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PA.C IF IC G-A.S A.ND ZLZC TR IC C O MPH.NT77 BEALE STREET, 31ST FLOOR ~ SAN FRANCISCO, CALIFORNIA 94106 ~ (415) 781-4211

JOHN C ~ MORRISSKYVICE OSESIDENT AND OENECAL COUNSEL

MALCOLMH. PLIRSUSHA550CIATE OEHECAL COVK5EL

CHARLCS T VAN DCVSCN, PHILIP A, CRANC, IIR.HCNRY J, LDPLANTCRICHARD A, CLARIIC

JOHN 0, S IDIONARTHVR L, HILLMAN,J R,

ROSCRT OHLSACHCHARLCS W THISSCLL

AIINTaPT CtataaL CDSSIu

November 13, 1978OIL~ IPT L HAPSICEDLENN Wa ~ T JSsass oaavsose LuscoctJACC E TAllsee JS~ EaNASD J OELLAOANTA

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Mr. John F. Stolz, ChiefLight Water Reactors Branch No. 1Division of Project Management ..U. S. Nuclear Regulatory CommissionWashington, D. C. 20555

Re: Docket No. 50-275-OLDocket. No. 50-323-OLDiablo Canyon Units 1 S 2

Dear Mr. Stolz:In response to informal Staff inquiries, attached

are 40 copies of: (1) revised responses to the NRC fireprotection review questions 5, 8, 9, 21, 23, 24, 26-29, 45,46, and 49-51 which supersede in part the responses in ourletters of February 6, 1978 and August 3, 1978; and (2) arevision to the report entitled "Supplementary Informationfor Fire Protection Review" which was attached to our letterof July 7, 1978. The revised part of each response is shownby a vertical bar in the right margin.

Five copies of this submittal have been sentdirectly to Mr-. Dennis Allison,-along with the five limiteddistribution sets of hand color-coded drawings d'or questions9, 26 and 5lss

Kindly acknowledge receipt of this material on theenclosed copy of this letter and return it to me in the en-closed addressed envelope.

qs11B1.OI< It 'ry truly yours,

EnclosuresCC w/encs.: Mr. Dennis Allison

Service List

Q.5 Substantiate the fire resistance capability of the following items byverifying that their construction is in accordance with a particulardesign that has'een fire tested.a. Rated fire barriers, including hatch covers and fire doors.b.. Fire barrier penetration seals, including containment penetrations.c. Fire stops in cable trays.d. Ventilation fire dampers. Provide a typical drawing showing how they

are installed in the ventilation ducts that penetrate rated firebarriers of safety related areas.

Also'dentify the design and the test method used and acceptance criteria.The design as tested should be representative of field installation.

Revised Res nse

a ~ Concrete walls

Concrete walls, floors, ceilings, and hatches, consisting 'of Portlandcement, sand, and aggregate, are heavily reinforced and minimumthickness is one foot. As specified in the 1976 edition of theUniform Building Code, Section 43, Table No. 43-B, Item No. 34, awall one foot thick would have a four hour fire rating.

Concrete block walls

Concrete block walls, consisting of expanded slag, aggregate,- are aminimum of 7 5/8" thick and are filled with grout and reinforced withNo. 4 bars at 16" on center. As specified in the 1976 edition ofthe Uniform Building Code, Section 43, Table 43-B, Items Nos. 30-33,a concrete block wall 7 5/8" thick would have a four hour fire rating.Construction is similar to "UL design No. U901, assembly rating - 4hours, bearing or non-bearing."

G sum wallboard artition

These walls consist of metal studs with two layers of 5/8" fire codeGypsum wallboard on one side and one layer of 1" Gypsum wallboard onthe other side. This assembly is rated for 2 hours based on testsperformed by the University of California on March 4, 1975. This typeof fire barrier,was used to. upgrade the exterior walls in the 4~electrical area of the turbine building.

Metal lath and plaster

All walls consist of 16 gauge metal studs at 16" on center with 3/4"Bypsum plaster on 3.45 diamond mesh on both sides. As specified inthe Gypsum Association Fi e Resistance Desicn Manual. 1978 Edition.this assembly (GA file No. HP 1725) is rated for two hours based onUnderwriter ~ ab's fire test UL R4024-9, 10, January 1967 ~ Thisassembly is similar to Item No. 64 in Table 43-B of the UniformBuilding Code, 1976 edition (two-hour rating).

Res nse to .5 - Continuation

Two-hour rated metal lath and plaster fire barriers are used inthe following areas at Diablo Canyon.

1. To separate the 4KV cable spreading rooms from the corridorta the west (turbine building, elevation 104').

2. To separate the lab area (zone 4-A) from the access controlarea (zone 4-B), auxiliarly building, elevation 85'.

3. To separate the computer rooms (zones 8-A and 8-D) form thecontrol room (zone 8-C) .

P rocrete 102 artitions and fire roofin of structural steel

Wall and deck fireproof design of 2". thickness qualifies for threehour fire rating based on the interpolation from small scale thermaltransmission testing done at an independent. testing laboratory. A

copy of the test report is attached. Applications in which Pyrocreteis used within the plant are:

l. The three hour fire barriers that separate the component coolingwater heat exchangers from the rest of the plant.

2. As a portion of the barriers-that separate the component coolingwater pumps from each other.

3. As'a portion of the barriers that separates the turbine drivenauxiliary feedwater pump from the motor driven auxiliary feedwater

pumps'.

As. barriers to isolate banks of safe shutdown conduits from theirenvirons (for example, in the 12kV switchgear room, fire zone 10).

5. To'upgrade certain corner seals in walls that are part of firebarriers.

Structural steel fireproof design meets U.L. design No. X716 (installedthickness of 7/8", qualifies steel for three hour fire rating) .Structural steel in the 4kV switchgear rooms is fireproofed 'withPyrocrete.

Metal lath and laster fire roofin of structural steel (su erstructurerotection)

,4 3/4" Gypsum-Perlite plaster over 3.4I metal lath. This assembly israted for three hours per U.L. fire test R3187-4,5,7, design 6-3 orX402, July 30, 1952.

Res onse to .5 — Continuation

Ventilation duct fire roofin

Metal lath and plaster ventilation duct fireproofing consist of3/4" Gypsum plaster over 3.45 diamond mesh. As specified in theGypsum Association Fire Resistance Design Manual, 1978 Edition,this assembly (GA file No. CM-1300) is rated for one hour based ontest 92/40 performed. by, Building Material and Structures, NationalBureau of Standards-, October 1942. This assembly is similar toItem No. 17 in Table 43-A of the Uniform Building Code, 1976 Edition(three-hour rating for one-inch Gypsum plaster over metal lath) .

In those safety-related, areas where the ventilation ducting hasbeen fireproofed, the duct supports will also be fireproofed. Theduct supports will have the same fire rating as the ducts themselves(except that the rating will be for fireproofing structural steel,not ducting).

Hatch covers

Hatch covers are either one foot thick concrete (rated at four hours)or one inch thick steel (no fire rating). The steel hatch coversprovide adequate fire resistance in the, areas: in. which they arelocated.

Fire doors

The ratings of all doors that are part of fire barriers defining firezones are shown on the attached fire zone drawings. In some situations,specialized requirements for doors preclude the doors from being U.L.labeled. These situations are summarized below:

1'. Certain exterior steel rolling doors "are unlabeled due to their size,but were manufactured to "A" label specifications.

I

2. Some exterior steel rolling doors cannot"be labeled due to a personnelaccess door built into the rolling door. Safe shutdown equipmentis not located close to any of these doors and the exterior firehazard in the vicinity of these doors is negligible.

3, The auxiliary saltwater pump room doors are required to withstandthe effects of a tsunami and be water tight. This type of doorconstruction has not been fire tested. The doors are satisfactoryfor the low fuel loading in the area, especially considering thateach auxiliary saltwater pump is in its own compartment.

4. A door that also acts as a missile barrier separates the dieselgenerators- from the turbine bay. The door is of heavier constructionthan an "A" labeled door, but is unlabeled.

Res onse to 0.5 — Continuation

5. The doors and associated panels between the turbine building andthe penetration area act as blow out panels for main steam linebreak pressure relief in the penetration area. The doors and panelare of three hour construction but "A" labeled latching mechanismswould interfere with their blow out function. The doors and panelsdo have closure devices that keep them normally closed.

6. In some areas monorails for equipment removal penetrate the firedoors (for example, the RHR pump room doors are built to "A" labelspecs., but are unlabeled due to the penetration). It is feltthat the sealed monorail penetration does not significantly degradethe effectiveness of the fire door. None of these doors are locatedin areas with any significant fuel loading.

7. Certain ventilation fan room doors have sliding plexiglass pressurerelief windows built into them to enable the door to be openedwhen the ventilation equipment is operating. As such, these doorsdo not have a fire rating. However, without the sliding windowthese doors would be equivalent to "B" labeled doors. The minimalfire hazard in the vicinity of these doors does not warrant a doorwith a fire rating. Locations where those door" are used in firebarriers are:

a. The door to the Unit 1 auxiliary building supply fan room(zone 8-B-1) from stairwell fire zone S-2.

b. The doors to the corridors adjacent to the auxiliary buildingand fuel handling building exhaust fan rooms (zones 3-P-3,3-P-4, 3-P-5, 3-P-6, 3-P-7). These doors are not part of fanroom fire barriers.

c. The door from zone 3-P-2 (area outside of fan rooms containingventilation ducting) to zone "31 (fuel handling buildingcorridor) .

8. In some areas, doors are unlabeled because their fire ratingat the time of purchase was not felt to be relevant due to thelow fuel loading environment in which they are located. However,many of these doors are equivalent to "B" labeled doors and are sodesignated on the attached drawings. PGandE has on recordcertification from the manufacturer that these doors are builtto the specification of a labeled door.

9. Doors leading to the stairwells inlabeled doors or are equivalent toreasons explained in No. 8 above) .accordance with NFPA Standards for

all cases are either "B""B" labeled doors ( or theThis door rating is in

stairwells.

Res onse to .25 — Continuation

10. Some of the doors in the auxiliary building mechanical equipmentareas and the 4kV electrical equipment area in the turbinebuilding are, either "B" labeled or equivalent to "B" labeleddoors. The 4kV electrical equipment area is separated from therest of turbine building by a three hour barrier with "A" labeleddoors. The low fuel loading within these areas does not warrantreplacement of these doors to attain an "A" rating.

ll. Certain fire zones have access openings which also serve asventilation flow paths. In these situations, it is not possibleto install fire doors in the access openings. Areas in whichthis occurs are the: (a) component cooling water pump rooms;(b) one of two RHR heat- exchanger compartments; (c) the recipro-cating charging pump room (all areas are at elevation 73 ft. inthe auxiliary building); and (d) the spent fuel pool heat exchanger,pump, and filter area (fuel handling building, elevation 100 ft.).Automatic sprinkler protection and smoke detectors will be providedfor the component cooling water pump rooms and the charging pumprooms (the RHR heat exchanger room adjoins the centrifugal chargingpump room). The spent fuel pool equipment is not required forsafe shutdown. The opening to this room leads to an open cooridorin which automatic sprinkler protection will be orovided and smokedetectors will be provided for the spent fuel pool equipment room.

12. The openings between fire zones 1-A and 1-B within the containmentdo not have doors but do have shielding barriers. No crediblefire could propagate from fire zone 1-A into fire zone 1-B. Withinfire zone 1-B, a reactor coolant pump oil fire would not spreadto fire zone 1-A because the RCP oil collection and drainage shieldwill contain the oil (along with preventing oil spillage onto hotpiping). There is no other credible fire within fire zone 1-Bthat could propagate to «ire zone 1-A.

As a result of PGandE's review of its fire protection program,in excess of 80 doors have been replaced at Diablo Canyon toattain labeled fire doors in fire zone boundaries. Thoseremaining doors that are unlabeled have been evaluated and arefelt to provide adequate fire protection for the hazards inquestion.

Res onse to .5 - Continuation

b. Pi e enetration seals

As discussed in our response to Question 18, three hour rated penetrationseals will b'e provided for the containment pipe penetration.

Pipe penetrations through fire barriers are sealed with materialssubjected to a three hour fire test in accordance with ASTM E-119-1973.Test reports are provided in our response to Question 33.

