ML18019A480

Forwards Response to NRC Question Re Flood Protection.Rev to SER Section 2.4.2.2 Requested to Reflect That Tech Spec for Watertight & Airtight Doors W/O Curbs at 261 Feet Elevation Not Needed

ML18019A480
Person / Time
Site:	Harris
Issue date:	11/12/1985
From:	Zimmerman S CAROLINA POWER & LIGHT CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
NLS-85-348, NUDOCS 8511180518
Download: ML18019A480 (7)

Text

REGULAT . ORMATION DISTRIBUTIO Y M ('RIDS)

ACCESSION NBR:8511180518 DOC ~ DATE: 85/11/12 NOTARIZED: NO DOCKET FACIL':50 400 Shearon Harris Nuclear Power Pl antr Unit 1~ Car ol ina 05000400 AUTH'AME AUTHOR AFFILIATION ZIMMERMAN~S,R, Car ol ina Power 8 Light Co, RECIP ~ NAME. 'ECIPIENT AF F IL'IA TI ON DENTON~H ~ RE Office~ of Nuclear Reactor Regulationi Director SUBJECT! For wards response to.NRC question re flood pr otectioq,Rev to SER Section 2 ' ' ' requested to.reflect that Tech. Spec- for water tight L airtight doors w/o curbs at 261- feet elevation not needed.

D1STRIBUTION CODE: 8001D COPIES RECEIVED!LTR 'NCL 'IZE'e TITLE: Licensing Submittal: PSAR/FSAR Amdts 8 Related Correspondence NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME; LTTR ENCL ID CODE/NAME LTTR= ENCL' NRR/DL/ADL 1 0 NRR LB3 BC NRR- LB3 LA 1 0 BUCKLEYzB 01 1 1 INTERNAL; ACRS 6 6 ADM/LFMB 1 0 ELD/HDS1 1 0 IE FII E 1 IE/DEPER/EPB 1 1 IE/DQAVT/QAB21 1 1 NRR/PE/AEAB 36'RR ROEpM ~ L" 1 1 0 NRR/DE/CEB 11 1 NRR/DE/EHEB 1 1 NRR/DE/EQB 13 2 2 NRR/DE/GB 28 '2' NRR/DE/MEB 18 1 1 NRR/DE/MTEB 17 1 1-=

NRR/DE/SAB 24 1 1 NRR/DE/SGEB 25 1 1 NRR/DHFS/HFEB40 1 1 NRR/DHFS/LQB 32 1 1 NRR/DHFS/PSRB 1 1 NRR/DL/SSPB 0 NRR/DS I/AEB 26 1 1 NRR/DSI/ASB 1 1 NRR/DSI/CPB 10 1- 1 NRR/DS I /CSB 09 1 1 NRR/DSI'/ICSB 16 1 1 NRR/DSI/METB 12' iu NRR~/DSI/PSB 19 1 1 RAB 22 1 1~

NRR/DSI/RSB: 23~ 1 1 EG FIL 04 1 1 RGN2 3" 3 ~

I/MIB 1 0 EXTERNAL': 24X 1 1 BNL(AMDTS ONLY) 1 DMB/DSS (AMDTS) 1 1 LPDR 03 1 NRC PDR 1 1 NSIC 05 1 GRUEL'rR 02'NL<

1 1 TOTAL NUMBER OF COPIES REQUIRED: LTTR 52" ENCL'

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~0 ~0 CÃQH Carolina Power & Light Company SERIAL: NLS-85-308 NOV 131985 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT UNIT NO. 1 - DOCKET NO.50-000 FLOOD PROTECTION

REFERENCE:

1) Letter dated October 25, 1980 from Mr. S. R. Zimmerman (CPRL) to Mr. Harold R. Denton (NRC).

2) Letter dated April 23, 1985 from Mr. A. B. Cutter (CPRL) to Mr.

Harold R. Denton (NRC) transmitting updated "pen and ink" copy'of Technical Speci fications.

Dear Mr. Denton:

Carolina Power R Light Company (CPdcL) provides additional information regarding flood protection to address questions raised by an Environmental and Hydrologic Engineering Branch reviewer. Each concern is identified and addressed in Enclosure l.

In Section 2.0.2.2 of the Shearon Harris Nuclear Power Plant (SHNPP) Safety Evaluation Report (SER), the NRC Staff required that a Technical Specification (TS) be written to ensure that watertight and airtight doors are normally in a closed position.'he TS would cover those doors without curbs on the 261 feet elevation. The CP&L position stated in Reference 1 is that since security surveillance will ensure that these few doors are normally closed, a separate TS would not serve any useful purpose. Therefore, Carolina Power dc Light Company did not propose any specification on door position status in Reference 2.

Based on the information provided to you in this letter and Reference 1, CPRL considers this matter closed and requests that you revise the SHNPP SER Section 2.0.2.2 to reflect that a TS is not needed. If you have any questions, please contact Mr. Gregg A. Sinders at (919) 836-8168.

