ML19353B074
| ML19353B074 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 12/06/1989 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML19353B073 | List: |
| References | |
| TAC-65508, TAC-65509, NUDOCS 8912110146 | |
| Download: ML19353B074 (7) | |
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,k UNITED STATES i
g NUCLEAR REGULATORY COMMISSION
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CASHING TON. D. C. 20665
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_ CLARIFICATION AND REVISION OF SAFETY EVALUATION BRURSWICr. STEAM ELECTRIC PLANT, Uf'ITS 1 AND E CAROLINA POWER & LIGHT COMPANY DOCKET h05. 50-325 AND 5C-324
_(TAC NOS. 65508 A2 65509)
Ey letter dated December 30, 1986 the staff issued its Safety Evaluation (SE) and approved exemptions from certain technical requirements contained in Section III.G. and III.J of Appendix R to 10 CFR Part 50.
The licensee reviewed the SE and by letter dated May 19, 1907 identified several instances where revisions were reevired to (1 correct specific errors, (2) clarify potentially confusing language, or 3) more accurately state actuc1 conditions.
The items are listed the saroe way they appecr in the licensee's letter.
Page references in parentheses are to pages in the NRC SE issted Decenbtr 30, 1986.
- l. Section 2,0 pALUATION
.1 Alternate Shutdown Cipability, Appendix R to IC CFR Port 50 (page 3)
The licensee indiceted that the reactor Luilding and service water building should be included in the areas requiring alternative shutdown capetility. The staff considers that no change in the SE is required.
All the areas for which the licensee has requested exernptions frcir III.G.2 based on n.etting III.L are included.
2.
Section E.1.1 Systerr.s Used For Post-Fire Safe Shutdown Systems Required For Scie Shutdown (page 4)
Change the second sentence in the first paragraph (added worcs and phrases are underlined) to read, " Reactor coolant inventory and pressure control can be maintained during hot shutdown by the use of si.fety relief valves and reactor core isolation cooling (RCIC) for a fire in the control room or a fire requirino Train 8 safe shutdown or the high pressure coolant injection (HPCI) system for a fire recuiring Train A safe shutdown or a fire not involving the control room.
The residual heat ren. oval (RhE) system will be used in the low pressure core injection (LPCI) mode during cold shutcown."
This change is required to show that both RCIC and HPCI may be used to achieve hot shutdown during fire conditions depending on the location of the fire.
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Section 2.1.1 Systems Used for Post-Fire Safe Shutdown Systems Required for safe Shutdown (page 4)
In the last line of the first paragraph, correct typographical errcr by changing "Section 3.3.3" to "Section 2.1.2."
4 Section 2.1.1 Systems Used For Post-Fire Safe Shutdown Areas where Alternate Safe Shutdown is Required (page 4)
The licensee indicated that the reactor building and service water building should be included in the areas requiring alternative shutdown capability and the the select nunber of fire areas referenceo against the individual buildings should be deleted. The staff considers that no change in the SE is required. All the fire areas for which the licensee has requested exemptions from III.G.2 based on meeting III.L are included.
S.
Section 2.1.1 Systems Used for Post-Fire Saf e Shutdown Areas where Alternate Safe Shutdewn is Required (page 4)
The licensee has reconnended expanding the second paragraph to describe in more detail the various alternative control stations located through out the plant. The staff has reviewed the SE paragraph and does not agree with this change.
The licensee submittal can be referred to for dettiils as necessary.
6.
Section 2.1.2 EVALUATION Performance Goal (page S)
In the first paragraph, third line, change the last word "cr" to "and/or".
The second sentence will then read "The controls of these functions can be accomplished using the alternate shutdown methods and/or the control room, depending upon the location of the fire." This change will accurately reflect actual plant design because in some instances a given function will be accomplished using only the alternate shutdown method or the control room, and in some instances both the alternate shutdowiImethod and the control room will be used to achieve safe shutdown.
7.
Section 2.1.2 EVALUATION Performance Goals (page 5)
The licensee has recont. ended replacing "RCIC and RHR alternate control station" with " remote shutdown panel" to accurately reflect plant design without ambiguity. We do not agree. The staff has used the words contained in the Brunswick alternative shutdown capability assessment report, Page 6-3 of Revision 0.