Electrical enetration seals

Containment electrical penetrations consist of 12" or 24" diameterschedule 40 pipe sleeves five feet long through the concrete contain-ment. Electrical conductors run inside the sleeves. At each end ofthe five foot long sleeve the electrical conductors pass through steelheader plates and are completely encased in self-extinguishing epoxy.The assembly of steel and epoxy is approximately four inches thick. Theepoxy has been tested in accordance with Method 2021, Federal Test MethodStandard No. 406 (identical to ASTM-D 635 test for flammability ofrigid plastics). The space within the sleeve between the two seals ispressurize6with dry nitrogen. The cabling is enclosed in steel junctionboxes at end'f the penetration sleeves and is run in steel conduitfrom there. For a fire to propagate through the containment, it wouldhave to breach the junction box, progress through the steel header plate,burn along five feet of electrical conductor in an oxygen free atmosphere,progress through the other steel header plate and the other junction box.While not having a specific fire rating, these containment penetrationsare felt to be adequate fire barriers.

Electrical penetrations through fire barriers (other'han containment)are either sealed with,grout, or silicone",'foam. -The silicone foam hasbeen subjected to a three-hour fire test in accordance with ASTM-E-119-1973. The grout used is a fine aggregate concrete and as such has thesame fire rating as concrete. The grout is injected to completelyfill the void in the fire barrier between the electrical conduits andthe poured concrete walls. The configuration of the grout and/orsilicone foam is such that the electrical penetration seals havethree-hour ratings.

c. Fire sto s in cable .tra s

All safety related electrical cabling is run in conduits except in thosefire zones that containonly one redundant electrical division (specifically,the 4.16kV cable spreading rooms, the D.C. switchgear and inverter rooms,and the 480V vital switchgear rooms). In all other areas of the plant,cable trays contain only non-safety related cabling. Cable tray firestops are installed at intervals of 4 feet on vertical trays, 10 feeton horizontal trays, and within 5 feet of cable tray crossings. Allcable entrances to the cable spreading room, control ro'om areas, andinter-connecting cable entrances between these two rooms are sealed.

Res onse to . 5 - Continuation

Cable tray fire stops are made 'of Dow Coxning Q3-6548 siliconefoam (refer to our response to Question 33 for test reports).For vertical cable trays, Marinite boards surround the siliconefoam to prevent ignition of the cabling above the fire stop.The Marinite boards extend out eight inches in all directionsfrom the cable tray.

Fire tests of cable tray fire stops in horizontal and verticalorientations were conducted by PGandE's Department of Engineering

,, Research in 1975. A 300,000 BTU/hr. flame was applied to'ignitethe cable insulation on one side of the fire stop. The test wasterminated once the cable insulation on one side of the fire stopwas completely burned (approximately 20 minutes). The fire stopsprevented the spread of fire to the other side of the fire stopfor both the horizontal and vertical cable trays.

d. Ventilation fire dam ers

Ventilation fire dampers are U.L. listed with a fire rating oflb hours (the maximum U.L. listing for fire dampers). Procurementspecifications for the ventilation system called for fire dampers ~

and not fire doors, therefore, the U.L. label is for 14 hours.The manufacturer of the fire dampers has indicated that none oftheir product line had been tested in excess of 14 hours. However,he felt the fire dampers would pass a fire test in excess of 14hours.

The areas in which fire dampers are used as part of fire zoneboundaries are predominantly electrical equipment areas. The14 hour rating for the fire dampers is felt to be sufficient;three hour fire doors are not warranted for these low fuel loadingareas.

Attached is a drawing showing typical fire dampers.

It is believed that the field .installation of ..all the above items doesnot deviate significantly from the test installations. Manufacturer'sinstructions'nd guidance, when provided, were followed to the extentpracticable.

If any additional fire testing of materials is to be done by PGandEfor Diablo Canyon, NRC will be allowed to review the test proceduresand witness the testing.

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FireRating

SoundRating

STC

GAFileNo. DETAILED DESCRIPTION

Aih ~ ~i Afh

VJALLS AND INTERIOR PARTlTloNS, NONCOMBUSTjBLEr.

Fire Sound

Q.~kmSKETCH AND DESIGN DATA

WP 1725

'Construction Type: Gypsum Plaster, Metal Lath, Metal Studss/q" 1:1, 1:1 fibered gypsum sand plaster applied over 3.4 lb.metal lath wire tied at right angles to each side of 2i/q" openweb metal studs 16" o.c. (NLB)

Thickness: 4>/4"LimitingHeight: 11'2"Approx. Weight: 16 psfFire Test: UL R4024.9, 10, 1.5 67

WP 1830

Construction Type: Semi-Solid Gypsum WallboardBase layer >/q" type X gypsum wallboard or veneer base ap.plied parallel to each side of 1~/a" x 6" type X gypsum boardstuds 24" o.c. with laminating compound combed over entiresurface of gypsum studs and 2" type G drywall screws at24" o.c. to studs. Face layer >/q" type X gypsum wallboard orveneer base applied parallel to studs on each side v ith lami.nating compound combed over entire contact surface and2" type G drywall screws spaced 24" o.c. into gypsum studs.Edges secured to top and bottom channels with li/q" type Sdrywall screws 24" o.c. Stagger joints 24" o.c. for each layerand side. (NLB)

Thickness: 3s/q"LimitingHeight: 14'0"Approx. Weight: 10 psfFire Test: UC,2.862

2HR

35to39

WP 1840

Construction Type: Solid Gypsum WallboardOne layer >/q" regular gypsum wallboard or veneer baseapplied with laminating compound over entire surface toeach side of 1" laminated, interlocking, gypsum coreboard.Stagger joints 24" o.c. each layer and side. (NLB)

Thickness: 2"LimitingHeight: 11'0"Approx. Weight: 9 psfFire Test: Ul R3564

Design U508, 3.24 53Sound Test: See WP 1310

WP 1850

Construction Type: Solid Gypsum WallboardOne layer >/q" type X gypsum wallboard or veneer baseapplied parallel to each side of 1" tongue and groove gypsumcoreboard with laminating compound combed over entiresurface. Stagger joints 24" o.c. each layer and side. (NLB)

Thickness: 2"LimitingHeight: 11'0"Approx. Weight: 9 psfFire Test: OSUT-1339,4 8 60Sound Test: See WP 1310

/

. WP 1930to

'4

Construction Type: Gypsum Plaster, Solid Metal Channel,Metal Lath

2>/q" solid 1:2.1:2 gypsum perlite plaster applied over eachside of 3.4 lb. metal lath wire tied to one side of s/q" coldrolled channels 16" o.c. embedded in pIaster. {NLB)

Thickness: 2i/q"LimitingHeight: 12'"Approx. Weight: 12 psfFire Test: UL R3453, 2.13.52

3HR

35to39

WP 2450Construction Type: Gypsum Block, Gypsum Plasteri/a" 1:3 gypsum-sand plaster applied over both sides of 3"thick hollow gypsum block. {NLB) Thickness: 4"

Approx. Weight: 21 psfFire Test: OSU T-118.27, 28,

7.18.50

Qi

TABLENO. 43 B-RATED FIRE RESISTIVE PERIOOS FOR VARIOUS (VALLSANO PARTITIONS>-Continued

MATERIALITEM"

NUMBER CONSTROCTION' Hr. 3 Hr. Hr.

huNIMVMFINISHEO THICKNESSFACE.TO

FACE'In

Inches)

Solid PerliteandPortlandCement

54

Perlitc mixed in thc ra!io of 3 cubic feet to 100 pounds of portlandcement and machine applied to stud side of I Y: niesh by No. 17gauge paper. backed woven wire fabric lath wire. tied to 4 deepsteel trussed wire'tuds 16 on center. Wire ties of 18 gaugegalvanized steel wire 6" on center vertically

3yi'olid

NeatiVoodFiberedGypsumPlaster

SolidGypsumWallboardPartition

Hollow(Studicss)Gypsum'wallboardPartition

55

56

57

58

r/i" by No. 16 gauge cold-rolled channels, 12" on center with 2.5.pound flat metal lath applied to one face and tied with No. 18gauge wire at 6" spacing. Neat gypsum plaster applied each side

One full.length layer Y('ype "X"gypsum wallboard laminatedto each side of I" full length V-edge gypsum coreboard wi(happroved laminating compound. Vertical join(s of face layerand coreboard staggered at least 3"

One full.length layer of /','ype "X"gypsum wallboard attachedto both sides of wood or metal top and bottom runners laminatedto each side of I'x6'ull-length gypsum coreboard ribsspaced 24" on center with approved laminating compound. Ribscentered at vertical joints of face plies and joints staggered 24'n

opposing faces. Ribs may be recessed 6" from the top andbottom

I'egular gypsum "V"edge full-length backing board attachedto both sides of wood or metal top and bottom runners withnails or I/I" drywall screws at 24" on center. islinin(um widthof runners I/,". Face layer of Yr" regular full.length gypsumwallboard laminated to outer I'aces of backing board withapproved laminating compound

2'r/i'oncombus-

(ible S(uds—InteriorPartitionwi(h PlasterEach Side

59

61

63

3'/i by No. 18 gauge s(eel studs spaced 24 on center./r'ypsumplaster on metal~lath each side mixed I:2 by.veight,

gypsum to sand aggrcgatc

3/i No 16 gauge 'ipprovcd nailablc s(tids spaced 24 oncenter. /," neat gypsum wood fibcrcd plaster each side over/I" rib metal lath nailed to studs with 6d common nails, '8

on center. Nails driven I I/i" and bent over

2Y( steel studs 16'n center formed with No. 16 gaugeangle flanges and No. 7 gauge wire diagonals. '/," perforatedgypsum lath attached to the studs each side wi(h No. 12

gauge wire clips at horizontal and vertical joints. Y(" gyp-sum plaster applied each side mixed I:2 by waght, gypsumto sand aggregate

2r/i" steel studs 16" on center formed wi(h No. 16 gaugeangle flanges and No. 7 gauge wire diagonals. '/i" pcrforatcdgypsum lath at(a«hcd to the s(uds each side with Nn. 12

gauge approved s(ccl wire clios. End joints of lath held by ap-proved end joint clips. r/4" pcrlite or vermiculite gypsumpbster applied each side

4" No. 18 gauge c!Iannel shaped stccl s(uds at 16 on center.On each side approved resilient clips prcsscd on(o stud flangea( 16 vertical spacing, rli pencil rods snap@9 in(o or ivire-tied onto outer loop of I.lips, metal lath svirc tied to pencilrods at 6 intervals, I" pcrli(e gypsum plas(cr, each side

2Yr" i fo. 18 gauge steel studs spaced 16" on center. Woodflibcrcd gypsum ptas(cr mixe(I I:I by svcight gypsum to sandaggregate applied on 3 4 pound nictal la(I( ivirc tied to studs.each side. r/. plaster applied over each face, including finishcoal

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FireRating

GAFileNo. DFTAILED DESCRIPTION

SKETCH AND DESIGN DATA

HR

CM 1100

Construction Type: Gypsum WallboardBase layer >/q" regular gypsum wallboard or veneer basetied to column with 18 gage wire 15" o.c. Face layer i/2"regular gypsum wallboard or veneer base applied with lami ~

nating compound over entire contact surface. Fire Test: NBS 303, 7.3.52

CM 1300Construction Type: Metal Lath, Gypsum Plasters/a" 1:3 gypsum sand plaster applied to 3.4 lb. metal lathwrapped and wire tied to column with 18 gage wire 6" o.c.

Fire Test: BMS 92/40, 10.7 42

CM 2010

Construction Type: Gypsum WallboardBase layer i/2" type X gypsum wallboard or veneer baseagainst flanges and across web openings fastened to 1~/a"metal studs with 1"

ape S drywall screws 24" o.c. atcorners. Face layers >/a'ype X gypsum wallboard or veneerbase and screw attached to studs with 1" type S drywallscrews 12" o.c. to provide a cavity between boards on theflange. Face layers across the web opening laid flat acrossthe base layer and screw attached with ls/a" type S drywallscrews 12" o.c. Metal corner beads nailed to outer layerwith 4d nails 1s/a" long, 0.067" shank, »/64" heads, 12" o.c.

Fire Test: UL R1319.80Design X518, 5 27 65

2HR

CM 2020

Construction Type: Gypsum WallboardThree layers of s/a" type X gypsum wallboard or veneer basearound column with first and second layers nailed with 1%"long ring shank nails as required for support. i/2" x 0.015"metal strapping 30" o.c. around second layer beginning 18"from each end nf column..Face layer attached to 1i/4" x1i/4" 25 gage steel angles held on corners by metalstrapping. Drywall corner bead applied each corner with 1"type S drywall screws spaced 12" o.c. at ea'ch corner.

