View source for A05420, Forwards Addl Info Supporting Util 850916 Request for Exemption from Fire Protection Requirements of 10CFR50, App R,Per NRC 851204 Request.Verbal Responses Provided to NRC During 851210 Site Visit

{{Adams
| number = ML20141M931
| issue date = 02/19/1986
| title = Forwards Addl Info Supporting Util 850916 Request for Exemption from Fire Protection Requirements of 10CFR50, App R,Per NRC 851204 Request.Verbal Responses Provided to NRC During 851210 Site Visit
| author name = Opeka J, Sears C
| author affiliation = CONNECTICUT YANKEE ATOMIC POWER CO.
| addressee name = Grimes C
| addressee affiliation = NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
| docket = 05000213
| license number = 
| contact person = 
| document report number = A05420, A5420, NUDOCS 8603030065
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 11
| project = 
| stage = Request
}}

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CONNECTICUT YANKEE ATOMIC POWER COMPANY BERLIN. CONNECTICUT P o BOX 270   HARTFoRo CONNECTICUT 06141-0270 T ELEPt+0NE 203-665-5000 February 19, 1986 Docket No. 50-213 A05420 Office of Nuclear Reactor Regulation Attn: Mr. Christopher I. Grimes, Director Integrated Safety Assessment Project Directorate Division of PWR Licensing - B U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Gentlemen:
Haddam Neck Plant AdditionalInformation for Exemption Requests from 10CFR50, Appendix R Fire Protection By {{letter dated|date=December 4, 1985|text=letter dated December 4, 1985}},(I) the NRC Staff requested additional information for the exemption requests from the fire protection requirements of 10CFR50, Appendix R submitted by onnecticut Yankee Atomic Power Company (CYAPCO) on September 16, 1935.t2) Verbal responses were provided to the NRC Staff on December 10,1985 during a site visit to inspect the fire barriers in question. Although concerns were raised during the visit with the evaluation provided for structural steel in Exemption Request 5, no further requests for additional information have bee.. received. This concern was n meeting summary supplied by NRC {{letter dated|date=December 18, 1985|text=letter dated December 18,1985}}.gedInin             the order not to delay the NRC Staff's continuing review, CYAPCO is providing formal written responses to the information requested previously.                Additional information for Exemption Requests 2, 3, 4,6,7, and 8 is attached. If additional information is required for Exemption Request 5, please let us know.
The attached additional information should resolve the items discussed above and result in the issuance of a favorable SER from the NRC Staff. To the extent the (1) F. M. Akstulewicz, Jr., lette. to 3. F. Opeka, dated December 4,1985,

==Subject:==
Exemption Requests from 10CFR50.48, Fire Protection.
(2) 3. F. Opeka letter to H. L. Thompson, dated September 16, 1985, 

==Subject:==

Fire Protection.
(3) F. M. Akstulewicz, J r.,      letter to Connecticut Yankee Atomic Power Company, dated December 18, 1985, 

==Subject:==
Meeting Summary on Plant                   ph g
inspection of Licensee Fire Protection Exemption Requests.                           ,,   g 0603030065 860219 3 PDR ADOCK 050 F

NRC Staff proposes to take action' denying any of the remaining unresolved exemption requests, CYAPCO requests an appeal meeting with appropriate NRC management prior to issuance of the final fire protection SER for the Haddam Neck Plant.
Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY.
k      .b J. F. Opeka '
Senior Vice President By: C. F. Sears Vice President Attachment cc:  D. M. Crutchfield W. V. Johnston O. D. Parr S
t

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:                                                                                                                     - Docket No.'50-213 A05420 I
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Attachment 4
Haddam Neck Plant AdditionalInformation Regarding Exemptions from the
* Fire Protection Requirements of 10CFR50, Appendix R i
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1 February 1986 i
                                                                                                                                                                       .I

Haddam Neck Plant Additional Information Regarding Exemptions from -
the Fire Protection Requirements of 10CFR50, Appendix R The additional information is provided by the exemption number used in the                  ,
{{letter dated|date=September 16, 1985|text=September 16,1985 letter}}.(l) i        Exemption Request No. 2
;        Question
:        Section 2.2. of your submittal states that modifications have been proposed to' reroute and/or protect the cables associated with safe shutdown equipment in j        Fire Zone A-ID so that a fire in Fire Zone A-1A will rot affect the operation of j        these components. Provide details of the proposed reroute and/or protection referred to above.

