ML18040A795

Forwards Response to NRC Concerns Re Plant Fire Protection Program,Including Criteria for Fire Protection of Safe Shutdown Sys within Fire Zone Not Complying W/Requirements of Section Iii.G & Analysis of Associated Circuits

ML18040A795
Person / Time
Site:	Susquehanna
Issue date:	12/18/1985
From:	Keiser H PENNSYLVANIA POWER & LIGHT CO.
To:	Adensam E Office of Nuclear Reactor Regulation
Shared Package
ML18040A797	List: ML18040A795 ML18040B129
References
PLA-2566, NUDOCS 8512230165
Download: ML18040A795 (24)

Text

REGULATORY. FORMATION DISTRIBUTION SY M (RIDS)

ACCESSION NBR;8512230165 DOC ~ DATE+ 85/12/18 NOTARIZED: NO DOCKET FACIL:50 387 Susquehanna. Steam Electric Stations Unit 1-, Pennsylva 05000387 50-388 Susquehanna Steam Electric Stationp Unit 2'g Pennsylva 05000388 AUTH ~ NAME . AUTHOR AFFILIATION KEISERrH.WE Pennsy)vania Power L Light Co, RECIP,NAME RECIPIENT AFFILIATION ADENSAMgE, BWR Project Directorate 3 sc ~p+

SUBJECT:

Forwards response to NRCconcerns re,plant fire protection program~including criteria for fire'rotection of sys within fire zone not complying w/requirements safe'hutdown; of Section III,G analysis of associated circuits.

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TITLE: OR Submi t tal: Inadequate Core Cooling (Item II ~ F.2) GL 8?<<28 NOTES: 1cy NMSS/FCAF/PM. LPDR 2cys Transcripts. 05000387 QL:

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07/17/82'cy 05000388 OLe03/23/84 RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL BWR PD3 PD 1 1 BWR PD3 LA 1 1 CAMPAGNONE 2 2 INTERNAL; ACRS'RR 17 10 10 ADM/LFMB 1 0 BWR D IR 1 1 NRR BWR PD1 1 NRR PWR A DIR 1 1 NRR PWR B DIR 1 NRR SHEA,J 01 2 2 NRR/DHFT DIR 1 1 ~

NRR O DIR 1 1 NRR/ORAS 08 1 1 OQ 1 1 RGN1 07 1 1 EXTERNAL: 24X 1 1 LPDR 03 2 2 NRC PDR 02- 1 1 NSIC 06 1 1 NOTES: 3 3 TOTALS NUMBER OF COPIES REQUIRED: LTTR 30 'NCL 33

Pennsylvania Power 8 Light Company Two North Ninth Street ~ Allentown, PA 18101 ~ 215 / 770.5151 Harold W. Keiser Vice President-Nuclear Operations 21 5/770-7502 DEC 18 1985 Director of Nuclear Reactor Regulation Attention: Ms. E. Adensam, Project Director BWR Project Directorate No. 3 Division of Licensing U.S. Nuclear Regulatory Commission Washington, DC 20555 SUSQUEHANNA STEAM ELECTRIC STATION RESOLUTION OF FIRE PROTECTION PROGRAM CONCERNS ER 100450 FILE 841-2,143 Docket No. 50-387 PLA-2566 50-388

Dear Ms. Adensam:

This letter is provided in response 'to the NRC staff's concerns regarding the Fire Protection Program at Susquehanna SES. Specifically, it addresses the concerns regarding the criteria for fire protection of safe shutdown systems within a fire zone which does not comply with the requirements of Section III G and analysis of associated circuits within fire zones outside the control room. Summary reports addressing each of these concerns are attached.

PP&L has initiated the development of a computerized Appendix R safe shutdown analysis program. We will compare the results from this program with the work which we have completed to date. This program, in addition to giving us a firm and auditable analysis by shutdown path, would also enhance our ability to maintain our Appendix R commitments and allow us to expeditiously evaluate the effects of plant changes with respect to these commitments.

We do not anticipate significant changes in the information previously submitted to you. We expect this comparison to be completed by the Fourth Quarter 1986 or the First Quarter 1987. If any plant modifications should be identified in this comparison process, we will discuss their implementation schedule with you. We will maintain our previously committed schedule for completing the already identified plant modifications.

