ML20154F889

Safety Evaluation Re Proposed Safe Shutdown Sys & Exemption Requests Concerning 10CFR50,App R.Licensee Request for Exemptions in Listed Areas Should Be Granted.Concept for Providing post-fire Shutdown Acceptable

ML20154F889
Person / Time
Site:	Fort Saint Vrain
Issue date:	05/10/1988
From:	Office of Nuclear Reactor Regulation
To:
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ML20154F845	List: ML20154F841 ML20154F866 ML20154F889
References
GL-86-10, NUDOCS 8805240115
Download: ML20154F889 (36)

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/ p uauq'o UNITED STATES

! " 3 s., I g NUCLEAR REGUi.ATORY COMMISSION ,

W ASHINGTO N, D. C. 20655

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION .

RELATING TO THE PROPOSED SAFE _SFUTDOWN , SYSTEM AND EXEMPTION RECUESTS CONCERNING 1,0 CFP PART 50, APPENDIX R FORT ST. VRAIN NUCLEAR GENERATING ST/ TION PUBLIC SERVICE CCPTANY OF COLORADO COCKET NO. 50-267

1.0 INTRODUCTION

This Safety Evaluation addresses the compliance of the Fort St. Vrain t'uclear Generating Station (FSV) with 10 CFR Part 50, Appendix R, Sections III.G ard III.J. concerning fire protection pro 5rar.s for ruclear power facilities. The NRC regulatory criteria that form the cerplete fire protection licensing basis for FSV also include:

- Appendix A to Branch Technical Position APCSB 9.5-1, Rev.1, and

- FSC letter of August 17, 1954 from Lee to Johnson (P-24281)

(Reference 14). This is also contained as Appendix A of Reference la.

By letter dated August 3. 1087 (Reference 15), the NRC reaffirmed that the above positicns represented the applicable regulatory basis for fire protecticn at Fort St. Vrain. This position has remained unchanged frcm earlier correspondence, includino Pcference 13. This evaluation discusses both the proposed post-fire shutdown systers arc the exemptions requested.

1.1 Post-Fire Shutdown Systens A review of the post-fire safe shutdown systers, proposed by Public Service Company of Colorado (PSC) for FSV fire prctection considerations, entitled "Fire Protection Shutdown /Cooldown Podel," was undertaken by Region IV personnel in accordance with TIA 83-105 in October 1985. The initial review of the PSC proposal (Reference 1) resulted in a number of questions which were transmitted to PSC by NRC letter dated November 1,1985 (Reference 3). PSC responded to these questions in their December 20, 1985 letter (Referente 4) which deferred tne submittal of an analysis to justify the

, effectiveness of the proposed post-fire shutdown models until the fourth quarter of 1986. A proposed FSV fire protection program plan was submitted December 15,1987 (Reference 20) per Generic letter 86-10.

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Review of the December 20, 1985 response resulted in a number of followup and clarification questions which were discussed during a telephone con- .

ference en February 26, 1986, and documented in PSC letters dated March 14 and April 4, 1986 (References 5 and 6, respectively).

1.2 Exemption Requests By letter dated April 1,1985 (Reference Id), the licensee submitted Appen-dix R Evaluation Report No. 4, which contained exemption recuests and pro-posed fire protection and systems-related modifications. Eleven exemptions frem the technical requirements of Section III.G and one exemption from Section III.J of Appendix R to 10 CFR Part 50 were requested.

A schedular exemption from 10 CFR 50.4P was also requested. However, in a letter dated July 22, 1956 the staff stated that this exemption was not r.eeded.

By letter dated May 31, 1985 (Reference 2), the licensee submitted Report No. 5, "Fire Hazards Aralysis and Evaluation of Fort St. Vrain Building No. 10 to BTP 9.5-1, Appendix A Guidelines."

Section III.G.2 cf Appendix R requires that one trein of cables and equip-cert necessary to achieve and raintain post-fire shutdown be maintained

> free of fire damage by one of the following means:

a. Separation of cables and equipment and associated ncn-safety circuits of redundant trains by a fire barrier having a 3-bcur rating. Struc-tural steel forming a part of or supporting such fire barriers shall i be protected to provide fire resistance equivalent to that required of the barrier;

t. Separation of cables and equipment and associated non-safety circuits of redundant trains by a horizental distance of more than 20 feet with no intervening corbustibles or fire hazards. In addition, fire detectors and an automatic fire suppression system shall be installed I

in the fire area; and

c. Enclosure of cables and equiprent and associated ncn-safety circuits of one redundant train in a fire barrier having a 1-hour rating. In addition, fire detectors and an automatic fire suppression system shall be installed in the fire area.

If these conditions are not met,Section III.G.3 requires an alternative I shutdown capability independent of the fire area of concern. It also requires that a fixed suppression system be installed in the fire area of  !

concern if it contains a large concentration of cables or other combustibles.

These alternative requirements are not deemed to be equivalent; however, they provide equivalent protection for those configurations in which they are accepted.

Because it is net possible to predict the specific conditions under which fires may occur and propagate, the design basis protective features are

3 specified in the rule rather than the design basis fire. Plant-specific features may require protection different frem the measures specified in ,

Section ill.G. In such a case, the licensee must deronstrate, by means of a detailed fire hazards analysis, that existing protection or existing protection in conjunction with proposed modificaticos will provide a level of safety equivalent to the technical requirements of Section III.G of Appendix R.

In summary,Section III.G is related to fire protection features for ensuring that systens and associated circuits used to achieve and maintain post-fire shutdown are free of fire damage. Fire protection configurations rust eitter reet the specific requirerents of Section 111.0 or an alternative fire protection configuration must be justified by a fire bazard analysis.

Our general criteria for accepting an alternative fire protection configur-ation are the following:

The alternative ensures that one train of equipment necessary to achieve hot shutdown frcm either the control room or er.ergency centrol stations is free of fire damage.

The alternative ensures that fire damace to at least one train of equiprent necessary to achieve cold shutdown is limited such that it can te repaired within a reasonable tire (miner repairs with correnentsstoredensite).

J Pedifications required to meet Section III.G would not enhance fire protectico safety above that provided by either existing or prcresed alternatives.

Modifications required to meet Section III.G wculd be detrimental to overall facility safety.

2.0 EVALUATICN 2.1 Pest-Fire Shutdown Syster.s The evaluation of the post-fire shutdown system was based on the Appendix R fire protection regulatory guidance contained in PSC's August 17, 1984 letter. This letter is included as Appendix A to Report No. 1 (see Refer-ences la and 14) and reflects the guidance provided by the NRC staff for fires in congested cable areas and noncongested cable areas.

It was not'ed (see Figures 4.4 through 4.18 of Reference Ic) that some elec-trical cables for Train A and Train B components are located in close proximity within the same fire area (s). The licensee is rerouting some of these cables to improve separation, and it is expected that the electrical separation specified in the exemption requests and proposed modifications will be verified during NRC inspections, af ter modifications are complete.

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. 6-i 2.1.1 Congested Cable Areas The-criteria delineated in the regulatery guidance for fires in con-gested cable areas were based on the use of the Alternate Cooling Fethod (ACM). The congested cable areas are defined as the Control Room, 4E0 Volt Switchgear Room, the Auxiliary Electric Room, and the congested cable area along the "G" and 'T walls (see References 13 and 14). ,

The ACM is an independent, diesel driven, 2500 kW electrical generator with an associated distribution syster that is used to provide power to selected plant components through ranual transfer switches. Under ACM liner cooldown, the initial action is depressurization which must te initiated within approxinately 2 hcurs; other actions are not recuired for a much lenger tir.e period (e.g., 11: + cooling must be initiated within 28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br />), but can be initiated ruch sooner.

The ACM provides a source of Prestressed Concrete Peactor Vessel (PCRV) i Liner Cooling Water (LCW). The procedure used to place the ACM in operation is AOP 48-01.

The NRC appreval of the ACM is contained in the Safety Evaluations enclosed in License Arendrents 14, 18 and 21 (References 7, 8 and 9),

i Sincethelicensesstates(seeReferences4and5, Item 6.b)that ,

"the design, 1 cads and intent nf the ACF has not been modified sig-  ;

nificantly sirce its use was approved," no additional review or appreval was required.

