ML18029A456
| ML18029A456 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 04/02/1985 |
| From: | Domer J TENNESSEE VALLEY AUTHORITY |
| To: | Vassallo D Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8504090023 | |
| Download: ML18029A456 (17) | |
Text
~'EGULATORY 1, ORMATION DISTRIBUTION SYS' (RIDS)
ACCESSION NBR;8504090023-DOC ~ DATE: 85/04/02 NOTARIZED:
YES DOCKET FACIL;50-259 Browns Ferry Nuclear Power Stations Unit 1< Tennessee 05000259 50 260 Browns Ferry Nuclear Power Stationi Unit 2i Tennessee 05000260 50-296 Browns Ferry Nuclear Power Stations Unit 3>
Tennessee 05000296 AUTH BYNAME AUTHOR AFFILIATION DOMER J,A Tennessee Valley Authority REC IP ~ NAME RECIPIENT AFFILIATION VASSALLOgDtB~
Operating Reactors Branch 2
SUBJECT; Forwards request for exemption from requirements of Section III~ G ~ 2 of App R to 10CFR50
~ Addi info re util 841031 request for exemption also encl'eview of encl. request in conJunction w/841031 submittal'equeste iper 10CFR50 F
1'ISTRIBUTION CODE+
A006D COPIES RECEIVED;LTR ENCL SIZE:
TITLE!
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TENNESSEE VALLEYAUTHORITY CHATTANOOGA. TENNESSEE 37401 400 Chestnut Street Tower II April 2, 1985 Director of Nuclear Reactor Regulation Attention:
Mr. Domenic B. Vassallo, Chief Operating Reactor Branch No.
2 Division of Licensing U.S. Nuclear Regulatory Commission Nashington, D.C.
20555
Dear Mr. Vassallo:
In the Matter of the Tennessee Valley Authority Docket Nos. 50-259 50-260 50-296 As a result of discussions with members of your staff regarding Br owns Ferry Nuclear Plant Appendix R late last year, we were requested to provide supplemental information in support of our proposed schedular exemption to Appendix R to 10 CFR 50.
Enclosure 1 provides the results of our review of compensatory measures to be implemented in support of the schedular exemption.
These proposed measures are based upon approval of our October 31, 1984 Appendix R submittal.
Me request your staff review this information expeditiously and approve our schedule exemption.
Enclosure 2 to this letter is an additional exemption request from the requirements of section III.G.2 of Appendix R to 10 CFR 50.
In accordance with the requirements of 10 CFR Part 50.12 we request you review this exemption request in conjunction with our October 31, 1984 Appendix R submittal.
If you have any questions, please get in touch with us through the Browns Ferry Project Manager.
Very truly yours, Subscribed,arri sworn to efore me ia o,~~
+day of I
otar y Public My Commission Expires TENNESSE VALLEY AUTHORITY J.
A. Domer Nuclear Engineer 1985.
Enclosur es cc:
See page 2
8504090023 850402 PDR maCZ 05000259 F
PDR An Equal Opportunity Emp1oyer
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Director of Nuclear Reactor Regulation April 1, 1985 cc (Enclosures):
U.S. Nuclear Regulatory Commission Region IX ATTN:
Dr. J. Nelson Grace, Regional Administrator 101 Marietta Street, NN, Suite 2900 Atlanta, Georgia 30323 Mr. R. J. Clark Browns Ferry Project Manager U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue
- Bethesda, Maryland 20814
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ENCLOSURE 1
BROWNS FERRY NUCLEAR PLANT PROPOSED APPENDIX R COMPENSATORY MEASURES I.
General A roving fire watch will be posted for the list zones which do not meet the requirements of 10 CFR 50 Appendix R and (1) do not have an exemption request filed for the fire zone or (2) do not have automatic detection and suppression.
The fire watches will begin in unit 2 immediately following the cycle 5 outage for the zones listed in Table A and in units 1 and 3
immediately following the cycle 6 outage for the zones listed in Tables B 4 C respectively.
The fire watches will remain until the modifications for that zone are complete or until the unit is in a cold shutdown condition.
For zones common to all units, all units are required to be in a cold shutdown condi tion.
