ML11187A340
| ML11187A340 | |
| Person / Time | |
|---|---|
| Site: | Watts Bar  |
| Issue date: | 06/21/2011 |
| From: | Office of Nuclear Reactor Regulation |
| To: | Division of Operating Reactor Licensing |
| References | |
| Download: ML11187A340 (16) | |
Text
WBN2Public Resource From: Poole, Justin Sent: Tuesday, June 21, 2011 7:50 AM To: Crouch, William D Cc: Bryan, Robert H Jr; WBN2HearingFile Resource
Subject:
Draft Request for Additional Information Regarding Fire Protection Attachments: WB2 FP RAIs draft group 6 handout.docx
- Bill, Attached are a draft version of the 6th group of fire protection RAIs that the staff would like to discuss during our meeting on June 30, 2011.
Justin C. Poole Project Manager NRR/DORL/LPWB U.S. Nuclear Regulatory Commission (301)4152048 email: Justin.Poole@nrc.gov 1
Hearing Identifier: Watts_Bar_2_Operating_LA_Public Email Number: 427 Mail Envelope Properties (19D990B45D535548840D1118C451C74D8CB267B87C)
Subject:
Draft Request for Additional Information Regarding Fire Protection Sent Date: 6/21/2011 7:49:54 AM Received Date: 6/21/2011 7:50:06 AM From: Poole, Justin Created By: Justin.Poole@nrc.gov Recipients:
"Bryan, Robert H Jr" <rhbryan@tva.gov>
Tracking Status: None "WBN2HearingFile Resource" <WBN2HearingFile.Resource@nrc.gov>
Tracking Status: None "Crouch, William D" <wdcrouch@tva.gov>
Tracking Status: None Post Office: HQCLSTR02.nrc.gov Files Size Date & Time MESSAGE 312 6/21/2011 7:50:06 AM WB2 FP RAIs draft group 6 handout.docx 52748 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:
Recipients Received:
REQUEST FOR ADDITIONAL INFORMATION OPERATING LICENSE APPLICATION WATTS BAR, UNIT 2 DOCKET NO.: 50-391 TAC NO.: ME3091 Office of Nuclear Reactor Regulation Division of Risk Assessment Fire Protection Branch Note that while questions have been developed for a number of the parts of the Fire Protection Report (FPR), this is not an exhaustive list of questions. The Fire Protection Branch expects that additional questions will be developed as our review progresses as well as following the as-yet undelivered complete as-designed FPR.
A number of the information requests may involve modifications to the FPR. This status is indicated at the end of the specific requests.
Draft versions of these information requests were a handout for a June 30, 2011 public meeting with TVA, where they were discussed.
In a number of the information requests below, summary evaluations are requested. The following elements, as a minimum, are expected to be addressed by the summary: 1) identification of the issue evaluated; 2) a description of the evaluation method; 3) a discussion of key assumptions, including their bases; and 4) results of the evaluation.
References to the WBN Unit 2 MSO Report, Revision 1 refer to the WBN Unit 2 Multiple Spurious Operation Evaluation Report, Revision 1, which was submitted to the NRC on November 5, 2010.
RAI number format Example: [RAI FPR V-1.X]
RAI - RAI FPR - topic or document from which the comment originates V - Section of the document Sequential comment for that section
.X - Indicates follow-up RAI RAI FPR I-1 Identify the meaning of the
- notation in the Combustible Load, Fire Severity column of Table I-1, Summary Compliance Fire Protection, of the as-designed FPR. One example of the notation is in the 676.0-A15 - U2 Containment Spray Pump 2B-B entry.
This RAI may involve an update to the FPR to incorporate the response to the RAI.
RAI FPR I-2 A sampling review of Table I-1, Summary Compliance Fire Protection, of the as-designed FPR
has identified the following:
Deviations / Evaluations identified in Table I-1 that are not reflected in Part VI.
Examples: Fire Areas 15-1 and 15-2 Cable protection indicated in Part VI not indicated in Table I-1.
Example: Fire Area 15-2 Manual actions identified in Part VI not indicated in Table I-1.