2.1.2 hencongested Cable Areas The criteria delineated in the regulatory guidance for fires in non-ccngested cable areas were based on the requirerents contained in Section III.L cf Appendix R to 10 CFR Part 50. The application of these criteria that apply to Fort St. Vrain is specifically defined i in References 13 and 14. The limiting consequences require that, "For any single fire in a non-congested cable area, reans shall be available to shut down and cool down the reactor in a manner such ,

that no fuel damage occurs (i.e., maximum fuel particle temperature does not exceed 2900 degrees F). There shall be nc siruitaneous rup-ture of both a primary coolant boundary and the associated secondary containment boundary such that no untonitored radiological releases of primary coolant occur."

The reans proposed by PSC in Reference la and updated in Reference 18, to shut dcwn and cool down the reactor, consist of two trains (A and B) of post-fire shutdown systems which provide for reactivity control, PCRV integrity, and decay heat removal.

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d.1.2.1 Reactivity Control Reattor shutdown is accomplished by insertion of the 37 control rod pairs via a manually or automatically initiated reactor scram. A scram is acccirplished by interrupting the power supply to the Control Red Drive Mechanisms (CRCM's) ard their associated holding brakes which allows the control rods to fall by gravity into the core. Two Vide Range Nuclear Instruments (one per train) are utilized to monitor the core reactivity. In addition, the FSV design ircludes a Reserve Shut-dcwn System (RSS) which can be manually actuated to insert separate neutron absorbing material into the core for reactivity control.

Use of the RSS is covered by FSV Interin Technical Specifications, LCO's 3.1.4 and 3.1.6.

Since (1) there is a high degree of assurance that sufficiert reutron absorbing material can te inserted to make the reactor subtritical,

(?) there will be little effect on core reactivity except for tempera-ture changes, and (3) there are adequate provisions for monitorina the core reactivity, we find the reactivity control provisions to be acceptable.

2.1.2.? PCRV Intecrity The shutdown models rade the assumption that the integrity of the PCRV would be ensured by maintaining the decay heat removal function.

PSC subsecuently provided (in Reference 4) the results of a study which fcund that "the absence of liner cooling had no sicnificant effect on maximum fuel or orifice valve temperatures while forced cir-culation ecoling is functioning."

Ir addition to maintaining the structural integrity of the PCRV, the integrity of the various PCRV penetratiens must also be maintained to control the prirary coolant inventory. The majority of the penetra-tiers are through the top head of the PCRV. These censist of 37 CRLM and purificatien system penetrations. Steam generator and helium circulator penetrations are located in the bottom head, and the safety valves and instruments penetrate the sidewalls. All penetrations have a double closure design and are relatively unaffected by fires from a loss of integrity viewpoint. A surrnary of the PSC evaluations is contained in Reference la, Section 2.1. '

Based on the results of the above study, we find the PCRV integrity provtsions te be acceptable.

2.1.2.3 Decay Heat Removal (DHR)

The post-fire shutdown model for DHR proposed in References la and 18 consists of two trains of components which provide for core heat removal, prirary coolant inventory control, process r.onitoring, and secondary heat removal.

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a. Core Heat Removal

- The post-fire shutdown model contains the following flow paths for core heat removal:

Train A - Condensate Pump IC provides condensate ficw from the Condensate Storage Tank threugh a steam generator to atmosphere for the first S hours after shutdown. Thereafter, the flow frcm the steam generator is recirculated through the DHR Exchanger. The Condensate Pump 10 also provides flow through a heliun circulator, Train B - The diesel driven fire water pump provides flow from the main cooling tower thrcugh a steam gererator and a helium circulator. These flows are vented to the atrosphere and returned to the turbine building sunp respectively.

These flow paths are shown scheratically in Figures 2.1-8 and 2.1-9 in Reference 18, copies of which are included in this evaluation as Attachments 1 and 2. A discussion of various espects of these ficw paths is contained in the following para-graphs.

1) The electrical power supplies utilized are the ACM diesel generator (DG) for Train A components and Emergency Diesel Generator (EDG) set B for Train B components. The use of the ACM 00 was necessitated by the lack cf sufficient separatien between the A and B EDO electrical cables. The proposed ACM DG electrical ficw path runs from the 4160 volt ACM bus te the HVAC switchgear bus, to its feeder supply at the Reserve Auriliary Transformer, threugh the feeder to the 4160 volt switchgear Bus 2 where it can be cross-connected to either Bus 1 or 3. The 4160 volt buses provide pcwer to their associated, essential, 400 volt buses (1, 2, and 3). The ECG's provid power directly to the associated 480 volt essential tus; EDG A to Bus 1. EDG B to Bus 3. (These flow paths can be seen on Figure 8.2-5 of the FSV FSAR.)

The preposed reans to provide electrical power are acceptable.

The adequacy of procedures, testing and training will be verified during routine inspection activities.

-?) The effectiveness of the flev paths through the stear generators in the proposed post-fire shutdown rodel was

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questioned in Reference 3. The requested aralyses were subritted by FSC letters dated February 17, ISE7 (P-87055),

and May 1, 1987 (P-87158) (References 16 and 17). Based on a reviev ef the available inferr.ation, the conceptual designs of the flow paths are acceptable provided: (a) the above analysis verifies the effectiveness of the flow path, and (b) sufficient makeup water capability is demonstrated.

The review of these analyses will be the subject of a separate Safety Evaluation.

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3) The design of both Trains A and B utilizes the service water system. Train A includes the use of the DHR Exchanger to .

transfer the heat renoved from the primary coolant in the steam generator to the service water system. A discussion of the service water system is centained in a subsequent subparagraph (d) on secondary heat removal.

4) Both post-fire shutdown trains provide for the operation of one Helium Circulator to transport the heat in the reactor core to the stean generaters; Train A utilizes cendensate flow directly, Train B utilizes fire rater through the Emergency Water Booster Pump to drive the circulator's water turbine. A review of FSAR Section 14.4.2.1, indicates that "One helium circulator can provide nearly 4.ET of rated flow through the reactor core when operated by itself with ccndensate r:ter supplied tc this water-turbine drive."

However, for Train B, operating on boosted fire water, approxir.ately 3% of rated helium flow can be achieved.

Based on this information (References 16 and 17), the primary flow requirement can be met.

I The water used to drive the water turbine of the circulators discharges into the Turbine Water Drain Tank where it is removed by one of two Turbine Water Reroval Purps. The tank is common to both trains and the purps are located approxicately 5 feet apart; therefore, adequate separation is not maintained. However, the licensee has proposed to compensate for potential fire damage to both purps by posting a fire watch (Reference 22). The adequacy of this procedure will be verified during future staff inspections.

FSC will permanently install a third Turbine Water Removal Pur.p a mintrum cf 50 feet from the existing tank and pumps.

This pump will be used in norral plant operation and also meet the criteria of redundant Appendix R emergency shutdown equipment.

A review of the ability to operate the circulators with the proposed auxiliary equipment (see Attachment 3 for flow diagram) disclosed provisions for providing bearing water but not for providing a source of the buffer helium for shaft sealing. The PSC response (Reference 4, Item 8)

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addressing the acceptability of operating a circulator without buffer helium indicates that tests which were conducted shcwed that there would be little effect on either helium egress or water ingress. Therefore, the bearing water system is adequate.

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8-The rakeup source to the bearing water syster is frcm the condensate tanks via the Emergency Bearing Vater Makeup .

Purp for Train A and the nomal Bearing Water Makeup Purp for Train B, both of which can be cross connected. While the makeup systems cppear to be acceptable, the power supply cables lack the required separation. The licensee proposed modifications which will result in gieater physical separation of the cabics. These redifications have been reviewed and found acceptable as discussed in cur evaluation of the exemption recuest for the Reactor Building (Sec Section 2.9).

b. Prinary Coolant Inventory Control Primary coolant inventory is controlled by maintaining PCRV integrity. A discussion of PCRV integrity is contained in Section 2.1.2.2, above,

c. Process Monitorine The process monitoring function is required to confim PCRV integrity, core heat removal and secondary heat removal.

1) PCPV Inteoritv Monitorinc PCRV integrity can be tonitored by the use of pritary coolant pressure and temperature indications, if available. PSC has, however, recuested an exemption from ronitoring PCRV integrity in their request for exemption from the requirerents  ;

contained in Section III.G.? of Appendix R for the reactor building. The basis for this exemption request is adecuate.