Fire Test: UL R1319 33Design X516, 11-3.60

CM 21100

Construction Type: Metal Studs, Gypsum WallboardOne layer >/q". type X gypsum wallboard or veneer baseattached to 1s/a" steel studs with 1" type S drywall screws12" o.c. Studs located at each corner of heavy steel column.1i/4" metal corner bead crimp attached at 6" intervals. Fire Test: UL R3501.58

Design X520, 10.10 67

CM 2120

Construction Type: Metal St0ds, Gypsum WallboardTwo layers of s/a" type X gypsum wallboard or veneer base,screw attached to 1s/a" metal studs located at each cornerof columns with 1" type S screws 24" o.c. for base layerand 1 s/a" type S drywall screws 12" o.c. for face layer. 1i/4"metal beads at corners attached with 6d coated nails 1 s/4"Iong, 0.0915" shank, i/4" heads, 12" o.c.

Fire Test: UL R2717-34Design X517, 5 15 64

(0(

TABLENO. 43 A—Mlt<lt4UMPROTECTION OF STRUCTURAL PARTS BASED ON TIMEPERIODS FORVARIOUS NONCOti'IBUSTIBLEINSUL*Tli4GMATERIALSs

STRUCTURALPARTS TO BEPROTECTED

ITEMNUMSER INSULATINGMATERIALUSED

Grade A concrete, members 6 x6 or greater (not includingsandstone, granite and siliceous gravel)'

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2r/s

MINIMUMTHICXNESS OFINSULATINGMATERIALFORFOLLOWING FIRE RESISTIVE

PERIODS(lnInches)

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2 Grade A concrete, members 8"x S or greater (not including

Grade A concrete, members l2 x l2 or greater (not includingsand>(one, grani(e and siliceous gravel)'

YI

SteelColumnsand AllMembersof PrimaryTrusses

lo

Grade B concrctc and Grade A concrete excluded above, members6'x 6 or

greater'rade

B concre(e and Grade A concrete excluded above, members8'x g orgreater'rade

B concrete and Grade A concrete excluded above, membersl2 x

l2'rgreater'lay

or shale brick wi(h brick and mortarfill''lollow

clay tile in two 2" layers; Yr" mortar betueen (ile andcolumn; /s metal mesh (wire diameter = .046") in horizontaljoints; tile fill'

Hollowclay tile; I/r Inortar between tile and column: /st me(alntesh (.046 wire diameter) in horizontal joints; Grade A concretelill'Ipbstered with I/. gypsum plaster

2 Hollow clay tile wi(h outside wire ties (.08 diameter) at eachcourse of tile or /s" metal mesh (.046 diameter wite) in horizontaljoints; Grade A concre(e f(ll'xtending I outside column on all sides

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SteelColumnsand AllMembersof PrimaryTrusses(Cont'd.)

l2

l3

I5

l6

l7

2 Hollow clay tile with outside wire ties (.08'iameter) at eachcourse of tile with or without Grade A concrete fII; s/i" mortar be-tween (ile and column

Solid gypsum blocks with woven wire mesh'n horizontal joims,laid with I mortar on IIangcs'nd plastered with I/:" gypsum ptas(er

Hollow gypsum blocks with /i" uide No. 12 gauge metal crampsand woven wire mesh'n horiszontal joints. PL denotes '/" gyp-sum plaster

Portland cement plaster over metal lath wire tied to s/s cold-rolledvertical channels with No. IS gauge wire ties spaced 3" to 6" oncenter. Plaster mixed I:2I/z by volume, cement to sand

Vermiculite concrete, I:4 mix by volume over papcrbackcd wirefabric lath wrapped directly around column with addi(ional 2 "x 2"NO. I6/l6 gauge LVire fabriC plaCed S/s" frOm Outer COnCrete Sur-face. rnite fabric tied with No. IS gauge Tvirc spaced 6" on centerfor inner layer and 2" on center for outer layer

Pcrlite or vermiculite gypsunt plaster over mc(al lath wrappedaround column and furred I I/s from column tlanges. Sheets lap-ped at ends and tied at 6 intervals with No. I8 gauge tie wire.Plaster pushed through to llanges.

Perlitc or vermiculite gypsum plaster over self-furring Inctal lathwrappLM directly around column, lapped I" and tied at 6" in-tervals uith No. Ig gauge wire

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3 '/!PL

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(Contin(red]

Q.S (RSP) The majority of the fire protection valves are either sealedopen with a metal tape and lead sealed or are supervised by admin-istrative controls. It is our position that you should implementone of the following in accordance with NFPA 13, Section 3-13.

a. All fire protection valves controlling the water supply to thefixed water extinguishing systems should be provided withelectrical supervisory switches arranged to give visual valveposition indication in the control room in the event the valveis closed or partially closed.

b. All the fire protection valves controlling the water supply tothe fixed water extinguishing should be locked open with astrict administrative key control procedure. The valve positionshould be verified periodically.

Revised Response

NFPA 13, Section 3-13 permits other alternatives to those listed inthe question. It continues to be our position that compliance withSection 3-13.2.3 (d), which allows sealing valves in the properposition with breakable seals and carrying out weekly documentedsurveillance, provides adequate assurance against misoperation offire protection system valves. Accordingly, there is no plan toinstall electrical supervisory switches with control room positionindicators or to lock fire protection system valves.

PGandE strongly believes that an administrative control procedure in-volving sealing valves is preferable to one using locks. In emer-gency situations, the operator may not have the necessary key readilyavailable to unlock and operate a valve. Being unable to quicklyopen or close-a locked valve could create hazardous situations.

The use of administrative controls of this nature is well establishedwithin PGandE. Such controls have a demonstrated successful history,which has been observed by NRC Inspection and Enforcement personnelduring the 15 year operating history of our Humboldt Bay Power Plant,Unit No. 3.

These administrative controls have included:

1. The PGandE System-wide use of tags (called "man-on-line" tags)for operating and maintenance clearances (instead of lockingvalves, electrical controls, etc.) to prevent hazards to per-sonnel. All PGandE operating and maintenance personnel areaware that violation of a clearance tag is grounds .for seriousdisciplinary action.

Revised Res onse (Continued)

2. The use of an administratively controlled sealed valve checklist at our Humboldt Bay Power Plant Unit No. 3 for the con-trol of all safety-related valves associated with the Unit.These include a number of fire protection system valves sincethis system provides a backup emergency core cooling function.

Finally, it should be noted that security requirements underlOCFR73.55 preclude unescorted access to the security pro-tected area of the plant for other than trained plant per-sonnel or other specially designated individuals. This pro-vides added assurance that valves will not be intentionallyor inadvertently operated without the knowledge of plantoperating personnel.

Q.9 (RSP) (4-2) In".the containment cable penetration zone (fire zone l-A),it is our position that automatic sprinklers be installed in areaswhere two or more divisions of safety systems cables could be affectedby a transient fire.

Revised Response

For the purposes of this discussion, the postulated fire within firezone 1-A will be assumed to affect equipment within a 20 foot diameter.This assumption is felt to be extremely conservative considering thenature and quantity of the fuel loading in the area; the in-depthdetection (14 smoke detectors in zone 1-A) and manual fire suppressioncapability in the area; and that a significant portion of this firezone will be designated as .a "No Storage" area. Specifically, 300o of theannular zone at elevation 91 feet will be posted as a "No Storage" area.

~he 60o sector of this zone. in the vicinity of the fuel transfer tubeassembly does not contain any safe shutdown components.) This area was

designated as a "No Storage" area because safe shutdown instrumentationcircuitry runs in that annular region approximately 20 feet above the 95

foot elevation. These conduits run below the open floor grating ateleyation 117 feet with cable tra s above the.conduits and piping below.The piping does not contain flammable liquids, gases, or oxygen. Therefore,with the "No Storage" provision, a fire due to fixed combustibles in thisare would not be capable of affecting redundant safe shutdown instrumenta-.tion conduits., However, the circuit routing for the safe shutdown'nstrumentation is described below to verify that proper separation doesexist between redundant components.

Steam generator pressure transmitter circuitry emanates from mechanicalpanels at elevation 117 feet mounted on the missile barrier wall adjacentto the four steam generators. , The conduits run,beneath the open floorgrating at elevation 117 feet and leave containment through containmentelectrical penetrations SE, 14E, 24E, and 31E at elevation 120 feet sixinches. The separation distances between the penetrations are 12 feet,20 feet, and 9 feet, respectively. No single fire would be capable ofaffecting the circuitry associated with all four steam generators. Inthe worst case, the postulated fire could result in level transmittersavailable for only two steam generators. However, only one steamgenerator is required for safe shutdown.

Mechanical =panels for reactor coolant system pressure transmitters andpressurizer pressure transmitters are located 180o apart at elevation95 feet in fire zone 1-A; from there the circuits run below the openfloor grating at elevation 117 feet to the containment penetrations.Containment penetrations for the electrical circuits from these trans-mitters are the same as specified for the-steam generator level transmitters.Therefore, the postulated fire could not damage all pressure transmitterscircuitry (a minimum of two pressure indications would be available afterthe postulated fire).

Revised Res onse to .9 — Continued

Pressurizer level transmitter circuitry for LT-459, LT-460, andLT-461 runs from the mechanical panels at elevation 95 feet in thevicinity of the pressurizer (but outside the missile barrier) tothe penetration area along the same routing as specified above.Pressurizer level signals leave containment through penetrations14E, 24E, and 31E. En addition, the pressurizer level transmitter(LT-'406) for= the dedicated safe shutdown instrument panel will belocated at least 20 feet from the other pressurizer level transmitters.Circuit routing from LT-406 to penetration 13E will be in the oppositedirection as the other pressurizer level transmitter circuits. Thus,any 20 foot diameter postulated fire in fire zone,l-A could not affectall pressurizer level transmitter circuits.

Reactor coolant system temperature element circuitry emanates from firezone 1-B and runs to electrical penetrations" 16E and 33E at elevation134 feet 8 inches. The four RCS temperature element circuits for loops 1and 2 pass through penetration 33E while loops 3 and 4 pass through 16E.The penetrations are separated by 32 feet. That penetration separationdistance is the closest distance the two sets of temperature circuitryrun to each other. Thus, the postulated fire could affect, at most,four of eight RCS temperature elements within fire, zone 1-A. Withinfire zone 1-B, the two groups of RCS temperature element circuits arecompletely isolated from another. A fire in zone 1-B could not affectmore than four of the eight temperature element circuits.

The remaining safe shutdown components and circuits within fire zone 1-Aare described in the June 6, 1978 report "Supplementary Information'orFire Protection Review."

Q.21 (4-32) Battery Room is located in Fire Zone 6-A. Provide drawingsshowing the ventilation systems of the three battery rooms, and theconstruction of the walls separating the three battery rooms fromeach other and from the rest of Fire Area 6-A is 3-hour rated.Drawings should show all fire doors and fire dampers as well as theirfire rating. Rubber ventilation seals at corners of walls are not anacceptable arrangement.

Revised Res onse

As shown on the revised fire zone drawings, fire zone 6-A has beensubdivided into five fire zones. Each of the battery rooms and associatedbattery charger and inverter rooms have been designated as fire zones.All doors and associated panels in these fire zone boundaries willbe replaced with "A" labeled assemblies. The corner seals in the wallswill be upgraded to a three-hour rated barrier. Within each of thesefire zones, the batteries are separated from the other electricalequipment by three-hour barriers (except for the doors built to "B"label specifications). Battery room ventilation is provided by a supplyfan and an exhaust fan located in compartments separated by 25 feet.Either fan provides adequate flow to limit hydrogen concentration wellbelow the exp$ osion concentration. Redundant Class 1E air flow switchesin the supply ducting will be installed to provide control room annunciationfor loss of battery room ventilation. Additional control room annunciationis provided for excessive hydrogen generation due to overcharge and batteryroom ventilation damper closure. Ventilation supply and exhaust ductingwithe.n.the battery rooms has been firegroofed to provide a one-hourrating. Battery room ventilation duct supports will also be fireproofedwherever the ducting has been fireproofed. Electrically supervised, oneand one-half hour rated fire dampers have been installed in the ventilationsupply and exhaust openings, such that heat and smoke from a fire in

.one battery room. will be confined to that room while normal ventilationis maintained to the other rooms. Air discharged from the battery rooms

is mixed with air flows from adjoining rooms and exhausted directlyoutside.