Very truly yours, H. W. Keiser Vice President-Nuclear Operations cc: M. J. Campagnone NRC R. H. Jacobs NRC

SUSQUEHANNA STEAM ELECTRIC STATION UNITS 1 & 2 FIRE PROTECTION PROGRAM APPENDIX R SUGARY REPORT FOR CONCERN $/2' CRITERIA FOR FIRE PROTECTION OF SAFE SHUTDOWN SYSTEMS WITHIN A FIRE ZONE WHICH DO NOT COMPLY WITH THE REQUIREMENTS,OF SECTION, III.G DOCKET NOS. 50-387 50-388 851223016 )

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SUSQUEHANNA STEAM ELECTRIC STATION UNITS 1 & 2 FIRE PROTECTION PROGRAM CONCERN 82 DOCKET NOS. 50-387 50-388

SUMMARY

REPORT INDEX PAGE SECTION

1.0 INTRODUCTION

........................................ 1 SECTION 2.0 METHODOLOGY UTILIZED ................................ 1 SECTION 3.0 ASSUMPTIONS & NRC GUIDANCE .......................... 2 SECTION 4.0 LISTING OF DEVIATIONS ............................... 2 SECTION 5.0 RESULTS ............................................. 3 SECTION 6.0 IDENTIFICATION OF MODIFICATIONS ..................... 5 SECTION 7.0 SCHEDULE ............................................ 5 SECTION 8.0 COMPENSATORY MEASURES ............................... 6 SECTION

9.0 CONCLUSION

.......................................... 6 APPENDIX A DEVIATION REQUESTS APPENDIX B TABLE: FIRE AREAS VS DEVIATION REQUESTS

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SUSQUEHANNA STEAM ELECTRIC STATION UNITS 1 & 2 FIRE PROTECTION PROGRAM DOCKET NOS. 50-387 50-388

SUMMARY

REPORT CONCERN 82: CRITERIA FOR FIRE PROTECTION OF SAFE SHUTDOWN SYSTEMS WITHIN A FIRE ZONE WHICH DO NOT COMPLY WITH THE RE UIREMENTS OF SECTION III.G (Deviation Request Response)

1.0 INTRODUCTION

As a result of audits performed in the first quarter of 1985 on the Fire Protection Program at Susquehanna Steam Electric Station (SSES), the NRC, in a letter dated April 18, 1985, issued a statement of their concerns related to the SSES Fire Protection Program. Subsequently, PP&L issued a letter numbered PLA-2482 dated June 11, 1985, which described each of the NRC concerns and delineated the description of the concern, a description of PP&L's method of resolution of the NRC concern and a description of PP&L's deliverables to the NRC. All of these items were discussed with and agreed to by the NRC staff.

The intent of this report is to provide a resolution to Concern 82, Criteria for Fire Protection of Safe Shutdown Systems Within a Fire Zone Which Do Not Comply With the Requirements of Section III.G, by identifying all applicable deviation requests. Justification is provided to show that a commensurate level of protection has been provided to assure safety is achieved and deviations from 10 CFR 50, Appendix R, Section III.G are acceptable.

2. 0 METHODOLOGY UTILIZED PP&L, has reviewed each Fire Area identified in the Fire Barrier Analysis and applied the methodology as described below:

a) Each specific requirement of 10 CFR 50, Appendix R, Section III.G was identified.

b) Specific guidance and information from Generic Letters 83-33, and 85-01 and Information Notice 84-09 was listed with the appropriate Appendix R requirement.

c) Fire protection features for each fire area which contain essential safe shutdown raceways, were compared to each Appendix R requirement and related guidance in order to determine compliance.

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d) When a Fire Area was found to be in compliance, the methods of compliance were documented.

e) Deviations from requirements were identified and data to describe the Fire Area and support the justification for the deviation was collected.

f) Deviations requests were written.

OR g) Additional analysis was performed or corrective action was identified as an alternative to preparing deviation requests.

3.0 ASSUMPTIONS AND NRC GUIDANCE 3.1 This response was based on the following NRC documents.

a) 10 CFR 50, Appendix R, Section III.G b) NRC Generic Letter 83-33 c) IE Information Notice 84-09 d) NRC Generic Letter 85-01 3.2 The following assumptions were used in formulating this response.

