ML20040E682
| ML20040E682 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 01/29/1982 |
| From: | Fay C WISCONSIN ELECTRIC POWER CO. |
| To: | Clark R, Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| TAC-43600, TAC-43601, NUDOCS 8202050241 | |
| Download: ML20040E682 (8) | |
Text
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WiSCORSin Electnc m cwa 231 W. MICHIGAN, P.O. BOX 2046, MILWAUKEE, WI 53201 January 29, 1982 N
Mr. H.
R.
Denton, Director p\\
D Office of Nuclear Reactor Regulation U. S. NUCLEAR REGULATORY COMMISSION RECUfVED 9
Washington, D. C.
20555 D
pEB o gg y,0 Attention:
Mr.
R. A. Clark, Chief
- Ram D
Operating Reactors, Branch 3
//'!
Gentlemen:
g DOCKET NOS. 50-266 AND 50-301 MODIFICATION TO FIRE PROTECTION EXEMPTION REQUEST POINT BEACH NUCLEAR PLa T, UNITS 1 AND 2 In a letter to you dated March 18, 1981, Wisconsin Electric Power Company, Licensee for the Point Beach Nuclear Plant, Units 1 and 2, requested, pursuant to 10 CFR Part 50.12(a),
extension of certain of the schedule dates in Paragraph (c) of the Commission's fire protection regulations as provided in 10 CFR Part 50.48.
That letter identified the specific paragraphs and schedule dates with which Licensee requested extensions, proposed alternative dates for meeting these regulatory require-ments, and provided a discussion and basis for granting these schedule extension requests.
The March 18 letter also requested an exemption from one of the substantive requirements of Section III.H of Appendix R to 10 CFR Part 50 and also provided a basis and discussion fcr that request.
In Mr. Clark's letter dated May 4, 1981, the NRC specifically addressed this latter exemption request, which was denied, and advised that the request for schedule extensions was under review.
We inave received no further information regarding the schedule extension requests.
In a subsequent letter dated October 2, 1981, Licensee informed the NRC that the requested extension dates, which appeared to be reasonable at the time of our March 18 request, had proven to be optimistic and unachievable.
We had underestimated the magni-tude of the significant impacts of the large work force necessary to implement the many modifications required in our operating nuclear plant and the problems of coordinating the design and implementation of fire protection features with the many other tasks required to be completed by the Commission, not the least lp 8202050241 s20129 bt(
PDR ADOCK 05000329 F
Mr. H.
R.
Denton January 29, 1982 of which are the many modifications and backfits required to meet the NRC's NUREG-0737 requirements.
The October 2 letter included several revised 10 CFR Part 50.48 projected schedule dates and included a status of completion of the fire protection items at Point Beach Nuclear Plant.
In light of our inability to meet those previous extension request dates, we hereby request that our March 18 submittal, made pursuant to 10 CFR Part 50.12 (a), for extension of certain of the schedule dates in Paragraph (c) of the 10 CFR Part 50.48 fire protection modifications be hereby modified to include the revised commitment dates as discussed herein.
In particular, Licensee requests:
1.
That the date in Paragraph (c) (5) for submitting plans and schedules for meeting the provisions of (c) (2), (c) (3), and (c) (4), with respect to the i
requirements of Section III.G of Appendix R to Part 50, be extended to June 30, 1982 and, with respect to the requirements of Section III.O of Appendix R to Part 50, be extended to January 31, 1982.
A.
Reassessment of Point Beach Nuclear Plant in accordance with Section III.G.2 for the submittal of information of the type requested in Generic Letter 81-12, " Fire Protection Rule (45 FR 76602, November 19, 1980)", will require a two-step submittal.
Step 1 covers the location, evaluation, plans, and schedules regarding safety-related circuits ant equipment required for hot shut-down.
Step 2 covers the location, evaluation, plans, and schedules for associated circuits of systems required fer hot shut-down and of systems whose fire-induced spurious maloperation could affect hot shut-down.
