ML073180233

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E-mail: Draft RAIs for Fire Protection and Electrical Systems
ML073180233
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 09/18/2007
From: Kimberly Green
NRC/NRR/ADRO/DLR
To:
Entergy Nuclear Operations
References
Download: ML073180233 (10)
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IPNonPublicHearingFile - Draft RAIs for Fire Protection and Electrical Systems Page 1 From:

Kimberly Green To:

dcroule@entergy.com Date:

Tue, Sep 18, 2007 4:23 PM

Subject:

Draft RAIs for Fire Protection and Electrical Systems

Don, Attached are draft requests for additional information related to the Indian Point license renewal application. Please review and provide me with a couple of possible times for a telecon to discuss. Th purpose of the telecon will be to obtain clarification on the staff's questions.
Thanks, Kim Green U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop O11 F1 Rockville, Maryland 20852-2738 phone: 301-415-1627 fax: 301-415-3313 email: kjg1@nrc.gov CC:

Bo Pham; IPNonPublicHearingFile; MICHAEL D STROUD; Rajender Auluck; Rani Franovich

Mail Envelope Properties (46F033BA.E31 : 8 : 11216)

Subject:

Draft RAIs for Fire Protection and Electrical Systems Creation Date Tue, Sep 18, 2007 4:23 PM From:

Kimberly Green Created By:

KJG1@nrc.gov Recipients entergy.com dcroule (dcroule@entergy.com)

MSTROUD CC (MICHAEL D STROUD) nrc.gov OWGWPO01.HQGWDO01 RCA CC (Rajender Auluck) nrc.gov OWGWPO02.HQGWDO01 RLF2 CC (Rani Franovich) nrc.gov TWGWPO03.HQGWDO01 BMP CC (Bo Pham)

IPNonPublicHearingFile CC (IPNonPublicHearingFile)

Post Office Route entergy.com OWGWPO01.HQGWDO01 nrc.gov OWGWPO02.HQGWDO01 nrc.gov TWGWPO03.HQGWDO01 nrc.gov Files Size Date & Time MESSAGE 1159 Tuesday, September 18, 2007 4:23 PM Draft RAIs FP and Elec 09-18-07.doc 67072 Tuesday, September 18, 2007 4:19 PM Options Expiration Date:

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Indian Point Nuclear Generating Unit Nos. 2 and 3 License Renewal Application Draft Request for Additional Information Set 1 Fire Protection and Electrical The staff reviewed the Indian Point Nuclear Generating Unit Nos. 2 and 3 (IP2&3) license renewal application (LRA), updated final safety analysis report (UFSAR), Section 9.5.1, Fire Protection System, and following fire protection current licensing basis documents listed in the IP2&3 Operating License Condition 2.K. and 2.H respectively:

NRC Fire Protection Safety Evaluation Reports (SERs) - IP2:

November 30, 1977, February 3, 1978, January 31, 1979, October 31, 1980, August 22, 1983, March 30, 1984, October 16, 1984, September 16, 1985, November 13, 1985, March 4, 1987, January 12, 1989, and March 26, 1996.

NRC Fire Protection Safety Evaluation Reports - IP3:

September 21, 1973, March 6, 1979, May 2, 1980, November 18, 1982, December 30, 1982, February 2, 1984, April 16, 1984, January 7, 1987, September 9, 1988, October 21, 1991, April 20, 1994, January 5, 1995, and supplements.

The staff has identified that fire protection systems and components discussed in the following sections have been excluded from the scope of license renewal and an aging management review (AMR). These systems and components were not included in the license renewal boundaries and appear to have fire protection intended functions required for compliance with Title 10 of the Code of Federal Regulations (CFR) 50.48, Fire protection, as stated in 10 CFR 54.4. Therefore, in order to complete our review, the staff requires responses to the following request for additional information (RAI):

DRAI 2.3.3.11-1 The following LRA drawings show fire protection system components as out of scope:

LRA drawing LRA-227551-0 shows following fire protection systems components out of scope (i.e., not colored in green):