===Response===
Details of the proposed reroute and/or protection are not available at this time due to the need to construct a new building to house the new switchgear equipment. Details of the reroute are scheduled to be available by September 1986. The proposed reroute and/or protection of cables associated with safe shutdown equipment in Fire Zone A-ID will be implemented so a fire in Fire Zone A-1 A will not affect the operation of safe-shutdown components in Fire Zone A-ID.
Exemption Request No. 3 Sections 3.1, 4.1, 6.1, 7.1, and 8.1 of your submittal request exemptions from the requirements of Section III.G.2.a of Appendix R for several nonrated or unlabeled doors and frames in addition to several unprotected duct penetrations in fire area boundaries. To facilitate the evaluation of these requests, provide the following for each opening (door and penetration).
Question i
: a. Describe the location and configuration of redundant or alternate safe j              shutdown equipment / circuits in relation to these openings, i

===Response===
Doors (5-3/D-1) and (S-3/D-2) do not separate redundant or alternate safe
(    1   )     (   1    )
shutdown components. See Figure 3.1 for the location of these doc,.s.
Question
: b. Verify that automatic suppression and detection systems, for which credit
;              is taken, are addressed in plant Technical Specifications.
4 4

===Response===
The suppression systems discussed in Exemption Request No. 3 are included in the Station Technical Specifications. The systems are 1) the preaction automatic sprinklers over each diesel generator, 2) the smoke detectors in the diesel generator rooms, and 3) the automatic sprinklers on the service building side of the fire barrier, except for the shower areas.
Question
: c. Describe what modifications are required for each opening to meet the requirements of Section III.G.2.a.

===Response===
The following modifications would be needed if the requirements of Section III.G.2.a were met:
: 1. The security hardware on each door would have to be removed, and
: 2. New fire rated door frames would have to be installed.
Question
: d. Provide additional information to support the basis that each opening provides a level of fire protection safety equivalent to that required by Section III.G.2.

===Response===
The following additional information is provided to support the exemption request:
: 1. The doors are fire rated for three hours,
: 2. The door frames are substantial and are mounted securely in place,
: 3. Automatic sprinklers are provided on the service building side (Fire Area S-3) of the fire doors, except for the shower areas. Sprinklers are located over the south side of the doors,
: 4. Preaction automatic sprinklers are installed over each diesel generator,
: 5. Smoke detectors are installed in Fire Areas D-1 and D-2, and
: 6. Three hour fire walls separate the diesel generator rooms. The doors and frames are only used to form " enclosures."
Exemption No. 4 Sections 3.1, 4.1, 6.1, 7.1, and 8.1 of your submittal request exemptions from the requirements of Section III.G.2.a of Appendix R for several nonrated or unlabeled

doors and frames in addition to several unprotected duct penetrations in fire area boundaries. To facilitate the evaluation of these requests, provide the following for each opening (door and penetration).
Question
: a. Describe the location and configuration of redundant or alternate safe shutdown equipment / circuits in relation to these openings.

===Response===
Redundant safe shutdown components exist within the control room.                The four doors at (S-1/T-1), (S-1/T-1), (S-1/S-4), and (S-1/S-4) and the ventilation
(    1   )(   2    )(     1    )     (   2   )
penetrations at S-1/S-4,5-1/S-4 and S-1/S-4 are not credited with providing A      B              C safe shutdown equipment separation. See Figure 4.1 for the location of the doors and ventilation penetrations.
Question
: b. Verify that automatic suppression and detection systems, for which credit is taken, are addressed in plant Technical Specifications.

===Response===
The present early warning detection system in the control room (Fire Area S-1) is included in the Technical Specifications. The control room Halon system and associated detectors will be included in the Technical Specifications af ter the system is installed. The smoke detection system in the mechanical equipment room and instrument shop area is not included in the Technical Specifications because it does not protect safety-related equipment or circuits.
Question
: c. Describe what modifications are required for each opening to meet the requirements of Section III.G.2.a.

===Response===
The existing doors are in place to provide steam-line break protection. All doors would have to be completely removed and replaced with rated fire door assemblies.      Fire doors would not provide the required steam-line break protection. Additionalinformation on the fire door at (S-1/T-1) was provided in CYAPCO's letter of February 6,1986.(I)
(1)    3. F. Opeka letter to C. I. Grimet, dated February 6,1986, 

==Subject:==
Fire Protection.
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                                                  . -4
:To provide the appropriate fire dampers, each wall penetration would have to be enlarged for the damper to be installed. Each wall has rebar installed and would require major modifications.
J Question                                                                                            ,
: d. Provide additional information to support the basis that each opening provides a level of fire protection safety equivalent to that required by Section Ill.G.2.