The location and evaluation effort for Step 1 is essentially complete.
We are currently developing detailed substantive exemption requests for'certain areas, plans, and schedules for implementation of plant modifications.
We anticipate submitting this information prior to March 31, 1982.
Determination of a definition of " associated circuits", the best approach toward analyzing such circuits, and the level of detail necessary to provide an appropriate response has complicated 4
our evaluation of associated circuits.
Recent
Mr.
H.
R.
Denton January 29, 1982 NRC Staff clarification of the Staff's interpre-tation of Generic Letter 81-12 will allow our evaluation to proceed at a more rapid pace.
We expect to make our Step 2 submittal by June 30, 1982 covering associated circuits, containing descriptions of proposed modifications, and any additional detailed exemption requests which may be warranted.
B.
Our evaluation in accordance with Section III.O is completed.
Our evaluation, plans, and a descriptive diagram are contained in Enclosure 1.
We expect to implement the described modification on Unit 2 during the spring 1982 refueling outage and on Unit 1 during the fall 1982 refueling outage.
2.
That the date in Paragraph (c) (5) for submitting design descriptions of modifications needed to satisfy Section III.G.3 of Appendix R be extended to June 30, 1982.
3.
That the implementation date in Paragraph (c) (2) for the installation of modifications that do not require prior NRC approval or plant shut-down be extended to nine months after June 30, 1982 for modifications required by Section III.G.
We also request that the scope of this extension request be expanded to include certain other fire protection modifications required by Sections III.F and III.M which cannot be completed in accordance with the existing implementation schedule.
The status and expected completion dates for these modifications are included herein.
A.
Modifications necessary to comply with Section III.G.2.
The scope, plans, and schedules for these modifications cannot be finalized until June 1982.
The requested extension is to allow nine months for implementation following submittal of this information.
B.
SER Item 3.1.9, Fire Barriers.
Fire barrier pene-tration seal work was essentially complete prior to the Unit 1 fall 1981 refueling outage.
The multitude of required outage activity, supervisory personnel availability, and physical plant limita-tions dictated the exclusion of all unnecessary contract personnel during the outage.
The major fire barrier penetration seal work remaining is the auxiliary feedwater pump room west wall which is affected by masonry wall requirements and post-TMI shielding requirements.
The wall was not available
Mr. H.
R. Denton January 29, 1982 for penetration seal installation prior to the Unit 1 outage.
The contractor has returned to the plant'and the remaining work is expected to be completed by March 1, 1982.
C.
SER Item 3.1.31, Emergency Diesel Generators -
Remote Panel.
The installation of necessary equipment is essentially complete.
Electrical checkout and operating procedures have been developed.
This modification is being implemented by plant personnel because of the safety significance of the diesel generate s.
The recent extreme weather conditions have increased the potential for required diesel generator operation.
This situation has precluded removal.of a diesel generator from service for final connections and checkout of the modification.
We expect to have this modification completed by March 1, 1982.
D.
SER Item 3.1.12, Fire Detection System.
Fire detectors were installed in the Unit 1 containment during the fall 1981 refueling outage as scheduled.
Detectors will be installed in the Unit 2 containment during the spring 1982 refueling outage.
The balance of plant fire detector installation is progressing but will not be completed prior to the Unit 2 contain-ment installation.
We expect the entire system to be operational by June 1, 1982.
E.
SER Item 3.2.2, Circulating Water Pumphouse Fire Protection.
Our June 23, 1981 letter committed to installation of a fire barrier wall to provide separation of the service water pumps.
Fabrication details are being prepared.
We expect implementation of this modification to be completed by March 1, 1982.
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4.
That the implementation date in Paragraph (c) (3) for the installation of modifications that do not require NRC approval, but require plant shut-down, be l
extended to before start-up after the earliest of the specified events commencing 180 days or more I
after June 30, 1982 for modifications required by Section III.G and to before start-up after the specified events commencing 180 days or more after January 31, 1982 for modifications required-by l
Section III.O.
i I
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Mr. H.