M.O Building PAB and BAB Charcoal Filter Deluge System LRA drawing LRA-227552-0 shows following fire protection systems components out of scope (i.e., not colored in green):

  1. 11 Fire Pump Room Fuel Oil Tank/Water Meter House Ignition Oil Tank and Pump Room Deluge System Main and Auxiliary Transformer Deluge System LRA drawing LRA-227553-0 shows following fire protection systems components out of scope (i.e., not colored in green):

Staircase No. 2, 3, 4, 5 and 6 Turbine Oil Piping System

LRA drawing LRA-227554-0 shows following fire protection systems components out of scope (i.e., not colored in green):

Staircase No. 1, 8, and 9 LRA drawing LRA-9321-40903-0 shows following fire protection systems components out of scope (i.e., not colored in green):

FP-T-4 Pneumatic Tank and Components LRA drawing LRA-9321-20913-001-0 shows following fire protection systems components out of scope (i.e., not colored in green):

Turbine Generator Building Automatic Deluge System.

Turbine Building Wall Spray System No. 3.

Yard Transformer Separation Main Transformer No. 31 Main Transformer No. 32 Unit Auxiliary Transformer Station Auxiliary Transformer North Half Sprinkler No. 6 Boiler Room Sprinkler System Sprinkler System for Auxiliary Feed Water Pump Room Lube Oil Storage Tank Lube Oil Reservoir Manual/Spray System No. 2, Boiler Feed Pump H2 Seal Oil Unit Manual Boiler Feed Pump Oil Accumulators No. 31 and 32 Boiler Feed Console Pump The staff requests that the applicant verify whether the above components are in the scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR in accordance with 10 CFR 54.21(a)(1). If these components are excluded from the scope of license renewal and not subject to an AMR, the staff requests that the applicant provide justification for the exclusion.

DRAI 2.3.3.11-2 LRA Section 2.3.3.11 discusses requirements for the fire water supply system but does not mention trash racks and traveling screens for the fire pump suction water supply. Trash racks and traveling screens are located upstream of the fire pump suctions to remove any major debris from fresh or raw water. Trash racks and traveling screens are necessary to remove debris from and prevent clogging of the fire protection water supply system. Trash racks and traveling screens are typically considered to be passive, long-lived components. Both trash racks and traveling screens are located in a fresh or raw water/air environment and are typically constructed of carbon steel. Carbon steel in a fresh or raw water environment or water/air environment is subject to loss of material, pitting, crevice formation, and microbiologically influenced corrosion, and fouling. The staff requests that the applicant explain the apparent exclusion of the trash racks and traveling screens that are located upstream of the fire pump suctions from the scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR in accordance with 10 CFR 54.21(a)(1).

DRAI 2.3.3.11-3 Section 3.13.B of the SER dated November 30, 1977, discusses the electrical tunnel fire protection water spray system, diesel generator water spray system, and containment fan cooler charcoal filter. These water spray systems do not appear in LRA Section 2.3.3.11 as being in the scope of the license renewal and subject to an AMR. The staff requests that the applicant verify whether these water spray systems for the electrical tunnel, diesel generator building, and containment fan cooler charcoal filter are in the scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR in accordance with 10 CFR 54.21(a)(1). If they are excluded from the scope of license renewal and not subject to an AMR, the staff requests that the applicant provide justification for the exclusion.

DRAI 2.3.3.11-4 Section 5.8.4 of the SER dated January 31, 1979, discusses the cable tunnel closed head pre-action sprinkler system. The closed head pre-action sprinkler system does not appear in LRA Section 2.3.3.11 as being in the scope of the license renewal and subject to an AMR. The staff requests that the applicant verify whether the closed head pre-action sprinkler system to cover the cable trays at multiple levels in cable tunnel is in the scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR in accordance with 10 CFR 54.21(a)(1). If they are excluded from the scope of license renewal and not subject to an AMR, the staff requests that the applicant provide justification for the exclusion.