Example: Fire Area 15-2 Resolve these conflicts and provide assurance that other, similar conditions have been identified and corrected.
This RAI may involve an update to the FPR to incorporate the response to the RAI.
RAI FPR II-23.1 The TVA response to RAI FPR II-23 (in the May 6, 2011 TVA letter) did not address where the responsibilities of the former General Manager, Operations Services were moved to when TVA Corporate Management was reorganized.
These responsibilities were specifically approved by the NRC in Supplemental Safety Evaluation Report (SSER) 18. It does not appear that these responsibilities were specifically distributed among the remaining identified positions.
Describe where each of these responsibilities will reside for Unit 2 operation.
This RAI may involve an update to the FPR to incorporate the response to the RAI.
RAI FPR II-25.1 The TVA response to RAI FPR II-25 (in the May 6, 2011 TVA letter) does not appear to address item 3 of the RAI, which states, in part:
The following text was removed from 8.1.c:
WBN may alter specific features of the approved Fire Protection Report provided:
(a) such changes do not otherwise involve a change in a license condition or the technical specification or result in an unreviewed safety question, and (b) such changes do not result in failure to complete the Fire Protection Program [FPP] as approved by NRC.
Provide a justification for this change. Is it TVAs position that may make changes as described in the deleted text without NRC approval? If so, describe the regulatory basis for changing license conditions, technical specifications, etc., without NRC approval.
RAI FPR II-31.1 The TVA response to RAI FPR II-31 (in the May 6, 2011 TVA letter) states that once a piece of
inoperable equipment is placed in the corrective action program, management attention will drive TVA to return that piece of equipment to operable status. The reviewers feel that reliance on a concept such as management attention, which is poorly defined and outside of an established process, is insufficient.
Describe the process in place to ensure that equipment is returned to operable status in a timely manner.
RAI FPR II-37.1 The TVA response to RAI FPR II-37 (in the May 6, 2011 TVA letter) states, in part: Section 14.1.1 addresses the areas outside of containment and 14.1.2 addresses the areas inside containment.
However, section 14.1.1 applies only to accessible areas. Also, Section B.14.1.2 still supports the earlier version.
Confirm that no Function A fire detectors are installed in inaccessible areas outside of containment.
Correct the Basis entry to align with the correct configuration.
RAI FPR II-39.1 RAI FPR II-39 asks about the compensatory actions to be taken in the initial period of inoperable status for safe shutdown equipment listed in Table 14.10. While the TVA response (in the May 6, 2011 TVA letter) states that the current configuration was approved by the NRC in Supplemental Safety Evaluation Report 18 (ML070530364), Appendix A to the BTP and Appendix R to 10 CFR 50 require licensees to be able to achieve and maintain safe shutdown after a fire. In light of this, the reviewers have these follow-ups:
Describe the process in place that ensures the plant can achieve and maintain safe shutdown after a fire, for the scenario where one or more pieces of equipment are inoperable, and the remaining redundant piece of equipment is damaged by the fire.
Describe the process in place that ensures the plant can achieve and maintain safe shutdown after a fire, when all redundant equipment, as listed in Table 14.10, is inoperable at the same time. One example would be all PORV N2 supply tanks are concurrently depressurized.
Describe the process in place to take into consideration equipment inoperability when planning maintenance or testing activities on a piece of equipment that is redundant to one that is inoperable. Describe any expected compensatory measures for this sort of scenario.
Describe the process in place to prevent a piece of required equipment from repeatedly being declared inoperable. Describe the process used to identify this condition and to prevent reoccurrence.
RAI FPR II-41.1 RAI FPR II-41 noted that there is no information in Part II, Section 12.2 Standpipes, Hose Stations, and Hydrants, of the as-designed FPR, regarding the seismic qualification of the standpipes and hose stations installed to protect areas containing Unit 2 safe shutdown equipment.
The TVA response to RAI FPR II-41 (in the June 7, 2011 TVA letter) does not fully cover the seismic requirements for standpipes and hose stations.