Ventilation for the battery charger and inverter rooms is provided by two100% supply fans (these fans also supply ventilation for the 480V switch-gear and are unrelated to the battery room ventilation). Electricallysupervised, one and one-half hour rated fire dampers have been providedin the supply and exhaust ducting to each room, such that heat and smokefrom a fire in one room will be confined to that room while normalventilation flow is maintained to the other rooms. Ventilation ductinginside these rooms has been fireproofed to provide a one-hour rating.Duct supports and ducting outside these rooms in fire zone 6-A-5 will alsobe fireproofed to provide a one-hour rating. One of two redundantsupply fans and motors will be encased within a one-hour barrier to preclude

Revised Res onse 0.21 - Continued

an exposure fire in fire zone 6-A-5 from affecting both fans.Furthermore, this fire zone will be designated as a "No Storage"area to prevent an exposure fire from breaching the equipment -hatchabove and possibly affecting components in the cable spreading room.

Smoke detectors are provided throughout these fire zones; in-depthfire suppression capability is provided by C02 hose reels, a firewaterhose reel, and portable extinguishers.

A fire in either a battery room and/or its associated battery chargerand inverter room will not adversely affect safe shutdown capability.Safe shutdown components that could be affected as a result of thisfire are tabulated and assessed in Section 5 of the June 6, 1978submittal entitled "Supplementary Information for Fire Protection Review."

The consequences of a fire in the areas adjoining the battery rooms (firezones 6-A-4 and 6-A-5) were also assessed in that report. Safe shutdowncapability cannot be affected as a result of fire in fire zone 6-A-5due to planned fire protection modifications to the ventilation systemin fire zone 6-A-5 and the designation of this zone as a "No Storage"area. The only safety related components located in fire zone 6-A-4are the reactor trip switchgear and the rod drive motor generator setcontrollers. The reactor trip switchgear contains two circuit breakersin series to interrupt power to the control rod drives. The probableresult, if any, of a fire in zone 6-A-4 would be for the reactor to trip.A fire in this zone could not prevent a reactor trip. Manual reactortrip from the control room would be possible by tripping the switchgearor by de-energizing the motor generatorsets irrespective of the fire inzone .6-A-4. Early warning of a fire is provided by seven smoke detectorsinstalled in fire zone 6-A-4.

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Q.23'RSP) (4-36) Control Room Complex is located in Fire Zone 8.

A. 'nit 1 Computer Room is also located in Fire Zone 8-A. The computerroom is cut"off from the control room by a 1-hour protection; however,the openings are unprotected. It is our position that 3-hour fire doorsand fire dampers be provided for the protection of openings that penetratethe wall separating the computer room from the control room. It is alsoour position that you provide automatic protection for the computer roomor show that a fire in the computer room will not affect the safe coldshutdown of the plant.

B. Control Room ventilation equipment is located in Fire Zone 8-B.Verify that the ventilation ducts that penetrate the floor of this roomhave 3-hour fire dampers installed at all floor penetrations. Alsoverify that fire hose reels can reach all .areas of the room and arereadily available.

C. Control Room is located in Fire Zone 8-C. Verify that fire hosestations in the area can cover all portions of the control room complex.

Identify those safety-related control room cabinets that contain cablesfrom both divisions. Provide an analysis of the consequences of a firein each cabinet. The analyses should take into account the damage towiring and, instrumentation in adjoining safety-related cabinets due toheat and corrosive vapors. In order to meet the guidelines of D.2 ofAppendix A,. it is our position that you provide smoke and heat detectorsin the control room cabinets.

r

Verify that all door and ventilation openings in the control room wallsand ceiling are protected by 3-hour'rated fire doors. It is our positionthat you provide smoke detectors-throughout the room at the ceiling level.

D. Office an'd Record Storage and Instrumentation Repair Areas are locatedin Fire Area 8-E and 8-F. Provide 3-hour fire rated construction includingthe protection of all ventilation and=door openings.

Revised Res onse

A. The existing barrier between the computer room and the control roomis consistent with the low fuel load within the computer room. It will beupgraded to a one hour barrier by extending the wall from the suspendedceiling to the concrete ceiling above. Providing a three hour door in aone hour rated barrier. is unnecessary and- will not be done.

In the event of a fire in the control room complex, the ventilation systemmode of operation is changed to 100X outside air make-up and exhaust to.provide smoke venting. Installation of fire dampers in the computer roomventilation penetrations would prevent proper smoke venting and mightdegrade the habitability of the control room complex. Fire dampers willnot be installed in the ventilation ducting.

Res onse to 9.23 - Continued

The plant computer is not required for safe shutdown nor would a firein the plant computer room affect control room safe shutdown capability.A fire in the computer room would be suppressed using portable extin-guishers and, if necessary, firewater hose reels located adjacent tothe control room complex. Automatic fire protection will not be providedfor this area. However, smoke detectors will-be installed in thecomputer room and 'the exhaust air duct from the computer room.

B. Units 1 and 2 auxiliary building supply fan rooms are located atelevation 140 ft. in fire zones 8-B-1 and S-B-2, respectively (referto revised fire zone drawing figure 3-10). Fire zones 8-B-1 and S-B-2are separated from the control room complex by three hour rated barriers.The floor, penetrations in the supply air plenum rooms communicate withthe auxiliary building mechanical equipment areas below. Fire dampersin the floor penetrations are not necessary to protect the control roomcomplex from a fire in zone 8-B-1 or 8-B-2 and could degrade the reliabilityof the auxiliary building ventilation system. Therefore, fire damperswill not be installed in the floor penetrations. However, the auxiliarybuilding supply fan rooms will be protected by smoke detectors and anautomatic sprinkler system. A firewater hose reel located outside thefan rooms provides satisfactory backup manual fire suppression capability.

, The Units 1 and 2 control room ventilation equipment rooms are located ate'levation 154 ft. 6 in. in fire zones 8-B-3 and-8-B-4 respectively(refer to revised fire zone drawing figure 3-11). Control room supplyand exhaust ducts penetrate the wall at column line "L". Installationof fire dampers in these penetrations would require extensive modifications,including relocation of major ventilation equipment. Since smoke

,detectors, automatic sprinkler protection, and a.firewater hose reel will ~

be provided for the control room ventilation equipment rooms, fire dampersare not felt, to be necessary for these penetrations.

C. Existing firewater hose stations provide proper coverage of allportions of the control room complex.

The only cabinets in the control room which contain cables from bothdivisions are the operator's control console and the main control board.Many precautions have been taken to minimize fire hazard in these boards.All wiring is routed internally in metal wireways. All switchingcomponents are contained in individual housings (modules) which have anelectrical insulating and fire retardant material on both sides. Wiringto the devices is separated by several inches of air. Wire insulationwas specifically selected for flame retardancy to prohibit release ofcorrosive gases.

As described in our revised response to Question 51, safe (cold) shut-down can be accomplished outside the control room assuming a loss ofthe main control board. However, early detection and suppressioncapability should minimize the damage caused by any postulated fire inthe main control board, and complete loss of the main control board isfelt to be an extremely unlikely occurrence.

Res onse to .23 — Continued

Thirteen ionization type smoke detectors will be installed in the maincontrol board and three ionization type smoke detectors will be installedin the operators cbntrol console. Smoke detectors will be installed inother control room cabinets also. The smoke detectors mounted in thesecabinets will have seismically qualified mounts.

The doors leading to the control room complex (consisting of fire zonesS-A, C, D, E, F, G, and H as shown on the revised fire zone drawingfigure 3-10) all are three-hour rated "A" labeled doors. With theexception of th'e ventilation penetrations into the control room complex(described in 23.B above), the control room complex is isolated fromthe rest of the plant by minimum three-hour rated fire barriers. Asdescribed in the revised response to Question 24, the safeguards rooms(fire zones 8-G and 8-H) will be separated from the rest of the controlroom complex by three-hour rated fire barriers. The computer rooms(fire zones 8-A and 8-D) are described in 23.A above and the remainderof the control room complex, fire zones 8-E and S-F, are described in23. D below.

Because the control room is continuously occupied, smoke detectors arenot necessary in the ceiling of the control room and will not be provided.

D. Pire zone 8-E, consisting of an office and a records storage room,is separated from the turbine building by a three-hour rated fire barrier.The wall separating zone 8-E from the control room (zone 8-C) is a three-hour rated concrete wall. Fire dampers have not been provided in theventilation ducting to fire zone 8-E. This was done to ensure propersmoke venting so that the control room complex would remain habitable ifa fire were to occur in this area. Smoke detectors and automatic sprinklerprotection have been provided within this fire zone.

Fire zone S-P, previously an instrument repair room, is now designatedas the securi'ty central alarm station. This room is separated from theturbine building by a three-hour fire barrier and the wall separatingzone 8-F from 8-C is a three-hour rated concrete wall with "C" labeleddoors+

Q.'24 Safeguards Room is located in Fire Zone 8-G and 8-H. Provide theresults of an analysis showing an exposure fire in the Safeguards Roomwill not prevent safe cold shutdown of the reactor. If the resultsof an analysis shows safe shutdown of the reactor will be jeopardizedby the exposure fire, provide additional measures including upgradingbarriers to 3 hours to ensure safe shutdown.

-Revised Res onse

The Unit 1 Safeguards Room is located in fire zone 8-G. The equipmentin this room consists of the two redundant safeguards trains withincabinets separated by about five feet. They are safety-related and afire in the room could conceivably cause undersirable spurious actions.

The north and west walls of fire zone 8-G are three hour rated firebarriers. The remaining walls that define this fire zone will beupgraded to three hour rated fire barriers. The floor and ceiling arethree hour barriers. Three hour rated fire dampers will be providedin the ventilation ducting to contain the total flooding fire suppressionagent (described below) ~

Strict administrative controls for this fire zone will greatly minimizethe possibility of an exposure fire from occurring. For 'example, smokingwill be prohibited in this area (to minimize fire hazard as well asprevent false alarms of. the smoke detectors). Combustible liquids willnot be authorized in this area and paper will be kept to a minimum.

In depth fire protection will be provided for this area. Four cross-zoned smoke detectors installed in the ceiling of the room will bepositioned .to provide early detection of a fire in any of the safeguardscabinets or the room itself. A total flooding automatic/manual actuatedHalon 1301 system will be provided with a reserve supply of Halon 1301for subsequent manual discharge if required. Halon 1301 design concen-tration will be specified to be 5% minimum, 7% maximum. The supplierfurnishing the Halon system will be required to verify the proper Halonconcentration within the room as well as within the safeguards cabinetsby test discharge. Two dry chemical and two CO2 portable extinguishersare located close by in the control room as well as firewater hose reelimmediately outside of the control room.

Any postulated fire in this zone would be immediately detected by smokedetectors and control room'personnel response would be in a matter ofseconds. With the proposed administrative controls and in-depth firedetection and suppression capability, an exposure fire in'the safeguardsarea would not affect safe shutdown. If the fire were a deep-seatedelectrical fire within a safeguards cabinet, the plant would be shutdown and the safeguards train could be de-energized. The automaticdischarge Halon could th'en be assured to completely suppress the fire andadditional levels of manual suppression capability are available as back-up protection. Safe shutdown capability is assured since such a postulatedfire would not affect the redundant safeguards train.

Revised Res onse to .24 — Continued

The Unit 2 Safeguards Room is located in fire zone S-H. All fireprotection commitments made for 'the Unit l Safeguards Room applyto the Unit 2 Safeguards Room.

Q.26 Provide the following information for all three diesel generators:

a. Verification that the fire hose can reach all areas of each dieselroom.

b. The results of an analysis of a fire in a diesel generator roomcaused by a break or leak in the day tank under the diesel engine.Verify that the fire will not spread to all three diesel generatorrooms through the floor drains.

c ~ The C02 system should only be locked out when personnel egress in theroom would take a longer time that the delay provided for systemdischarge.

Revised Res onse

a e A fire hose reel station. for each unit will be added that canreach all areas of each diesel generator room. Location of hosereel stations is shown on the drawings provided for Question 38.

