ML022540304
| ML022540304 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 09/11/2002 |
| From: | Gramm R NRC/NRR/DLPM |
| To: | Venable J Entergy Operations |
| Kalyanam N, NRR/DLPM, 415-1480 | |
| References | |
| TAC MB3724 | |
| Download: ML022540304 (5) | |
Text
September 11, 2002 Mr. Joseph E. Venable Vice President Operations Entergy Operations, Inc.
17265 River Road Killona, LA 70066-0751
SUBJECT:
WATERFORD STEAM ELECTRIC STATION, UNIT 3 - REQUEST FOR DEVIATION FROM REQUIREMENTS OF APPENDIX R TO PART 50 OF TITLE 10 OF THE CODE OF FEDERAL REGULATIONS (TAC NO. MB3724)
Dear Mr. Venable:
By letter dated November 9, 2001, Entergy Operations Inc., the licensee for Waterford Steam Electric Station, Unit 3 (Waterford 3), requested approval to deviate from certain technical requirements of Section III.G of Appendix R, "Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979," to Title 10 of the Code of Federal Regulations, Part 50 (10 CFR Part 50). Specifically, Waterford 3 proposed noncompliance with meeting required circuit separation requirements specified in 10 CFR Part 50, Appendix R, Section III.G, for three cables located above the refueling water storage pool.
While Waterford 3 was licensed to operate on March 31, 1989, and therefore excluded from meeting the Appendix R technical requirements, by letter dated November 10, 1981, you committed to meet the technical requirements and incorporated the requirement to meet Section III.G of Appendix R into the approved fire protection program. Implementation of the approved fire protection program is an operating license condition for the facility.
The staff has reviewed the deviation request and found it acceptable. Therefore, the request for deviation from a commitment to meet Section III.G of Appendix R to 10 CFR Part 50, as described in the attached safety evaluation, is granted.
Sincerely,
/RA/
Robert A. Gramm, Chief, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-382 cc: See next page
Mr. Joseph E. Venable September 11, 2002 Vice President Operations Entergy Operations, Inc.
17265 River Road Killona, LA 70066-0751
SUBJECT:
WATERFORD STEAM ELECTRIC STATION, UNIT 3 - REQUEST FOR DEVIATION FROM REQUIREMENTS OF APPENDIX R TO PART 50 OF TITLE 10 OF THE CODE OF FEDERAL REGULATIONS (TAC NO. MB3724)
Dear Mr. Venable:
By letter dated November 9, 2001, Entergy Operations Inc., the licensee for Waterford Steam Electric Station, Unit 3 (Waterford 3), requested approval to deviate from certain technical requirements of Section III.G of Appendix R, "Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979," to Title 10 of the Code of Federal Regulations, Part 50 (10 CFR Part 50). Specifically, Waterford 3 proposed noncompliance with meeting required circuit separation requirements specified in 10 CFR Part 50, Appendix R, Section III.G, for three cables located above the refueling water storage pool.
While Waterford 3 was licensed to operate on March 31, 1989, and therefore excluded from meeting the Appendix R technical requirements, by letter dated November 10, 1981, you committed to meet the technical requirements and incorporated the requirement to meet Section III.G of Appendix R into the approved fire protection program. Implementation of the approved fire protection program is an operating license condition for the facility.
The staff has reviewed the deviation request and found it acceptable. Therefore, the request for deviation from a commitment to meet Section III.G of Appendix R to 10 CFR Part 50, as described in the attached safety evaluation, is granted.
Sincerely,
/RA/
Robert A. Gramm, Chief, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-382 cc: See next page DISTRIBUTION PUBLIC PDIV-1 r/f Rids OgcRp RidsAcrsAcnwMailCenter RidsNrrDlpmLpdiv1 (RGramm)
RidsNrrPMNKalyanam RidsNrrLADJohnson RidsRgn4MailCenter (KBrockman)
PQualls Accession No.: ML022540304
- The SE provided by staff was used with minor editorial changes OFFICE PDIV-1/PM PDIV-1/LA SPLB*
PDIV-1/SC NAME NKalyanam DJohnson JHannon RGramm DATE 9/6/02 9/6/02 03/29/02 9/6/02 OFFICIAL RECORD COPY
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION LICENSEE REQUEST FOR DEVIATION FROM CERTAIN REQUIREMENTS OF SECTION III.G OF APPENDIX R TO 10 CFR PART 50
1.0 INTRODUCTION
Appendix R, "Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979," to Title 10 of the Code of Federal Regulations, Part 50 (10 CFR Part 50),
establishes fire protection features required to satisfy General Design Criterion 3, "Fire Protection," of Appendix A to 10 CFR Part 50 with respect to certain generic issues for nuclear power plants licensed to operate prior to January 1, 1979. While Waterford Steam Electric Station, Unit 3 (Waterford 3) was licensed to operate on March 31, 1989, and therefore excluded from meeting the Appendix R technical requirements, by letter dated November 10, 1981, Entergy Operations, Inc. (Entergy or the licensee), committed to meet the technical requirements of Appendix R to 10 CFR Part 50 for Waterford 3. The licensee incorporated the commitment to meet Section III.G of Appendix R into the approved fire protection program.