These seismic requirements are in place not only to ensure that no required equipment is damaged by water leaks, but also to ensure that fire fighting capability is maintained after an earthquake.
Provide details regarding the seismic qualification of the standpipe and hose station systems, as well as the water supply system that supplies it, that are installed in areas containing Unit 2 safe shutdown equipment.
This RAI may involve an update to the FPR to incorporate the response to the RAI.
RAI FPR II-43 In Part II of the as-designed FPR, the key of the Inaccessible Areas Table has been reversed.
Revision 41 of the FPR [pg. II-11]:
- Inaccessible only during resin transfer.
(FPR-Preparer)
- Refer to Part VII for engineering evaluation.
As-designed FPR [pg II-12]:
- Inaccessible only during resin transfer.
- Refer to Part VII for engineering evaluation.
The instances or
- or ** in the body of the table were not changed.
In the March 31, 2011 letter, TVA described this change as Corrected the application of the notes. No effect on FSSD. Examination of the balance of the FPR indicates that the original configuration was correct. For example, it is clear that the rooms marked with ** in the as-designed version are inaccessible permanently, not just during resin transfer.
The reviewers are concerned about this change since it appears unrelated to any NRC question. Additionally, if the change is correct, this indicates that the current Unit 1 FPR is in error.
Justify the change (including the current FPR configuration for Unit 1) or correct the error.
This RAI may involve an update to the FPR to incorporate the response to the RAI.
RAI FPR III-15 Part III, Section 7.4, Multiple High Impedance Faults, of the as-designed FPR, states in part:
Sustained high impedance faults, on even one power cable, are considered highly improbable. However, simultaneous Multiple High Impedance Faults (MHIF) has been considered in the evaluation of the electrical power system's capability to supply power to the required fire safe shutdown loads. This evaluation is documented in "Appendix R - Multiple High Impedance Fault Analysis" (reference Calculation WBPEVAR9509001).
Add the above calculation to the FPR Part II, Section 4.0, References.
Ensure that an extent of condition review has been performed to ensure that other, similar, instances, have been identified and added, if necessary.
This RAI may involve an update to the FPR to incorporate the response to the RAI.
RAI FPR III-16 Part III, Section 7.5, Current Transformer Secondaries, of the as-designed FPR, states in part:
When a secondary circuit of a Current Transformer (CT) opens due to a fire at a remote location, ionized gases and/or additional fires in other locations could be generated, resulting in fire propagation to additional fire areas. Fire hazards due to a fire-induced open circuit in the secondary of CTs installed in high energy panels (i.e., 6.9kV switchgear) of the required power systems have been evaluated. Three types of CT circuits used in the auxiliary power system have been evaluated: ground fault, differential relaying, and protective relaying.
[emphasis added]
Confirm that the fire hazards due to a fire-induced open circuit in the secondary of CTs installed in high energy panels (i.e., 6.9kV switchgear) of the non-required power systems have been evaluated.
Describe the specific methods used for the fire hazards analysis.
This RAI may involve an update to the FPR to incorporate the response to the RAI.
RAI FPR III-17 Part III, Section 7.2, Associated Circuits by Common Power Supply and Common Enclosures FPR, of the as-designed FPR, states in part:
These original electrical design practices provided confidence that no associated circuits of concern by common power supply (Type I) or by common enclosure (Type III) exist. As an additional check, a review was conducted of the existing
electrical protection and coordination for the safe shutdown power supplies. As expected, most of the circuit protective devices reviewed had been properly selected and were coordinated. Design changes have been initiated to correct the few remaining deficiencies identified during the review.
Provide a list of the design changes with the actual or scheduled completion dates.
Confirm that all design changes have been completed or will be completed prior to the Unit 2 fuel load.
This RAI may involve an update to the FPR to incorporate the response to the RAI.
RAI FPR V-13 Part V, Section 2.2.2 Operator Locations Prior to Initiating Manual Actions and t=0 Definition, of the as-designed FPR, states, in part: The time requirements for completion of manual operator actions are based on defining the initiating time t = 0 as the time when the reactor is tripped from the Main Control Room (MCR).