As discussed in Section 4.1.11 of the Diablo Canyon Fire ProtectionReview (Amendment Sl), a postulated fire within a diesel generatorroom would not affect safe shutdown. As described in our responseto Question 57, the diesel generators are properly protected fromeach other and from other hazards in the area. Curbs will be addedto the doorways to the diesel generator rooms to contain any oilspillage. The diesel generator room floor drainage system willdrain postulated day tank fuel oil spillage to the turbine buildingsump. Numerous four-inch floor drains are provided in the dieselgenerator rooms, in particular, floor drains are located directlybeneath the day tanks. Each floor drain is covered by a circulargrating and a supporting steel catch basin in the throat of thedrain. This prevents debris from entering the drain system. Acommon four-inch header connects the drains from the individualcompartments with the turbine building sump. This drain header isa minimum of 3b ft. below the floor drain openings. Drainage ofan oil spill in a compartment would not result in a flame pathwaydown the drain line since flame passage would be inhibited by thefloor drain covers, oxygen depletion in the drain line, and theconsiderable distance downward and laterally that the flame wouldhave to traverse to propagate to an adjacent compartment. If theinterconnecting header is postulated to be blocked between thediesel generator compartments and the turbine building sump anda large oil spill from one compartment occurs, the fuel oil in thedrain provides flame trap protection since the system would be solid-filled and flame cannot migrate from the burning surface of thefuel oil in the affected compartment to the unaffected compartments.

Revised Res onse to .26 — Continued

Complete combustion of a 550 gallon diesel generator day tank wouldgenerate about 77 x 106 Btu of heat (approximately 100,000 Btu/ft2) .

However, the diesel generator rooms are routinely inspected at leastonce per eight hour shift and drainage is provided in each room.Therefore, diesel fuel leakage would not accumulate in the compartment.If a fire were to start in a diesel generator room, the automatictotal flooding CO2 system would quickly extinguish -it. Therefore,it is felt that a fire of this magnitude would not occur in a dieselgenerator room. Even if it did, the fire should not breach thebarrier between the diesel generator room. In the unlikely eventthat such a fire occurred, it would not affect safe shutdowncapability because it would be confined to a single diesel generator.

c. The-C02 system in the diesel generator rooms will be operable at alltimes when equipment in the area is required to be operable, exceptwhen personnel are working in a diesel generator room., When anoperator makes a routine inspection of the equipment in a dieselgenerator room, he would not ordinarily lock out the C02 system. Ifmaintenance work is being done on a diesel generator, the normallyclosed three hour rated equivalent rolling fire doors for the otherdiesel generator rooms would protect those diesel generators.

If a COZ system is locked out, that information is alarmed in thecontrol room. While the system is locked out, personnel working inthe area provide continuous surveillance. In the event that the C02

system is inadvertently left locked out after the maintenance work isdone, the control room operators would be alerted to that fact by theC02 system status board.

Additional Information

Diesel generator backup control circuitry is fed off of a differentelectrical division than the normal control circuitry. Thus, a firein certain areas (4.16KV cable spreading room, 480V switchgear room,and inverter room) could, for example, affect the "F" bus dieselgenerator circuitry and the "F" bus backup control circuitry for the"G" bus diesel generator. A fire in one of these areas could render the"F" bus diesel generator inoperative, but the "G" bus diesel generatorwould still be operative using the normal "G" bus control circuitry.As described in FSAR Section 8.3.2, the manual transfer switches totransfer the diesel generator control circuitry from normal to backupare located within each diesel generator compartment. There is noautomatic'ransfer scheme and the manual transfer switch is maintainedin the normal position. As shown in FSAR Figure 8.3-12 (schematicdiagram — 4KV diesel generator controls), damage to the backup controlcircuitry cannot affect diesel generator operation using normal controlcircuitry. Thus, a single fire can affect, at most, one diesel generator.

Revised Res onse to .26 - Continued

Backup power for the diesel fuel transfer pumps comes from Unit 2.The backup power circuits for the two transfer, pumps run from theUnit 2 480V switchgear rooms to the Unit 1 480V switchgear rooms. Inrunning from the Unit 2 to the Unit 1 switchgear rooms, the redundant

-backup circuits run in the same fire zone. However, the transfer'switches to transfer power for the pumps from Unit 1 to Unit 2 arelocated in the Unit 1 switchgear rooms. Thus, damage to the backuppower circuits could not affect fuel transfer pump operation fromUnit 1 power. This is shown on the fuel transfer pump electricalschematic, drawing 437657.

As identified in the June 6, 1978, submittal, "Supplementary Infor-mation for Fire Protection Review," diesel fuel transfer pumps powercircuits are separated-by approximately 15 ft. in the auxiliarybuilding, elevation 73 ft., fire zones 3-J-1 and 3-C (ref: drawing57691). Since fire zone 3-J-1 will have automatic sprinkler protection,the area has low fuel loading and both fire zones have smoke detectors,it is felt that the 15 ft. separation for these redundant circuits isadequate. However, two-hour protection of the conduits will be provided.

These same circuits run through an office area containing a whole bodycounter in fire zone 4-B at elevation 85 ft. In running up the wall ofthis office, the conduits maintain their 15 ft. separation and are eachenclosed behind two-hour rated metal lathe and plaster walls thatisolate the conduits from the office and each other. One conduit runsabove the suspended ceiling in the south end of the office while theredundant conduit runs above the suspended ceiling in the counting roomto the north (fire zone 4-A). This office area has been designated as a"No Storage" area and automatic sprinkler protection is provided forthe space.

As identified in the June 6,,1978 report "Supplementary Information forFire Protection Review," a.fire in a diesel generator compartment couldadversely affect operation of both diesel fuel transfer pumps.For example, a fire in diesel generator 1-1 compartment could conceivably(1) start the fuel transfer pump(s) and supply fuel to the'diesel generator1-1-day tank, or (2) prevent fuel, transfer pumps. from starting when requiredto replenish other diesel generator day tanks. Revision 6 of drawing 437657(fuel transfer pump electrical schematic) shows the circuit modificationthat will be made to correct this potential problem. Relays located infire zone ll-D controlled by control switches in the diesel generatorcompartments will cause the fuel transfer pump(s) to start. If a fire inthe diesel generator compartment causes an open circuit in the controlcircuit, neither pump will start and fuel will not be supplied to theaffected diesel generator. However, the pumps can still start to providefuel for the other diesel generators. If the fire causes a short toground in the control circuit, a fuse would blow and again fuel would notbe provided to the affected diesel generator, but could be supplied to the

Revised Res nse to -26 — Continued

other two diesel generators. Protection of the circuit susceptibleto fire-requires two fuses in series; the fuses will be coordinatedto ensure proper operation. Testing will be conducted to verify thiscoordination results in proper system response. If the fire causesa short in the control circuit, the transfer pump will start and tryto supply fuel to the affected diesel generator. However, to preventthat from occurring, fusible plugs will be installed in the air linesto the day- tank level control valves (the valves fail closed on lossof air). Since the fire would melt the fusible plugs prior to affectingthe control circuit, no additional fuel would be introduced into thediesel generator compartment.

The new relays located in- fire zone ll-D will be mounted above the onehour suspended ceiling. These relays are located in junction boxesBTA211 and BTA208 separated by approximately 15 ft. as shown onRevision 18 of drawing 57579. There is no fuel load .above the suspendedceiling and automatic sprinklers will be, installed in the ceiling.This circuit modification will ensure proper fuel transfer pump operationduring normal plant operation as well as during and after a dieselgenerator'ire.

Q. 27 (4-45) ln Unit 1, 4. 16 KV cable spreading rooms separate each divisionwith.3-hour fire rated barrier.

Revised Res onse

The walls that separate the three-4.16KV cable spreading rooms willbe upgraded to two-hour rated barriers. This will be accomplishedby fireproofing the exposed'teel beams in the walls and ceiling ofthe 4.16KV cable spreading room and fireproofing the one-inch gapsbetween the concrete block walls and the poured concrete walls. Thefireproofing of the structural steel will be in accordance with arated U.L. design. Outside walls on the'north and east are alreadytwo-hour rated barriers. The doors separating these rooms are "B"labeled and are felt to provide adequate fire protection for thesmall quantity of combustible materials in the area. It is notconsidered necessary or cost effective to replace these doors andframes to obtain "A" labels. Two-hour rated fire barriers will beconstructed in the corridors west of the 4KV cable spreading roomsto separate redundant safe shutdown electrical circuits in these areas.These compartmentalized corridors will be included within the firezone boundaries of the respective 4KV cable spreading rooms as shownon the revised fire zone drawing 3-2. This modification will resultin each redundant 4KV division at elevation 104 ft, in the turbine buildingbeing enclosed'within a minimum two-hour fire barrier. Ventilationair supply ducting to each 4KV cable spreading room at elevation 104 ft.is contained within its respective division's fire zone. Ventilationair exhausts from each cable spreading room to each respective 4KVswitchgear room above.

In-depth fire protection in this area is provided by smoke detectors,CO2 hose reels, a firewater hose reel, and portable extingui'shers.All comments and commitments made, regarding,fire„area 12 in Unit 1apply equally to fire area 23 in Unit 2.

Circuitry from one electrical division may be located within the 4.16KVcable spreading room of a redundant division in certain instances. Forexample, in the "G" bus cable spreading room; conduit K2669 contains "F"bus control circuitry for. an auxiliary saltwater pump. That circuitis an automatic start circuit for the "G" bus auxiliary saltwater pumpdue to under voltage of the "F" bus. Damage to that control circuit asa result of a "G" bus cable spreading room fire would not preventoperation of the auxiliary saltwater pump powered off of the "F" bus.This is shown on Revision 10 of drawing 437594, Schematic Diagram—Auxiliary Saltwater Pumps. Other instances where circuitry from one„division is located in the cable spreading room of a redundant divisionhave been reviewed and in none of the instances are the circuits inquestion required for safe shutdown, nor would damage to the circuitsadversely affect safe shutdown capability.

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Q.28 All three divisions are located at the ceiling in the corridor adjacentto 4.16KV cable spreading room and the turbine building at elevation104'. Provide automatic sprinklers at the ceiling throughout thecorridor in accordance with Section D.3 of Appendix A.

Revised Response

The three divisions of 4.16KV cables located at the ceiling of thecorridor adjacent to the 4.16KV cable spreading rooms are in conduitsand are well =separated. The fuel load .in this corridor is negligibleand barriers separate this corridor from the other low fuel loadcompartments adjacent to it. Because this corridor will be within asecurity area allowing only limited access to the area, it would notbe a normal area for storage. Therefore, it is unlikely transientcombustibles would be present in this area. (Fire zone 13-F at ele-vation 119 ft. is a designated storage area for the turbine building.The area contains no safety related equipment or circuitry and isproperly isolated from the rest of the turbine by three-hour firebarriers.)

As described in the revised response to Question 27, redundant safeshutdown electrical circuits will be separated from each other by two-hour rated fire barriers. As a result of these barriers, automaticsprinkler protection will not be provided since a fire in this areacould affect at most one electrical division. This would not affectsafe shutdown capability.

Circuitry in fire zones 12-D and 12-F required for safe shutdown hasbeen identified and tabulated in Section 5 of the June 6, 1978, reportentitled "Supplementary Information for Fire Protection Review." Controlcircuits for the auxiliary feedwater pumps in conduits K2665 and K2666in fire zone 12-F were previously identified as cbeing required for safeshutdown. These circuits are from the feedwater pumps and are part ofthe automatic start circuitry for the auxiliary feedwater pumps. Assuch, they are not required for safe shutdown and damage to the circuitswould not affect safe shutdown capability.

Q.29 (4-46) The fire hazard analysis for 4.16 the KV switchgear rooms is, not acceptable. Provide 3-hour fire barriers which separate allthree divisions from each other and from other areas of,'the plantas recommended in Section D.5 of Appendix A.

'Revised Res onse

The walls that separate and enclose the three 4.16KV switchgear roomswill be upgraded to two hour rated barriers.". This will be accomplishedby fireproofing the exposed steel beams in the walls and ceiling ofthe 4.16KV switchgear rooms and fireproofing the one-inch gaps between.the concrete block walls and the poured concrete walls. The fire-proofing of the structural steel will be in accordance with a ratedU.L. design. Outside walls on the north and east are already two hourrated barriers. The doors to these rooms are "B" labeled and are feltto provide adequate fire protection for the small quantity'of combustiblematerials in the area. Xt is not considered necessary, or cost effectiveto'replace these doors and frames to obtain "A" labels.