R. Denton January 29, 1982 A.
The scope, plans, and schedules for modifications required by Section III.G cannot be finalized until June 1982.
The requested extension is necessary to allow for implementation following submittal of this information.
B.
A unit outage of significant duration is required to facilitate installation of the reactor coolant pump oil collection system.
Our earliest opportunity to implement this modification on Unit 1 will be the fall 1982 refueling outage.
The bases for the schedule extensions and additional considerations presented with the original March 18 request and our October 2 letter are applicable to this modified schedule request.
We particularly note that there are no urgent considera-tions which necessitated the immediate implementation of the Appendix R requirements.
The Commission has previously pointed out that the fire-protection neasures already implemented at the Point Beach Nuclear Plant and all other operating nuclear plants give reasonable assurance that these plants can continue to operate safely even though the final rule may require additional fire protection measures at some of the plants.
Please advise us if you have any questions regarding this request or need any additional information at this time.
Very truly yours, j
h l
/60 ',
l
/
Assistant Vice President l
C. W.
Fay Enclosure Copy to NRC Resident Inspector
1 REACTOR COOLANT PUMP LUBE OIL COLLECTION The major potential for oil leakage occurs during normal operation from unpressurized sites.
This leakage can run down the shaft, exit the shaft housing, and ignite upon contact with the hot reactor coolant pump body.
At Point-Beach Nuclear Plant, we have closed up openings in the Inung shaft housing so that-the housing provides an approximate 20-gallon capacity oil sump.
The housing has been fitted with an overflow pipe so that additional oil leakage will overflow onto the existing oil deflector cone.
The existing deflector cone will prevent oil from coming in contact with the hot reactor coolant pump body.
A leak-off tray will be added to the deflector cone with drain piping to a collecting tank.
Spilled oil will thereby be diverted and collected away from its potential ignition source.
We believe that this system will provide suitable oil collection from unpressurized leakage sites.
The oil lift pump is normally operated for a period of less than three minutes during unit start-up.
During this period the reactor coolant pump and piping are cold and containment integrity has not been established.
The allowable operating range between high and low oil level alarms in the 175-gallon oil reservoir is two inches.
A major leak in the pressurized system would rapidly decrease the level in the oil reservoir which would result in a low-level alarm.
This would necessitate immediate shut-down, repair, and cleanup before the pump could be restarted and system heatup begun.
We do not believe that this type of event would present a fire hazard because there would be no hot surfaces to collect and ignite the oil and because of the timely response from operations and maintenance personnel.
In the normally unpressurized. condition, leakage from the high pressure system would be in the form of dripping oil.
The combination of our existing and proposed oil collection system provides suitable collection capability for this condition.
It is conceivable that some quantity.of oil could be sprayed out of a small leak in the'high pressure system during the less than three minutes of lift pump operation.
The quantity of oil spilled would have to be small to avoid low-level alarm l
annunciation.
However, we recognize that.this could be a fire hazard.
Therefore, an enclosure will be provided around the oil j
lift pump and piping, oil cooler' oil piping will be equipped with j
flange covers, and an oil cooler drip pan'will be provided to-contain oil leakage from high pressure sources.
i 1
. The general arrangement of the reactor coolant pump lube oil collection system is shown on Figure 1.
The protective components of this system will collect potential oil leakage from pressurized and unpressurized sources and drain it away from hot potential ignition sources.
The system will meet the intent of Section III.O of Appendix R.
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_.-ENCLOSURE 1
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Oil lift pump and piping t
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Oil cooler drip tray.
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cone assembly.
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Oil deflector cone leak-off tray.
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Oil collection tank.
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3/4" diameter drain pipe.~
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1" diameter drain pipe.
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.y-I EL.13'-O-l POINT BEACH NUCLEAR PLANT REACTOR COOLANT PUMP LUBE OIL COLLECTION SYSTEM 4
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