The fire watch will be posted so these zones containing cables, equipment, or associated circuits requiring modification to meet Section III.G.2 of Appendix R will be checked by the fire watch approximately every 20 minutes unless the zone is provided with automatic detection and suppression.
Details concerning each fire zone are provided below.
II.
Fire Watches A.
Control Building Fire Area The Control Building is designated as a single fire area for the purpose of conducting the Appendix R analysis.
- However, for these compensatory
- measures, the building is subdivided into numerous fire zones by nonfire-rated walls, floors, and ceilings.
Two fire zones within the Control Building contain required cables which do not comply with the separation requirements of Appendix R.
Some cables are located in the Control Room which does not have any automatic suppression or detection.
No additional fire watches will be posted in the Control Rooms because they are continually manned according to 10 CFR 55, and the continually manned control room personnel will be considered the fire watch.
The other cables are located in the Spreading Room which is provided with automatic suppression and detection, and no fire watch will be provided.
B.
Reactor Building Fire Area Although the Reactor Building is designated as one fire area for the purposes of conducting the Appendix R analysis, the building is subdivided into several elevations and rooms (fire zones) by nonfire-rated floors, walls, and ceilings.
The fire zones within the Reactor Building which contain required cables and equipment which are not separated in accordance with the requirements of Appendix R are located on elevations 639, 621, 593, 565, and the RHR corner rooms on elevations 541 and 519, and the torus area on elevation 519.
Elevations 593, 565, and the RHR corner rooms on elevation 541 and 519 have or will have fixed automatic suppression and detection.
A fire watch on approximately 20-minute rounds will be posted on elevations 639 and 621 in accordance with Section I.
A fire watch will not be posted in the torus area on elevation 5'19 since an exemption request has been submitted for the tor us area on elevation 519.
C.
Shutdown Board Rooms A, B, C,
D, E,
and F
Each Shutdown Board Room is designated a separate fire area for the purposes of conducting the Appendix R analysis.
A r oving fire watch on approximately 20-minute rounds will be posted in Shutdown Board Rooms A, B, C,
D, E,
and F in accordance with Section I.
D.
Diesel Generator Building (units 1 and 2) and Diesel Generator Building (unit 3)
Each Diesel Generator Building is designated a separate fire area for the purposes of conducting the Appendix R analysis.
A fire in either one of the Diesel Generator Buildings will not impair the capability of providing onsite power necessary to reach safe shutdown.
Power will be provided by the units 1 and 2 diesel generators for a Unit 3 Diesel Generator Building fire, and power will be provided by the unit 3 diesel generators for a Units 1 and 2 Diesel Generator Building fire.
Therefore, a fire watch will not be posted in the Diesel Generator Buildings.
E.
Turbine Building, Intake Pumping Station, and Interconnecting Cable Tunnel The Turbine Building, Intake Pumping Station, and the inter connecting cable tunnel are designated as one fire area for the purposes of conducting the Appendix R analysis.
- However, each of these areas is considered a separate fire zone.
A roving fire watch on approximately 20-minute rounds will be posted in the Intake Pumping Station (elevation 550) in accordance with Section I.
There are no required cables or equipment which require modification to comply with the separation requirements of Appendix R in the cable tunnel between the Intake Pumping Station and the Turbine Building.
Therefore, no fire watch will be posted for this fire zone.
One train of cabling for a required safe shutdown system is located in the cable tunnel interconnecting the Turbine Building and the Intake Pumping Station.
The redundant train and associated circuits which could affect the redundant train are embedded in the floor elevation 565 of the Turbine Building."-
The embedded conduits have some pull boxes that open into the pipe tunnel below the Turbine Building.
There are some openings from
the pipe tunnel into the Turbine Building which would not meet the requirements of Section III.G.2 of Appendix R.
Because TVA has not met the literal definition of Section III.G.2, an exemption is being r equested (attached).
Therefore, no fire watch will be stationed in the Turbine Building.
III. Radiological Impacts of the Proposed Action Mith the provision of the specified interim compensatory
- measures, the degree of fire protection provided will be such that there is no significant increase in the risk of fires at Browns Ferry Nuclear Plant.
Consequently, the probability of fires has not been increased and the post-fire radiological releases will not be greater than previously determined, nor does the proposed exemption otherwise affect radiological plant effluents.