Describe any differences in the t = 0 definition for fires that cause an automatic reactor trip (that is where the reactor is not tripped from the MCR). Provide a technical justification for any differences between the two cases.
This RAI may involve an update to the FPR to incorporate the response to the RAI.
RAI FPR V-14 Part V, Section 2.4 Access Routes to Manual Action Locations, of the as-designed FPR discusses reentry into large fire areas, but does not include a discussion of timeliness.
Part V, Section 2.1.2.2.d, states: OMAs to be performed in the fire affected room in about an hour or less are specifically evaluated and documented in FPR Part VII.
Explain the relationship between Sections 2.1.2.2.d and 2.4 of Part V. Also, provide an explanation of which manual actions are governed by Section 2.1.2.2.d and which are governed by Section 2.4 of Part V.
RAI FPR V-15 Part V, Section 2.1.2 Acceptance Criteria, of the as-designed FPR states, in part: OMAs for important to safe shutdown components require no further detailed evaluation.
This section also contains a list of the assumptions that may apply to the manual action Feasibility and Reliability analysis. The third assumption states: Operator Manual Actions with a required completion time (allowable time) of 120 minutes or greater are considered feasible and reliable and do not require further evaluation.
The FPR provides references to evaluations and criteria that apply to manual operator actions.
Confirm that evaluations have been performed. If evaluations have been performed but not included in the FPR, provide an explanation of why they are not needed in the FPR.
If evaluations were not performed, provide a justification for not performing any evaluations..
RAI FPR V-16 In Part V, Section 2.3 Manual Actions Prior to Main Control Room Abandonment, of the as-designed FPR, credit is taken for, automatic detection and suppression systems, which would also result in detection of the fire in its early stages. However, some areas of the control building, such as some battery board rooms and the relay room, do not have suppression.
Deviation 2.3 in Part VII of the as-designed FPR discusses alternative shutdown areas that lack suppression, but does not specifically justify that components (such as the power operated relief valves (PORV)) wouldnt be damaged or spuriously operate for a fire in these areas before effective suppression could be applied.
Provide a technical justification that demonstrates that, for areas without automatic suppression in the control building, a fire would not damage or spuriously operate equipment important to safe shutdown. For example, justify that the PORVs will not open, prior to closing the PORV block valves from the main control room for a fire in the areas of the control building that lack automatic suppression.
RAI FPR VI-9 Part VI, Section 3.67.3.1 of the as-designed FPR is the safe shutdown analysis for the Unit 1 annulus (Analysis Volume AV-091). The reviewers did not expect to find Unit 2 equipment affected by a fire in this Analysis Volume, which they expected to be Unit 1 only area since it is part of the Unit 1 reactor building.
Provide more detail on and an explanation for this configuration.
This RAI may involve an update to the FPR to incorporate the response to the RAI.
RAI FPR VI-10 The reviewers did not expect to find opposite unit operator manual actions identified for a fire in other units reactor building, which they expected to be single unit areas. For example, Unit 1 OMAs in the Unit 2 reactor building.
In other instances, the text description identified potential damage to opposite unit systems for a fire in the other units primary containment. For example Part VI, Section 3.67.3.4, states, in part: A fire in Analysis Volume 92C could potentially affect systems and components necessary to maintain the Unit 1 and Unit 2 steam generator inventory control functions Analysis Volume Description Opposite Unit Item 091 Unit 1 Annulus OMAs 092C Unit 1 Primary Containment Potential System Damage
092D Unit 1 Primary Containment Potential System Damage 117 Unit 2 Annulus OMAs Provide more detail on and an explanation for these configurations.
This RAI may involve an update to the FPR to incorporate the response to the RAI.
RAI FPR VI-11 Provide a level of detail concerning the repair procedure for 2FCV742B (found in Part VI, Section 3.19.5.1 of the as-designed FPR [Analysis Volume AV-036]) similar to that found in the description of the repair procedures for 1MTR30176B (found in the same section).