?) Core Heat Peroval and Secondary Heat Pereval Monitorine Cere heat reeoval monitoring is proposed to be accomplished by monitoring prirary coolant flow in conjunction with secon-dary heat teroyal monitorirg (i.e., steam generator flow and exit terperature). Coolant flow is detected by moni-toring the differential pressure across the circulator; the secondary heat removal is detected by monitoring feedwater flow and steam generator exit terperature and pressure. 1 When questier.ed en the adequacy of this design, PSC responded  !

(Reference 4. Item 15) that if prinary flow could be confirmed.

heat would be transferred to the helium as it passed through

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the core, and that monitoring steam generator flew, temperature, and pressure would verify decay heat removal. The fledwater flow instruments have a range of 0-1,200,000 lb/br. and the condensate flow available is about 37 percent of the range.

Thus, accurate flow measurerent is possible.

In order to adequately monitor heat removal, PSC has proposed to only monitor the steam generator exit for constant or decreasing terperature at constant pressure. Since, the

governing parameter for the heat removal process is to rain-tain adequate subcooling margin on the steam generator .

cutlet, this proposal is acceptable.

In additien, the circulator flow instrurents lack the required separation and are included in the reactor building exemption reauest. The adequacy of the propcsed instrumen-tation bas been addressed in the exerption request evaluation (see Section 2.9).

d. Secondary Heat Peroval As discussed above, secendary heat is reroved in Train A through the use of the DPR Exchanger where the decay heat, which was transferred to the feedwater in the steam generators, is trans-ferred to the service water system. The service water medels are shewn scheratically in Figures 2.1-11A and 2.1-11B of Reference 18. These figures are included as Attachments 4 and 5.

1) The Train A service water (SW) syster utilizes a SW pump to provide flow fror the SW cooling tower through the SW strainer to the various system cooled coroonents or '*1 cads." The return path from these loads is back to the SW cooling tcwer where one nf the SV ccoling tower fans is operated to reject tFe heat tc the atmosphere. Makeup flew to the SW cooling tcher is provided from the domestic water supply. The SW purp and the tower fan can all be powered fron the ACM DG.

2) The Train B SW system utilizes a circulating water pump to provide ficu from the Main Cooling Tower tc the Sh system, through the various loads, and back to the tower. The licensee's evaluation of the need for operating a Main Cooling Tower Fan is contained in Reference 4. Item 5.

This evaluation, performed before the DHR Exchanger heat load was deleted from the Train B rodel, concludes that cooling assistance is not required. If cooling is desired, either (a) makeup water nay be added or (b) a fan may be operated.

3) PSC provided a discussion of single failure considerations for corponents commen to both proposed trains of SW in Reference 4, Item 1. In particular, the SW strainer and

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the flew control valves to the various loads were addressed.

Since these components are water-filled rechanisms which can be ranually operated, their use was determined to be acceptable.

2.1.3 Implerentatien of Post-Fire Shutdown Model The ability to physically implement the required flow paths for the post-fire shutdown trairs discussed in the preceding section was

also evaluated. This evaluation considered whether the flow paths were physically practical and if the flow paths could be established .

wittiin the required tire period.

2.1.3.1 Establishing Flow Paths A review of numerous facility piping and instrurentation drawings (Pt. ids) showed that the proposed flow paths were possible, but that nu.nerous interconnections and aligr.ments would be necessary.

In resporse (Reference 4. Item 2b) to questioning en why all valves necessary to complete the flow path were not included in the listings provided in Reference la, the licensee stated that only those manual valves whose positicr.s are required to be changed were listed. Further scme additional ranual velves which were PSC reviews added did identify (All power operated valves were checked, whether to the listings.

rcquired to change position or not.) The plant procedures do not require a check of valve positions cn a routine basis but only when returning a system to operatien following an outage. A further discussion of the PSC position, contained in Reference 10, states that the existing controls are adequate and that controls over non-Technical Specification systers/cceponents will be incorporated in the Fire Protection Progran.

The acceptability of the valve lineup surveillance will be evaluated during an NRC inspection.

The availability of the post-fire shutdown equiprent will be demonstrated through the Fire Protection Operability Requirements submitted to the MRC cn December 15, 1987, as part of the FSV Fire ,

Protecticn Prcgram Plan. PSC bas proposed demonstrating the  ;

operability of post-fire shutdown trains in a simulated post-fire l envircr.' rent to the extent possible. Whether or not adequate testing  !

and adequate walkdcwns have been perforred will also be determined I during an NRC inspection.

F.1.3.7 Manual Actions and Timing  ;

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, A concern was raised in Reference 3 that the numerous ranual actions  !

required to implement the post-fire shutdown models may require more manpower than would be available. The PSC response contained in Reference 4 (Items 12 ard 13) concluded that all required r,anual actions could be accomplished within the required time limit of 90 minutes by the nine personnel required to be on shift. The response stateT that although five perscnnel are dedicated to the Fire Brigade, the remaining four, operating independently for 85 minutes, could implement the post-fire shutdown model. It was noted that all actions

! were assumed to be mutually independent and that no supervision nor control room ronitoring had been considered. PSC agreed to perform a more realistic assessment of the manpower requirerents in Reference 5.

PSC has now provided for ter, personnel on shift and has made an  !

assessment of the manning recuired to accomplish required manual actions

-11 for each fire area (Reference 11). This includes control reem ranning.

Subject to ccnfirmation through NRC inspection efforts that procedures ,

and-training are adequate, we cenclude that the proposed staffing level is acceptable.

2.2 Exemption Request for Three Room Co,ntrol Complex and Diesel Generator Rooms 2.2.I Exerption Requested The licensee requested exemptions from the technical requirerents of Section III.G.2 of Appendix R to 10 CFR Part 50 in these areas to the extent that it requires that openings in ?-hcur rated fire barriers be protected with similarly rated fire dampers, doors, and penetration seals.

1.2.1.1 Discussion (ThreeRoomControlComplex}

The Three Rcce Control Complex has been considered as a single fire area. It houses the 400-volt switchgear room, the auxiliary electric ecuipment room, battery rocms, and the control room. The perimeter walls are constructed cf reinforced concrete ar.d have a 3-hcur fire rating. They have unrated dampers designed to close automatically when the Halen fire suppression system actuates. Dccrs in the Control D.oom were originally UL-labeled, 3-hour fire door asserblies; however, hardware has been changed and security modifications have been made.

As a result, these doors are not now considered 3-hour fire doers.

The penetration crenings in the Three Room Control Complex walls are sealed with both fire-rated and unrated penetration seals.

The walls feature sore steel columns which are partially erbedded within the walls. The exposed steel is unprotected inside the icwer two reor.s of the Three Room Control Complex proper. The steel columns in the control room itself are enclosed by concrete blocks. The steel columns are not an integral part of the concrete wall from the stand-point of structural integrity or fire rating. In the event nf a fire, the vertical loads carried by these steel columns will be transferred to the concrete walls and down to the foundations.

Existing fire protection consists of halon and water spray fire sup-pression systems in the 480-volt switchgear and auxiliary electric equipment rooms; a halon fire suppression system in the control room, a partial fire detection system in the control room and area-wide fire-detection systems in the rest of the Three Room Control Complex; and po~rtable fire extinguishers and manual hose stations. In addition, automatic water spray systems exist along the "G" and N" walls outside of the Three Room Control Complex. In Appendix R Evaluation Report No. 4, the licensee comitted to repair the docrs in the west wall of ,

the Three Room Control Complex and to upgrade the seals in the west l wall to be 3-hour fire rated.

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2.2.1.2 Discussion (Diesel Generator Rooms)

• l The diesel generator roces are considered as two separate fire areas.

They are bounded by reinforced concrete walls and ceiling having a fire resistance rating of at least 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. Several unrated darpers exist in the HVAC duct penetrations of these walls where they form a common boundary with the Turbine Building. The dampers were installed in conjunction with the existing carbon dioxide fire suppression system for each recm and are designed to close when the systen actuates. No unprotected penetrations exist in the commen wall between the diesel generators. Existing fire protection includes fire detection systers, the above-referenced automatic fire suppression systems, portable fire extinguishers, ard manual hose stations.