Therefore, there should be no significant radiological impact associated with the proposed exemp'tion.
TABLE A
/,'Approx.)
Fire Match Frequency Automati c Detection and Suppression Provided in the z
Reactor Building Unit; 2 Elevation 639 Elevation 621.25 Elevation 593 Elevation 565 20 minutes 20 minutes None None No Yes Yes RHR Corner Rooms (Elevations 541 4 519)
None Yes Intake Pumping Station - Common (Excluding the cable tunnel to the Turbine Building)
Elevation 550 20 minutes Partial Control Building Unit 2 Elevation 606 (Units 1
4 2 cable spreading room)
Elevations 593 (Unit 2 Battery Board Room complex)
None None Yes Yes Shutdown Board Rooms C and D
(Elevation 621.25)
(Elevation 593.0)
Same 20 minutes No
TABLE B Z
e (Approx.)
Fire Match Frequency Automati c Detection and Suppression Provided in the Z
Reactor Building Unit 1
Elevation 639 Elevation 621.25 20 minutes 20 minutes No No Elevation 593 Elevation 565 None None Yes Yes RHR Corner Rooms (Elevations 541 4 549)
None Yes Control Building Unit 1
Elevation 606 (Units 1
h 2 cable spreading room)
Elevations 593 (Unit 1 Battery Board Room complex)
None None Yes Yes Shutdown Board Rooms A and B
(Elevation 621.25)
(Elevation 593.0)
Same 20 minutes No
TABLE C Reactor Building Unit 3 Elevation 639 Elevation 621.25.
Elevation 593 Elevation 565 (Approx.)
Fire Match Frequency 20 minutes 20 minutes None None Automati c Detection and Suppression Provided in the e
No No Yes Yes RHR Cor ner Rooms (Elevations 541 5 519)
None Yes Control Building Unit 3 Elevation 606 (Units 3 cable spreading room)
Elevation 593 (Unit 3 Battery Board Room complex None None Yes Yes Shutdown Board Rooms E and F
(Elevation 621.25)
(Elevation 593.0)
Same 20 minutes No
08 I,
ENCLOSURE 2 BHOMNS FERRY NUCLEAR PLANT APPENDIX R EXEMPTION REQUEST EXCEPTION-Section III.G.2 requires that redundant safe shutdown circuits be separated by 3-hour fire rated barriers or by more than 20 feet of horizontal space and fire detection and automatic suppression installed in the area.
Contrary to this requirement safe shutdown circuits located in the cable tunnel between the Turbine Building and the Intake Pumping Station are not separated from the redundant circuits located in the pipe tunnel in literal compliance with Section III.G.2.
JUSTIFICATION -
One division of redundant safe shutdown circuits for the EEL and HHRSH systems are routed in embedded conduit through the Turbine Building until they enter the cable tray tunnel located under elevation 565 of the Turbine Building.
The circuits ar e routed in cable trays from there to the Intake. Pumping Station.
The redundant division of EECM and HHHSH circuits are routed in embedded conduits in the ceiling of the pipe chase to the Intake Pumping Station.
There are two recessed cable pull areas
,in the pipe chase at column lines T8 and T15 which have a
metal cover plate over the opening.
The access to the cable pull areas is from inside the pipe chase.
The cable tray tunnel and pipe chase are of reinforced concrete construction equivalent to 3-hour fire rated barriers.
Access to the cable tray tunnel from the Turbine Building is by an opening from elevation 565 near column lines T12/K.
The opening is at elevation 572.5'.
Accesses to the pipe chase are from the Backwash Receiving Rooms T-1 and T-3 located on elevation 533 of the Turbine Building near column lines T6/h and T12/g, respectively.
The Turbine Building is not provided with area-wide fire detectors and automatic suppression systems; however, it is TVA's position that adequate separation is provided for the EEOC and RHRSH circuits.
This is based on the long, circuitous path between the redundant circuits.
The shortest path between the redundant circuits is approximately 380 feet horizontally and 32 feet verti-cally, which also includes the elevation 565 floor slab.
Therefore, TVA requests an exemption to the literal compliance to the separation requirements for the redundant safe shutdown circuits located in the cable tray tunnel and pipe chase in the Turbine Building.
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