Implementation of the approved fire protection program is an operating license condition for the facility.
By letter dated November 9, 2001, Entergy requested a deviation from certain technical requirements of Appendix R for Waterford 3. Specifically, the licensee requested a deviation from the required circuit separation requirements specified in 10 CFR Part 50, Appendix R, Section III.G, for three cables located above the refueling water storage pool (RWSP).
2.0 DEVIATION REQUESTED The licensee requested a deviation from the technical requirements of Section III.G of Appendix R to 10 CFR Part 50, to the extent that it requires that redundant trains of cables within a fire area be separated by 1) a three-hour rated fire barrier, 2) a one-hour rated fire barrier with fire detection and an automatic fire suppression system, or 3) 20 feet (ft) with no intervening combustibles with fire detectors and an automatic fire suppression system. The deviation would apply to three essential plant cables, 32562B, 32562F, and 32561D, located within fire area RAB31 where the cables transverse above the RWSP.
3.0 DISCUSSION Cables 32562B, 32562F, and 32561D are located in dedicated conduit in the fire area where they transverse the RWSP. The cables are located near the top of the RWSP, approximately
2 5 ft above the top of the water and 3 ft below the top of the tank. Cables 32562B and 32562F are B Train-required direct current (DC) cables. Cable 32561D is a AB Train-required DC cable. The cables are not separated from the redundant A Train cables by 20 ft, with no intervening combustibles. The RWSP has no fire detector or automatic fire suppression system.
4.0 EVALUATION The cables are in dedicated conduit, where they transverse through a concrete tank approximately 5 ft above the level of the water and 3 ft below the ceiling. The tank contains only water. The RWSP is inaccessible during normal plant operation. Technical Specifications require that 475,500 gallons of borated water be maintained in the tank during operation. There is no possibility of a transient combustible fire in this tank during plant operation. A self-induced cable fire, in a dedicated conduit, would be confined to the affected cable in the conduit and would not affect the redundant safe shutdown cables. Since redundant trains of cables are not susceptible to fire damage inside of the tank where the deviation was requested, the installed configuration provides a level of fire protection equivalent to literal compliance with the regulations.
5.0 CONCLUSION
On the basis of its evaluation, the staff concludes that not meeting the fire protection features specified in Section III.G.2 of Appendix R for Cables 32562B, 32562F, and 32561D inside of the RWSP is an acceptable deviation from the technical requirements of Section III.G.2 of Appendix R to 10 CFR 50. The licensees request for deviation is, therefore, granted.
Principal contributor: Phil Qualls Date: September 11, 2002
January 2002 Waterford Generating Station 3 cc:
Mr. Michael E. Henry, Administrator and State Liaison Officer Department of Environmental Quality P. O. Box 82135 Baton Rouge, LA 70884-2135 Vice President, Operations Support Entergy Operations, Inc.
P. O. Box 31995 Jackson, MS 39286-1995 Director Nuclear Safety Assurance Entergy Operations, Inc.
17265 River Road Killona, LA 70066-0751 Wise, Carter, Child & Caraway P. O. Box 651 Jackson, MS 39205 General Manager Plant Operations Waterford 3 SES Entergy Operations, Inc.
17265 River Road Killona, LA 70066-0751 Licensing Manager Entergy Operations, Inc.
17265 River Road Killona, LA 70066-0751 Winston & Strawn 1400 L Street, N.W.
Washington, DC 20005-3502 Resident Inspector/Waterford NPS P. O. Box 822 Killona, LA 70066-0751 Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 Parish President Council St. Charles Parish P. O. Box 302 Hahnville, LA 70057 Executive Vice President
& Chief Operating Officer Entergy Operations, Inc.
P. O. Box 31995 Jackson, MS 39286-1995 Chairman Louisiana Public Services Commission P.O. Box 91154 Baton Rouge, LA 70825-1697