The licensee justifies the exemptions in these areas on the bases of the existing fire protection, the proposed modifications, and the ability te safely shut down the plant in the event of a fire.

2.2.3 Evaluation The technical requirements of Section III.G are not met in these locaticns because the penetrations of the 3-hour fire barriers are not all protected by doors, derpers, or penetratior, seals that have a 3-hour fire rating. In addition, there exists sore unprotected steel in the perimeter walls of the Three Room Control Cceplex.

We vere concerned that in the event of a fire of significant magnitude, products of cccbustion weuld pass through the wall and oamage redundant /

alternate shutdcwn systers en the other side. However, the aress on both sides of these walls are protected by automatic fire detection systens as described in the Appendix R Evaluation Report. These systems alarm in the control reem. Ve therefore expect that any potential ,

fire would be detected in its incipient stages before significant '

flare spread or room temperature rise occurred. The plant fire brigade L would then be dispatched and would put out the fire using ranual fire fighting equipment.

If rapid fire spread cccurred, the automatic fire suppression systers l would actuate to control the fire and reduce the rise in ambient terper-ature. Until this occurred, the existing walls which surround these areas would act to confine the effects of the fire to the area of origin.

Becau's4~ openings exist in the walls, we expect a quantity of smoke and hot gases to pass through ther and enter the adjcining locations.

But the smoke wculd be so dissipated and the hot gases would be cooled to the point where, in our judgment, they would not represent a sig-nificant threat to post-fire stutdown systems outside of the fire area.

2.2.4 Conclusion Based on our evaluation, we conclude that the licensee's alternate fire protection configuration, wi+.h the proposed rodifications, will

s 4 achieve an acceptable level of fire safety equivalent to that provided by Section III.G.2. Therefore, the licensee's recuest for exemption ,

fora complete 3-heur fire barrier in the Three Room Control Complex and Diesel Generator Roons should be granted.

2.3 Exemption Request for Control Room 2.2.1 Exerptien Recuested The licensee requested an exemption from the technical requirerents of Section III.G.3 cf Appendix R to 10 CFR Part 50 to the extent that it requires that a fire detection system be installed throughout a fire area that hes been provided with an alternate shutdown capability.

2.3.2 Discussion The control rocm is a separate room within the Three Room Control Complex. It is bounded by walls that have a 3-hour fire rating, except for the doors, dampers, and penetration seals which are evaluated in Secticn 2.2.

The principal fire hazard within the area consists of cable insulation and paper. Existing fire protection includes an areawide halon fire suppression systen, fire detectors in the control room cabinets and consoles, portable fire extinguishers, and manual hose stations.

l The licensee justifies the exerption en the basis of the existing prctection, the continueus presence of control room operators, and the ability te safely shut down the plant after the fire, independent of the Three Room Control Complex.

2.3.3 Evaluation The technical requirerents of Section III.G are not ret in this loca-tion because of the absence of a fire detection system that provides areewide coverage. ,

he were concerned that because of the absence of an areawide fire detection system, a fire could develop which would damage post-fire shutdown systens to the extent that the plant could not be safely shut down after the fire. However, the control room is continuously manned and autoratic smoke detectors are located in the control room cabinets and consoles. We, therefore, have reasonable assurance that a fire wculd be detected and suppressed by the control roem operators or the plant fire brigade early, before significant darage occurred.

If a serious fire developed, the existing halon fire suppression system would be tranually actuated to put out the fire or control it until the i plant fire brigade arrived.

If such a fire caused the loss of redundant post-fire shutdown systems, the Alternate Cooling Method is available to bring the plant to a safe l

e l1 shutdown condition. This ACM capability is physically and electrically independent of the Three Room Control Complex. Therefore, an areawide

• fi m detection system in the control rocm is not necessary to provide us with reascnable assurance that a fire would be detected and post-fire shutdewn capability maintained free of fire damage.

2.3.4 Conclusion Based on our evaluation, we conclude that the licensee's alternate fire protection configuration provides an acceptable level of fire sefety equivalent to that providcd by Section III.G.3. Therefore, the licensee's request for exemption for an areawide fire detecticn in the control room should be granted, f'

2.4 Exemption Recues,t for Turbine Building 2.4.1 Exemption Requested The licensee requested an exemption from the technical r>quirements cf Section III.G.2 of Appendix R to 10 CFR Part 50 to te extent that it requires that a fire detection system be provided *.nroughout a fire area.

2.4.2 D_iscussion The Turbine Building houses the secondary plant eouipment including such ccrponents and systers as the turbine generator, main condenser; steam, condensate, arc' feed systems; HVAC systems; and the emergency water booster pumps.

The building is essentially e three-level structure, except for the access control bay portion. It is constructed of insulated dual corrugated steel walls and a metal deck-type roof.

The principal fire hazards in the building consist of accumulations of lube oil, hydraulic oil, hydrogen gas, and cable insulation.

However, the locations which contain the largest concentration of these hazards are separated from the rest of the building by 2- or 3-hour fire-rated walls and ceilings, are protected by automatic ,

fire suppression systems, or both.

Existing fire protection includes partial fire detection and fire suppression systems, as discussed in Appendix R Evaluation Peport No. 4, manuaT hese stations, and portable fire extinguishers. In Report No. 4 the licensee committed to modify and extend the existing fire detection system detectors throughout the area of the first two levels of the turbine building and at elevation 4846 feet 6 inches of the access control bay. The fire detection system will be in accordance with the provisions of National Fire Protection Asscciation (NFPA),

Standard No. 72E.

The licensee ,iustifies this exemption en the basis of the existing fire protection, the proposed redifications, and the fact that there ,

are no post-fire shutdcwn systems in those locations where no fire detectors will be provided.

2.4.3 Evaluation The technical requirements of Section III.G.2 are not ret in this location because redundant, post-fire shutdown systens are not separated by more than 20 feet, free of intervening corbustibles. In addition, automatic fire suppression and detection systems are not provided throughout this area. Our evaluation of the separation and fire suppression issues is contained in Sections 2.5 and 2.10 of this repert.

Our principal concern with this exemption was that t'ecause of the absence of an areawide fire detection system, a fire of significant magnitude enuld develop and danage systers needed to safely shut down the plant. Hcwever, a fire detection system that reets the require-centr. of PWpA Standard i:o. 72E will be installed at every elevation of this fire aree that dces contain post-fire shutdown systems. If a fire shculd occur in these locations, we expect it to be detected by the system. An alarr veuld be transmitted automatically to the control room and the fire brigade wculd subsequently be dispatched. The brigade ,

would put out the fire using ranual fire fighting equipment.

If fire shculd break cut on the operating floor or the upper elevations of the Access Contrcl Bay, we expect it to be discovered, after some time delay, by plant operatnrs or the security fcrce. Until the arrival of the fire brigade, there are no post-fire shutdown systems that ceuld be damaged by fire in these locations. Therefore, an areawide fire detection system is not necessary to provide reascrable assurance that the pcst-fire shutdown capability will remain free of fire damage.

2.4.4 Conclusion Based on our evaluation, we conclude that the licensee's alternate fire protection configuration, with the proposed modifications, will achieve an acceptable level cf fire safety equivalent to that provided by Section III.G.2. Therefore, the licensee's request for exemptien for an areavide fire detection systen in the Turbine Building should be granted.

2.5 ExemptionTequest for Access Control B_ay 2.5.1 Exemption Requested  ;

The licensee requested an exerption from the technical requirements of Section 111.0.2 to the extent thet it requires that redundant ,

post-fire shutdown systems be separated by 20 feet free of intervening ccrbustible raterials or by a 1-hour fire barrier and that the area be i protected ty an autcratic fire 59ppression system and a fire detection  !

system.

i i

2.5.2 Discussion The- Access Control Bay is a multi-level structure which is part of the larger Turbine Building Fire Area. It extends upward frem eleva-tion 4046 feet, 6 inches to the roof at elevation 4938 feet 0 inches.

Three reinforced concrete floors and one partial steel grating floor further subdivide the Access Control Bay %cve elevation 4046 feet 6 inches. Within this structure, the liunsee has identified redundant ,

reactor plant exhaust fans, o elevation 4046 feet 6 inches, that are not protected per the requirements of Section III.G. The fans are separated from each other by about 18 feet, and there are no intervening cerbustibles.