3.2.1 Fire Areas as identified in PPGL response to Concern f/1 Unrated Fire Barrier Analysis (PLA-2529, September 4, 1985) are acceptable. Changes to those fire areas may change these exemption requests.

3.2.2 It was assumed that the requirement for fire suppression in 10 CFR 50, Appendix R III.G.3 applies to both III.G.3a and III.G.3b.

3.2.3 It was assumed deviations from NFPA codes which concern the detection system monitoring functions and control room response do not require a deviation request. These deviations have already been identified in Section 3.2, Item 95 of the Fire Protection Review Report Revision 1 and 2.

3.2.4 It was assumed that all existing fire rated barriers (1.5, 2, and 3 hrs.) which were approved by NRC in SER Rev. 0 are acceptable as fire area boundaries.

4.0 LISTING OF DEVIATIONS 4.1 Previous deviation request numbers 1 through 7 were submitted on September 4, 1985 (PLA-2529) as PP&L's response to NRC Concern //1 and 4b.

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4.2 The NRC has previously approved two exemption requests. We have assigned the request for "One-Hour Wrap Without Sprinklers for Fire Zones 1-2D, 0-2B and 0-28H", dated February 9, 1982, (PLA-1013), as Request 88. The request. for "Spacing Closer than 20 feet Without a 1-Hour Wrap for Equipment in Fire Zone 2-5A" dated December 13, 1983 (PLA-1985) as Request 89. These were approved by the NRC in SER Supplements 734 and /36, respectively.

H 4.3 Request /310 concerns a future plant modification related to the fifth diesel generator installation which will be transmitted separate from this response.

4.4 Appendix A to this 'report contains the remainder of PP&L's deviation requests.

5.0 RESULTS 5.1 As described in Section 4.0, Deviation Requests 11-23 contained in Appendix A to this report and previous requests 1 through 9, comprise PP&L's response to NRC Concern //2, Criteria For Fire Protection of Safe Shutdown Systems Within a Fire Zone Which Do Not Comply With the Requirements of Section III.G.

5.2 The following conditions were identified through our analysis. The specific actions to bring each condition into compliance are given below:

A) Condition:

Fire Zones 0-26M and 0-26R contained essential safe shutdown raceway. The raceway separation satisfy the requirements of Regulatory Guide 1.75. The physical arrangement of the cable chases precluded transient combustibles. Fixed C02 fire suppression was provided. This configuration was previously

. used as a justification for not protecting the essential safe shutdown raceways with a one hour fire rated barrier.

Action:

These zones are now part of Fire Area CS-9 (Control Room) which uses alternate shutdown paths. Fire Zone 0-26M and 0-26R were reanalyzed to assure that cables in these zones did not prevent safe shutdown using Alternate Shutdown Paths as analyzed for the Control Room Analysis. As a result of this analysis supporting Concern No. 4b a deviation request is not required.

The following raceway in fire zone 0-26R will be wrapped with a 1-hour barrier:

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B) Condition:

Fire Zones 2-5A, 1-3A and 1-4A contained some raceways not wrapped from "wall to wall" and these raceways are not encompassed by Deviation Request t/13.

Action:

The raceways in Fire Zone 2-5A were reanalyzed and protection is not required for the following raceways:

E2PK43 F2P375 E2PK44 F2P773 E2P373 F2P774 F2P803 The following raceways which are not completely wrapped with a fire rated barrier between fire zone boundaries will be provided with a fire rated wrap from wall to wall:

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Hour required because there are no sprinklers.

F1M434 1W300 F1KL12 13 14 15 FlKH12 13 14 15 1-4A F1K017 C) Condition:

Fire Zones 1-5B and 2-5B contained both Division I and Division II Core Spray Valves and Cable. These fire zones contained low combustible loading and a 6-foot separation was considered justified.

Action:

Since this condition and its justification does not support the conclusions drawn for these fire zones in the Fire Barrier Analysis, we have decided not to submit a deviation request.

These zones have been reanalyzed to demonstrate other safe shutdown paths are available. This will result in a change to the descriptions of Fire Zone 1-5B (RCIC path to be added) and 2-5B (HPCI Path to be added) in the Fire Barrier Analysis Report.