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8.
Section 2.1.2 EVALUATION Conanon Enclosure (page 6)
In lir.e six, change the wora " seals" to " barriers". The second sentence will then read, "Additicnally, these cables will be physically protected by erpropriate ftre protection measures (e.g., cable insulation, conduits and rated tire barriers)." This change is required to correct the wrong usage of the term
- fire seal". A rated fire seal will prevent fire spread between two separate fire areas but will not protect cables passing through it, since they will be damageo on the fire side of tie barrier containing the fire seal, hcwever, cables protected by rated fire barriers (such as a wrap or wall) will remain intact ano functional for the full fire rating of the barrier.
9.
Section 2.1.2 EVALUATION SpuriousSjgnals(page6)
Paragraph I does nct i.ccount for exemptions to Section 'III.G.2 of Appendix R to 10 CFR Part 50 that have been approved by the statf.
It should be revised as follows.
"1.
Devices which would af tect proper safe shutdown system operation.
These devices have been included in the list of required equipment and will be separated or protected in accordance with Section llI.G.2 of Appendix R, or as provideo for in exemptions grantea from the technical provisions of Section III.G.2 of Appendix R per the licensee's requests Nos. 7.2.1 through 7.2.7."
- 10. Section 2.1.2 EVALUATION SpuriousSignals(page6)
Paragraph 2.b indicates replacing " single-pole breakers with new two-pole breakers." The licensee indicated that this original proposal for the isolation of power supplies for the t:SIVs cannot be carried out as the existing power distribution panel is not constructed to permit the installation of two-pole circuit breakers without extensive modifications.
The licensee plans to ado qualified isolation switches to prevent spurious operation of the MSIVs by opening both the line and neutral of the existing MSIV power supply.
The staff considers that the installation cf such qualified isolation switches to interrupt both line and neutral of the existing power supply is acceptable.
The first sentence of this paragraph should be changed to reaa, " Isolation switches will be providea to isolate the ac power supply for the 11SIVs."
4 11.
Section 2.1.2 EVALUATION Spurious Signals (page 6)
In paragraph 2c, line 3, af ter the words " circuit breakers" add "and/or isolation switches This change is consistent with isolation of the KSIVs as discussed in item 10.
12.
Section 2.3.1 Reactor Building Units 1 and 2 DISCUSSION (page10)
Change the word " rooms" to " tunnels" in the first sentence of the second paragraph.
The sentence will then read, "These fire areas consist of the Unit I and Unit 2 Reactor Buildings except for the Emergency Core Ccoling System (ECCS) tunnels." The terminology " room" was inadvertently used by the licensee in Section 7 of the Alternate Shutdown Capability (ASCA) report.
The word "tunhels" is properly used in Section 2 of the report.
This change is recessary to reflect terminology in the staff's Saf ety Evaluation that is consistent with the licensee's teminology,
- 13. Section 2.3.1 Reactor Building Units 1 and 2 DISCUSSION (page 10)
Change the sixth paragraph to read, "Open stairways and open pipe chases extend from the 17 foot elevation to the refueling deck on the 117 foot elevation. An open refueling hatchway extends from the 20 foot elevation to the 117 foot elevation." This change is necessary to reflect actual plant design.
- 14. Section 2.3.1 Reactor Building Units 1 and 2 DISCUSSION (page11)
The numbering sequence for licensee proposed corrective modifications listed in the last paragraph under the Discussion section shows as (1),
(2) and (4).
Therefore it is this minor typographical error.necessary to change (4) to (3) to correct
- 15. Section 2.3.1 Reactor Building Units 1 and 2 DISCUSSION (page 11)
Revise the end of the last paragraph to show that existing deep beams serve as draft stops in most locations.
The sentence with this revision and the correction of No.14 above will then read "and (3) install closely spaced closed sprinklers and draft stops (where deep beams ao not exist) across each separation zone to serve as water curtains."
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Section 2.3.2 Emergency Core Cooling System Rooms Discussion (page12)
Two typographical errors occurred in the second paragraph.