The fire hazard in the Access Control Bay consists of charcoal, lubricating oil, and cable insulation which represent a fire load of about 20,750 BTV/sq. ft. This quantity of cerbustibles, if totally consumed, would produce an equivalent fire severity of about 16 minutes as determined by the ASTP E-119 time-temperature curve.

Existing fire protection includes ranual hose stations, portable fire extinguishers and autcmatic fire suppression over the charcoal filters.

In Appendix R Evaluation Report No. 4, the licensee comitted to install an autcratic fire cetection syster on elevation 4C46 feet 6 inches of the Access Control Bay. The system will be in accordance with the provisions of NFPA Standard No. 72E. In addition, the licen-see preposed to relocate cables and transfer switches to the Train A fan so that the switches are located at least 25 feet away frer its redundant Train B switch and cables are routed to each of the fans to enter from opposing directicns and thereby obtain the maxirum separaticn from the redundant cables of the opposite train.

The licensee justified this exerption en the basis of the existing fire protection and the proposed modifications. In addition, the licensee indicated that shculd these fans be damaged by a fire, alter-nate cooling is available through a chiller unit and recirculation fan that are located in another fire area.  ;

2.5.3 Evaluation

, Although the licensee requested an exerption from Section I!!.G.2, the requirements of Section III.G.3 apply because of the availability of th~e alternative Reactor Building cooling capability. The require-

~~

rents of Section III.G.3 are not met in the Access Centrol Bay because of the absence of an areawide fixed fire suppression system.

Our principal concern with the level of fire safety in this location I was that because of the relative proximity cf the reactor plant exhaust

fans, a fire cf significant magnitude would damage redundant post-fire

! shutdown systees to such an extent that safe shutdown could not be l

achieved and ma'.ntained.

i I

l 4

However, the fire load in this location is not significant and the combustible materials are dispersed thrcughout the elevation. If a .

fire should occur, it would be detected by the fire detection system in its incipient stages before significant flare propagation or room terperature rise occurred. The alarm would be autoratically transmitted to the control room. The fire brigade would then be dispatched and would put out the fire using ranual fire fighting equiprent. Pending arrival of the brigade, the effects of the fire would be mitigated because the smoke and hot gases would rise up into the high ceiling area, which would tend to act as a heat sink. Also, the fan motors and related cables would be shielded from the effects of a fire by the metal fan enclosures. Nevertheless, if a fire did damage both reactor plant exhaust fans, the licensee will be able to recover from this datase by relying upon a chiller unit and recirculation fan that is 1cceted in a separate fire area. Therefore, the fixed fire suppressior system is not necessary to provide reascnable assurance that safe shutdorn can be achieved and maintained.

2.5.4 Conclusion Based en our evaluation, we conclude that the licensee's alternate fire protection configuration, plus the proposed modifications, will achieve an acceptable level of fire protection equivalent to that provided by Section III.G. Therefore, an exemption for the absence of a fixed fire suppression system in the Access Control Bay should be granted.

2.6 Exenstion Pecuests_ for Outside Areas-Exterior Routino and , Turbine Reacter Buildines-Conmon Wall 2.6.1 Exe_mption Requested The licensee requested an exerption from the technical requirements of Section III.G 2 of Appendix R to 10 CFR Part 50 in these lccations to the extent that it requires a 3-hcur fire barrier to separate redundant / alternate snutdewn related systers in separate fire areas.

2.6.7.1 Ciscussion(OutsideAreas-ExteriorRoutingl The Alternate Cooling Method (ACM) diesel and certain ACM-related components are relied upcn as the emergency power source for post-fire  !

t shutdown Train A. The ACM diesel, transformers, plant 4-kV switch-gearr 4-kV HVAC switchgear, 4160/460-volt transformers, reserve auxil'Tary transformer bus, and ACM 4-kV switchgear are located outside of the Turbine Building. There is also ACM equiprent located in the Evaporative Cooler Building, east of the Turbine Building naar its southeast corner. ACM equipment in this building consists of the ACM batteries, ACM motor control center, and ACM 480-volt load center.

The Turbine Building contains the emergency diesel designated as the i;

energency power supply for post-fire shutdown Train B. Cabling and corponents as!.nciated with post-fire shutdown Train B are located

, within the Turbine Building.

l

Cabling from the ACM diesel feeding the 4-kV switchgear, and then routed to the 4160/480-volt transformers, is used as the ersergency ,

bactfeed to load centers in the Three Roem Control Complex to serve as the power supply for post-fire shutdown Train A. The cable routings up to the 4160/460-volt transformers are routed underground, with the excwption of overhead bus duct feeds between the 4-kV HVAC .

switchgear, reserve auxiliary transforcer, and the plant 4-kV switch-gear. Feeds from the transferrers into the Three Poem Control Complex are cpen, ventilated, bus ducts routed abcve around. These feeds pass along the east side of the Turbine Building wall.

The 4-kV switchgear is located south of the Turbine Building in the vicinity of the diesel generator rooms. The south wall of the diesel generator recrs is reinforced concrete construction. The 4-kV switch-gecr is 1ccated insice e separate metal enclosure that is accessed from the yard area. The a-kV switchgear enclosure is located approximately 8 feet south of the Turbine Building with open space in-between. Cabling within the 4-kV switchgear enclosure enters from undergreurd.

The reserve auxiliary transformer bus duct is also used as part of this ACM backfeed. The reserve auxiliary transformer is located out-side, approximately 20 feet from the Turbine Building. The closest post-fire shutdewn Train B compenent is the Train B emergency diesel generator. The crergency diesel generator room is a separate fire area, ard is separated fror the outside by a reinforced concrete wall.

An HVAC switchgear enclosure associated with ACV. is also located south of the Turbine Building, 7.5 feet from the building but more than 30 feet froni the nearest rest-fire shutdown corponents within the Turbine Building.

4 ACP corponents in the Evaporative Cooler Building are used as part of rest-fire shutdown Trcin A. The Evaporative Cooler Building is a separate fire area, since it is a separate building with exterior walls to the cutside. This building is separated from the Turbine Building by approximately 10 feet of open space, free cf intervening cortustibles.

Other components in the yard area associated with the ACM, when used for the Train A erergency power supply, are the ACP diesel ACM trans-former, and the ACM 4-kV switchgear. These structures are located more;than 100 feet east of the Turbine Building.

2.6.2.2 Discussion (Turbine /Reacter Buildings-Cerron Wall)

The Turbine Building and Reactor Building are considered as two separate fire areas. The conron wall between these two areas is constructed of corrugated steel. All openings in this wall are sealed so as to raintain the pressure differential required for the Reactor Building. Redundant shutdown post-fire equipment that is located en l

)

- t

-19 both sides of the wall and is separated by at least 35 feet. Existing ,

fire protection includes fire detection and fire suppression systems, .

rantial hose stations, and portable fire extinguishers, as described in Appendix R Evaluation Report No. 4.

The licensee justifies the exemptions on the basis of the existing fire protection, the spatial separation between post-fire shutdcwn systems, and the ability of the non-rated walls to provide a degree of passive fire protection until any potential fire is extinguished.

2.6.3 Evaluation The technical requirerents of Sections III.G.? and III.G.3 are not met in these locations because normal post-fire shutdown systems are not separated from their redundant counterparts or the systems t associated with the alternate cooling method by a 3-hour fire-rated tarrier.

Our principal concern was that a fire of significant magnitude may result ir damage to components associated with the normal post-fire stutdown systems and the alternate cooling rethod.

If a fire were to occur.in the above-referenced cutside locations, a potential exists for components associated with the ACK to be damaged.

Fevever, because these areas are located cutside and away from the nerrai post-fire shutdown systems located within the Turbine Building, we do not expect the products of combustion or radiant energy from 4

such a fire to affect the norral post-fire shutdown systems. Smoke and hot gases would tend to be dissipated in the open air. Radiant energy would be mitigated by the intervening open space and by the exterior walls of the Turbine Building.