Provide this level of detail for all other repair procedures that currently lack it in Part VI.
This RAI may involve an update to the FPR to incorporate the response to the RAI.
RAI FPR VII-2.1 The reviewers feel that the TVA response to RAI FPR VII-2 part 6 (in the June 7, 2011 TVA letter) does not adequately answer the question regarding the additional service life caused by the late licensing of Unit 2.
Provide a technical justification and summary evaluation that demonstrates that the fire water system will maintain functionality for all hose stations and suppression systems for the lifetime of the Unit 2 license.
RAI FPR VII-2.2 The TVA response to RAI FPR VII-2 parts 3 and 4 (in the June 7, 2011 TVA letter) describe the current pipe corrosion testing program as focused on the three hose stations identified by the initial calculation as failing before the initial fire water system service life expired.
Describe how the additional service life (caused by the later licensing of Unit 2) will affect the scope of the pipe corrosion testing program. If the scope will be unchanged, provide a justification for the unchanged scope.
RAI FPR VII-2.3 Describe the conditions necessitating the replacement of the B train high pressure fire protection header identified in TVAs response to RAI FPR VII-2 (in the June 7, 2011 TVA letter). Also, identify the length of pipe replaced, the pipe material that was replaced, and what material it was replaced with. Explain the conditions that would prevent the same problem from affecting the A train header, thus necessitating its replacement as well.
The TVA response to RAI FPR VII-2 part 5 (in the June 7, 2011 TVA letter) a water treatment program to address problems due to the use of raw water, but does not provide details of the program or discuss the effectiveness of the program.
Provide details concerning the raw water treatment program. Justify the effectiveness of the raw water treatment program at WBN in light of the continued problems with corrosion, wall thinning, microbiologically induced corrosion, biofouling, etc., experienced by the fire water system. Describe any corrective actions taken or planned to improve program performance.
RAI FPR VII-2.5 Describe the discrepancy between FPR Part VII, Section 3.3 and FPR Part II, Section 12.1 regarding the frequency of testing identified in the TVA response to RAI FPR VII-2 (in the June 7, 2011 TVA letter). Identify what the correct value is.
RAI FPR VII-12 It appears that the description of the Reactor Building Equipment Hatches (757.0-A11 and 757.0-A15) in Part VII, Section 6.1.2 Discussion and Justification, of the as-designed FPR is in conflict with the information in the balance of the FPR. For example, the description identifies Thermo-Lag installations in each of these rooms, but both Table I-1 and Part VI, Section 3.83.2.1, indicate that none is installed in room 757.0-A15.
Resolve these conflicts and provide assurance that other, similar conditions have been identified and corrected.
This RAI may involve an update to the FPR to incorporate the response to the RAI.
RAI FPR VII-13 Part VII, Section 2.8 Reactor Coolant Pump Oil Collection System, of the as-designed FPR states, in part:
In designing the oil collection system, it is not feasible in all instances to prevent minor amounts of oil from becoming entrained in the ventilation air and escaping the collection system. This oil becomes a thin film on piping and supports in the vicinity of the RCPs.
Using Unit 1 operating experience, describe in detail all Unit 1 locations, outside the oil collection system, where RCP oil has been found. Provide the estimated amount of oil discovered and if the oil was a fine film or pooling.
Using Unit 1 operating experience, provide the details of any preventative maintenance activity or modifications that have been utilized to reduce or eliminate oil leaking outside the RCP oil collection system.
Describe, in detail, any design differences between the Unit 1 and Unit 2 RCP oil collection
system.
Describe any physical or operational design differences between Unit 1 and Unit 2 that could change the surrounding environment of the RCPs and affect the function of the RCP oil collection system.
Identify the methods and procedures that Unit 2 will use to monitor the effectiveness of the RCP oil collection system during start up and operation. This includes possible changes to RCP maintenance and modification to the RCP oil collection system.
RAI FPR VII-14 Part VII, Section 2.8 Reactor Coolant Pump Oil Collection System, of the as-designed FPR describes the design of the oil collection system and the significant airflow environment where the system has to function. The installation and design of the stainless steel mirror insulation and certain properties of the RCP oil is also discussed.