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The following additional raceway will be wrapped to assure the availability of the HPCI Path for Zone 2-5B and the RCIC Path for Fire Zone 1-5B. '

Zone 1-5B JB1253 E1K053 E1K489 Zone 2-5B E2KK24 E2KK25 E2KK26 E2KK27 E2K1C8 D2P006 D) Condition:

Fire Area CS-7 contains a minority essential raceway. The low combustible loading, separation of raceways in accordance with Regulatory Guide 1.75, limited space for transient combustibles, and fixed CO fire suppression was the previous justification for not providing a 1-hour fire rated barrier.

The loss of the minority raceway would result in the loss of the Division I Switchgear Cooling Fan control circuit.

Action:

This fan can be started remotely using the interim procedures provided as a result of Control Room Fire Analysis which was our response to NRC Concern 84b. Therefore, a deviation request will not be submitted, and the permanent modification for the fan circuits as outlined in the Control Room Analysis Concern i4b will be'mplemented to also correct this problem.

6.0 MODIFICATIONS The only modifications identified are the raceways which require additional wrapping and were identified in Section 5.2.

7.0 SCHEDULE Any modifications committed to in this report will be accomplished in accordance with the schedule provided below. The commitment date is tied to the end of outage referenced. Actual dates provided are for outage time frame reference only. This is the same schedule identified in our response to NRC Concerns 1 and 4b (PLA-2529, 9/4/85).

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UNIT COMPLETED BY REFERENCE DATE Modification in End of Unit //1 October 23, 1987 Unit Pl & Common 3rd Refueling Outage Modification in End of Unit f/2 April 29, 1988 Unit 82 2nd Refueling Outage 8.0 COMPENSATORY MEASURES Compensatory measures currently in place will remain in place until all identified modifications are completed.

9.0 CONCLUSION

Upon completion of the identified modifications and with the acceptance of all deviation requests identified herein, the NRC's concerns related to Concern F2, Criteria For Fire Protection 'of Safe Shutdown Systems Within A Fire Zone Which Do Not Comply With the Requirements of Section III.G, will be resolved.

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SUSQUERQHHR'S~ ELECTRZC STATZCH UNZTS 1 & 2 PZRE PROTECT+ Paar+ - CONCERN S2 DOCKETS NO i 50-387 50-388 APPENDXX A DEVXATZON REQUESTS

DEVIATION REQUEST NO. 11 PAGE NO. 1 APPENDIX R DEVIATION RE UEST HVAC PENETRATIONS REACTOR BUILDING FIRE WALLS DEVIATION RE VEST:

We request approval of the following:

Fire rated walls between fire areas which have a combustible load (in-situ and transient) on both sides of the wall of one hour or less are acceptable as Fire Area Boundaries without fire dampers installed in the horizontal ventilation ducts that penetrate the walls.

FIRE AREAS AFFECTED:

This deviation applies to any fire wall where the fire loading [in-situ and transient] on each side of the wall is less than 1-hour.

REASON FOR DEVIATION RE UEST:

NRC guidance to 10 CFR 50 Appendix R Section III.G.2 requires that fire areas shall have three hour barriers, and such barriers shall have fire rated dampers installed at duct penetrations. Various fire walls within the Unit 1 and Unit 2 Reactor Building have ventilation system (HVAC) duct penetrations without fire dampers thus rendering the rating of the barrier less than three hours.

EXISTING CONDITIONS:

The maximum combustible loading [in-situ and transient] is less than 1-hour.

JUSTIFICATION:

The National Fire Protection Association "Fire Protection Handbook" (14th edition, page 7-64) states:

"In the gauges commonly used, some sheet metal ducts may protect an opening in a building construction assembly for up to 1-hour, if properly hung and adequately fire stopped. Therefore, ducts passing through fire barriers having a rating of up to 1-hour fire resistance can be assumed to present no extraordinary hazard. If the wall, partition, ceiling or floor is required to have a fire resistance rating of more than 1-hour, a fire damper is required

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DEVIATION REQUEST NO. 11 PAGE NO. 2 The 18-gauge minimum ducts used at Susquehanna are heavier than the commonly used gauges referred to by the NFPA Statement. The ducts are seismically hung and adequately fire stopped.

A 1-hour fire test of horizontal steel ducts without a fire damper at the fire wall penetrations was conducted by Underwriters Laboratories using ASTH E-119 criteria. The test confirms the validity, of the NFPA statement. The test report is Attachment Number 1 to this request.

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