Ventilation air for the 4KV switchgear rooms is supplied by fans -locatedin fire zone 13-E via ducting running through fire zone 13-D. Smokedetectors and automatic sprinkler protection will be provided for the4KV switchgear ventilation fans'in fire zone 13-E. The ventilationducting to each switchgear room in fire zone 13-D will be fireproofed toprovide one hour rated protection and one and one-half hour rated fire damperswill be provided in the ventilation ducting where it passes from firezone 13-D into the switchgear rooms. Three hour rated fire damperswill be installed in the ventilation exhaust ducting in, the ceiling ofthe 4.16KV switchgear rooms. This will isolate the 4.16KV switchgearrooms from the turbine building operating deck (el. 140 ft.) .

In-depth fire protection in these areas is .provided by smoke detectors,CO2 hose reels, a'irewater hose reel, and portable extinguishers.

Q.45 Demonstrate that the Diablo Canyon can be safely shutdown assumingthat a fire is induced by a safe shutdown earthquake. Describeportions of the fire protection system that are designed for a

seismic'vent.

Revised Res nse

Fire suppression capability „after a safe shutdown, earthquake will consistof manual hose reels and portable extinguishers. Hose reels have beenprovided throughout the plant so that all are'as of the plant are accessibleby at least one hose stream. Portions of the firewater system will beseismically qualified so that all hose re'els in safety related areas ofthe plant will be available following a safe shutdown earthquake. Thequalified system will consist of the 300,000 gallon firewater tank, thetwo motor-driven fire pumps, and the fire mains and piping required toprovide water -to the hose reel stations in safety related areas of theplant. Cross-ties between the auxiliary building and the turbine buildingwill be provided so that the fire pumps can supply water to any firesystem component within the plant without the use of the yard loop.Check valves will be installed in the six yard loop feeder lines into theplant. This will prevent water loss out of the yard loop (which couldconceivably be damaged as a result of an earthquake) . The check valveswill have normally closed, manual by-passes to.,ensure availability of abackup water supply for the transformer deluge systems. The attachedfigure shows what portion of the firewater system will be seismicallyqualified.

The seismically qualified portion of the fire system can be readilyisolated from the rest of the fire system. The existing turbine buildingsprinkler systems and new. sprinkler systems to be provided in-the, turbinebuilding can be isolated from the rest of the system by closin'g twovalves per unit. Reactor coolant pump sprinklers can be isolated fromthe seismically qualified portion of the fire system by closing valves inthe lines to the sprinkler systems or by closing the containment firesystem isolation valves inside or outside of containment. The existingauxiliary building sprinklers can be isolated by closing one valve.Additional auxiliary building automatic sprinklers to be installed willbe readily isolatable by closing five valves (total for both units) .All sprinkler systems have flow alarms to provide control room annuncia-tion of system actuation and/or leakage. Sufficient firewater would beavailable for multiple hose streams even considering the water that couldbe lost from breaks in non-qualified sprinkler piping prior to plantoperators isolating the leaks. 'Backup fire protection capability willbe provided by three-250 gpm portable engine-driven fire pumps. Connec-tions will be installed from the auxiliary saltwater system (at thecomponent cooling water heat exchanger) to provide suction to the portablepumps. The pump discharge can be tied into a fire main to resupply thefirewater tank or to pressurize the fire system for long-term firefighting. The port'able pumps will be stored in a suitable area to ensurethat they will not be affected by a seismic event.

Revised Res onse to .45 — Continued

All buildings in which the qualified fire system piping is run havebeen re-evaluated for the Hosgri earthquake and, where necessary, arebeing strengthened as a result of the analysis. The qualified firesystem piping runs in the vicinity of some non-Class I equipment inthe turbine building; however, as a part of the Hosgri re-evaluation,supports for major non-Class I equipment are being reanalyzed andmodified where necessary. Area's in which the seismically qualifiedportions of the fire system are run will be reassessed to ensuredamage to non-Class I equipment or piping will not render the firesystem inoperative.

Fire protection system modifications will be evaluated to ensure thatin the event of a seismic disturbance, the new fire protection systemswill not adversely affect safety. related equipment. This will beaccomplished by supporting fire system components such that thecomponents will not endanger safety related equipment in the area.This .evaluation will be.,done in particular for any additional firesystem/sprinkler ay~stem iplng, smoke detectors within safety relatedcabinets and the Safe cards Room Halon 1~301 s stem.

3

Plant operating procedures specify that after a seismic event, athorough inspection of all plant areas be conducted to assess, and ifpossible, remedy any damage that might have occurred to plant componentsas a result of the seismic event. Any earthquake induced fire or potentialfire hazard created by the earthquake would be identified during. thisinspection and, if necessary, the plant fire brigade would be dispatchedto the fire. This inspection of all plant areas would be completedwithin two hours after a seismic event.

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Q.46 Describe the procedure employed for heat and smoke removal using fixedor portable equipment in areas that house safety related systems orcomponents. Describe how these areas can be ventilated for manual firefighting purposes. Include a discussion regarding control accesses tothe equipment as well as the ability to handle high temperature gasesand particulates.

Revised Res nse

The ventilation systems either supply fresh outside air to rooms orexhaust air from rooms into a closed duct system (or both for some rooms).Ventilation exhaust capability, either manual or automatic, exists in allplant areas.

Situations where rated fire dampers have been provided include: a) roomsthat have total flooding C02 protection, b), where heat (and smoke) trans-,mission through a fire barrier might result in a fire propagating to anadjacent room, and c) where it is desirable to reduce air flow to confinethe fire. Ventilation for manual fire fighting in areas with normalventilation flow cut-off can be accomplished with portable blower-exhaustfans and by opening doors. Four portable fans, each rated at 750 cfm,are available. These fans could exhaust to the outside or to nearbyoperating ventilation exhaust ducts. Self contained breathing apparatusis available as described in our response to Question 40. Fire damperswould not normally be opened until after the fire was extinguished. Ifthe normal ventilation system is used for heat and smoke venting, systemdesign is such that the heat and smoke would be discharged outside, andnot to other rooms. Distances between air intakes and exhausts arespecified in Section 5.4.4.2 of the Fire Protection Review (Amendment 51).These distances are adequate to ensure against contamination of intake air.

Additional Information

The June 6, 1978 submittal "Supplementary Information for Fire ProtectionReview" identified the ventilation system components required for safeshutdown equipment and tabulated the fire zones in which ventilationcomponents/circuitry are located. As shown on the attached table,redundant ventilation system components/circuitry are located in the samefire zone in certain instances. This table also specifies the fireprotection modifications to be made in these fire zones. As a result ofthese planned modifications, it is extremely unlikely that a fire wouldadversely affect redundant ventilation system components.

However, if such a fire were to affect redundant ventilation systemcomponents, numerous actions could be taken to prevent this fire fromaffecting safe shutdown capability. Some of these actions are describedbelow:

a) If a cable spreading room or control room fire affects the auxiliarybuilding or fuel handling building ventilation fans, the equipmentcan be controlled at the motor control centers.

Revised Res onse to .46 — Continued

b) Operation of redundant pumps could be staggered to prevent motoroverheating. A temperature'onitoring system'as'een piovidedfor the vital equipment rooms and pump bearing temperature andmotor bearing and stator temperature indication is available inthe control room.

c) The unit can be kept at hot standby until the necessary ventilationis lined up. Hot standby can be adequately maintained with onlythe turbine driven auxiliary feedwater pump. This component, doesnot require ventilation to operate.

d) Portable ventilation fans can be used and doors can be opened toprovide air circulation. Four portable fans (total for the twounits), each rated at 750 cfm, are available.

The fans run off of ll5 volt ac power. Suitable electrical outletsare located throughout the plant to power these fans. Xf loss ofoff-site power occurs, the fans could be readily plugged into thereceptacles for the emergency ac lighting. The emergency ac lightingcircuits can carry the additional load from these fractional horse-power fans as well as the emergency lights themselves.

e) The ventilation system has been conservatively designed to provideadequate cooling for all equipment under all operating modes. Evenwith portions of the ventilation system inoperative, equipment roomtemperatures, while higher than normal, would not be so high as tocause equipment failure. Equipment life may be shortened but wouldcertainly be available for the duration of the safe shutdown process.

f) Auxiliary building ventilation is provided by Unit 1 and Unit 2

supply and exhaust fans. No single fire can affect both Unit l andUnit 2 auxiliary building ventilation. There is free communicationbetween the Unit l and Unit 2 portions of the auxiliary building.Zf one unit lost all or a portion of its ventilation, the secondunit's ventilation system could pick up much of the load. Openingdoors and rigging portable fans would be especially effective in theauxiliary building.

En conclusion, due to the planned fire protection modifications, it isfelt that redundant ventilation components will not be affected by afire. Even if they were, enough mitigating actions can be taken toprevent such a fire from affecting safe shutdown capability.

DIABLO CANYON UNITS 1 AND 2FIRE ZONES IN WHICH REDUNDANT VENTILATION FOR

SAFE SHUTDOWN EQUIPMENT COULD BE AFFECTED

Fire Zones

AuxiliaryAuxiliary Building* Fuel Handling .Bldg.""* ~ "Saltwater-- . -480V-Swgr."" "4KV.Su ply Exhaust Supply Exhaust Pumps R Inverter Sw r.

3-L (Aux. Uldg. el. 85')3-P-1 (Fuel hdl. bldg. supplyfan room)

3-P-4 (Aux. bldg. exh. fanE-1 room)

3-Q-1 (Aux. feedwater pumproom)

3-X (Aux. bldg. el. 100')

3-AA.(Aux. bldg. el. 115')4-A (Lab area)6-A-5 (Space west ofbatteries, el. 115')

7-A (Cable spreading room)

8-B-l (Aux. bldg. supply fanroom)

8-C (Control room)

10 (12KV swgr. room)

12-D, 12-F (Corridors 4KVarea)

13-E (4KV swgr. vent. room)

31 (Fuel hdl. bldg. corridor)

4,6

2.3

3,5

1,3

4,6

3,4

1,3

2/3

3,5

4,6

3,4

1/3

2/3

3,5

4,6

2/3

3,5

2/3

2,3,4

2/3

1,3

Notes

* Required for component cooling water pumps, charging pumps, and RHR pumps.**Required for auxiliary feedwater pumps.

Notes (Continued)

-- = Ventilation components not located in this fire zone.

1 = Automatic sprinkler protection in the fire zone.

2 = Fireproofing of circuitry to ventilation components.

3 = Smoke detectors in the fire zone.

4 = Posted "No Storage" area.

5 = Total flooding C02 system.

6 = Exposure of these components is limited to electrical circuits in juction boxes and one foot ofconduit high on the west wall of zone 3-L near the ceiling.

Q. 49 Hydrogen lines are presently located near safety-related equipmentand cables throughout your plant. It is our position that hydrogenlines whose explosion could affect safety equipment be relocatedprior to fuel loading. Modify you design to meet this position.Provide the location in which all such situations exist.

Revised Res onse

Excess flow automatic shutoff valves have been provided for thehydrogen system which will shut off hydrogen supply if system demandexceeds 50 cfm. If a shutoff valve trips. closed, an alarm willannunciate in the control room. These trip valves are locatedoutside of the plant in the hydrogen bottle storage vault. Thevalves are inherently reliable, passive elements, and the lightweight internals and housings, would not be vulnerable to damage froma seismic event since the valves are rigidly supported in place.These valves would provide protection against and indication of asignificant hydrogen leak.

To further minimize hazards from a hydrogen explosion, hydrogen lineswill be rerouted out of certain areas containing safety-relatedequipment and will be enclosed within a guard pipe where it runs inany areas containing safety-related equipment. The guard pipe willbe vented to the outdoors and will be pressure tested to verify thatit is leak tight. The guard pipe will be constructed of carbon steelpiping and fittings. Hydrogen leakage in safety-related areas wouldrequire failure of both the:.hydrogen piping and the guard piping.This could be postulated to occur only in the event of complete collapseof the piping system. If this were to occur, 'hydrogen flow would besufficient to trip the excess flow valves. A small. hydrogen leak(insufficient to close the trip valves) is unlikely to occur in safety-related areas and, as described below, would not .create a hazard.