DRAI 2.3.3.11-5 Section 3.1.5 of the SER dated March 6, 1979, discusses two 2500 gpm fire pumps, one electric motor driven and one diesel engine driven, along with two jockey pumps. The two jockey pumps and their associated components do not appear in LRA Section 2.3.3.11 as being in the scope of the license renewal and subject to an AMR. The staff requests that the applicant verify whether the jockey pumps and their associated components are in the scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR in accordance with 10 CFR 54.21(a)(1). If they are excluded from the scope of license renewal and not subject to an AMR, the staff requests that the applicant provide justification for the exclusion.

DRAI 2.3.3.11-6 Section 3.1.8 of the SER dated March 6, 1979, discusses dry-pipe pre-action sprinkler systems for all cable trays in the electrical tunnels, electrical penetration areas, and cable trays in the motor control center areas. The dry-pipe pre-action sprinkler systems do not appear in LRA Section 2.3.3.11 as being in the scope of the license renewal and subject to an AMR. The staff requests that the applicant verify whether the dry-pipe pre-action sprinkler systems for all cable trays in the electrical tunnels, electrical penetration areas, and cable trays in the motor control center areas are in the scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR in accordance with 10 CFR 54.21(a)(1). If they are excluded from the scope of license renewal and not subject to an AMR, the staff requests that the applicant provide justification for the exclusion.

DRAI 2.3.3.11-7 Section 5.9.1 of the SER dated March 6, 1979, discusses automatic deluge foam suppression systems for various areas in turbine building. The foam suppression systems do not appear in

LRA Section 2.3.3.11 as being in the scope of the license renewal and subject to an AMR. The staff requests that the applicant verify whether the foam suppression systems for various areas in the turbine building are in the scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR in accordance with 10 CFR 54.21(a)(1). If the system is excluded from the scope of license renewal and not subject to an AMR, the staff requests that the applicant provide justification for the exclusion.

DRAI 2.3.3.11-8 Section 5.11.1 of the SER dated March 6, 1979, discusses wet pipe automatic sprinklers in the diesel generator building sump area beneath each diesel engine and on the diesel day tank.

The wet pipe automatic sprinkler system does not appear in LRA Section 2.3.3.11 as being in the scope of the license renewal and subject to an AMR. The staff requests that the applicant verify whether the wet pipe sprinkler system to protect the diesel generator building sump area and diesel day tank is in the scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR in accordance with 10 CFR 54.21(a)(1). If the system is excluded from the scope of license renewal and not subject to an AMR, the staff requests that the applicant provide justification for the exclusion.

DRAI 2.3.3.11-9 Section 5.13.1 of the SER dated March 6, 1979, discusses the charcoal filter manual water spray system. The manual water spray system and its associated components do not appear in LRA Section 2.3.3.11 as being in the scope of the license renewal and subject to an AMR. The staff requests that the applicant verify whether the charcoal filter manual water spray system and its associated components are in the scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR in accordance with 10 CFR 54.21(a)(1). If the system is excluded from the scope of license renewal and not subject to an AMR, the staff requests that the applicant provide justification for the exclusion.

DRAI 2.3.3.11-10 Section 5.15.1 of the SER dated March 6, 1979, discusses automatic water spray systems for oil-filled transformers located adjacent to the control building. The automatic water spray systems and their associated components do not appear in LRA Section 2.3.3.11 as being in the scope of the license renewal and subject to an AMR. The staff requests that the applicant verify whether the automatic water spray systems for oil-filled transformers are in the scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR in accordance with 10 CFR 54.21(a)(1). If the system is excluded from the scope of license renewal and not subject to an AMR, the staff requests that the applicant provide justification for the exclusion.

DRAI 2.3.3.11-11 Section 2.1 of the SER dated May 2, 1980, discusses an automatic water curtain to protect an 8' wide x 12' high opening in the primary auxiliary building. The automatic water curtain and its associated components do not appear in LRA Section 2.3.3.11 as being in the scope of the license renewal and subject to an AMR. The staff requests that the applicant verify whether the automatic water curtain is in the scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR in accordance with 10 CFR 54.21(a)(1). If the system is excluded from the scope of license renewal and not subject to an AMR, the staff requests that the applicant provide justification for the exclusion.

