L-81-286, Responds to 810604 Request for Addl Info Re Exemption from Requirement to Install Fire Rated Dampers in safety- Related Duct Penetrations in Auxiliary Bldg
| ML17212A354 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 07/10/1981 |
| From: | Robert E. Uhrig FLORIDA POWER & LIGHT CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| L-81-286, NUDOCS 8107200389 | |
| Download: ML17212A354 (11) | |
Text
REGULATQP
'NFORMATION DISTRIBUTION TEM (RIDS)
ACCESSION'BR:8107200389 DOC ~ DATE: 81/07/10 NOTARIZED:
NO FACIL~:50"335 St'+ Lucie'lanti Unit i~ Florida Power 8 Light'o>
AUTH',NAME AUTHOR AFF ILIAT'ION UHRIGiR,E ~
Flor,ida Power 8 Light Co.'ECIP
~ NAMEi RECIPIENT AFFII ZATION DENTONpH',R~
Office>> of Nuclear Reactor Regulationi Director~
SUBJECT:
Responds to 810600 request for<< addi info re exemption from requirement to install fire rated dampers in safety-related duct, penetrations in auxiliary bldg DISTRIBUTION GODET A006S COPIES RECEIVED:LTR ENCL SIZE'.: '
T>>ITLEtt: Fire Protection Information (After Issuance of OP, Lic ~ )
NOTES't:
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FLORIDAPOWER & LIGHTCOMPANY July 10; 1981 L-81-286 Office of Nuclear Reactor Regulation Attention:
Mr. Harold R. Denton, Director U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Dear Mr. Denton:
Re.
St. Lucie Unit 1 Docket No. 50-335 10 CFR Appendix R Exemption Request Additional Information on Fire Dampers'in Safet -Related Ductwork
/
col Pc Please find attached the additional information you requested in your letter dated June 4, 1981 regar'ding fire dampers in safety-related ductwork of the Auxiliary Building.
This information is transmitted in support of our exemption request.
from the requirement to install fire rated dampers in safety-related duct penetrations.
Very truly yours, Robert E. Uhrig Vice President Advanced Systems and Technology REU/JEM/mbd Attachment cc:
Mr. James P. O'Reilly, Region II Harold F. Reis, Esquire 5
i/(
8l07200389 810710 PDR ADOCK 05000335 F
PDR PEOPLE... SERVING PEOPLE
ATTACHHENT 1 Page 1
1.
NRC REQUEST: "List the a
e safety-related duct penetrations of the auxiliary building in which you are requesting
. approval not to install dampers.
/
PPL RESPONSE: 'able X provides a 1 ti f
es a
est ng of those penetrations which are to be excluded from the requirements of Appendix R,Section XXX. G 2.
NRC REQUEST:
o Provide details supporting your, conclusion that the radiological boundary of the Auxiliary Building could be violated.
FPL RESPONSE:
Duct penetration No.'
10 4
o.
s
, 1
& 15 from Table.X
= of are requested to be exempt from the requireme 't Appendix R,Section XXX. G for the followin en' reasons
)
These penetrations exist in ventilation ducting which is commen to both emergency exhaust fans (HVE-9A,B) of the ECCS Area Ventilation System.
2)
The single failure of a safety-related fire damper at one of these penetrations could result in the partial or total failure of the EC S
e C
Area Ventilation System to perform its safety function.
0 3)
The ECCSVentilation System is designed to provide post-LOCA filtration and adsor ti of f so p
on o
xssion products in the exhaust air from areas of the Auxiliary Building w'hich contain the following equipment a)
Containment isolation valves.
b)
Low pressure safety injection pumps.
c)
High pressure safety injection pumps.
d)
Containment spray pumps.
e)
Shutdown heat exchangers.
)
Piping which contains recirculating contairiment sump, water following a LOCA.
The ventilation system is sized to maintain a s ightly negative pressure of between 1/4 and 1 inch wg in the ECCS area with respect to suirounding areas of the Reactor Auxiliary Building.
The single failure described in
'paragraph (2) above, could result in the following:
Page 2
a)
Loss of the pressure differential between the ECCS area and the surroun-ding areas of the Auxiliary Building, thus disrupting the air flow from areas of low radioactivity to high radioactivity.
r b)
The build-up of airborne. rpdioactivity in the ECCS area, and its subsequent escape to other areas of the Auxiliary Building..
Duct penetration Ho.'s 1 3~ 4, 5~
6 7,
8 9>
ll, 12, 13, 16; 17, 18, 19, 20 6 21 are re-quested to be exempt from the requirements of,
.Appendix R,Section III. G for the following reasons:
1 1)
These penetrations exist in ventilation ducting which is common to both main
- supply fans (HUS-AA, B) of the Reactor Auxiliary Building Main Ventilation System.