Simila ly, if a fire were to occur inside the Turbine or Reactor Puildings, we expect the fire to be detected by the automatic fire detection systems, plant operators, or the security force. The fire vculd either be extinguished manually by the plant fire brigade or by the automatic fire suppression systems. Because these locations are  ;

large open plant areas, the smoke and hot gases from such a fire might ,

a spread within each area. But it is our judgment that the retal and  !

1 masonry valls which bound these fire areas are capable to a significant extent of confining the effects of the fire to the immediate fire area..until the fire is extinguished. Because these walls are not all tire-rated, some products of corbustion may spread beyond them.

However, the sricke and hot gases would be cooled ard dissipated so

< that there will be no threat to the redundant / alternate post-fire

shutdown systems in the adjoining fire areas. Therefore, complete 3-hour fire-rated walls are not necessary to provide reasonable

~

assurance that post-fire shutdown conditions could be achieved and maintained with undamaged systers in the other fire areas.

. s 2.6.4 Conclusion Based on our evaluation, we conclude that the licensee's alternate fire protection configuration will achieve an acceptable level of fire safety equivalent to that achieved by corrpliance with Sections III.G.2 and III.G.3. Therefore, the licensee's recuest for exemption for a 3-hour fire wall between the Turbine Building and the Reactor Building and cutside areas should be granted.

2.7 Exemption Requests for Alterna,te Cooling Method /Co,ngested Cable _

Area Interface 2.7.1 Exemption Reques,ted_

The licensee requested an exerption from the technical recuirerents of Section III.G.2 of Apperdix R to 10 CFR Part 50 to the extent it requires that redundant postafire shutdown-related systems be separated  :

by more than 20 feet free of intervening combustibles and the area bc protected by autcratic fire detection and suppression systers.

2.7.? Discussion Cabling associated with pcst-fire shutdown corponents passes through the ecngested cable areas (CCA) outside of the "J" and "G" walls for the Three Room Control Complex and then into the Three Poom Control -

Complex. For a fire at these locations, safe shutdown would be achieved using systercs associated with the ACF. In general, ACP corr-ponents and cabling are located in other fire areas cutside of the Peactor and Turbine Buildings. Post of the cab 1?s and components for the ACK that are located in the Reactor and Turbine Buildings are incated rore than 40 feet away from the congested cable area. For those systems that are located less than 40 feet from the CCA, des-cribed in Appendix R Evaluation Report No. 4, the licensee has identi-fied other systers that could be employed to achieve safe shutdown.

The principal fire hazard in these ACM CCA interface areas is cable irsulation. Hcwever, the areas of cercentrated quantities of cables are protected by autcratic sprinkler systers. In addition, these locations are protected by fire detecticn systers and are provided with portable fire extinguishers and manual hose stations.

The licensee justified this exerption on the basis of the existing fire' protection, the spatial separation tetween post-fire shutdown systirTs, and the availebility of a number of systers that could be relied upon to achieve and raintain safe shutdown after a fire.

2.7.3 Evaluatinn The technical requirerents of Section III.G are not ret in these loca-tiens because the alternate shutdown capability is not physically and electrically independent of the fire area.

. s v

1

• Our principal concern with the level of fire safety in these locations was that a fire of significant magnitude might damage systems associated ,

with both the manual shutdown capability ard the alternate cooling method. There is no majcr unmitigated fire hazard in these locations.

The only significant hazard which would represent a threat to shutdown systems is the concentration of combustible insulation on the cables.

However, these cable concentration areas are protected by autcratic sprinHer systems. The suppressien systems along the "G" and "J" walls were originally designed for manual actuation. Hewever, at our recuest, the licensee converted these syster.s to automatic actuation.

We acknowledged that this conversion wculd not ccmpletely conform to the guidelines of NFPA Standards 13 and IE. But, it was cur judgment that en at.tcmatic syster would achieve a higher level cf protection. l The interface areas will be protected by an autcmatic fire detection syster thet reets the requirerents of NFPA Standard No. 7PE. As a result, we expect any potentiel fire to be detected early, before significant firc prcpagation or room temperature rise occurs. The fire would then be extinguished by the plant fire brigade using ranual fire fighting equipment. If rapid fire spread cecurred, we expect the autcratic wet pipe sprinkler systers to actuate ard limit fire spread, rederate room temperature rise, and protect the rest-fire shutdewn cables along the "G" and "J" walls. Until the arrival of the fire brigade, the spatial separation between pcst-fire shutdown f.ystems provides passive protection to prevent damage to redundant /

elternate post-fire shutdown systems. For those systers which are not sufficiently separated, the licensee has identified alternate means of achieving and maintaining safe shutdown that would not be affected by a fire.

2.7.4 Cor.clusion Based en our evaluatien, we conclude that the licensee's alternate fire protection ccnfiguratien will achieve an acceptable level of '

fire safety equivalent to that achieved by corpliance with Section III.G. Therefore, the licensee's request for exerptien in the ACM CCA Interface Areas should be granted.

i 2.8 Exemption Request for Energency lighting l

2.8.1 Exemptior Pequested The 11ces w: requested an exemption frem the technical requirerents of Se~ction !!!.J of Appendix R to 10 CFR Part 50 te the extent that it requires er .mency lights to be powered by irdividual 8-hour battery packs.

2.8.2 Discussion The plant is presently equipped with hard-wired, essential /ernergency

backup lighting systems powered frem the standby diesel generaters  !

j and the plant DC syster. However, these systems are not sufficiently 1

independent so that they would be available in the event of a fire, i

-??- t In Appendix R Evaluation Report No. 4, the licensee connitted to a install a new system for the Reactor and Turbire Puildings. Outlying , :

stmetures requiring access for post-fire shutdown functions that '

are not covered by ACM-pewered lights will be covered by 8-hour battery lights. The new erergency lighting system will have the following attributes:

1. Viring and lights configured so that multiple physically separate systems would result with each system ccvering a zene or quadrant.

Lighting equipment in each zone will be separated by a minimum cf 20 feet frcm that of another zone. Loss of any cne zone because cf a postulatea fire would be compensated for by the lights in the adjacent zones, including permanently installed but movable "exten- l sien lights" where necessary;

2. Separate and independent power feeds for each zone covered;

3. Electrical pcwer supplied frcm the ACM diesel; 4 Breaker ccordination so th'at only one circuit would fail given the loss of any ene indivinal light unit, or e single fault such t as due to a fire;

5. A minimal number of lights per circuit so that the lighting availability loss wculd be minimized given a circuit loss;

f. A mix of local area lights and spot flocd beams plus extension lights where necessary; 1

7. Receive a field check /walkdown to confirm adequate nur.ters. l locations, and positioning of lights.

Essential valve operators or equiprent components recuiring manual operator actier(s) will be covered by local zone lighting and/or spot teams. Therefore, if a fire failed the local circuit, the spot beams frcr a distance greater than 30 feet would still be functional. In addition, extension li S hts will be available in selected areas where  ;

valves are 1ccated in upper galleries.

The licensee justifies this exerption on the bases that the proposed rew lighting syster provides en equivalent level of emergency lightirg to individual 8-hour battery packs. l 2.8.3 Evaluation The technical requirements of Section III.J are not ret in the Reacter and Turbine Buildings because the new emergency lights are not powered by individual 8-hcur batteries. ,

i l

I

l We had two concerns with the proposed emergency lighting system in these buildirgs. The first was that a sufficient number of lights .

would not be installed so as to provide an adequate level cf illumin-ation. Hewever, all essential valves and equipment corponents requiring l

manual cperator actions, and access and egress routes thereto, will i be covered by the local zere lighting and/or spot bears. In addition,

, at etr request, the licensee in Appendix R Evaluation Report No. 4, l comitted te verify the adequacy of the illurination by conductino I

a field valkdown with plant cperators to confirm the adequacy of the turbers, locations, and positioning of the lights.

The second concern was that a fire could damage the power supply to l

the erergency lighting. HowcVer, the new system is designed in such l a manr.er that a fire in any one :ene would not affect the emergency lighting in adjacent zones. Therefore, individual 8-hcur batteries for each emergency light are not necessary to provide reasonable assur-ence that sufficient emergency lighting would be available to complete post-fire shutdewn functions.

2.8.4 Conclusion Based on our evaluatien, we conclude that the licersee's a ternate configuration will achieve an acceptable level of safety, eauivalen*

to that achieveo by compliarce with Section III.J. Therefore, the licensee's recuest for exemptien for individual 8-hcur battery powered ertrgency lighting in the Reactor and Turbine Buildings should be granted.