DRAI 2.3.3.11-12 LRA Tables 2.3.3-11-IP2 and 2.3.3-11-IP3 exclude several types of fire protection components that appear in the SERs and/or UFSAR, and which also appear in the LRA drawings colored in green. These components are listed below:

  • hose connections
  • hose racks
  • yard hose houses
  • interior fire hose stations
  • pipe fittings
  • pipe supports
  • threaded connections
  • restricting orifices
  • chamber housings
  • heat-actuated devices
  • tank heaters
  • thermowells
  • water motor alarms
  • expansion joint
  • filter housing
  • gear box housing
  • heat exchanger (shell)
  • heat exchanger (tube)
  • heater housing
  • diesel driven fire pump engines muffler
  • orifice
  • sight glass
  • strainer housing
  • flexible hose
  • latch door pull box
  • pneumatic actuators
  • actuator housing dikes for oil spill confinement buried underground fuel oil tanks for emergency diesel generators expansion tank fire water main loop valves post indicator valves jacket cooling water keepwarm pump and heater lubricating oil collection system components for each reactor coolant pump lubricating oil cooler auxiliary lubricating oil makeup tank rocker lubricating oil pump floor drains and curbs for fire-fighting water backflow prevention devices flame retardant coating for cables fire retardant coating for structural steel supporting walls and ceilings

For each, determine whether the component should be included in Tables 2.3.3-11-IP2 and 2.3.3-11-IP3, and if not, justify the exclusion.

DRAI 2.3.3.12-1 The following LRA drawings show fire protection system components as out of scope:

LRA drawing LRA-9321-24403-0 shows following fire protection systems components out of scope (i.e., not colored in brown):

  • Appendix R Diesel Generator Halon 1301 System
  • TSC/Plant Computer Halon System
  • Record Room Vault Halon 1301 System for Unit 3 LRA drawing LRA-D-8775-002-0 shows the following fire protection systems components out of scope (i.e., not colored in brown):
  • Cable Spreading Room (CSR) Halon 1301 System The staff requests that the applicant verify whether the above components are in the scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR in accordance with 10 CFR 54.21(a)(1). If these components are excluded from the scope of license renewal and not subject to an AMR, the staff requests that the applicant provide justification for the exclusion.

DRAI 2.3.3.12-2 Section 5.4.1 of the SER dated January 31, 1979, discusses the manually actuated CSR Halon total flooding fire suppression system. The total flooding Halon fire suppression system does not appear in LRA Section 2.3.3.12 as being in the scope of the license renewal and subject to an AMR. The staff requests that the applicant verify whether the CSR Halon fire suppression system is in the scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR in accordance with 10 CFR 54.21(a)(1). If the system is excluded from the scope of license renewal and not subject to an AMR, the staff requests that the applicant provide justification for the exclusion.

DRAI 2.3.3.12-3 Section 3.1.9 of the SER dated March 6, 1979, discusses a total flooding carbon dioxide (CO2) system for the switchgear room. The total flooding CO2 fire suppression system does not appear in LRA Section 2.3.3.12 as being in the scope of the license renewal and subject to an AMR.

The staff requests that the applicant verify whether switchgear room total flooding CO2 fire suppression system is in the scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR in accordance with 10 CFR 54.21(a)(1). If the CO2 system is excluded from the scope of license renewal and not subject to an AMR, the staff requests that the applicant provide justification for the exclusion.

DRAI 2.3.3.12-4 Section 2.2 of the SER dated May 2, 1980, discusses the total flooding CO2 fire suppression system for the diesel generator rooms. The CO2 fire suppression systems do not appear in LRA

Section 2.3.3.12 as being in the scope of the license renewal and subject to an AMR. The staff requests that the applicant verify whether the diesel generator rooms CO2 total flooding fire suppression systems are in the scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR in accordance with 10 CFR 54.21(a)(1). If the CO2 systems are excluded from the scope of license renewal and not subject to an AMR, the staff requests that the applicant provide justification for the exclusion.