2)
The single failure of a safety-related fire damper at one of these penetrations could result in the partial or total failure of the Auxiliary Building Hain Ventilation System to perform its radio-logical safety function.
3)
The Reactor Auxiliary Building Hain Ventilat'ion System is designed to pro-vide, air flow from areas of low potential
~
radioactivity to areas of higher poten-tial radioactivity.
This function is, accomplished by the proper distribution of supply air, concurrent with the operation of the ECCS area exhaust ventilation system.
The single failure described in paragraph (2) above could result in the loss of air flow to an area adjacent to
.the ECCS rooms, thus enhancing the possi-bility of leakage out of the ECCS area.
Duct penetration Ho.'s 25, 26 and 27 from Table 'I are requested to be exempt from the requirements of Appendix R,Section III. G for the following reasons:
Page 3
1)
These penetrations exist-in ventila-tion ducting which is common to both the booster fans and air conditioners of the Control Room HVAC System.
2)
The single failure of a safety-related-fire damper at one of these penetrations
'could result in the partial or.complete failure of the Control Room HUAC System
'o perform its safety functions.
3)
The control room ventilation system is.
designed to:
I
\\
a)
~ Limit Control Room doses 'due to air-borne activity to within GDC 19 limits.
b)
Permit personnel occupancy and proper functioning instrumentation and controls during normal and LOCA conditions.
c)
Permit personnel occupancy during a chloxine release accident.
'hese functions are accomplished by iso-lating normal unfiltered. aix intakes during accident conditions, recirc'ulating contxol "room air through HEPA and charcoal filters, and maintaining. the Control Room at a slight positive pressure when receiving outside air make up..
The single failure described in 'paragraph (2) above could prevent this system from.
inducing a positive pressure in the Control Room, or recirculating the Control Room air fox filtration and adsorption of fission products.
3.
NRC REQUEST:
Provide details supporting your conclusion that the operation of vital emergency safeguards equipment could be affected.
FPL RESPONSE:
Duct penetration No.'s 1, ll, 12, 13, 16 and 20 from Table I are reque'sted to be exempt from the
~
requirements of Appendix R,Section III. G for the following reasons:
1)
These penetrations exist in ventilation ducting which is common to both main supply fans (HVS-4A, B) of the Reactor Auxiliary Building Main Ventilation System.
Page 4
- 2).The single failure of a safety related fire damper at one of these penetrations could result
, in the partial or total failure of the Auxiliary
,Building Main Ventilation System to perform its safety related cooling function.
3)
The Reactor Auxiliary Building ventilation system is designed to provide an air supply for'meeting the cooling requirements of safety related equipment, such as the low and high'ressure safety injection pump motors and the containment spray'ump.
This system provides a minimum of four air changes per hour for each of the rooms'n the building, and is sized to achieve the design ambient maximum temperature of 104 degrees F. in the equipment areas with an outside air 'temperature of 93 degrees F.
The initiation of a SIAS signal automatically directs the required air flow to safety related equipment, by the use of motor;operated dampers to isolate non-vital portions.of the system.
The single failure described in paragraph (2) above, would result in the loss of cooling to redundent com-ponents required for reactor safety, due to the utilization of a common supply duct.
This would result in increased equipment temperatures with subsequent reduced reliability.
Duct penetration No.'s 22, 23
& 24 from Table I are requested to be exempt from the requirements of Appendix R,Section III. G for the following reasons:
'1)
These penetrations exist in ventilation ducting which is common to both supply fans (HVS-5A, B) of the Electxical Equipment Room Ventilation System.
2)
The single failure of a safety-related fire damper at one of these penetrations could result.in the partial or total failure of the Electrical Equipment Room Ventilation System to perform its safety-related function.
3)
The Electrical Equipment Room Ventilation System is designed to provide,coo1ing to the Electrical Equipment Rooms lA and 1B, as well as the Cable Spreading Room.
This ventilation
Page 5
system is. safety-related since it is required for the proper functioning of emergency elec-trical distribution equipment.
The single failure described in paragraph (2) above could result in the loss of cooling to one or all three of these rooms due to the use of a common ventilation duct for the supply fans.
The sub-sequent increase in equipment temperature would result in reduced equipment'eliability.
TABLE I DUCT.
PENETRATION NO.
SAFETY RELATED VENTILATION DAMPERS REQUEST FOR EXCLUSION
- BETWEEN FIRE AREA NO.
SAFETY RELATED,'
PENETRATION SIZE
+APPROXIMATE AND FIRE AREA NO.
