ML18019A581
| ML18019A581 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 02/13/1986 |
| From: | Cutter A CAROLINA POWER & LIGHT CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0800, RTR-NUREG-800 NLS-86-040, NLS-86-40, NUDOCS 8602200200 | |
| Download: ML18019A581 (24) | |
Text
ACCESSION NBR:
FACIL: 50-450 AUTH. NAME CUTTER> A. B.
REC IP. NAME DENTONi H, R.
REGULATORY FORMATION DISTRIBUTION BY EM (RIDS)
Bb02200200 DOC. DATE: Sb/02/13 NOTARIZED:
NO DOCKET 0 Shearon Harris Nuclear Power Plant>
Unit 1 i Carolina 05000400 AUTHOR AFFILIATION Carolina Power 5 Light Co.
RECIPIENT AFFILIATION Office of-Nuclear Reactor. Regulationi Director (post 851125
SUBJECT:
Forwards addi deviations to Branch Technical Position
- 9. 5-1 to NUREG-0800> per 851204 meeting. Clarification oF previously granted deviation requests Zc Util.850405 response to question 410. 45 re fire areas also encl.
DISTRIBUTION CODE:
B001D COPIES RECEIUED: LTR ENCL SIZE:
TITLE: Licensing Submittal:
PBAR/FSAR Amdts 5 Related Correspondence NOTES:
RECIPIENT ID CODE/NAME PNR-A ADTS PWR-A EB PNR-A FOB BUCKLEY'S B 01 PNR-A RSB INTERNAL:
ACRS 4f ELD/HDSl IE/DEPER/EPB 3b NRR BWR ADTB NRR PWR-B ADTB NRR/DHFT/HFIB DIR 04 RM/DDAMI /MIB EXTERNAL: 24X DMB/DSS (AMDTB)
NRC PDR 02 PNL GRUEL' COP IEB LTTR ENCL 1
1 1
1 1
2 2
1 1
b b
1 0
1 1
1 0
1 0
1 1
1 0
1 1
0 1
1 1
1 1
1 1
RECIPIENT ID CODE/NAME PNR-A PD2 PD PWR-A EICSB PNR-A PD2 LA PNR-.A PBB ADM/I FMB IE FILE IE/DGAVT/GAB 21 NRR PWR-A ADTS NRR ROE'. L NRR/DHFT/MTB NRR/DBRO/RRAB RGN2 BNL(AMDTS ONLY)
LPDR 03 NBIC 05 CO< IES LTTR ENCL 1
1 1
1 1
1 1
1 1
0 1
1 1
1 1
0 1
1 1
1 1
1 3
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1 1
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CSQP Carolina Power & Light Company SERIAL: NLS-86-000 FEB iS <g86 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.
I. - DOCKET NO.50-000 DEVIATIONSFROM BTP 9.5-1
Dear Mr. Denton:
Carolina Power R Light Company hereby submits additional deviations to the Branch Technical Position (BTP) 9.5-1 to NUREG-0800. Attachment 1 provides the technical information needed for your review. These deviations were discussed with your staff at a December 0, 1985 meeting. contains clarification to (I) previously granted deviation requests and (2) CPRL's response to Question 010.05 dated April 5, 1985.
Should you have any questions concerning this letter, please contact Mr. Patrick Carier at (919) 836-8165.
Your ery tr ABC/PPC/crs (3290PPC)
Attachment cc:
Mr. B. C. Buckley (NRC)
Mr. G. F. Maxwell (NRC-SHNPP)
Dr. 3. Nelson Grace (NRC-RII)
Mr. Travis Payne (KUDZU)
Mr. Daniel F. Read (CHANGE/ELP)
Wake County Public Library
. B. Cutter - Vice Pr
'dent Nuclear Engineering & Licensing Mr. Wells Eddleman Mr. 3ohn D. Runkle Dr. Richard D. Wilson Mr. G. O. Br ight (ASLB)
Dr. 3. H. Car penter (ASLB)
Mr. 3. L. Kelley (ASLB)
Mr. H. A. Cole Seom00200 SiOiXS, M PDR ADOCK 05000400 A
PDR~
411 Fayetteville Street o P. O. Box 1551 o Raleigh, N. C. 27602
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ATTACHMENTI DEVIATIONREQUESTS (3294PPC/crs)
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DEVIATIONA
SUMMARY
A deviation is requested from BTP 9.5-1, Section C.5.g of NUREG-0800 from having to provide self-contained emergency lights for access and egress routes (1) to perform cold shutdown operations and (2) in certain outdoor areas to safe shutdown equipment.