Yours very truly, 85li1805i8 85iii2 S. R. Zi merman PDR ADOCN 05000400 Manager F PDR

'uclear Licensing Section GAS/crs Enclosure cc: Mr. R. Benedict (NRC) Wake County Public Library Mr. B. C. Buckley (NRC) Mr. Wells Eddleman Mr. G. F. Maxwell (NRC-SHNPP) Mr. 3ohn D. Runkle Mr. R. Gonzales (NRC-EHEB) Dr. Richard D. Wilson Dr. 3. Nelson Grace (NRC-Rll) Mr. G. O. Bright (ASLB)

Mr. Travis Payne (KUDZU) Dr. 3. H. Carpenter (ASLB)

Mr. Daniel F. Read (CHANGE/ELP) Mr. 3. L. Kelle (ASLB) 411 Fayetteville Street ~ P. O. Box 1551 o Raleigh, N. C. 27602

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ENCLOSURE 1 In a letter dated October 25, 1980 (Serial: NLS-80-020), you stated that the only doors potentially exposed to high water from a probable maximum precipitation (PMP) event are three doors shown on FSAR Figure 1.2.2-27. You further state these doors are normally locked and electronically monitored to alarm if opened.

FSAR Figure 1.2.2-28 which was not mentioned in your letter shows other exterior entrances which appear to also be exposed to potential high water. Please explain why water will not enter safety-related buildings through these exterior entrances.

Also, provide assurances that water will not enter safety-related buildings through interior openings. For example, if water enters the Turbine Building or some other nonsafety-related building, will it be possible, for this water to then enter a safety-related building through an opening between the two structures?

The staff notes that in a letter dated October 5, 1983 (Serial: LAP-83-058), you committed to providing "watertight or airtight doors". It is not clear whether the doors that you identified on FSAR 1.2.2-27 are air or watertight. Please describe the type of door at each entrance and if not watertight, provide a discussion of how much water will leak in during a PMP event. Also discuss the effect that leakage will have on safety-related components.

B. ~Res ense

1. FSAR Fi ure 1.2.2-28 FSAR Figure 1.2.2-28 was deleted from the SHNPP FSAR by Amendment 15 due to the cancellation of Unit 2. The openings for doors that were indicated on deleted FSAR Figure 1.2.2-28 will be closed, sealed, and will not exist.

2. Water from Nonsafet -Related Buildin Enterin a Safet -Related Buildin Carolina Power dc Light Company has previously addressed this concern in response to DSER Open Item 1'/220 and applicable discussions are presented in FSAR Sections 2.0.2.3, 3.0.1, and IOA.5.3. IVater entrance from nonsafety-related buildings into safety-related buildings is prevented by seismically designed reinforced concrete walls, curbs, waterstops, doors and drain systems.

For example, the Waste Processing Building has five entrances at elevation 261 feet msl. Three of these entrances are protected by tornado missile doors with approximately a two-inch door sill and a door sealing system that will prevent water from entering through these normally closed, outswinging doors. These doors are shown on FSAR Figure 1.2.2-09. The two remaining doors are outswinging, industrial steel, personnel doors of which one is a normally closed emergency exit door. These doors, as discussed in FSAR Section 2.0.2.3 and on SER pg. 2-16 lead to areas containing locker rooms and shower stalls which do not contain any safety-related equipment.

Flooding of safety-related areas of the RAB from the Turbine Building were addressed in our transmittal of October 25, 1985 (Reference 1). Doors at site grade elevation 261' 0" (D-l, D-5, D-7, D-52) are normally closed tornado (1961GAS/crs )

type doors with seals that will prevent PMP related water entry. Water entry from the Turbine Building lower elevation to RAB areas is discussed in FSAR Section 10.0.5.3. Therefore, it is not possible for water due to flooding from PMP to enter safety-related buildings through openings between the nonsafety buildings and safety buildings or via ponding at site grade.

3. Waterti htor Airti ht Doors In a letter dated October 5, 1983, CPdcL.stated, that watertight or airtight doors were provided. Upon further review of the applicable door specifications, it was determined that the manufacturers of the doors were not required to provide an "airtight" or "watertight" door but a door that will meet tornado or tornado missile resistance criteria. However, these doors will also

- prevent PMP related water from entering safety-related plant areas as described above although not specifically designed for this event (i.e., PMP flooding).

Page 2-18 of the SHNPP SER requires that the applicant describe how pump operability and ponded water levels in the area between the Retaining Wall and the Fuel Handling Building will be-monitored and the actions to be taken if pumps malfunction or the level of ponding rises above elevation 236 feet msl.

Two pumps are located in each of the areas (Unit 3 area and Unit 0 area) between the Retaining Wall and the Fuel Handling Building on the west side of the Fuel Handling Building. These pumps will operate to remove water that accumulates in the respective area. To assure that the area above the remains free of water under normal conditions, the operation of each 216'levation pump will be checked weekly by jogging the level control switch for each sump pump. In addition, the area will be checked subsequent to heavy rainfall to observe for removal of water from the area. If both pumps become inoperable and water accumulates to elevation 221 feet msl, additional temporary pumps will be installed to remove the accumulated water.

5. Fuel Handlin Buildin Wall Desi n Page 2-18 of 'the SHNPP SER states "The staff, however, will require that the applicant provide assurance that the wall of the fuel handling building can withstand a hydrostatic level of 236 feet msl.

As stated in FSAR Section 3.0.2, the walls of the Fuel Handling Building and Waste Processing Building exposed to accumulated storm water in the area between the Retaining Wall and the Fuel Handling Building are capable of withstanding the corresponding hydrostatic loads. The wall,of the Fuel Handling Building can-withstand a hydrostatic load up to a level of 236 feet msl due to flooding from the PMP.

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