2.9 _Exerptien Pecuest for Reactor Building 2.9.1 Exemption Requested The licensee requested an exerption from the technical requirements of Section III.G 2 of Apperdix R to 10 CFR Part 50 to the extent that it requires that redundant post-fire shutdown systems be separated by 20 feet free of intervening corbustibles and be protected by automatic fire detection and suppressior. systers.

2.0 ? Discussion The Reactor Building is a single fire area. It contains redundant corponents and cables associated with the turbire water removal purps, bearing water pumps, primary coolant and steam generator instrurenta-tion',_ It also contains Train A components and cables associated with the erergency bearing water rakeup punp and Train B cceponents and cables associated with the bearing water makeup pump.

The principal fire hazard in this location consists of hydraulic oil associated with the hydraulic pcver units and over the helium circulator-turntable. Additional combustible materials include lubricating oil and cerbustible cable insulation.

Existing fire protection includes automatic sprinkler systems for the hydraulic oil fire ha:ards and cable concentration areas, manual hose

l o 4

-24 I stations, and portable fire extinguishers. In Appendix R Evaluation i Report No. 4, the licensee connitted to irstall a fire detection system ,

to provide areawide coverage of the Reactor Building below the refueling e ficor in a ma iner that reflects the potential preblem of smoke stratifi-cation. The licensee also ccmritted to reroute certain post-fire shutdown cables to achieve at leest 50 feet of horizontal separatien er 30 feet of separation if an intervening floor exists between redur. dant systems except as identified and evaluated in this Safety Evaluation. A third turbine water renoval purp, permanently installed l

e minitun of 50 feet frer the existing tanks and purrs, will also be provided to compensate for the potential less cf redundant turbine water reroval pumps on elevation 4740 feet 6 inches.

l The licensee justified the exemption en the existing fire protectien, the prepcsed modificaticos, and the spatial separation between redundart pcst-fire shutd~.m systcms. ,

?.9.3 Evaluatiog The technical requirer.ents cf Section Ill.G.2 are not ret in the Reactor Euilding because the intervening space between redundant post-fire shutdnwn systems contains scre corbustible material. In addition, the fire detecticn system dces not extend to the refueling floor and i abose, and the existing sprinkler systers do not provide areawide ccverage. 1 Our principal concern was that a fire of significant ragnitude would ,

i dar.aSe systers associated with redundant post-fire shutdewn retheds.  ;

Fewever, the rajcr fire hazards in this area are covered by an autcratic fire suppressien system. Consequently, a fire involving these hazards weeld be nitigated by the syster. Peraining combustible raterials are gerere11y dispersed threuphout the remainder of the area. As a result, a fire involving these materials veuld be of limited magnitude ,

ard ex. tent and would be characterized, initially, by low flane propaga-tion and arbient terperature rise.

If a fire did occur, it would be detected early by the fire detection systers. Where no detectors have been provided above the refueling floor, no shutdown systems exist. Upon actuation of the detection system or discovery of the fire by plant personnel, the control room would be notified and the f be brigade dispatched. The fire would then be either suppressed manually, using portable fire fighting equiprent, nr automatically, if the fire originated in the sprinkler area.'~Until the fire is controlled, the spatial separation between post-fire shutdown systems, which in part extends over more than ene ficor elevatten, will provide reascnable assurance that a post-fire shutdown capability will remain free of fire damage.

2.9.4 Conclusion l

Based on our evaluation, we conclude that the licensee's alternate l fire protection configuration, with the comitted modifications, will  !

i .

J j provide an acceptable level cf fire safety, equivalent to that achieved  !

by coepliance with Section III.G.2. Therefore, the licensee's request .

l for exemption in the Reactor Building should be granted.

2.10 fxe,rJtio M e,qu,est q for Turbine Puilding  ;

1 i 2.10.1 Exerption Requested The licensee requested an exemption frcm the technical requirerents  ;

cf Section !!!.G 2 of Appendix R to 10 CFR Part 50 te the extent that ,

it requires that the redundant post-fire shutdown systems be separated  !

I by r. ore than 20 feet of intervening combustibles and be protected by

autoratic fire detection ard suppression systers. [

t 2.10.2 Discussion ,

i The Turbine Building houses the secondary plant equiprent including [

! such corponents and systers as the turbine generator, main condenser, '

steam, condensate and feed systems, HVAC systems, and the erergency water teoster pumps.

! In Table 3.11-1 ef the Appendix R Evaluation Report No. 4 the licensee idertified the post-fire shutdewn systems which de rot meet the separ-j ation requirements cf Secticn Ill.G. The licensee comitted to either:

1) rercute fire-vulnerable cables outside of the fire area, or 2) j protect ore post-fire stutdewn train by a 1-hcur fire barrier, or 3)

I rercute fire-vulnerable cable to achieve at least 30 feet of horizontal  ;

j separatice with sore intervening cables frcm its redundanf alternate j

ccunterpart. For any other fire vulnerable cables or systers, the i i licensee has identifiec a redundant rear.s cf achieving rest-fire '

i shuttern if these systets were lost because of a fire.

The licer.see juttifies the exerption en the bases of the existing fire protection, the prepcsed redifications, the spatial separat1cn between post-fire shutdown systems, ard the availability of a nurber of different systers that would be. relied upon to achieve and maintain post-fire shutdown en ;itions.

l 2.10.3 Evaluation The technical requirements of Section Ill.G are not ret in this area l

tecause redundant post-fire shutdown syster.s are not separated by were i than'.20 feet free of intervening corbustibles. In addition, auton.atic

< fire suppression and detection systens are not provided throughout the a rea . We evaluated the lack of areawide fire detection in Section 2.4 of this safety evaluation.

i Our principal concern was that a fire of significant ragnitude would damage systers associated with redundant pcst-fire shutdown methods.

4 Hewever, the rajor fire hazards in this area are covered by an auto-

. matic fire suppression system, or are separated by fire walls, or I

1 4

_ . - . . . - _..m . . . , _ . _ _ . _ - . - - , -. _ - - , _ , _ _ _ , _ _ _ - -

both. Consequently, a fire involving these hazards would be nitigated by the protection. Remaining combustible materials are generally -

dispersed throughout the remainder of the area. As a result, a fire involving these raterials would be of limited ragnitude and extent and would be characterized, initially, by low flame propagation and ambient temperature rise.

If a fire did occur, it would be detected early by the fire detection system. Where no detectors have been provided, no post-fire shutdcwn systers exist. Upon actuation of the detection system or discovery of the fire by plant personnel, the contrcl room would be notified and the fire brigade dispatched. The fire would then be either suppressed manually, using portable fire fighting equipment, or automatically, if the fire originated in a sprinkler area. Until the fire is cen-trolled, the spatial separation between rest-fire shutdown systers, which in part extends over rore than one floor elevaticn, will provide reasonable assurance that a post-fire shutdown capability will remain free of fire cr age.

2.10.4 Conclusion Based on our evaluation, we conclude that the licensee's alternate fire protection configuraticn with the comitted modifications, will provide an acceptable level of fire safety, ecuivalent to that achieved by ccr.pliance with Section III.G.E. Therefore, the licensee's request for exemption in the Turbine Building should be granted.

2.11 Building 10 Building 10 is a new structure, erected subsequent to our "Appendix A" fire protectier evaluation. It is located east of the Control Ccrplex and is connected with it by a bridgelike walkover structure. The exterior walls are constructed cf reinforced concrete. The floors are concrete on earth or concrete on metal panels. The roof is constructed of concrete on retal panels. The building has been divided into six firo areas occupied for offices, computer rooms, electrical and rechanical equipment roces, and related areas. Fire protection includes fire detection systems, halon fire suppression systems, and portable fire extinguishers.

In Appendix R Evaluation Report No. 4, the licensee identified one deviation from the technical requirecents of Section III.G.2 of Appendix R to 10 CFR Part 50. ,The licensee requested approval of an exemptien from these require ents to the extent that they require that structural steel which is part of a fire barrier be protected so as to achieve a fire rating equivalent to the rating of the boundary. The structural steel is part of a 3-hour fire wall that separates two rooms that contain redundant post-fire shutdown systens. The licensee justifies the exemption on the basis of the low fire loading and the exiiting automatic fire protertion.