DESCRIPTION 1.
There are plant areas (such as containment) which require eight-hour emergency lighting units for cold shutdown manual operations.
In our response to NRC question 010.23 (NLS-80-297, dated 3uly 16, 1980), CPRL showed that approach to cold shutdown could commence approximately four to eight hours subsequent to the fire. SHNPP contends that the benefits of eight-hour battery powered emergency lighting would be minimal for these cold shutdown activities.
SHNPP proposes to provide dedicated portable emergency lighting for those areas which require cold shutdown manual operations and access and egress routes thereto which would occur approximately four hours or later after the fire started.
The portable lights willbe clearly marked "For Use During Cold Shutdown After a Fire Only." The capacity of the lights willbe checked once every six months.
2.
As part of our alternative shutdown steps, the controls for the emergency diesel must be verified. These controls are located away from the power block in the diesel generator building. Fixed emergency lighting willbe provided at the control panel.
However, SHNPP believes that lighting powered by our security diesel provide sufficient illumination for access and egress in the outdoor area from the power block to the diesel generator building.
CONCLUSION 1.
CPRL believes that this deviation is justified for the following reasons:
a.
The dedicated portable emergency lighting is not used to achieve hot shutdown.
b.
The portable emergency lights are used for cold shutdown manual operations and access and egress thereto which would not be needed until four hours or later after the fire.
Based on the above, CPRL believes that the addition of eight-hour emergency lighting units in these areas would not enhance the safe shutdown capability of the plant, and the dedicated portable lighting units would provide greater flexibilityand versatility.
2.
CPRL believes that the use of emergency lights powered by the security diesels willprovide sufficient lighting for the operator to transit from the power block to the Diesel Generator Building and is technically equivalent to the guidance provided in BTP 9.5-1, Section C.5.g of NUREG-0800.
(3294PPC/crs)
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DEVIATIONB
SUMMARY
A deviation is requested from BTP 9.5-1, Section C.5.b(2) of NUREG-0800 from having to provide 20 feet of horizontal separation with no intervening combustibles between Motor Control Center (MCC) lA35-SA and MCC 1835-SB in fire zone I-A-0 COM E
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(RAABLO-0 COM E).
AREA DESCRIPTION Plant Location: Reactor Auxiliary Building Elevation 261'ire Area: 1-A-BAL SSA Area: FAABLO Fire Zone:
1-A-0 COM E Other Safe Shutdown E ui ment within the SSA Area:
l.
2.
30 5.
6.
Chilled Water Pumps Condenser Water Circulating Pumps (Chilled Water Systems)
Closed Expansion Tanks (Chilled Water Systems)
HVAC Chillers Air Handling Units Cable for Safe Shutdown Systems Listed in the SSA, Table 9.5B-Of (Both SA and SB Trains)
DISCUSSION The Motor Control Centers identified above are separated by approximately 16 feet and an automatic fire detection and suppression system has been provided at this location.
A one-hour partial height fire wall has been constructed between the equipment and intervening combustibles have been eliminated by the application of a one-hour fire wrap system on the cable tray. This fire zone has a low combustible loading as detailed in the FSAR Fire Hazard Analysis Section 9.5A.3, page 9.5A-31. Additional information for this area is available in licensee submittal NLS-80-205 dated 3une 12, 1980.
CONCLUSION CPRL believes that this deviation is justified for the following reasons:
l.
2.
3.
5.
Separation of approximately 16 feet is provided.
Low combustible loading.
Intervening combustibles have been wrapped with a one-hour fire barrier.
Suppression and detection systems are provided in the area.
Partial height wall is provided between the equipment.
Based on the above, a commensurate level of protection in lieu of the 20 feet separation has been provided for this area.
(3294PPC/crs
)
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DEVIATIONC
SUMMARY
A deviation is requested from BTP 9.5-1, Section C.5.b(2) of NUREG-0800 from having to provide a one-hour fire rated barrier between instrument racks Al-R22, Al-R23, and Al-R20 and their related cables (10989A, 10988A, and 10988B, respectively).
AREA DESCRIPTION Plant Location: Reactor Auxiliary Building Elevation 261'ire Area:
1-A-BAL SSA Area:
FAABLO Fire Zone:
1-A-0-CHLR Other Safe Shutdown E ui ment within the SSA Area:
l.
