BVY 08-083, Request for Revision to Existing 10 CFR 50 Appendix R Exemption Response to Request for Additional Information
| ML083370180 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 11/20/2008 |
| From: | Michael Colomb Entergy Nuclear Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| BVY 08-083 | |
| Download: ML083370180 (6) | |
Text
--Entergy Entergy Nuclear Operations, Inc.
Vermont Yankee P.O. Box 0250 320 Governor Hunt Road Vernon, VT 05354 Tel 802 257 7711 November 20, 2008 BVY 08-083 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
References:
(a)
Letter, VYNPS to USNRC, "Request for Revision to Existing 10 CFR 50 Appendix R Exemption," BVY 08-040, dated July 11, 2008 (b)
Letter, USNRC to VYNPS, "Vermont Yankee -
Request for Additional Information Regarding Technical Specification Change Relating to Degraded Grid Protection System Instrumentation (TAC No. MD81 11)," NVY 08-080, dated August 19, 2008
Subject:
Vermont Yankee Nuclear Power Station License No. DPR-28 (Docket No. 50-271)
Request for Revision to Existing 10 CFR 50 Appendix R Exemption Response to Request for Additional Information
Dear Sir or Madam,
In Reference (a), Entergy Nuclear Operations Inc. (ENO) submitted a request for a revision to an existing 10 CFR 50 Appendix R exemption from the 20 foot separation requirement between redundant cable trays. This letter is in response to your staffs request for additional information (RAI) provided on October 21, 2008. Attachment 1 to this submittal provides ENO's response to each of the RAI questions.
This supplement to the original exemption request does not change the scope or conclusions in the original application.
There are no new regulatory commitments being made in this letter.
Should you have any questions or require additional information concerning this submittal, please contact Mr. David J. Mannai at (802) 451-3304.
I declare under penalty of perjury, that the foregoing is true and accurate.
Executed on November 20, 2008 Sincerely, Michal JA Cokmb Site Vice President Vermont Yankee Nuclear Power Station Attachments (1) cc listing (next page)
- 4wo,
BVY 08-083 / page 2 of 2 cc:
Mr. Samuel J. Collins Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Mr. James S. Kim, Project Manager Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 0 8 C2A Washington, DC 20555 USNRC Resident Inspector Entergy Nuclear Vermont Yankee, LLC 320 Governor Hunt Road Vernon, Vermont 05354 Mr. David O'Brien, Commissioner VT Department of Public Service 112 State Street - Drawer 20 Montpelier, Vermont 05620-2601
Docket 50-271 BVY 08-083 Request for Revision to Existing 10 CFR 50 Appendix R Exemption Vermont Yankee Nuclear Power Station Response to Request for Additional Information
BVY 08-083, Attachment 1, Page 1 of 3 Request for Revision to Existing 10 CFR 50 Appendix R Exemption Vermont Yankee Nuclear Power Station Response to Request for Additional Information RAI No.1:
Clarify the type and configuration of the fire and/or smoke detection system that is provided in Fire Zone RB-3.
Background:
Sections 3.2 and 4.0 of the July 11, 2008 Request for Revision to Existing 10 CFR 50 Appendix R Exemption make reference to a fire detection system being provided in the northwest corner of Fire Zone R13-3. Section 6.0 of the April 24,1985 Request for Exemption -10 CFR 50, Appendix R, Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979 states that a smoke detection system has been provided in the northwest corner of Fire Zone RB-3.
Response to RAI No. 1:
Table 1 of the Vermont Yankee Nuclear Power Station (VY) Fire Hazards Analysis describes the types of detectors for the various fire zones. The 252' elevation of the Reactor Building is divided into two fire zones, RB-3 and RB-4. There are a total of 87 ionization-type smoke detectors that provide coverage for the entire area.
RAI No.2 Clarify the type and configuration of the wet fire suppression system that is provided in Fire Zone RB-3 including the details of the pre-action feature.
Background:
Section 3.2 of the July 11, 2008 Request for Revision to Existing 10 CFR 50 Appendix R Exemption states that automatic water spray suppression is provided in the northwest corner of Fire Zone RB-3. Section 6.0 of the April 24,1985 Request for Exemption -10 CFR 50, Appendix R, Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979 states that a pre-action automatic sprinkler system has been provided in the northwest corner of Fire Zone RB-3.
Response to RAI No. 2:
The two exposed cable tray systems in Fire Zone RB-3 are protected by a pre-action automatic sprinkler system that is installed beneath the lowest level of cable trays, and above the top level of trays. The sprinkler system will promptly suppress any fire in this area and ensure that redundant safety systems are preserved.
These systems have air in the sprinkler piping which is under pressure. This provides a means of supervising the pipe integrity. When a fire occurs, a supplementary fire detection device in the protected area is actuated. The detection system opens a water control valve which permits water to flow into the piping system, usually before a sprinkler is activated. When sprinklers are subsequently opened by the heat of the fire, water immediately flows through the sprinklers.
BVY 08-083, Attachment 1, Page 2 of 3 Request for Revision to Existing 10 CFR 50 Appendix R Exemption Vermont Yankee Nuclear Power Station Response to Request for Additional Information RAI No. 3:
Confirm whether 1-hour raceways are provided in Fire Zone! RB-3 including details on the type of assemblies and locations.
Background:
Section 5.2 of the December 1, 1986, Safety Evaluation (SE) by the Office of Nuclear Reactor Regulation notes that the licensee proposed to provide a 1-hour fire rated barrier for cables in raceways required for safe shutdown that pass through the separation zone in the northwest corner of Fire Zone RB-3.
Response to RAI No. 3:
Entergy Nuclear Operations (ENO) did not identify any raceways which required protection with a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> fire barrier within the separation zone until a re-analysis that was performed in 1995 and 1996. At that time, ENO identified that power cables to MCC 9B, which were routed in conduit under the RB3-SII trays (see Figure 1) in the Northwest Corner of Elevation 252', protruded into the separation area for a few feet until the conduits made a 90 degree turn and exited the area to the east. ENO provided a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 3M Interam fire barrier in Fire Zone RB-3 in the area of the cable route where separation was reduced.
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