The rooms on both sides of this wall are equipped with an automatic fire detection system. If a fire should occur, it would be detected in its

i ,

formative stages before significant temperature rise occurs. The fire would then be put out manually using portable fire extinguishers. If rapid .

fire spread occurred, we expect the automatic fire suppression system to actuate to control the fire. The system has sufficient extinguishing agent for a manually initiated second discharge if the fire was not com-pletely extinguished after the first discharge. Until the fire is extinguished, and consice-ing the low fire loading (ecuivalent to a 15-minute duratiun on the ASTM E-119 time temperature curve), it is our judgrent that the unprotected steel will rer.ain undamaged and the integrity of the fire wall will be traintained. We, therefore, conclude that the licensee's fire protecticn configuration will provide an equivalent level of fire safety to that achieved by compliance with Section III.G. Therefore, the Mcensee's request for exemption for unprotected structural steel should ta granted.

At our requcst, the licensee also submitted, in Report No. 5, dated May 1985, a ccrparison of the fire protection for Building 10 to the guidelines of Appendix A tc ETP APCSB 9.5-1. The licensee has indicated that the guidelines pertaining to the provisien of a standpipe system, yard hydrant, fire hose, and related equipment are not applicable to Building 10. We were concerned that in the event cf a fire in those arels not protected by an autcmatic suppression system, the licensee would not have a readily available means to apply water frcm hose streams onto the fire. However, the fire brigade wculd be able to bring hcses from either stations in the turbine building or a yard hydrarit near the builfi ng. The licensee has cerfirmed this capability by test. On this basis, we consider this issue closed.

In the trip rercrt dated September 12, 1983 which documented the results of an NFC site audit, we stated that the licensee did not have within its organi:aticn or as a consultant a qualified fire protection engineer

' responsible for the formulation and implementation of the fire protection prog rar.. However, by letter dated October 16, 1986 (Reference 21), the licensee informed the staff of the addition of a fire protection engineer to the PSC staff. He is responsible for the develeprent of the Fire Protec-tien Program Plan ar.d is the Program Manager of the Fire Protection Program.

On this basis, the staff considers this issue closed.

2.12 Licensee Coments By letter dated January 16, 1987 (Reference 19), the licensee provided cements regarding the staff's November 18, 1986 draft safety evaluation.

In generah these corrents have been reflected in the final safety evaluation. '

However, the staff's description of 'ae licensee's comitment regarding '

the proposed emergency lighting system for the reactor and turbine buildings re..ain the same as in the original draft. The licensee was concerned that the staff has interpreted the ccmitment to provide separate and independent power feeds for each emergency lighting zone to rean that independent power sources will be provided. The staff recognizes that the alternate cooling method (ACM) diesel will be the only source of power for the new anergency 1

l

lighting system. The pcwer feeds to the individual zones will, bewever, be designed such that no two adjacent zones will be affected by any fire. '

The ste" finds this concept acceptable, and no further clarification to the drait safety evaluation is necessary.

3.0 ENVIRONMENTAL CONSIDERATION

S Pursuant to 10 CFR 51.30, the staff concludes the following about the listed factors:

(1) The need for the proposed actions is described above; (2) The alternative to the exemptions would be to require literal compliance with Section IV.F. of Appendix E to 10 CFR Part 50. Such an action would not enhance the protection cf the environr.ent and would be adverse to the ,

public interest generally; i s

(3) The issuance of the exerptions, or their denial, would not  ;

affect the envirenrertal impact of the facility; and (4) No consultation with cther agencies or persons is reeded.

Based on the abcVe assessment, the NPC staff concludes, pursuant to 10 CFR 51.37, thet the issuance of these exemptions will have no significant impact en the environment (52 FR 36319, September 28,1987),

d.0 CONCLUS10t!S 4.1 Post-Fire Shutdcwn Systens i

The concepts subritted by the licensee for providing post-fire shutdown j under fire considerations are adequate and therefore, acceptable. The  ;

remaining aspects identified herein will be addressed during inspection  ;

activities, and in confirmatory analyses as discussed in Section 4.3. i l

4.2 Exemptions Based on our evaluation, we conclude that the licensee's existing fire )

protection configuration, with the proposed modifications, achieves an  ;

equivalent level of safety to that attained by compliance with  !

Sections III.G and III.J. Therefore, the licensee's request for i exerptions in the following areas should be granted:  ;

1. Three Rocm Control Ccmplex (Fire Barriers)

2. Control Room (Fire Detectors)

3. TurbineBuilding(FireDetectors) l

4 Building 10 (Structural Steel)

5. Acc1ss Control Bay (Separation Requirements)

6. Exterior routing of shutdown cabling

7. ACM CCA Interface Areas (Separation Requirements)

8. Corren Vall-Turbine Buildirg/ Reactor Building

9. Reactor Building (Separation Requirerents)

10. Turbine Building (Separation RecJirements)

11. Diesel Generator D.coms (Fire Barriers)

12. 8-hcur battery pack energency lighting 4.3 Confirmatory Evaluations As noted in Section 2.1.2.3(a)(2), PSC has submitted aralyses addressing the effectiveness of the ficw paths through the steam generators (for decay  ;

heat removal). The staff has requested it's contractor, Oak Ridge National '

Laboratory, to review these analyses. These evaluations will be considered confirnattty ar.d will be reported in a separate Safety Evaluation.

Dated: May 10, 1988 Reviewers: D. Kubicki, DPWRL-8, HRR R. Ireland, Region IV R. Fullikin, Region IV Attachments:

1 Figure 2.1-8

2. Figure 2.1-9

3. Figure 2.1-10 4 Figure 2.1-IIA

5. Fig: re 2.1-IIB p e=

l 4

3

References

1. Appendix R Evaluation:

a. Report No. 1, Shutdown Model, November 16, 1984 (Rev. 6)

b. Report No. 2, Electrical Peviews, December 17, 1984 (Rev. 4)

c. Report No. 3, Fire Protection January 17, 1965 (Rev. 4)

d. Report Mc. 4, Exerptions and Modifications, April 1,1985 (Rev. 2)

2. Fire Hazards Analysis ard Evaluation of Building 10 to the BTP 9.5-1 Appendix A Guidelir.es, Report No. 5, May 31, 1985 (Rev. 1).

3. NRC letter, Butcher to lee, dated November 1, 1985.

4. PSC letter, Walker to Berkcw, dated December 20,1985 (P-85488) .

5. PSC letter, Walker to Berkcw, dated March 14,1986(P-36209).  ;

6. PSC letter, Kaiker to Berkcw, dated April 4, 1986 (P-86266).

7. License Ar.endrent No. la with NRC letter, Cer.ise to Walker, dated June 18, 1976.

8. License Arendment No. 18 with NRC letter, Denise to Fuller, dated October 28, 1977.

9. License Arendment No. 21 with NRC letter, Camrill to Millen, dated June 6,. 979.

10 PSC letter, ',:3rembourg to Berkcw, dated May 15, 1986 (P-86307).

11. PSC letter, Killiams to Berkcw, dated July 15,1986(P-86462).

12. PSC letter, Cabr to NRC (LER 86-020), dated August II, 1986 (P-86513).

13. NRC letter, Vagner to Lee, dated June 4, 1984

14. PSC letter, Lee to Johnson, dated August 17,1984(P-84281).

15. hRC letter, Crutchfield to Williars, dated August 3, 1987.

16. PSC letter, Brey to Berkow, dated February 17,1987(P-87055).

17. PSC letter, Brey to Calvo, dated May 1, 1987 (P-87158).

18. PSC letter, Warembourg to Calvo, dated May 15,1987(P-87167).

19. PSC letter, Villiams to Berkov, dated January 16,1987(P-87013).

i

. r .

20. PSC letter, Williams to Calvo, ' dated Decerrber 15,1987(P-87422).

~

21. PSC letter, Williams to Berkott, dated October 16,1986(P-86572).

Additional updates to References 1 & 2 were provided in:

PSC letter, Lee to Johnsen, dated August 30, 1985 (P-85301).

PSC letter, Lee to Hunter, dated September 26,1985(P-85341).

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