ML112990942
| ML112990942 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 06/30/1982 |
| From: | Musolf D Northern States Power Co |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML112970274 | List: |
| References | |
| NUDOCS 8207080403 | |
| Download: ML112990942 (6) | |
Text
REGULATURY FORMATION DISTRIBUTION SY*M (RIDS)
AOCESSION NbR:8207080403 DUC.DATE: 82/06/30 NOTARIZED: YES FACIL:50-263 Monticello Nuclear Generating Plant, Northern States AUTHNAME AUTHOR AFFILIATION MUSCLFrD.
Northern States Power Co, RECIP.NAME RECIPIEN[ AFFILIATION Office of Nuclear Reactor Regulation, Director DOCKET #
05000263
SUBJECT:
Forwards NEDO-22087, "Fire Protection & Safe Shutdown Sys Analysis Rept," per 10CFR50,App R,Section IIIG.2 SEe 7
requirements.Exemption requests encl.
r
,76.od 220 DISTRIBUTION CODE: A006S COPIES RECEIVED:LTR.3 ENCL SIZE TITLE: Fire Protection Information (After Issuance of OP. Lic.)
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Northern States Power Company wS 414 Nicollet Mall Minneapolis, Minnesota 55401 Telephone (612) 330-5500 June 30, 1982 Director Office of Nuclear Reactor Regulation U S Nuclear Regulatory Commission Washington, DC 20555 MONTICELLO NUCLEAR GENERATING PLANT Docket No. 50-263 License No. DPR-22 Fire Protection and Safe Shutdown Analysis for Meeting the Requirements of Appendix R,Section III.G.2, Including Exemption Requests Attached you will find 40 copies of a General Electric (GE) report titled "Fire Protection and Safe Shutdown Systems Analysis Report" (Attachment 1).
The purpose of this submittal is to present for the NRC Staff evaluation the following:
- 1. A description of the methods used in determining compliance with 10 CFR Part 50, Appendix R, at the Monticello Nuclear Generating Plant.
- 2. The results of the above analyses including a description of necessary modifications.
- 3. Our disposition of previously existing open items in Monticello's Fire Protection Safety Evaluation Report dated August 29, 1979 which were superseded by Appendix R,Section III.G.
- 4. The necessary information pursuant to our request for exemption from certain requirements of Appendix R.
An estimated 20,000 man hours at a cost of 1.3 million dollars were expended in preparing this submittal to comply with section III.G.2.
This research effort has identified a backfit modification program which would cost over 10 million dollars to fully implement. Accordingly, where substantial 3 ~I'additional fire protection is not gained or where strict compliance with Appendix R does not necessarily result in improved protection of public health and safety, exemptions from the requirements of Section III.G.2 are requested as stated in Attachments 2 through 5. is the principal report documenting the analysis used and the approach taken in complying with Appendix R,Section III.G.2. Except where noted, Northern States Power Company commits to completing the recommended modifications as delineated in the following sections of the GE report.
9207080403 820630 PDR ADOCK 05000263 F
NORT 4
N STATES POWER COM*NY Director of NRR June 30, 1982 Page 2 Section 5.4 Safety Evaluation Report (SER).
In our March 19, 1981 letter and earlier correspondence we indicated we would compare certain SER items against the criteria of Section III.G.2 of Appendix R. These items were listed in Supplement No. 1 to the Monticello Fire Protection Safety Evaluation Report dated February 12, 1981.
The disposition of remaining SER items is as follows:
- 1. Automatic Water Suppression, 3.1.2(2):
The pre-action sprinkler syst~m has been upgraded to provide a design density of 0.30 gpm/ft over the entire diesel generator area.
- 2. Automatic Water Suppression Systems and Fire Barrier/Penetra tion Seals, 3.1.2(3) and 3.1.8(2):
The two hour walls between fire zones 13B and 19A and B have been upgraded to the requirements of III.G.2.
- 3. Fire Barrier/Penetration Seals 3.1.8(1):
The cable tray run between fire zones 13C and 19C has been protected to the requirements of III.G.2.
- 4. Fire Barrier/Penetration Seals 3.1.8(4):
The one way 3-hour fire walls in fire zones 12B and 14B provide adequate protection as determined by location of the safe shutdown systems in the fire protection analysis.
- 5. Fuses and Battery Rooms, 3.1.15 and 3.2.5:
This item is resolved by the proposed modifications in Fire zones 7A, B and C.
- 6. Fire.Pumps, 3.2.3:
The screen wash pump has been upgraded to be equivalent to an Underwriters Laboratories approved pump with the exception of a suction strainer which will be installed during the pump's scheduled maintenance outage.
- 7. Gas Suppression Systems and Cables, 3.1.3 and 3.1.9:
The HPCI and RCIC cable separation and reroute previously committed to, has been shown to be inadequate to meet the safe shutdown system performance goals of our analysis.
Rather, the selective rerouting of existing SRV, core spray and suppression pool cooling cables, (as described in modifi cations for fire zones 7A, 7B, 7C and 8) will ensure the minimum safe shutdown systems are available for any design basis fire.
Contrary to earlier discussion on this item there are no existing alternate shutdown systems for the entire Monticello plant and none are proposed as a result of our analysis.
Section 5.4.1 Fire Barrier Upgrade:
NSP commits to upgrade all fire barriers listed in Table 5-10 of Attachment 1 to a 3-hour equivalent rating consistent with Section III.G.2 of Appendix R. In each case where fire severity is less than 30 minutes for fire zones adjacent to a fire barrier, an exemption request for structural steel forming a part of that barrier is requested in Attachment 2.