===Response===
The following additional information is provided to support the exemption request:
: 1. The fixed fire load in the I&C hallway / turbine building is very low.
The protection provided by the 4" thick steam protection doors
  .                  assures that a fire in the hallway or turbine hall would not present an 1
exposure hazard in the control room, and
: 2. The metal ventilation ducts which enclose these openings provide                        ,
adequate separation for the fire loading of the area. Also, the installation of fire dampers could preclude the use of the control room smoke removal system.
Exemption Request No. 6 Sections 3.1, 4.1, 6.1, 7.1, and 8.1 of your submittal request exemptions from the requirements of Section Ill.G.2.a of Appendix R for several nonrated or unlabeled doors and frames in addition to several unprotected duct penetrations in fire area boundaries. To facilitate the evaluation of these requests, provide the following for each opening (door and penetration).
Question
: a. Describe the location and configuration of redundant or alternate safe shutdown equipment / circuits in relation to these openings.

===Response===
The block wall between Fire Areas T-1 and S-3, the fire dampers located at S-3/T-1 and S-3/T-1 and the doors located at (S-2/T-1), (S-2/T-1) and (S-3/T-1)                     .
A            B                             (    1   )(     2  )     (   1  )
do not provide separation of redundant safe shutdown com ponents.               See Figures 6.1 through 6.3 for the location of the wall, dampers and doors.
Question                                                                  .
: b. Verify that automatic suppression and detection systems, for which credit is taken, are addressed in plant Technical Specifications.
3

===Response===
The automatic detection and suppression systems are included in the Technical Specifications. These systems include 1) the automatic total flooding Halon 1301 fire suppression system in the switchgear room (S-2),2) the smoke detection and cable tray automatic sprinklers in the cable spreading area (S-3A), 3) the automatic sprinklers in the service building (S-3), and 4) the partial automatic sprinklers and selected deluge systems in the turbine building (T-1).
Question
: c. Describe what modifications are required for each opening to meet the requirements of Section III.G.2.a.

===Response===
The following modifications would be needed if the - requirements of Section Ill.G.2.a were met:
: 1. The two in hour fire rated dampers would need to be replaced with three hour rated dampers,
: 2. The three doors would need to be replaced with three hour fire rated door assemblies that also provide protection for a steam-line break, and
: 3. The two hour block wall would need to be upgraded to three hours.
Question
: d. Provide additional information to support the basis that each opening provides a level of fire protection safety equivalent to that required by Section III.G.2.

===Response===
The following additional information is provided to support the exemption request:
: 1. The block wall and its associated doors and dampers on the turbine building side are protected by automatic sprinkler systems. The combination of sprinklers and physical separation (distance between hazard and wall for safety-related versus safe shutdown areas) assures adequate fire separation, and
: 2. A copy of the test report on the fire rating of the block wall was provided to the NRC during the December 10,1985 site visit.
Exemption Request No. 7 Sections 3.1, 4.1, 6.1, 7.1, and 8.1 of your submittal request exemptions from the requirements of Section III.G.2.a of Appendix R for several nonrated or unlabeled doors and frames in addition to several unprotected duct penetrations in fire

area boundaries. To facilitate the evaluation of these requests, provide the following for each opening (door and penetration).
Question
: a.                                     Describe the location and configuration of redundant or alternate safe shutdown equipment / circuits in relation to these openings.

===Response===
The switchgear room ventilation ducts at S-2/S-4, S-2/S-4 and S-2/A-2 do not A            B    B separate redundant or alternate safe _ shutdown equipment or circuits.                                                                                                                                                                                                                                                            See Figure 7.1 for the location of the ventilation ducts.
Question
: b.                                    Verify that automatic suppression and detection systems, for which credit is taken, are addressed in plant Technical Specifications.

===Response===
The automatic total flooding Halon 1301 fire suppression system in the switchgear room is included in the Technical Specifications. The smoke detection system in the mechanical equipment room and instrument shop is not included in the Technical Specifications because it does not protect safety-related equipment or circuits.
Question
: c.                                    Describe what modifications are required for each opening to meet the requirements of Section Ill.G.2.A.

