ML18139C170
| ML18139C170 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 12/10/1982 |
| From: | Varga S Office of Nuclear Reactor Regulation |
| To: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| References | |
| NUDOCS 8212220481 | |
| Download: ML18139C170 (7) | |
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. '.~n*1pIBUTION Doc et File NRC PDR Local PDR ORB 1 File D. Eisenhut OELD DEC 1 0 "1982 Docket Nos. 50-280 and 50-281 Mr. t1. L. Stewart Vice President - Nuclear Operations Virginia Electric and Power Company Post Office Box 26666 Richmond, Virginia 23261
Dear Mr. Stewart:
E. L. Jordan D. Neighbors C. Parrish R. Ferguson NSIC J. M. Taylor ACRS (10)
J. Heltemes T. Wambach
SUBJECT:
DRAFT SER ON APPENDIX R EXEMPTION REQUEST lAJe have completed our review of your Appendix R exemption requests and have enclosed our draft SE~.
We request that you review this draft SER for accuracy of technical content and inform us within three weeks of any corrections you consider necessary.
~Jith respect to followup action regarding exemption denials, there are three options:
(1) appeal denials to NRR management; {2) propose another alternative that requires an exemption; or {3) make modifications to meet the specific requirements of Appendix R.
Please inform us within three week regarding which action you plan to take.
If an appeal meeting is requested, it should be limited to the technical review of the information on the record and should be held within six weeks.
If, for denied exemptions, you choose to propose an alternative which also requires an exemption, it should be filed under the provisions of Section 50.12 of 10 CFR Part 50.
If you choose to propose such an alternative we request that you do so within 60 days.
If, for denied exemptions, you propose to make modifications which meet the specific requirements, of Section III.G of Appendix R, no additional submittal is necessary, unless the modifications are to provide alternative shutdown capability.
In these cases, you will be given 6 months to provide the description of the modifications for alternative shutdown capability.
If you have any questions regarding this letter or the draft SER~ please contact your Project Manager.
Sincerely,
~:riginal signed by:'
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8212220481 821210 PDR ADOCK 05000280 F
PDR Steven A. Varga, Chief Operating Reactors Branch No. l Division of Licensing
Enclosure:
SEE PREVIOUS NRC Form 318 for Concurrences*
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OFFICE. "'C'(:'"Wf~i1t!'tt):S JY'tr~~:i~lil:>' /'f~~~a~;aclY- *ms........................................................................
DATE*......................**.....J.2/.~./.82.........12./.l./.B2......
NRC FORM 318 (10-80) NRCM 0240 0 FF IC IA L R l!!C OR D CO PY USGf'O; 1981-335-960 I
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e Docket Nos. 50-280 and 50-281 Mr. ltJ". L. Stewart Vice President - Nuclear Operations Virginia Electric and Power Company Post Office Box 26666 Richmond, Virginia 23261
Dear Mr. Stewart:
SUBJECT:
DRAFT SER ON APPENDIX R EXEMPTION REQUEST DIST.UITON Docket File NRC PDR Local PDR ORB 1 File D. Eisenhut OELD E. L. Jordan D. Neighbors C. Parrish R. Ferguson NSIC J. M. Taylor ACRS (10)
J. Heltemes T. Wambach We have completed our review of your Appendix R exemption requests and have enclosed our draft SER.
We request that you review this draft SER.for accuracy of technical content and inform us-within three weeks of any corrections you consider necessary.
With respect to followup action regarding exemption denials, there are three options:
(1) appeal denials to NRR management; (2) propose another alternative that requires an*exemption; or (3) make modifications to meet the specific requirements of Appendix R.
Please inform us within three week regarding which action you plan to take.
If an appeal meeting is requested, it should be limited to the technical review of the information on the record and should be held within six weeks.
If, for denied exemptions, you choose to propose an alternative which also requires an exemption, it should be filed under the provisions of Section 50.12 of 10 CFR Part 50.
If you choose to propose an alternative we request that you notify us within 60 days.
If, for denied exemptio*ns, you propose to make modifications which meet the specific requirements, of Section III.G of Appendix R, no additional submittal is necessary, unless the modifications are to provide alternative shutdown capability.
In these cases, you wi11 be given 6 months to provide the description of the modifications for alternative shutdown capabiiity.