DRAI 2.3.3.12-5 Section 2.6 of the SER dated May 2, 1980, discusses the switchgear room automatic total flooding CO2 fire suppression system. The CO2 fire suppression system does not appear in LRA Section 2.3.3.12 as being in the scope of the license renewal and subject to an AMR. The staff requests that the applicant verify whether the switchgear room automatic total flooding CO2 fire suppression system is in the scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR in accordance with 10 CFR 54.21(a)(1). If the system is excluded from the scope of license renewal and not subject to an AMR, the staff requests that the applicant provide justification for the exclusion.

DRAI 2.3.3.12-6 Section 2.7 of the SER dated May 2, 1980, discusses an automatic total flooding CO2 fire suppression system for the CSR. The automatic total flooding CO2 fire suppression system does not appear in LRA Section 2.3.3.12 as being in the scope of the license renewal and subject to an AMR. The staff requests that the applicant verify whether the CSR automatic total flooding CO2 fire suppression system is in the scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR in accordance with 10 CFR 54.21(a)(1). If the system is excluded from the scope of license renewal and not subject to an AMR, the staff requests that the applicant provide justification for the exclusion.

DRAI 2.3.3.12-7 LRA Tables 2.3.3-12-IP2 and 2.3.3-12-IP3 excludes several types of CO2 and Halon 1301 fire suppression system components that appear in the SERs and/or UFSAR, and which also appear in the LRA drawings colored in brown. These components are listed below:

strainer housings pipe fittings pipe supports couplings odorizer threaded connections flexible hose latch door pull box pneumatic actuators For each, determine whether the component should be included in LRA Tables 2.3.3-12-IP2 and 2.3.3-12-IP3, and if not, justify the exclusion.

DRAI 2.5-1 General Design Criterion 17 of Title 10 Code of Federal Regulations Part 50 (10 CFR Part 50),

Appendix A, requires that electric power from the transmission network to the onsite electric distribution system be supplied by two physically independent circuits to minimize the likelihood of their simultaneous failure. In addition, the guidance provided by letter dated April 1, 2002, Staff Guidance on Scoping of Equipment Relied on to Meet the Requirements of the Station Blackout (SBO) Rule (10 CFR 50.63) for License Renewal (10 CFR 54.4(a)(3)), states:

For purposes of the license renewal rule, the staff has determined that the plant system portion of the offsite power system that is used to connect the plant to the offsite power source should be included within the scope of the rule. This path typically includes switchyard circuit breakers that connect to the offsite system power transformers (startup transformers), the transformers themselves, the intervening overhead or underground circuits between circuit breaker and transformer and transformer and onsite electrical system, and the associated control circuits and structures. Ensuring that the appropriate offsite power system long-lived passive structures and components that are part of this circuit path are subject to an aging management review will assure that the bases underlying the SBO requirements are maintained over the period of extended license.

According to the above, both paths, from the safety-related 480 Volt (V) buses to the first circuit breaker from the offsite line, used to control the offsite circuits to the plant should be age managed. The guidance does not specify that the switchyard is not part of the plant system nor that the switchyard does not need to be included in the scope of license renewal. Explain in detail which high voltage breakers and other components in the switchyard will be connected from the startup transformers up to the offsite power system for the purpose of SBO recovery.

DRAI 2.5-2 NEI 95-10, Industry Guideline for Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule, Appendix B indicates that elements, resistance temperature detectors (RTDs), sensors, thermocouples and transducers should be included in the list of components/commodity groups subject to an aging management review (AMR) if a pressure boundary is applicable. Explain why these components are not included in Section 2.5 of the LRA.

DRAI 2.5-3 NEI 95-10, Appendix B indicates that electrical splices, terminal blocks, control cables and isolated-phase bus should be included in the commodity group of cables & connections, bus, electrical portions of electrical and I&C penetration assemblies. Explain why these components are not included in Section 2.5 of the LRA.

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