPPRESSION 2.20 AUTOMATIC FIRE SUPPRESSION IN FIRE ZONE 2-5D 2.21 AUTOMATIC FIRE SUPPRESSION AND INTERVENING COMBUSTIBLES IN )

FIRE ZONE l-3A 2.22 AUTOMATIC FIRE SUPPRESSION AND INTERVENING COMBUSTIBLES IN .

FIRE ZONE 2-3B-N 2.23 NUCLEAR BOILER INSTRUMENTATION IN FIRE ZONE 1-5A-S ,

NUCLEAR BOILER INSTRUMENTATION IN FIRE ZONE 2-5A-N 2.24 CATEGORY I COMPONENTS IN FIRE ZONES 1-3C-W AND 2-3C-W i

48

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v 2.25 CONTROL STRUCTURE HVAC SYSTEM COMPONENTS - FIRE ZONES 0-29B i AND 0-30A 2.26 0UTSIDE AREAS - LACK OF SEPARATION OF SAFE SHUTDOWN COMPONENTS AND ELECTRICAL CABLES !

2.27 REACTOR COOLANT MAKEUP AND DEPRESSURIZATION SYSTEMS 2.28 CONTROL STRUCTURE CHILLER ESW VALVES - INSUFFICIENT FIRE BARRIER, FIRE ZONE l-3A 2.29 CONTROL ROOM RAISED FLOOR AND CONTROL STRUCTURE CABLE CHASE FIRE PRO 1ECTION Based on evaluations in this report, adequate justification has remet been demonstrated for the following deviation from Appendix R:

Section in this recort Title 2.30 SAFE SHUTDOWN ANALYSIS - EVALUATION OF HIGH IMPEDANCE FAULTS Based on evaluations in this report, the following requests for deviation from Appendix R have been found not necessary and should be withdrawn:

Section in this report Title 2.5 PARTIAL RATING OF WALLS AND FLOOR / CEILING 2.8 FIRE AREA D-3 BOUNDARIES i

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v t e Letter Sequence Other
TAC:59647, (Open) TAC:59648, (Open)
Initiation Request, Request Acceptance... Administration Questions Answers Results Approval... Other: ML20245F047
MONTHYEAR1989-04-28 [Table View]

ML20245F047

Text

1.0 INTRODUCTION

3.0 CONCLUSION

1.0 INTRODUCTION

3.0 CONCLUSION

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