In the first line change " fire" to "five," and in the fifth line change "be" to "the." 7nese two sentences will then read, *With the exception of five pipe penetrations...," and "The penetrations in the west wall of each room are to the drywell...."
- 17. Section 2.3.3 Diesel Generator Building Basement EVALUATION (page15)
The fourth paragraph clearly characterizes the Halon system as being second echelon protection with primary protection being provided by the fire brigade.
This is not the case.
The system is primary protection.
It is designed to provide prompt suppression of incipient fires.
The existing third and fourth paragraphs should be replaced with the following:
"We have reascnable assurance that any fire in this area would be detected in its incipient stage by the area-wide ionization-type fire detection system, and promptly extinguished by the automatic halon suppressiun system.
Further assurance of prompt fire suppression is provided by the area-wide automatic sprinkler system which provides back-up to the halon suppression system.
In addition, the fire brigade will have been dispatched to the area and be available for manual fire fighting activities if required."
18.
Section 2.3.8 Control Building Extended DISCUSSION (page 20)
A typographical error occurred in the first sentence where reference was made to "A)pendix R" rather than " Appendix A" of BTP APCSB 9.5.1.
The sentence siould be corrected to read.
"Section 0.1.(c) of Appendix A to BTP APCSB 9.5-1 states that...."
- 19. Section 2.3.8 Control Building Ex tended EVALUATION (page21)
The second sentence of the secono paragraph indicates that a 3-hour fire rated barrier is maintained between the cable spreading rooms and the Control Room.
The Control Room floor construction is suitable to qualify the floor as a rated fire barrier.
However, the licensee is not maintaining the floor as a fire rated barrier due to the inability to install, inspect, and repair penetration seals.
This ir. ability results from the existing configurations of cables which preclude access to the penetra tions. The fourth paragraph of the Discussion correctly describes this situation.
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6-The second paragraph should be revised as f ollows.
"The exemption we granted from Section III.G 3 for the Control koom by letter dated Novenber 10, 1981 was based, in part, on the licensee's commitnent to separate the Control Room from adjacent areas with 3. hour fire rated barriers in accordance with our guicelines.
The licensee subsequently identified a number of penetrations in the floor /ceiltr.g assemblies separating the Unit 1 and Unit 2 cable spreading rooms from the Control Room that could not be inspected. Consequently, the licensee (1) no lon (E)ger credits this floor / ceiling assently as a fire area boundary; has redefined the Control Building Fire Area-23E to incluce the Control Room, Unit I and Unit 2 table spreading rooms, stairwells, elevator shaft, computer rooms, HVAC room, air conaltioning condenser room, and elevator nachinery room; ano (3) has provided alternative shutdown capability independent of the entire fire area." Therefore, the exempticn we granted for the Control Room is still valid.
Date: December 6, 1989
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d Mr. L. W. Eury Brunswick Steam Electric Plant Carolina Power & Light Company Units I and 2 i
cc:
f Mr. Russell B. Starkey, Jr.
Mr. H. A. Cole ProjectManager Special Deputy Attorney General Brunswick Luclear Project State of horth Carolina P. O. Box 10429 P. O. Box 629 Southport, North Carolina 28461 Raleigh, North Carolina 27602 Mr. R. E. Jones, General Counsel Mr. Robert P. Gruber Carolina Fower & Light Company Cxecutive Director P. O. Box 1551 Public Staff - NCUC Raleigh, North Carolina 27602 P. O. Box 29520 Raleigh, North Carolina 27626-0520 Hs. Frankie Rabon Board of Conunissioners P. O. Box 249 Bolivia, North Carolina 28422 Resident irspector U. S.-Nuclear Regulatory Commission Star Route 1 P. O. Box 208 Southport, North Carolina 28461 Regional Administrator, Region II U. S. Nuclear Regulatory Commission 101 Marietta Street, Suite 2900 Atlanta, Georgia 30323 Mr. Dayne H. Brown, Chief Radiation Protection Branch Division of Facility Services N. C. Departnent of Human Resources 701 borbour Drive Raleigh, North Carolina 27603-2008 Mr. J. L. Harness Plant General Manager Brunswick Steam Electric Plant P. O. Box 10429 Southport, North Carolina 28461 t
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