L-82-433, Forwards Response to Question 410.52 Re Fire Protection Requirements

Forwards Response to Question 410.52 Re Fire Protection Requirements

ML17213A557
Person / Time
Site:	Saint Lucie
Issue date:	10/07/1982
From:	Robert E. Uhrig FLORIDA POWER & LIGHT CO.
To:	Eisenhut D Office of Nuclear Reactor Regulation
References
L-82-433, NUDOCS 8210130348
Download: ML17213A557 (4)

Text

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

AOCESSION NBR:8210130348 DOCeDATEe 82/10/07 FACIL:50 389 St, Lucie Plant~ Unit 2i Flor ida AUTH~ NAME AUTHOR AFFILIATION UHRIG<R,E, Florida Power 8 Light Co.

~RE~C IP e NAME, RECIPIENT AFFILIATION EI'SENHUTi D ~ G, D i v i s i on of Licensing

SUBJECT:

Forwards response to Question 410,52 requirementse DISTRIBUTION CODE:

B002S

~COPIES RECEIVED!LTR TITLE! Licensing Submi tta 1: Fir e )Pr otecti on NOTE S!

NOTARIZED:

NO Power K Light Co>

re fire protection ENCL SIZE:.

DOCKET 05000389 RECIPIENT ID CODE/NAME LIC BR P3 BC INTERAL: ELD/HDS2 NRA/DE/ADMQE NRR/DSI/ASB RGN2 COPIES LTTR ENCL 1

1 1

0 1

0 1

1 1

1 RECIPIENT ID CODE/NAME

NERSESgV, 01 IE FILE 07 CgB 06 04 COPIES LTTR ENCL 1

1 1

1 1

EXTERNAL: ACRS NRC PDR NTIS 10 02 6

6 1

1 1

1 LPDR NSIC 03 05 TOTAL NUMBER OF COPIES REQUIRED+

LTTR 22 ENCL 20

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. O. BOX 14000, JUNO BEACH, FL,33408 FLORIDAPOWER & LIGHT COMPANY October 7,

1982 L-82-433 Office of Nuclear Reactor Regulations Attention:

Nr. Darrell G. Eisenhut, Director Division of Licensing U. S. Nuclear Regulatory Commission Washington, D.

C.

20555

Dear ter. Eisenhut:

Re:

St. Lucie Unit No.

2 Docket No. 50-389 Fire Protection - Response to question 410.52 Attached please find Florida Power and Light Company's (FPL) response to

. Question No. 410.52 requesting additional information on St. Lucie Unit No.

2 fire protection requirements.

If you have any questions on this submittal, please contact us accordingly.

Very truly yours, Ro rt-

. Uhrig Vice President Advanced Systems and Technology REU/RJS/JES/jea Attachment cc:

J.

P. O'Reilly, Region II Harold F. Reis, Esquire

-""82iOi30348 82i.007

--'PDR ADOCK 05000389

-FDR PEOPLE... SERVING PEOPLE

Question No.

410.52 The applicant provided a brief description of the methodology used to review the plant against the requirements of Appendix "R" as a response to CMEB Question 280.25 dated March 1982.

In a meeting with the applicant May 1982, the applicant committed to define "fire areas" as "fire zones" and defined "fire areas" to be in accordance with Appendix "R".

It is therefore not clear whether the response to CMEB 280.25 is still correct.

The applicant also provided and expanded discussion of the methodology used to verify compliance with Appendix "R" by means of telecons but has not documented this expanded discussion.

Therefore the applicant should

1) verify that the response to CMEB 280.25 is still appropriate,

2) verify that a fire is assumed to destroy all equip-ment/cables within a fire area and

3) discuss the methods used to identify which cables or pieces of equipment must be protected or relocated.

~Res ense 410.52 As outlined in the response to CMEB question 280.25 a safe shutdown analysis was performed in order to insure that no single fire can prevent St Lucie Unit 2 from achieving a safe cold shutdown.

This was done by compiling a list by fire area of all equipment, power sources and cables required to bring the plant to cold shutdown.

The analysis conservatively assumed that all equipment and cables within a single fire area that are not protected were destroyed.

A fire area is defined as any region that is completely en-closed (floors, walls

& ceilings) by barriers that have a three hour fire rating.

This includes three hour rated fire seals for all barrier penetrations (Note that in certain cases deviations from this re-quirement were requested in FP&L Letter L-82-282).

The areas used in this analysis can be found in Items 1 and 2 of FP&L Letter L-82-282, dated July 14, 1982.

In a number of cases the analysis indicated that both redundant means of performing safe shutdown functions could be impaired.

In these instances the vital:equip-ment and/or cables associated with one redundant train of these vital functions were either relocated or pro-tected to assure that cold shutdown could be safely achieved.

The cables that required relocation or pro-tection were identified in Item 1 of the above re-ferenced letter.

Thus, the response to CMEB question 280.25, which stated that no single fire can prevent the plant from being brought safely to cold shutdown, is still applicable.