Confirm that only non-combustible, non-permeable stainless steel mirror insulation is installed on the RCPs and reactor coolant piping and that all mirror insulation panels are fitted together with overlapping seams and secured in place. Provide the installation and material details of any RCP or reactor coolant piping insulation that does not meet the above criteria, and provide a technical justification for acceptability.
Describe in detail the nearest ignition sources to the RCPs and locations similar to where Unit 1 RCP oil has been found outside the oil collection system.
Provide the fire point and auto ignition temperature for the type of RCP oil used at Watts Bar
- 2. Also, provide a technical justification for acceptability.
This RAI may involve an update to the FPR to incorporate the response to the RAI.
RAI FPR VII-15 Part VII, Section 2.8 Reactor Coolant Pump Oil Collection System, of the as-designed FPR states, in part:
In designing the oil collection system, it is not feasible in all instances to prevent minor amounts of oil from becoming entrained in the ventilation air and escaping the collection system. This oil becomes a thin film on piping and supports in the vicinity of the reactor coolant pumps (RCP).
Discuss the actions that will be taken with regard to manufacturers recommendations to eliminate or significantly reduce oil misting and the controls in place to assure RCP oil of different (more combustible) properties will not be used in the future.
This RAI may involve an update to the FPR to incorporate the response to the RAI.
RAI FPR VII-16 The terms embedded duct and embedded collector box are used throughout Part VII, Section 6.2 Justification for Fire Damper Surveillance Requirements, of the as-designed FPR, and its subsections.
Explain what embedded means in this context.
This RAI may involve an update to the FPR to incorporate the response to the RAI.
RAI FPR VII-17 Part VII, Section 6.3.1 Statement of Condition, of the as-designed FPR, states, in part: A portion of the gap between the door and frame of fire door W9 exceeds the maximum 3/16-inch clearance, but does not continue to identify the extent of the non-conforming condition.
Identify the maximum gap for fire door W9 and justify why it is acceptable.
This RAI may involve an update to the FPR to incorporate the response to the RAI.
RAI FPR VIII-13.1 The reviewers intended RAI FPR VIII-13 to cover testing and operability requirements of hire hydrants. However, the RAI was ambiguously worded, and contained an alternate interpretation. The TVA response to RAI FPR VIII-13 (in the May 26, 2011 TVA letter) thus did not answer the intended question, but instead the alternate interpretation. This follow-up seeks to correct this miscommunication.
Confirm that all hydrants, as identified in Part VIII, entry F.16, of the as-designed FPR, that are used to provide protection to the refueling water storage tanks and the primary water storage tanks are listed in Part II, Table 14.7. Otherwise, add these hydrants to the table or document the operability requirements and testing and inspection requirements that apply to these hydrants. If these hydrants are not added to Table 14.7, describe the differences in operability requirements and testing and inspection requirements of these hydrants and those in the Table.
RAI FPR VIII-14.1 The reviewers intended RAI FPR VIII-14 to cover testing and operability requirements of hire hydrants. However, the RAI was ambiguously worded, and contained an alternate interpretation. The TVA response to RAI FPR VIII-14 (in the May 26, 2011 TVA letter) thus did not answer the intended question, but instead the alternate interpretation. This follow-up seeks to correct this miscommunication.
Confirm that all hydrants, as identified in Part VIII, entry F.17, of the as-designed FPR, that are used to provide support manual fire suppression activities around the cooling towers are listed in Part II, Table 14.7. Otherwise add these hydrants to the table or document the operability requirements and testing and inspection requirements that apply to these hydrants. If these hydrants are not added to Table 14.7, describe the differences in operability requirements and
testing and inspection requirements of these hydrants and those in the Table.
RAI FPR VIII-17.1 RAI FPR VIII-17 requested conformance information regarding detailed guidance regarding seismically qualified standpipes and hose stations. The TVA response to RAI FPR VIII-17 (in the June 7, 2011 TVA letter) did not supply this information, instead referring to an earlier RAI response.