NORTI-N STATES POWER COM*NY Director of NRR June 30, 1982 Page 3 Section 5.4.2 Safe Shutdown System Modifications The following modifications to safe shutdown system equipment will be made in the below listed fire zones, except where exemption requests are noted:
- 1. FIRE ZONE 1F -
An exemption as stated in Attachment 3 is requested from protecting suppresion pool temperature and level with an equivalent 3-hour barrier rating consistent with III.G.2.
- 2. FIRE ZONES 2B and 2C -
The cabling for the low pressure per missives in the low pressure core cooling systems will be rerouted to prevent loss of the automatic function of the core spray and LPCI systems.
- 3. FIRE ZONE 3A -
The RHR auxiliary air compressor power sources will be separated by a three hour equivalent fire barrier in this zone to prevent total loss of the RHR service water system.
- 4. FIRE ZONE 3C - The low-low level initiation signal and the low pressure permissive cabling for the low pressure core cooling system in this zone will be rerouted to prevent loss of the automatic functions of the core spray and LPCI systems.
- 5. FIRE ZONES 7A and7B -
A battery system design modification involving cable and power supply separation will be imple mented to ensure that the automatic function of core spray B, the manual operation of Suppression Pool Cooling (SPC)-B, and three S/RV's, and required auxiliary support systems are available following a fire in these fire zones.
- 6. FIRE ZONE 7C -
Same as for Fire Zone 7A and 7B above.
- 7. FIRE ZONE 8 -
The circuits required for manual and automatic operation of core spray-B, and manual operation of SPC-B, three S/RV's and required auxiliary support systems will be routed to the control room independent of the cable spreading room. In addition, administrative controls will be provided to preclude unacceptable spurious operation of MOV-2029, MOV-2032 and MOV's 2404 and 2405 by leaving their source breakers open except under controlled conditions.
MOV 2029 is the shutdown cooling system isolation valve, a high/
low pressure interface. MOV 2032 is a RHR system connection to radwaste which could disable RHR by flow diversion. MOV's 2404 and 2405 are cleanup system connections to radwaste which could be spuriously opened to cause a substantial loss in reactor inventory.
- 8. FIRE ZONE 14A -
Separation of diesel generator control circuitry will be established to ensure availability of one diesel generator to provide onsite AC power.
- 9. FIRE ZONE 14A, 15A and Yard - A modification of the diesel oil transfer system for these zones will be made to assure long term fuel oil supply to the diesel generators.
z' NORTI-N STATES POWER COMONY Director of NRR June 30, 1982 Page 4
- 10. FIRE ZONE 23A - An exemption from providing a 3-hour barrier between redundant emergency and RHR service water pumps is requested as stated in Attachment 4.
Section 5.4.3 Required Exemption For the reasons stated in this section of Attachment 1 and in accordance with the provisions of 10 CFR 50.48(c)(6) and 10 CFR 50.12, an exemption for the control room from the specific requirements of Appendix R,Section III.G.2 is requested (i.e., separation of cables and equipment and associated non-safety circuits of redundant trains by a horizonal distance of 20 feet and installation of an automatic suppression system). Attachment 5 provides a quantitative fire hazards analysis to justify the conclusions reached for the control room in Attachment 1.
Due to the major change in direction to our approach to fire protection at Monticello precipitated by this complex and extensive analysis of the requirements of III.G.2, much of the detailed analysis and design descrip tion for the modifications indentified in this submittal remain to be done.
In addition, a second look effort is in progress to verify information submitted and conclusions drawn in this report. Accordingly in order to backfit the modifications committed to in this submittal with a reasonable assurance of accuracy and overall safety, we are requesting extension of the following schedular exemptions granted in your May 4, 1982 letter as follows:
- 1.
That the implementation date in paragraph (c)(2) for installation of modifications required by Appendix R,Section III.G.2, that do not require prior NRC approval or plant shutdown, be extended from nine months after June 1, 1982 to December 1, 1983.
- 2.
That the implementation date in paragraph (c)(3) for the installation of modifications required by Appendix R,Section III.G.2, that do not require prior NRC approval, but require plant shutdown, be extended from before startup after the first refueling or extended outage commencing 180 days or more after June 1, 1982, to before a startup after the first refueling outage commencing in 1985 (scheduled for January, 1985).
In the event our design verification of backfit modifications uncovers any corrections or additions not previously identified in this submittal, they will be supplied in a timely manner. Please contact us if you have any questions related to this submittal or if we can furnish additional information related to this issue.
David Musolf Acting Head-Nuclear Support Services DMM/KNC/bd cc:
Secretary of the Commission (original and 2 copies)
Regional Administrator-III, NRC NRR Project Manager, NRC NRC Resident Inspector G Charnoff Attachments
UNITED STATES NUCLEAR REGULATORY COMMISSION NORTHERN STATES POWER COMPANY MONTICELLO NUCLEAR GENERATING PLANT Docket No. 50-263 LETTER DATED JUNE 30, 1982 REQUEST FOR RELIEF FROM REQUIREMENTS OF 10 CFR PART 50, SECTION 50.48(c)(2),(c)(3), and APPENDIX R, SECTION III.G.2 Northern States Power Company, a Minnesota corporation, by this letter dated June 30, 1982 hereby submits a request for relief from the requirements of 10 CFR 50, Sections 50.48 (c)(2), (c)(3), and Appendix R,Section III.G.2.
This submittal contains no restricted or other defense information.
NORTHERN STATES POWER COMPANY By k
D M Musolf Acting Head-Nuclear Support Se ices On this dI day of before me a notary public in and for said County, personall/ appeared D M Musolf Acting Head-Nuclear Support Services, and being first duly sworn acknowledged that he is authorized to execute this document on behalf of Northern States Power Company, that he knows the contents thereof and that to the best of his knowledge, information and belief, the statements made in it are true and that it is not interposed for delay.