2.
3.
5.
6.
Chilled Water Pumps Condenser Water Circulating Pumps (Chilled Water Systems)
Closed Expansion Tanks (Chilled Water Systems)
HVAC Chillers Air Handling Units Cable for Safe Shutdown Systems Listed in the SSA, Table 9.5B-Vf (Both SA and SB Trains)
DISCUSSION Multi-cycle sprinklers actuated by thermal detection are provided above the instrument racks.
Ionization-type smoke detection is provided above the instrument racks.
Hose stations, portable fire extinguishers, and manual alarm stations are provided in and adjacent to the fire zone.
Intervening combustibles presently are in the form of fire resistant IEEE-383 cables with fire breaks between the racks.
The combustible loading in this fire zone is moderate and is described in the SHNPP FSAR Fire Hazard Analysis Section 9.5A.3, page 9.5A-30. Additional information for this area is available in licensee submittal NLS-80-205 dated 3une 12, 1980.
The instrument racks identified above initiate Auxiliary Feedwater isolation signals.
The instrument racks are separated by approximately 18 feet of distance.
Their related cables, identified above, are routed in embedded conduit within the zone in question with the only exposed portions at the terminal box connection on each rack.
CONCLUSION CPRL believes that this deviation is justified for the following reasons:
Suppression and detection systems are provided in the area.
Hose stations, portable fire extinguishers, and manual alarm stations are provided in and adjacent to the fire.
Separation of approximately 18 feet is provided.
Related cables are routed in embedded conduits.
Intervening combustibles are IEEE-383 cables with fire breaks between the racks.
1 3.
5.
Based on the above, a commensurate level of protection in lieu of the one-hour fire rated barrier has been provided for this area.
(3294PPC/crs
)
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DEVIATIOND
SUMMARY
A deviation is requested from BTP 9.5-1, Section C.5.b(2) of NUREG-0800 from having to provide a three-hour rated enclosure between electrical pull boxes B5031-SB and 8 1551-SA.
AREA DESCRIPTION Plant Location: Reactor Auxiliary Building Elevation 261'ire Area:
1-A-BAL SSA Area:
FAABLO Fire Zone:
I-A-0-COR and 1-A-CHLR Other Safe Shutdown E ui ment within the SSA Area:
l.
2.
3.
Q, 5.
6.
Chilled Water Pumps Condenser Water Circulating Pumps (Chilled Water Systems)
Closed Expansion Tanks (Chilled Water Systems)
HVAC Chillers Air Handling Units Cable for Safe Shutdown Systems Listed in the SSA, Table 9.5B-Of (Both SA and SB Trains)
DISCUSSION Electrical pull box B5031-SB located in fire zone I-A-0-COR and electrical pull box B1551-SA located in fire zone 1-A-0-CHLR are physically separated by approximately 21 feet of distance.
These pull boxes are utilized for cables that support the Emergency Service Water Intake Structure HVAC System.
Ionization detectors are provided in the zone where the electrical boxes are located.
Partial automatic suppression system actuated by thermal detectors is installed in the fire zone over electrical pull box 81551-SA.
The partial suppression deviation was granted for the area in Supplement 2 to the Safety Evaluation Report.
Intervening combustibles present are in the for m of fire resistant IEEE-383 cables.
Both fire zones under consideration have moderate combustible loadings as described in the SHNPP FSAR Fire Hazard Analysis, Section 9.5A.3, pages 9.5A-28 and 30. Additional information for this area is available in the licensee submittal NLS-80-205 dated 3une 12, 1980.
CONCLUSION CPRL believes that this deviation is justified for the following reasons:
l.
2.
3.
The equipment is separated by a distance of approximately 21 feet.
Detection is provided in the zone where the boxes are located.
Partial suppr ession is provided in the fire zone over pull box B1551-SA.
Intervening combustibles are fire resistant IEEE-383 cables.
Based on the fire prevention features provided, CPRL concludes that further consideration of three-hour rated enclosures for the equipment would not greatly enhance fire protection in the zones and provides an acceptable deviation to NUREG-0800, Section C.5.b(2).