If you have any questions regarding this letter or the draft SER, please contact your Project Manager.*
Enclosure:
Draft SER o~~
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See next pa e 12/"1 /82 DATE
- NRC FORM 318 (10-80) NRCM 0240 Sincerely, Steven A. Varga, Chief Operating Reactors Branch No. 1
- oivision of Licensing
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OFFICIAL RECORD COPY USGPO: 1981-335-960
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Mr. W. L. Stewart Virginia Electric and Power Company cc:
Mr. Michael W. Maupin Hunton and Williams Post Office Box 1535 Richmond, Virginia 23213 Mr. J. L. Wilson, Manager P. O. Box 315 Surry, Virginia 23883 Donald J. Burke, Resident Inspector Surry Power Station U.S. Nuclear Regulatory Commission Post Office Box 166 Route l Surry, Virginia 23883 Mr. J. H. Ferguson Executive Vice President - Power Virginia Electric and Power Company Post Office Box 26666 Richmond, Virginia 23261 James P. O'Reilly Regional Administrator - Region II U. S. Nuclear Regulatory Commission 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303
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I Chemical Engineering Branch/Fire Protection Section 1.0 Introduction
- Exemption Request Surry Power Station Unit Nos. 1 and 2 Docket No. 50-280/281 By letter dated July 23, 1982, the licensee requested exemptions from Section III.G of Appendix R in the control room and Unit 1 and 2 emergency switchgear rooms to the extent that it requires a fixed suppression system be installed in addition to the alternative shut-down capability that has been P.rovided.
2.0 Control Room 2.1 Exemption Requested The licensee requested an exemption from Section III.G, "Fire Protection of Safe Shutdown Capability" of Appendix R to 10 CFR Part 50 to the extent
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that it requires the installation of a fixed suppression system in the control room.
2.1 Discussion The control room has a fire detection system, hose station, and fire extinguishers.
An alternate safe shutdown system is also available for the c~ntrol room.,The room is continuously manned and the fire
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- 2. 2 EVALUATION Because the fire hazard is light, and the control room is continuously manned, there is reasonable assurance that a fire would be promptly exti ngufshed.
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2 Conclusion Based on our evaluation, we conclude that the installation Df a fixed fire suppression system will not significantly increase the level of fire protection in the control room, and therefore, the exemption should be granted.
3.0 Units 1 and 2 Emergency Switchgear Rooms 3.1 Exemption Requested The licensee requests an exemp~ion from Section III.G of Appendix R to the extent that it requires a fixed suppression system be installed in addition to the alternative shutdown capability that has been provided.
3.2 Discussion Separate areas located below the control room and the machine shop are provided for each unit 1s emergency switchgear and control relays.
There are two emergency switchgear rooms in each area, one for. each division, and a single relay room.
Each.room has approximately 2500 square feet of floor space.
The rooms within each area adjoin.each, other in an 11 L11 shaped configuration with open passageways-between them.
There is also an open passageway with a three hour fire-rated sliding door between the Unit 1 and Unit 2 areas.
The sliding fire door is held _open by a fusible link.
The emergency switchgear and relay room areas for' each unit are bounded on all sides by concrete which provides a three-hour fire
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barrier. The individual rooms within each area are also separated by three-hour rated concrete walls.
As noted aboye, these walls are.
penetrated by open passageways.
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3 The emergency switchgear and relay rooms contain safety-related switch-gear-and control relays, including redundant equipment required for.safe.
shutdown, and the remote shutdown control panels for each unit.
Large quantities of safety-related power and control cables are routed above the switchgear cubicles and relay boards throughout the area and in the open passageways between rooms.
The emergency 125-volt de batteries are also located in the area in separate rooms within their associated division switchgear rooms.
An alternate safe shutdown system is available for each unit's emergency switchgear room.
The combustible materials in t~e area consist of a large amount of electrical cable insulation and parts of electrical components in the switchgear cubicles and relay boards.
There is also a potential for a small amount of transient lubricating oil to be transported via the Unit" 2 switchgear rooms to mechanical equipment room No. 3.
t{~'le cable insulation comprises a fuel load of 2.66 x 105 BTU/sq. ft.
which if totally consumed would correspond to a fire severity of about two hours on the ASTM E-119 standard time temperature curve.
Fire protection in each emergency switchgear room consists of smoke detectors, standpipe hose ~tations and portable fire extinguishers.
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The licensee justifies the exemption on the basis of (1) standpipe hose stations have been provided and (2) the installation of an automatic ~uppression ~ystem in the area would not enhance fire protection safety.
- 3. 3 Evaluation In areas where alternative shutdown capability is req*uired,Section III.G.3 ~lso requires the installation of a fixed suppression system if t~e area contains a large concentration of cables or other combus-tibles. The emergency switchgear rooms have' alternative shutdown capability, but do not have a fixed suppression system.
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4 The licensee has not provided a technical basis to justify the exclusion of a fixed suppression system in the area with the large-amount of in-situ combustibles and to support his conclusion that a fixed suppres~ion system would not enhance fire protection safety. The proposed altern-ative has not been shown to be equivalent to the technical requirements of Section III.G of Appendix R.
3.4 Conclusion The licensee has not provided justification that the level of protection afforded by the existing fire P.rotection measures in the emergency switchgear rooms are equivalent to the technical requirements of Appendix R.
Therefore, the licensee's request for exemption should be denied.
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