Provide plant conformance information for the detailed guidance regarding seismically qualified standpipes and hose stations in the paragraph that begins: The standpipe system serving such hose stations at the end of entry E.3.d, in Part VIII Appendix A Guidance, of the FPR.
This RAI may involve an update to the FPR to incorporate the response to the RAI.
RAI FPR VIII-20 A change was made to Part VIII, entry F.1.B, of the FPR to change the Plant Conformance entry from:
Administrative procedures limit the amount of combustible materials within the area and control hot work activities. [emphasis added]
to:
Administrative procedures control the type of combustible materials within the area and control hot work activities. [emphasis added]
It appears that this change was made between Revision 40 and the as-designed version of the FPR.
The NRC position is that administrative procedures for combustible control should have both of these attributes (limiting the amount and controlling the type of combustible materials), as described in Regulatory Guide 1.189, Revision 2 regulatory position 2.1.
Confirm that the procedures for WBN unit 2 consider both of these attributes. If not, provide a technical justification for this change.
This RAI may involve an update to the FPR to incorporate the response to the RAI.
RAI FPR VIII-21 The NRC determined that the WBN fire protection program was acceptable in part due to the use of noncombustible insulating liquid in transformers in safety related buildings.
Supplemental Safety Evaluation Report 18 (ML070530364) states, in part:
Transformers insulated with Askarel oil (a noncombustible insulating liquid) are located in various areas of the plant without being located in a separate room.
Near these transformers are various redundant safety-related cable trays or conduits or both.
and The staff finds that the applicant's proposed use of transformers filled with noncombustible insulating liquid conforms to the guidelines of Position D.1.g of Appendix A to BTP (APCSB) 9.5-1 and, therefore, is acceptable.
Element D.1.g of NRC Branch Technical Position (BTP) 9.5-1 APCSB Appendix A (ML070880458) states in part:
High Voltage - High amperage transformers installed inside buildings containing safety-related systems should be of the dry-type or insulated and cooled with noncombustible liquid. [emphasis added]
Part VIII of the as-designed version of the FPR states the following in the Plant Conformance column of the table:
High Voltage - High amperage transformers are not installed within building spaces. Transformers installed within safety-related buildings are either dry-type or insulated and cooled with "high fire point" (650 F) liquid. [emphasis added]
The reviewers do not believe that the underlined text describes compliance, but rather an alternative to the requirements.
Describe TVAs understanding of the term high voltage - high amperage transformers as used in the Appendix A to BTP 9.5-1 Guidelines.
Confirm the insulating liquid used in transformers installed in safety related buildings is noncombustible.
If the insulating liquid is not noncombustible, Identify the locations where combustible oil filled transformers are installed. Provide the locations to the level of detail of room subdivisions used to assemble analysis volumes (for example, room 692.0-A1 has been subdivided into 692.0-A1A1, -A1A2, -A1A3, -A1AN, -
A1B1, -A1B2, -A1B3, -A1BN and -A1C).
Provide a technical justification for this deviation for each analysis volume containing combustible oil filled transformers. Each justification should include, but not be limited to, consideration of: fire protection features (i.e., detection and suppression), fire rated barriers, nearby safe shutdown equipment or components, smoke effects, diking, and effects on manual actions that require reentry or transit of the area.
This RAI may involve an update to the FPR to incorporate the response to the RAI.
A sampling review of the NFPA 13-1973 compliance matrix in Part X of the as-designed FPR identified the following:
Items 1-11.5 and 3-12.1.5 are identified as Deviations in the matrix, but detail is not provided after the matrix for these items.
Item 3-14.2.1 thru 3.4 is identified as a Deviation in the matrix, but detail is not provided after the matrix for this item. Additionally, other, similar, items (for example 3-14.5 and 3-14.1.5 thru 1.8) are identified as Alternatives.
Resolve these conflicts and provide assurance that other, similar conditions have been identified and corrected.
This RAI may involve an update to the FPR to incorporate the response to the RAI.