(3294PPC/crs)
DEVIATIONE
SUMMARY
A deviation is requested from BTP 9.5-1, Section C.5.b(2) of NUREG-0800 from having to consider intervening combustibles between the following equipment:
- 1) instrument rack Al-R29 and its related cable (11958C) and AFW pump lA-SA and its related cable (11921A) and 2) instrument rack Al-R29 (cable 11958C) and its alternate (cable 12092A).
AREA DESCRIPTION Plant Location: Reactor Auxiliary Building Elevation 236'ire Area:
1-A-BAL SSA Area: FAABL3 Fire Zone:
1-A-3-PB Other Safe Shutdown E ui ment in the SSA Area:
l.
Air Handler AH-29 2.
Motor Control Centers 1822 and lA22 3.
SW Booster Pumps 0.
Air Handler AH-9 5.
Air Handler AH-6 (local) 6.
Air Handler AH-7 (local) 7.
RHR Heat Exchangers 8.
CCW Heat Exchangers 9.
CCW Pumps 10.
CVCS Charging Pumps 1 l.
Air Handler AH-10 12.
Air Handler AH-1 1 (local) 13.
Auxiliary Feedwater Pumps DISCUSSION l.
Instrument rack Al-R29 (cable 11958C[SB]) is physically separated from AFW pump lA-SA by approximately 21 feet of distance.
Power cable 11921A(SA) to the AFW pump is routed in embedded conduit except at the pump where exposed conduit is routed into the termination box for the motor. This termination point is in excess of the 21 feet of separation.
2.
Instrument rack Al-R29 (cable 11958C[SB]) provides the suction pressure for the Safe Shutdown Division II Auxiliary Feedwater Pump.
This is the alternate indication provided for the condensate storage tank level (cable 12092A[SA]) which is assigned to Safe Shutdown Division I. These cables are separated by approximately 50 feet of distance.
Intervening combustibles are present between these components in the form of IEEE-383 cables.
This location is provided with an automatic suppression system actuated by thermal detection.
Ionization detectors are also provided in this location for fire detection.
This zone has low combustible loading as described in the SHNPP Fire Hazard Analysis, Section 9.5A.3, page 9.5A-29. Additional information for this area is available in licensee submittal NLS-80-205 dated 3une 12, 1980.
(3294PPC/crs
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CONCLUSION CPRL believes that this deviation is justified for the following reasons:
5.
Low combustible loading in the areas.
Suppression and detection systems are provided in the areas.
Instrument rack Al-R29 and cable 11958C(SB) are physically separated from AFW pump P lA-SA by approximately 21 feet.
Intervening combustibles are fire resistant IEEE-383 cables.
The power cable, 11921A(SA), for the AFW pump is routed in embedded conduit.
Based on the fire prevention features provided, CPRL concludes that further consideration of intervening combustibles would not greatly enhance fire protection in this zone and provides an acceptable deviation to NUREG-0800, Section C.5.b(2).
(3294PPC/cr s )
DEVIATIONF
SUMMARY
A deviation is requested from BTP 9.5-1, Section C.5.b(2) of NUREG-0800 from having to provide a three-hour rated enclosure for cable 10137B in fire area 1-A-SWGRA (FAASGA).
AREA DESCRIPTION Plant Location: Reactor Auxiliary Building Elevation 286'ire Area: I-A-SNGRA SSA Area: FAASGA Other Safe Shutdown E ui ment within the SSA Area:
l.
Battery Charger lA-SA 2.
Battery Charger 1B-SA 3.
Distribution Panel lA-SA 125V DC R Distribution Panel lA 125V DC 5.
ESS Sequence Panel lA-SA 6.
Transfer Panel A 7.
6.9kV Emergency Switchgear lA-SA 8.
080V Emergency Switchgear 1 A2-SA 9.
080V Emergency Switchgear 1A3-SA 10.
Cable for Safe Shutdown Systems Listed in the SSA, Table 9.5B-Of DISCUSSION The cable is routed in dedicated conduit within the fire area.
The cable provides control to the reactor coolant vent valve 2RC-V280 SA which is required to prevent a high pressure reactor coolant leak.
The cable is not required to function during or after the fire. The valve can spuriously open only if a stray voltage (hot shorts) from another power source penetrates the conduit and makes direct contact with the cable leads of 10137B.
The area is protected by early warning ionization detectors and the combustible loading in the fire area is considered low as described in the FSAR Fire Hazard Analysis, Section 9.5A.8, page 80. Additional information for this area is available in licensee submittal NLS-80-205 dated 3une 12, 1980.