===Response===
i                                                Major wall and ceiling modifications would be required to install three hour rated fire dampers.
Question
: d.                                    Provide additional information to support the basis that each opening _
provides a level of fire protection safety equivalent to that required by Section III.G.2.

===Response===
I The following additional information is provided to support the exemption request:
: 1.                                   The switchgear room is located below the mechanical equipment room (MER). The MER has a very light fire loading. The sheet metal duct work, and.the fact that the fire would have to burn downwards, 4
assures that the switchgear room would not be affected by a MER j
d'
   ._m___________   ______ __ . . _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ . _ . . _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ . _ _ . _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ .

fire. Detection in the MER provides early warning of a smoke / fire condition, and
: 2. The low fire loading in the health physics (HP) building, which the exhaust duct from the battery area passes, is not severe enough to penetrate the sheet metal duct enclosure. The battery exhaust only passes through a small section of the HP building before exiting to the roof.
Exemption Request No. 8 Sections 3.1, 4.1, 6.1, 7.1, and 8.1 of your submittal request exemptions from the requirements of Section III.G.2.a of Appendix R for several nonrated or unlabeled doors and frames in addition to several unprotected duct penetrations in fire area boundaries. To facilitate the evaluation of these requests, provide the following for each opening (door and penetration).
Question
: a. Describe the location and configuration of redundant or alternate safe shutdown equipment / circuits in relation to these openings.

===Response===
The doors at (S-3/S-5) and (S-3/A-1) and the ventilation ducts at S-3/S-5,
(   1    )     (   1   )                                 A S-3/S-5, S-3/S-5, S-3/S-4 through S-3/S-4, and the electrical bus duct enclosures E        F         A                F at S-3/S-5, S-3/S-5 and S-3/S-5 do not separate redundant or alternate safe B         C            D shutdown equipment or circuits. See Figures 3.1 through 8.3 for the locations of the doors and ducts.
Question
: b. Verify that automatic suppression and detection systems, fer which credit is taken, are addressed in plant Technical Specifications.

===Response===
The automatic suppression and detection systems in Fire Areas A-1, S-3 and S-5 are included in the Technical Specifications. These systems are:
: 1. The smoke detectors and automatic sprinklers in selected areas of Fire Zone (A-1A). Smoke detectors are also provided in Old Fire Area A-9, Waste Drumming Room,
: 2. The smoke detectors provided throughout Fire Zone (S-3A) and the automatic sprinklers designed for cable tray protection installed within the trays in Fire Zone (S-3A),
: 3. The automatic sprinklers provided in Fire Zone (5-3B) throughout el. 31'6", in the service building, except for the shower areas, and

                                                          -S-
: 4. The automatic sprinklers provided throughout Fire Area S-5.
4 The smoke detection provided in the mechanical equipment room and instrument shop, Fire Area S-4, is not included in the Technical Specifications because it does not protect safety-related equipment or circuits. Also, the automatic
;           Halon 1301 fire suppression system in the Nuclear Records' Storage Room is not included in the Technical Specifications because it does not protect safety-
!           related equipment or circuits.
I
           - Question h           c. Describe what modifications are required for each opening to meet the i                 requirements of Section Ill.G.2.a.
i

===Response===
The following modifications would be needed if the requirements of Section Ill.G.2.a were met:
: 1. The doors would have to be replaced with three hour rated fire door assemblies,
: 2. Each ventilation opening would need to be fitted with rated fire
  !                      dampers. This would require major wall and ceiling modifications,
: 3. The bus ducts would have to be sealed. This is not feasible, and i
: 4. The steel beams would need to be coated.
Question
!           d. Provide additional information to support the basis that each opening 1
provides a level of fire protection safety equivalent to that required by Section Ill.G.2.

===Response===
I           The following additional information is provided to support the exemption request:
: 1. The doors have sprinklers located above to provide ccoling,
: 2. Fire Area S-5 is protected by automatic sprinklers. This sprinkler i
system provides coverage over the steel beam, bus ducts and ventilation penetrations, and
: 3. The cable spreading area is located below the mechanical equipment room (MER). The sheet metal enclosures and the ' fact that a fire would have to burn downward assures that the cable spreading area would not be affected by an MER fire, in addition, the safe shutdown cables in the cable spreading area are protected by automatic -
sprinklers, s}}