Pire zones containing safety-related equipment in which the hydrogenpiping (within guard pipe) will run are:

1. Pire pump room (fire zone 3-R) elevation 115'. This area isventilated by the fuel handling building supply and exhaust fans.Ventilation air to this room is provided by supply ducts overthe fire pumps; the air exhausts through floor-to-ceiling accessopenings to a ventilation corridor to the north. There are nopockets near the ceiling of this room where hydrogen couldaccumulate.

2. Penetration areas (fire zones 3-BB and 3-CC), elevation 115'nd100'. In the penetration areas, elevations 100'nd 115'ommunicate,the volume of these fire zones are 400,000 ft3 each and ventilationair from these areas exhaust to the outdoors through openings inthe ceiling (including an 8" gap between the containment structureand the ceiling)

Revised Res onse to .49 — Continued

There are no pockets in the ceilings of the elevation 100'nd115'reas; any hydrogen leakage in these areas would migrateto the ceiling of the elevation 115'rea and would be purgedto the outdoors.

3. Auxiliary building, elevation 100'fire zone 3-X). Hydrogenpiping in fire zone 3-X is confined to just the volume controltank compartment and the adjacent compartment. The volumecontrol tank i:s not required for safe shutdown. These areasare ventilated by the auxiliary building supply and exhaust fans.Supply air to these compartments is provided via the access waysto the compartments and each compartment is provided with anexhaust register. The exhaust air -is ducted to the auxiliarybuilding exhaust fans. The exhaust ducting will be modified toensure air at the top of the compartments is exhausted from thecompartment. With this modification, no pockets will exist inthe compartments where hydrogen could accumulate.

I'n

summary, large hydrogen leaks in safety-related areas are unlikely,and if such a lea occurred, the excess flow trip valves would preventhydrogen build up. Small hydrogen leaks in safety-related areas cannotbe reasonably expected to occur and even if such a lea: were to occur,an explosive concentration of hydrogen could not build up since theseareas are properly ventilated to purge any hydrogen leakage.

Installation of portable hydrogen bottles for the chemical and volumecontrol system in the volume contro'ank compartment was evaluatedand found to be unsatisfactory for the following reasons:

1. The hydrogen bottles would have to be transported throughareas containing safety-related equipment. The potentialhazard of a handling accident creating a hydrogen bottle,missile is felt to be much more serious than retaining hydrogenpiping enclosed within a guard pipe.

2. OSHA requirement for storage of hydrogen bottles in anoccupied building may create conflicts with existing PGandEsafety and operations standards for nuclear plants.

3. The volume control tank compartment is a high radiation area.Additional personnel exposure and possible contamination ofzhe hydrogen bottles would result from storage of the bottlesin that area.

It is felt that, the reroute and installation of guard piping for thehydrogen system will minimize the potential of a hydrogen explosionaffecting safe shutdown equipment.

Q.50., Supplement the information which has been provided to include a listingof all systems and components such as instruments and controls which areessential to achieve and/or maintain cold shutdown (safe shutdown). Also,identify any of these systems and/or components whose associated electricalcircuitry and/or cables are not redundant.

Revised Res nse

The systems, components and instruments which are required to achieve and/ormaintain a safe cold shutdown condition are listed in the attached .table.-The redundancy.-of the components and instruments is also included. Thisinformation is. an excerpt from Section 2 of PGandE's June 6, 1978, submittalentitled "Supplementary Xnformation for Pire Protection Review". "

DIABLO CANYON UNITS 1 AND 2

FIRE PROTECTION REVIEW OF

E UIPMENT RE UZRED FOR SAFE SHUTDOWN

SYSTEM AND COMPONENTS REDUNDANCY AND/OR COMMENTS

l. Emer enc Power Su 1

A. Diesel Generator 2 of 3 required

B. Diesel fuel oil transfer pumps and daytank level control valves

*1 of 2 pumps required, 1 of 2

LCV's per day tank required

C. 125v DC batteries

D. Battery chargers

E. Znverters

F. 4KV power supplies to 480v load centersand load center transformers

2 of 3 required

2 of 5 required

2 of 4 required

2 of 3 required

G. 125v DC supplies to 4KV switchgear 2 of 3 required

H. 125v DC power supplies to main controlboard

Z. Instrument AC power

2 of 3 required

2 of 4 channels required

2. Auxilia Feedwater S stem

A. Auxiliary feedwater pumps (turbine drivenauxiliary feedwater pump l-l and electricmotor driven auxiliary feedwater pumps1-2 and 1-3) .

1 of 3 pumps required

B. Associated steam supply valves for pump 1-1:FCV-95, FCV-15, FCV-152FCV-37, FCV-38

Applicable only to pump 1-1Required for pump l-l1 of 2 valves required for pump l-l

C.

Pump 1-2:Pump 1-3 ~

Associated level control valves:Pump 1 1 LCV 106'CV 107'CV 108

LCV-109LCV-110, LCV-illLCV-113, LCV-115

1 of 4 valves required for pump l-l1 of 2 valves required for pump 1-21 of 2 valves required for pump 1-3

D. Water supply and associated valves:

(1) Condensate storage tankor (2) Raw water reservoir,

FCV-436, FCV-437

1 of 2 water supplies requiredNo valves required

1 of 2 valves required for rawwater reservoir

SYSTE.'1 AND COMPONENTS REDKK4dhCY TIED/OR COKKtFZS

3. Residual Heat Removal S stem

A. Residual heat removal pump

B. Residual heat removal heat exchanger

1 of 2 pumps required

1 of 2 HX required

C. Residual heat removal valves:8701, 8702 (hot leg RHR suction)HCV-637, HCV-638 (RHR flow path)8809-A, 8809-B (RHR flow path)

Both valves required1 of 2 valves required1 of 2 valves required

D. RHR heat sink:Component cooling water systemAuxiliary saltwater system

See Item 5

See Item 6

4. Char in and Boration

Charging pumps (2 centrifugal and1 reciprocating pump)

1 of 3 pumps required

B. Charging pump cooling:Component cooling water systemAuxiliary saltwater system

see Item 5see Item 6

C. Centrifugal. charging pump auxiliarylube oil pumps

F

D. Charging and boration flow path

Only utilized to start pumps.Can be by-passed.

1 flow path required

and a. Charging through reactor coolantpump seals via RCP seal injection

or b. Charging through regenerative HXand valves HCV-142, 8108, 8107 and:

oz

or

1. Valve 8145,pressurizer

2. Valve 8146,cold leg

3. Valve 8147,cold leg

charging to auxiliaryspraycharging to loop 3

charging to loop 4

(1) Using boric acid tanks:Boric acid tanksBoric acid tank heaters*Boric acid tank temperature controllers*Boric acid transfer pumpsBoric acid filterValves 8104, FCV-110AHeat tracing for boric acid lines in

flow path*Charging pumpsValve FCV-128

1 of 2 tanks required1 of 2 heaters per tank required1 of 2 TIC's required1 of 2 pumps requiredOnly flow path required1 of 2 valves required1 of 2 heat traces required

1 of 3 pumps requiredRequired for centrifugal chargingpumps. Two manual by-pass flowpaths.No additional components required

Flow path through HX requiredand all valves required for thisflow path.Valve required for pressurizerspray.Valve required

Valve required

*Components are not required for safe shutdown but have been tabulated to assess inwhat areas a fire could damage these components.

)

SYSTEM AND COMPONENTS DANCY AND/OR COMMENTS

or (2) Using boron injection tanks:Refueling water storage tankValves 8805A, 8805BCharging pumpsValve FCV-128

Valves 8803A, 8803BBoron injection tank (BIT)BIT heater*BIT temperature controller*Valves 880lA, 8801BHeat tracing for boric acid linesin flow path*

5. Com onent Coolin Water System

Required for this flow path1 of 2 valves required1 of 3 pumps requiredRequired for reciprocatingcharging pump1 of 2 valves requiredRequired1 of 2 heaters requiredRequired1 of 2 valves required1 of 2 heat traces required

A. Component cooling water pump

B." Component cooling water heat exchanger

1 of 3 pumps required

1 of 2 HX required

C. Component cooling water valves:FCV-430, FCV-431 (CCW vital service headers)FCV-355 (CCW miscellaneous service header)

FCV-364, FCV-365 (CCW to RHRHX)

1 of 2 valves requiredRequired for charging pump 1-3cooling1 of 2 valves required for RHR

system cooling

D. CCW pump auxiliary lube oil pump Only required to start CCW pump

E. CCW heat sink:Auxiliary saltwater system See Item 6

6. Auxilia Saltwater S stem

A. Auxiliary saltwater pump 1 of 2 pumps required

B. Auxiliary saltwater valves:FCV 602 g FCV 603 (ASW to 'CCWHX) 1 of 2 valves required

7. Main Steam S stem

A. Main steam isolation valves:FCV 41 g FCV 42 g FCV 43 ~ FCV 44

Required to close only for amain steam line break

B. 10% power relief valves:PCV-19, PCV-20, PCV-21, PCV-22

1 of 4 valves required. Backupto 10% power relief valves pro-vided by 35% power relief systemand 40% steam dump valves.

C. Steam generator safety valves Five per loop, 20 total. Requiredto lift if only 1 of 4 10% powerrelief valves is available.

D. Steam generator blowdown isolation valves: ., Required to close. to maintainFCV 760 J FCV 761 J FCV 762 g FCV 763 water inventory for safe shutdown

*Components are not required for safe shutdown but have been tabulated to assess inwhat areas a fire could damage these components.

'YSTEM AND COMPONENTS DANCY AND/OR COMMENTS

8. Instrumentation

A.

B.

Steam Generator level

SG 1 1'T 517~ LT 518'T 519SG 1-2: LT-527, LT-528, LT-529SG 1 3 LT 537'T 538'T-539SG 1 4 LT 547'T 548'T 549

Steam generator pressure

Loop 1: PT 514@ PT 515@ PT 516Loop 2: PT-524, PT-525, PT-526Loop 3: PT 534'T 535, PT 536Loop 4: PT-544, PT-545, PT-546

1 steam generator required forcooldown, 1 of 3 LT's requiredfor that SG.

' steam generator required forcooldown1 of 3 PT's required for that loop

C. Reactor coolant system temperature

Loop. 1: TE-413A, TE-413BLoop 2: TE-423A, TE-423BLoop 3: TE-433A, TE-433BLoop 4: TE-443A, TE-443B

1 of 2 required per loop, 1

loop required for cooldown

D. Reactor coolant system or pressurizer pressure 1 of 4 requiredPT-403, PT-405, PT-455, PT-456

E. Pressurizer levelLT 459'T 460/ LT 461@ LT 406

1 of 4 required

F. Boric acid tank levelLT-102, LT-106

1 of 2 required

'.

Ventilation for Safe Shutdown E i ment

A. Control room supply fansS-35, S-36

1 of 2 fans required. Unit 2

ventilation also available forshared control room.

B Auxiliary building supply and exhaustfansS-31, S-32E-l, E-2

1 of 2 required1 of 2 required

C. 480 volt switchgear room and inverterroom supply fansS-43, S-44 1 of 2 required

D. 4.16KV switchgear room supply fansS 67/ S 68~ S 69 2 of 3 required

E. Auxiliary saltwater pump room exhaustfansE-101, E-103 1 of 2 required

Fuel handling building supply andexhaust fansS-l, S-2E-5, E-6

1 of 2 required1 of 2 required

~ y -5-

SYSTEM AND COMPONENTSREDUNDANCY 'AND/OR COMMENTS

A. Primary water supply:Raw water reservoir.

-1 of 2 water supplies requiredin the event of a fire

B. Secondary-water supply:Fire water storage tank,Fire pumps O-l, 0-2 1 of 2 pumps required for this

water supplyll. Pressurizer S ra **

A. Water supply to charging pumps 1 of 2 supplies required

(1) Boric acid tanksBoric- acid tank heaters*Boric acid tank temperature controllers*Boric acid transfer pumps,Boric acid filterValves 8104, FCV-llOAHeat tracing for boric acid lines inflow path*

1 of 2 tanks required1 of 2 heaters per tank required1 of 2 TTC's required1 of 2 pumps requiredOnly flow path required1'f 2 valves required1 of„ 2 heat traces required

or (2) Refueling water storage tankValves SSOSA, 8805B

Required for this flow path1 of 2 valves required

B. Charging pumps 1 of 3 pumps requiredC- Charging flow path

Valves HCV-142, 8108, 8107Regenexative HZValve 8145, auxiliary pressurizer spray

Valves requiredFlow path requiredManual by-pass around valve 8145

* Components are not requi.red for safe shutdown but have been tabulated to assess inwhat areas, a fire could damage these components.

