ML17321A097
| ML17321A097 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 06/15/1984 |
| From: | Alexich M INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| AEP:NRC:0692R, AEP:NRC:692R, NUDOCS 8406210349 | |
| Download: ML17321A097 (6) | |
Text
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REGULATO INFORMATION DISTRIBUTION
~TEM (RIDS)
ACCESSION NBR:6006210349 DOC ~ OATEN'0/06/15 NOTARIZED:
NO DO FACIL:50-315 Donald C ~
Cook Nuclear Power Plantg Unit'i Indiana 8
'50-316 Dona'Id C ~
Cook Nuclear Power Pl anti Unit 2i Indiana 8
05000316 AUTH ~ NAME AU/I)OR AFFILIATION ALEXICH,M.P, Indiana 8 M,ichigan Electric Co.'ECIP
~ NAME RECIPIENT AFFILIATION DENTONiH',RE Office of Nuclear Reactor Regulationi Director
SUBJECT:
Requests addi technical exemption from App R requirements re penetration seals in seismic gaps between conte'inment 8
auxijiary bldg 8 ventilation ducts that penetrate fire barriers
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DISTRIBUTION CODE:
A006S COPIES RECEIVED:LTR 'NCL SIZEo 0
TITLE:
OR Submittal: Fire Protection NOTES RECIPIENT ID'CODE/NAME NRR ORB1 BC 01 INTERNAL: ELD/HDS3 IE/WHITNEYi L NRR i'JAMBACH NRR/DL D IR RGN3 COPIES LTTR ENCL 3
1 0
1 1
0 1
1 1
1 RECIPIENT ID CODE/NAME IE FILE 06 NRR F IORAYANT07 NRR/DE/CEB 09 O4 COPIES LTTR ENCL 1
1 2
2 2
2 1
1 EXTERNAL: ACRS NRC PDR NTIS 11 02 3
3 1
1 1
LPDR NSIC 03 05 2
2 1
1 TOT'AL NUMBER OF COPIES REQUIRED:
LTTR 22 ENCL
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INDIANA 8 N ICHIGAN ELECTRIC CON PANY P.O. BOX 16631 COLUMBUS, OHIO 43216 June 15, 1984 AEP:NRC:0692R Donald C.
Cook Nuclear Plant Unit Nos.
1 and 2
Docket Nos. 50-315 and 50-316 License Nos.
DPR-58 and DPR-74 REQUEST FOR ADDITIONAL TECHNICAL EXEMPTIONS WITH REGARD TO CERTAIN FIRE DAMPERS AND "SEISMIC GAPS" Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Dear Mr. Denton:
The purpose of this letter is to request technical exemption for two areas of Appendix R.
The areas involved are (1) penetration seals in the seism1c gaps between the conta1nment and the auxiliary building, and (2) ventilation ducts identified in this letter wh1ch penetrate fire barriers.
The need for addit1onal exemptions was just recently d1scovered.
From discussions with our fire protection consultant we believe these conditions are minor deviations from the literal requirements of Appendix R.
The seismic gaps were originally designed at the Donald C.
Cook Nuclear Plant to assure that the containment and auxiliary building would be decoupled following a design basis earthquake so that the movement of one building would not adversely affect the other.
In
- addition, as part of the design basis of the plant, analyses had to be performed to show that the auxiliary building would not be adversely affected by the consequences of High Energy Line Breaks outside containment.
It is our current bel1ef that some of these analyses took credit for available relief area associated with the gaps.
We are currently review1ng our records to determine whether this in fact was done.
We will advise you accordingly. If we had to provide continuous fire protection by sealing those gaps, this would be an extreme burden because of the additional structural and thermohydraulic analyses required to substantiate that the plant was still with1n the envelope of its original design criteria.
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Mr. Harold R.
ton,. 'EP:NRC:0692R We believe that we can provide adequate engineering justification to show that the seismic gaps can be left open without destroying the capability of the plant to be safely shutdown in the event of a fire.
However, our detailed technioal justification for the seismic gap exemption does not accompany this letter because of the time required to complete these analyses.
We anticipate that the results of these analyses will be available on July 16, 1984.
In the area of HVAC ductwork, we have recently discovered that technical exemptions are required for 17 duets which penetrate f1re barriers.
These areas are typified by low combustible loading, and duct outlets being located in an area sufficiently removed from equipment important to the safe shutdown of the facility.
Sound engineering evaluations can be used to justify our request for technical exemption of the requirements for fire dampers.
As of now seventeen (17) duct penetrations have been identified as falling into that category.
They include:
No. of e
45ft x 35ft 40ff x 40ff 36ff x 36ff 52ff x 24ff 72ff x 30ff 34tt x 3Ptt 36ff x 24ff 44ff x 24ff 24ff x 30ff 25ff x 28ff 26ff x 30" 650t-Pff 650 '-0ff 650t-Pff 609'-pff 609'-Off 609'-pff 609'-0ff 609'-pff 609'-0ff 587tt pfl 587ffpff Auxiliary ff tf Building ff ff ff Since we only recently discovered this problem, we have not had time to complete the required engineering evaluat1on.
This evaluation is also scheduled for completion by July 16, 1984.
Th1s letter has been prepared following Corporate procedures which incorporate a reasonable set of controls to insure its accuracy and oompletness pr1or to signature by the undersigned.
Very trul your s
/ y(
M.. Alexicb QIL/<~
Vice Pr esident~'PA/cm ceo John E. Dolan W.
G. Smith, Jr.
Bridgman R.
C. Callen G. Charnoff E.
R. Swanson, NRC Resident Inspector - Bridgman
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