UENTILATION SYSTEM W x H (inches)
LOCATION OF CONCERN Page 1
SAFETY RELATED FUNCTION 2
35
& 47 35
& 47 Auxiliary Bldg. Main
.64 x 30 Ventilation'ystem,"
ECCS Ventilation System Fire area 35; in ceiling by, south wall
". 36 x 48- --',
Fire area 35>
-.. in ceiling.
between HPSI Pumps 1A & 1C Refer to FPL response for Items 2
& 3 Refer to FPL response to Item 2 35
& 38 Auxiliary Bldg. Main 48 x 18 Ventilation System Fire area 35; east wall Refer to FPL respo for Item:2
'5/76/38
& 36 36
& 39 Auxiliary Bldg. Main 26 x 10 Ventilation. System Auxiliary Bldg. Main 20 x 20 Ventilation System Fire area 36; east wall of north-south corridor by charging pump area Refer to FPL for Item 2 Fire area 36; Refer to FPL in north-south,for Item 2 corridor by charging pump area response response'9
& 36 39
& 36 Auxiliary Bldg. Main Ventilation System Auxiliary Bldg. Main Ventilation System 26 x 10 18x8 Fire area 39; south wall Fire area 39; s'outh wall in corridor Refer to FPL for Item 2 Refer to FPL for Item 2 response response 35
& 36 35
&36'uxiliary Bldg. Main Ventilation System Auxiliary Bldg. Main Ventilation System 18 x 14 32x8 Fire area 35; south wall Fire area 35; south'wall Refer to FPL response for Item 2 Refer to FPL response for Item 2
TABLE I Page 2
PENETRATYON
- BETNEEN FYRE AREA NO.
'AFETY RELATED NO.
AND FIRE AREA NO.
PENTZLATYON SYSTEN PENETRATION:SME ".
- APPROXQfATE
~ 'AFETY RELATED M x H (inches)
LOCATION FUNCTION 10 34
& 32 ECCS Ventilation System 24 x 10 Fire area 34; Refer to FPL respons west vali
. 'o Item 2 49&61 Auxiliary Bldg. Main Ventilation System 70 x 48 Fire area 49; Refer to FPL in ceiling by to Items 2
west vali respons 12 Auxiliary Bldg. Hain Ventilation System
?Ox 48 Fire area 49; west wall Refer to FPL respons to Items 2' 3
13 47
& 48 47
& 61 Auxiliary Bldg. Main 70 x 48 Ventilation, System ECCS Ventilation System 48 x 36 Fire area 47;
.east wall Fire area 47; in ceiling by east wall Refei to FPL respons to Items 2
& 3-Refer to FPL respons
.to Item 2 15 47 &80 ECCS Ventilation System 48 x 36 Fire area 47; Refer to FPL response north wall to Item 2 16 17 18 19 20 21 47
& 55 78
& 55 78
& 77 77
& 45 49
& 55 55
& 50
, Auxiliary Bldg. Main Ventilation System Auxiliary Bldg. Main Ventilation System Auxiliary Bldg. Main Ventilation System Auxiliary Bldg. Main Ventilation System Auxiliary Bldg. Main
~ Ventilation System Auxiliary Bldg. Main Ventilation System 70x 18 26 x 10 18 x 10 12x8 18 x 12 12x8 Fire area 47; south vali Fire area 78; vest wall Fire area 78; east vali Fire area 77.;
east wa11 Fire area 49;
-south wall Fire area 50; south wall of north-south Refer to FPL rinse to Items 2
& 3 M Refer to FPL response to Item 2 Refer to FPL response to Item 2 Refer to FPL responsei to Item 2
'efer to FPL response to Item 2 Refer to FPL response to Item 2
TABLE I PENETRATION
ABETMEEN FIRE AREA NO, NO.
AND FIRE AREA NO SAFETY RELATED VENTILATION SYSTEM Page 3
'ENETRATION SIZE
- APPROXIMATE, SAFETY RELATED W..x H
.inches)
LOCATION FUNCTION
~
22 23 24 56 S 71 56 a 57 56 6 60-
'lectrical Equip.
Rm. Supply System Electric Equip.
Rm. Supply System Electric Equip.
Rm. Supply System Fire area 56; north wall
. 'Fire area 60; south wall-96 x 25 56 x 48
= 'ire area 56; in ceiling by east wall 62.x 26 See FPL response For Item 3 See FPL response For Item 3 See FPL response For Item 3 25 26 27 71 a 70 71
& 70 70 6
73 Control Room HVAC System (Supply)
Control Room HVAC System (Return)
Control Room HVAC System (Supply)
.'66 x 38 f
66x 38 18x8 Fire area 71; west'all Fire area 71; west wall
- Fire Area 70; south wall See FPL resp For Item 2 See FPL response For. Item 2 See FPL response For Item 2