CONCLUSION CPRL believes that this deviation is justified for the following reasons:
l.
2.
3.
Combustible loading is low in the area.
The cable is routed in a dedicated conduit.
Detection system is available in the area.
The dedicated conduit provides adequate protection from external hot shorts.
Based on the fire prevention features provided, CPkL concludes that a commensurate level of protection has been provided in lieu of a three-hour enclosure as described in NUREG-0800, Section C.5.b(2).
(3294PPC/crs)
DEVIATIONG
SUMMARY
A deviation is requested from BTP 9.5-1, Section C.5.b(2) of NUREG-0800 from having to provide a three-hour rated enclosure of emergency service water motor operated valve 3SW-B15 SA in the Unit 2 tank building. The only SSA equipment in the area is two emergency service water valves 3SW-B15 SA and 3SW-B16 SB.
AREA DESCRIPTION Plant Location: Reactor Auxiliary Building Unit 2 Tank Area Elevation 236'ther Safe Shutdown E ui ment Within the SSA Area:
No other SSA equipment.
DISCUSSION One of the above mentioned valves is required to open in order to discharge service water from the ESW pumps.
The valves are located approximately 10 feet apart and approximately 10 feet above the floor slab.
This area was previously designated for Unit 2 equipment which has since been deleted, therefore, the only intervening combustible is the lubrication oil located inside the motor operators.
The conduits containing the cables supplying 3SW-B15 SA willbe protected within a three-hour rated enclosure.
Ionization detectors willbe installed over the valves to provide early warning detection.
CONCLUSION CPRL believes that this deviation is justified for the following reasons:
2.
3.
The only intervening combustible is the lubricating oil located inside the motor op'erators.
The conduit enclosing cables to valve 3SW-B15SA willbe protected by a three-hour wrap.
Detection above each valve willbe provided.
The valves are located high above the floor and approximately 10 feet of horizontal separation.
Based on the fire prevention features provided, CPRL concludes that the addition of a three-hour enclosure around 3SW-B15 SA would not greatly enhance the fire protection in this area and provides an acceptable deviation to NUREG-0800, Section C.5.b(2).
(3294PPC/crs)
l) Clarification to previously granted deviation requests
- 2) Clarification to CPRL's response to Question Ol0.05 (3294PPC/crs
)
Clarification to Previously Granted Deviation Requests CPRL would like to assure that clarification is obtained for previously approved deviations.
In applicant's letter dated February 20, 1980, a deviation was requested from BTP 9.5-1, Section C.5.b(2) of NUREG-0800 from having to provide 20 feet of horizontal separation with no intervening combustibles in fire area 1-A-BAL. This deviation was approved in the Safety Evaluation Report Supplement No. 2, Section 9.5.1(3), Page 9-6.
CPRL would like to clarify that the required power and control cables are also included in the definition of equipment.
CPRL has assumed that the required control and power cables for the "equipment" meet or exceed the following:
a) the separation distances provided for the equipment; b) the automatic suppression and detection systems provided for the equipment provide the same level of protection for the cables; c) the fire breaks provided in the cable trays (intervening combustible) provide the same level of protection for the equipment and required cables.
The February 20, 1980 submittal accurately describes the conditions for both the equipment and their required cables.
This clarification was discussed with your staff during a 3anuary 30, 1986 telecon.
(3294PPC/crs)
Clarification of CPRL Response to Question 010.05 dated April5, 1985 On April 5, 1985, CPRL provided our response to Question 010.05.
The question requested that CPRL demonstrate how the Shearon Harris plant meets BTP 9.5-1 Section C.5.b and C.5.c for the fire areas using alternative or dedicated shutdown.
Our response stated that for the areas using alternative and dedicated shutdown, a deviation would be submitted for not providing fixed suppression in the rooms under consideration per 10CFR50, Appendix R, Section III.G.3.
The fire protection licensing criteria for the Shearon Harris Plant is BTP 9.5-1 of NUREG-0800 and not 10CFR50, Appendix R.
BTP 9.5-1, Section C.5.c does not require the installation of a fixed suppression system.
Therefore, CPRL is withdrawing our commitment and willnot be submitting deviation requests for a fixed suppression system for the areas using alternative or dedicated shutdown.
The above approach was discussed with your staff and concurred with during a conference call held on 3anuary 16, 1986.
(3294PPC/crs)
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