**Allcomponents requ'ed for Pressurizer Spray have been tabulated for Charging andBoration. Alternative pressurizer spray methods available provided reactor coolantpumps and PCV-455A and PCV-455B operable (valves require instrument ai ) . Backup,pressure relief capability provided by pressurizer power relief valves (PCV-455C,PCV-456, PCV-4741.

Q.51 ~ Assuming that an emergency alternate method is employed, outside of thecontrol room, to achieve and/or maintain a safe cold 'shutdown, provideresponses to items below:

1. Provide a list of essential safe shutdown equipment with a descrip-tion of- how remote instrumentation and control would be accomplished.Identify each safe shutdown equipment and/or its associated instru-mentation and control equipment for which electrical energy isessential for its proper operation.

2. Provide supporting information which may be used to conclude that(if a fire occurs in the main control zoom or cable spreading room)electrical power, instrumentation, or control required for safe shut-down equipment will not be lost, assuming that the offsite power gridis not available.

3. Confirm that the associated electrical design or corresponding remoteshutdown instrumentation and control panels is the same for the twounits.

4. Identify and describe any changes in the original electrical designas a result of the incorporation of this emergency alternate methodfor achieving and/or maintaining a safe shutdown.

Revised Res onse

Control of E ui ment at the Hot Shutdown Remote Control Panel

In the event that the control room is uninhabitable or portions of itare non-functional as a result of a fize in either the cable spreadingroom or the control room, safe (cold) shutdown would be carzied out atthe hot shutdown remote control panel located at elevation 100 feet inthe auxiliary building (west end of fire zone 5-A-4). For a tabulationof how safe shutdown components would be controlled outside of thecontrol room, refer to the attached table, "Status of Safe ShutdownEquipment Assuming Loss of Cable Spreading Room/Control Room." Tooperate equipment from the hot shutdown panel, the dooz panels would beopened, a transfer switch (one for each component). would be thrownfrom "control room" to "local", and the control switch could thenoperate the component in question. All of these actions are annunciatedor indicated in the control room. Once the transfer switch is thrownto the local position, control circuitry running in the cable spreadingroom and control room is isolated from the rest of the circuit. None

of the circuitry associated with the hot shutdown panel controls runsin the cable spreading room or control room, nor do any power circuitsfor safe shutdown components run in the cable spreading room or controlroom. Thus, any fire damage as a result of a cable spreading room orcontrol room fire cannot a'ffect control of safe shutdown equipmentfrom the hot shutdown panel. The electrical and instrument schematicsfor the following safe shutdown equipment with control at the hotshutdown panel verify the above statements:

Revised Res onse to .51 -(Continued)

~Drawin

~corn

nant

" 437583437584

437507

102036Sh. 8,8A437595497597437607102032Sh. 26102036Sh. 30A437593437594102036Sh. 16,16A

Motor-driven auziliary feedwater pumpsFCV-95; steam supply valve for turbine-drivenauxiliary feedwater pump

LCV-106, 107, 108, 109; level control valves forturbine-driven auxiliary feedwater pump

LCV-110, ill, 113, 115; level control valves formotor-driven auxiliary feedwater pumps

Centrifugal charging pumpsBoric acid transfer pumpsValve 8104, emergency borate valveHCV-142; charging pump discharge.to regenerative

HX valveFCV-128; charging pump discharge headervalve

Component cooling water pumpsAuxiliary saltwater pumps10% power relief valves

Local Control of Safe Shutdown E i ment

Some safe shutdown equipment might have to be operated locally-atthe switchgear, or in the case of certain motor operated valves,manually. For example, the diesel generators and the fire pumps arecontrollable locally, the RHR pumps and the reciprocating chargingpump can be started at the 4KV switchgear, and the auxiliary buildingand/or fuel handling building ventilation can be started at their 480Vmotor control centers if necessary. The electrical schematics for

these'afe

shutdown components with local controls verify the above statement:

~Drawin

437625

437591437595445643

437630

~corn anent

"F" Bus Diesel Generator automatic startingand loading ("G" and "H" bus similar)

RHR pumpsReciprocating charging pumpAuxiliary building and fuel handling buildingventilation fansFire pumps

A cable spreading room or control room fire would not prevent operationof these components either locally or at the switchgear. Zn situationswhere it might be necessary to manually open or close a motor operatedvalve, the motor operator for the valve would be de-energized at themotor control center to prevent a subsequent fault in the circuitryfrom causing spurious valve movement. This de-energizing requirementwill be incorporated into: the emergency operating procedures. All safeshutdown air operated valves fail to their desired position if the airsupply is removed.

Revised Res onse to . 51 .(Continued)

Instrumentation Re ired for Safe Shutdown

Existing safe shutdown instrumentation with readouts in the controlroom or at-the hot shutdown panel could be affected by a cablespreading room fire. To prevent loss of vital instrumentation dueto cable spreading room fire, dedicated safe shutdown instrumentationwill be provided that is not vulnerable to a cable spreading room(or control room) fire. The parameters to be monitored will bepressurizer pressure and level, reactor coolant system temperature,and steam generator level and pressure.. These parameters, along withreactor coolant system boron concentration (determined from thereactor coolant system sampling system or change in boric acid tanklevel), are sufficient to take the plant to a safe (cold) shutdowncondition. The dedicated safe shutdown instrumentation will beseparate from the protection system instrumentation.Steam generator pressure will be provided by pressure indicatorson the main steam lines outside containment (fiie zone 3-BB).Two reactor coolant system temperature elements will be locatedin fire zone 1-B; pressurizer pressure and level and steamgenerator level transmitters (one per SG) will be located in firezone 1-A. The circuits from these transmitters will pass throughthe containment and terminate at, the dedicated safe shutdowninstrument panel in fire zone 3-BB at elevation.100 feet. Thepower supply for,the instrumentation will be vital instrument AC

power, Channel IV. Circuit routing for the Instrument AC powerwill be confined to the "H" bus electrical rooms and fire zone 3-BB.Since none of the circuitry associated with the dedicated safe shut-down instrumentation or its power supply passes through the cablespreading room or the control room, a fire in either of theseareas cannot affect this instrumentation. Electrical design of thehot shutdown panel and associated local panels is the same for thetwo units. All electrical modifications (including dedicated safeshutdown instrumentation) will be done for both units.

Conse ences of a Fire at the Hot Shutdown Panel

A fire in the west end of fire zone 5-A-4 could affect the hotshutdown panel or the circuitry to the hot shutdown panel. Thisarea has a minimal fuel loading, smoke detectors have been providedin the area, and the area has been designated as a "No Storage" area.Thus, it is felt that a significant fire would not occur in thisarea. However, the consequences of such a fire are described below.

There are three considerations in assessing the consequences of ahot shutdown panel fire:1. damage to circuitry running to the hot shutdown panel,

2. a fire that affects the transfer switches within the hotshutdown panel, and

3. components affected in the control room due to the hot shutdownpanel fire.

Revised Res onse to 0.51 (Continued)

Control circuit- routing for all the pumps and motor operated valveswith controls at both the hot shutdown panel and the control room issuch that damage to the circuits to the hot. shutdown panel will notaffect control room circuitry and vice versa. This is demonstratedon the electrical schematics listed above for the pumps and motor-operated valves that have controls at the hot shutdown panel. Duringnormal operation, the hot shutdown panel control circuitry is isolatedfrom the rest of the circuit by open contacts located, in the 480V or4KV motor control centers. Any damage to this isolated circuitryrunning between the motor control room center and the hot shutdown panelcannot-in any way affect control room operation of this component.This is true for all 480V pumps and motor operated valves, with controls.at the hot shutdown panel.

A fire affecting the transfer switches in the hot shutdown panel couldconceivably cause control of components to be taken away from the controlroom and transferred to the hot shutdown panel. Switches within themotor control centers will be provided to restore control back to thecontrol room (as shown on the electrical schematics). Once this switchis thrown, operation of the equipment from the control room cannot beaffected by a hot shutdown panel fire.Circuitry for the electrohydraulic auxiliary feedwater level controlvalves (LCV-110, ill, 113, 115), if damaged by a fire in or near the hotshutdown panel, could prevent control room operation of these valves.However, these valves would still be manually operable and, as Statedabove, the motor-operated auxiliary feedwater level control valves wouldstill be operable from the control room.

Valves FCV-128 (charging pumps discharge header) and HCV-142 (chargingpump discharge to regenerative heat exchanger) have pneumatic controlsat the hot shutdown panel. Damage to the pneumatic controller or tubingas a result of a hot. shutdown panel fire could prevent control roomoperation of these valves. However, FCV-128 is normally open and failsopen on loss of air. Furthermore, the reciprocating charging pump doesnot require this valve for'peration. HCV-142 is not required forcharging via the reactor coolant pump'eal flow path; furthermore, amanual by-pass around HCV-142 could be opened if necessary.

The 10% power relief valves (PCV-19, 20, 21, 22) have pneumatic controlsof the hot shutdown panel also. However, a backup pneumatic air supply(air bottles) independent of the hot shutdown panel would allow valveoperation from the contxol room in the event of a fire at the hot shutdownpanel.

'evised Response to .51 (Continued)

A hot shutdown panel fire that 'affects instrumentation with readoutsat the hot shutdown panel would affect control room readout of thatsame instrumentation. However, sufficient redundancy in instrumentationis provided in the control room such that loss of that instrumentation

. with readouts at the hot shutdown panel would not affect safe shutdowncapability from the control room. None of the hot shutdown panelinstrumentation is associated with the protection system.

The components described above are all of the safe shutdown componentswith controls/readouts at the hot shutdown panel. Zn summary, safeshutdown capability from the control room is not adversely affected bya hot shutdown panel fire.

(5DIABLO CANYON UNITS 1 AND 2

STATUS OF SAFE SHUTDOWN EQUIPMENT ASSUMINGLOSS OF CABLE SPREADING ROOM/CONTROL ROOM

SYSTEM AND COMPONENTS COMMENT

Emer enc Power Su 1

Diesel generatorsDiesel fuel transfer pumps

Local controls in DG roomsUnaffected by CSR/CR fire

Auxiliar Feedwater S stem

Motor driven auxiliary feedwater pumpsTurbine driven auxiliary feedwater

pumpAuxiliary feedwater level control

val'ves

Control at HSD panelControl at HSD panel

Control at HSD panel

Residual Heat Removal S stem

RHR pumpsRHR valves

Control at 4KV switchgearOpen 8701, 8702 manually; HCV-637,HCV-638 fail open; 8809A, 8809Bnormally open, fail as is

Char in and Boration

Boric acid transfer pumpsValve 8104Centrifugal charging pumpsFCV-1281) Reactor coolant pump seal

flow pathor 2) HCV-142

Valves 8107, 8108a) Valves 8146, 8147

or b) Valve 8145 (pressurizer spray)

Com nent Coolin Water S stem

Control at HSD panelControl at HSD panelControl at HSD panelControl at HSD panelAvailable

Control at HSD panelNormally open, fail as isFail open on loss of airOpen manual by-pass

Component cooling water pumpsCCW vital service header valvesCCW to RHR HX valves

Control at HSD panel1 of 2 valves open," fail as isFail open on loss of air

Auxilia Saltwater S stem

Auxiliary saltwater pumpsASW valves

Control at HSD panelFail open on loss of air

SYSTEM AND COMPONENTS

Main Steam S stem

COMMENT

10% power relief valvesSteam generator blowdown isolationvalves

Control at HSD panelFail closed on loss of air

Instrumentation

Steam generator levelSteam generator pressureReactor coolant system temperaturePressurizer pressurePressurizer levelBoric acid tank level

Indication at DSSIP*Local indicationIndication at DSSIPIndication at DSSIPIndication at DSSIPLocal indication

Ventilation for Safe Shutdown E ui ment

Auxiliary building ventilationFuel handling building ventilation

'80Vswitchgear and inverter roomventilation

4KV switchgear room ventilationAuxiliary saltwater pump ventilation

Start at motor control centerStart at motor control centerNot affected by CSR/CR fire

Not affected by CSR/CR fireNot affected by 'CSR/CR fire

'ire 'System

Fire pumps .Local controls at fire pumps

*DSSIP = Dedicated safe shutdown instrument panel