ML20052E628
| ML20052E628 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 04/29/1982 |
| From: | Davidson D CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | Schwencer A Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8205110295 | |
| Download: ML20052E628 (7) | |
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' THE CLEVELAND ELECTRIC ILLUMIN ATING COMPANY P.o BOX 5000 m CLEVEL AND. OHIO 44101 e TELEPHONE (216) 622-9800 m ILLUMINATING BLDG e 55 PUBLIC SOUARE Serving The Best Location in the Nation Dalwyn R. Davidson V'CE 5'RES'DE NT g
S e STI M E NGINEERING AND CONSTRUCTION Q
4 April 29, 1 RECEIVED p
MAY 101982>- p Mr. A. Schwencer Chief, Licensing Branch No. 2
- ts haut um wca r-Division of Licensing emgm u U. S. Nuclear Regulatory Commission 9
Washington, D. C.
20555 g
Perry Nuclear Power e t
Docket Nos. 50-440; 50-441 Response to Request for Additional Infor=ation -
Fire Protection
Dear Mr. Schwencer:
This letter and its attachment is submitted to provide revised responses to the concerns identified in your request for Fire Protection.
It is our intention to incorporate these responses in a subsequent amendment to our Fire Protection Evaluation Report.
Very Truly Yours, Dalwyn R. Davidson Vice President System Engineering and Construction DRD: mlb cc:
Jay Silberg John Stefano Max Gildner John Stang N. Fioravante 1.
5 8205110295 920429 PDR ADOCK 05000 gfl F
Question Topic 10:
Secondary power supplies for all fire detection systems.
Response
Section c-6a(6) of the SRP states that primary and secondary power supplies should satisfy the provisions of Section 2220 of NFPA 72D, and that this can be accomplished by using normal offsite power as the primary supply with a 4-hour battery supply as secondary supply; and by providing capability for manual connection to the Class IE emergency power bus within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of loss of offsite power.
The normal and reserve battery chargers associated with the 125VDC power system, and the normal and alternate inputs for the 120 VAC UPS system are powered from normal 480V plant power with provision of being automatically transferred to Class 1E diesel generator power.
This power distribution scheme concurs with Section 2223.b of NFPA 72D, with the exception that the 4-hour battery requirement is not met.
The battery for the 125 VDC system is capabic of a 15 minute duty cycle, and the battery for the UPS system is capable of a one hour duty cycle. However, on loss of offsite power, the fire suppression and detection loads are automatically transferred to diesel generator power.
(The only exception to this is in the case of a LOCA.
On LOCA initiation, the 4.16kV stub bus, which connects the fire suppression and detection loads to Class 1E power, is tripped. At a point in time after LOCA loads have been sequenced onto the diesel generators, the stub bus will be re-connected to Class 1E power.
Ilowever, this would affect the power supplied to the fire suppression and detection loads only if a LOCA is simultaneous with a loss of offsite power condition.
This is a double contingency, and does not have to be postulated.)
Furthermore, Section 2223.e of NFPA 72D states that if two or more engine driven generators are provided in addition to the primary power supply, a battery is not required.
If a loss of offsite power would occur resulting in the need to transfer to Class IE diesel-backed power, the power would be supplied by the Class 1E Division 2 diesel generator.
However, if the Division
Question Topic.10:.(Con't)
Pg. 2 2 diesel generator is not available, the Division 1. diesel generator can be used to power the stub bus via the Class IE 4.16kV system tie breakers.
' This cross ticing of the Division 1 diesel can not be accomplished within the 30 second limitation of Section 2223.e of NFPA 72D, but it can be accomplished within the 15 minute. duty cycle of the 125VDC system battery.
Although the specific details set forth in any one of the provisions 2
of Section 2220 of NFPA 72D are not completely complied with, the re-3' liability of the power sources used to power the fire suppression and de-tection equipment is considered to be comparable to that of a system
)
. meeting Section 2220 requirements.
i 9
i 9
A
Question Topic 26:
Comparison of PNPP's fire protection program to the guidance set forth in 10 CFR 50, Appendix R.
Response
Appendix R Section PNPP Position II.A, Comply; see Perry nuclear Power Fire Protection Program Plant Fire Protection Eval-untion Report (PNPP-FPER)
Pages 5-2 through 5-6.
PNPP will follow-the fire protection program outlined in the NRC staff supplemental guidance
" Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls and
- Quality Assurance," dated August 29, 1977.
II.B, Fire Hazards Analysis Comply; see PNPP-FPER Section 1.0.
The results of PNPP's 4
analysis to assure fire protection'-
for aafe shutdown capability, which were presented in an April 30, 1982 meeting with NRC(CHEB), will appear in the next amendment to the PNPP-FFER.
II.C Fire Protection Features Comply; see PNPP-FPER and PNPP-FSAR Sections 9 5.1 and 13.1 II.D Alternative or Dedicated Comply; see written commitments Shutdown Capability in letter of April 1,198E, to A.
Schwencer from D. R. Davidson, as modified by verbal commitments made by CEI in an April 26, 1982, meeting with CHEB.
l L-
O Question Topic 26:
(Con't)
Pg. 2 III.A Comply; Lake Erie is the source i
Water Supplies for Fire of fire protection water for Suppression Systems PNPP. There are two structures which supply this wat;er to the emergency service water pumphouse where the fire pumps are located.
During normal operation, lake water will be supplied to the pumps through the intake tunnel.
Should the intake tunnel become obstructed, an alternate source of this lake water supply is available through the discharge tunnel. For a detailed description of these dual intakes see FSAR section 3.8.4.1 9 III.B Sectional Isolation Valves Comply; All fire hydrants at PNPP are provided with a lateral which contains a key operated valve so that the hydrant may be isolated for main-tenance and repair.
III.D Manual Fire Suppression Will comply; Standpipe and hose systems at PNPP are so installed that at least one effective hose stream will be able to reach any location that contains or presents an exposure fire hazard to structures, systems, or components important to safety.
Standpipe and hose stations are located inside of containment, but not inside drywell.
However, adequate lengths of hose shall be provided to reach any location inside the dry well with an effect-ive hose stream. The water supply for the standpipe and hose stations inside of containment is the normal fire service water supply.
III.E Hydrostat'.c Hose Tests Will comply; fire hose will be hydrostatically tested per Appendix R criteria L
III.F Automatic Fire Detection Will comp 3,y or will submit request -
for exemption from Appendix R,Section III F, recommendations for automatic fire detection for specific areas based on results of the recently completed safe shutdown analysis. Automatic fire detection is currently provided based on the results of the fire hazards analysis presented in Section 4.0 of the PNPP-FFER.
III.G Fire Protection of Safe Will comply or will justify Shutdown Capability deviations which will nonetheless provide equivalent. fire protection for redundant cables and equipment as agreed to by NRC and CEI in an April 26 meeting on Section III.G compliance.
III.H Fire Brigade Will comply.
III.I Fire Brigade Training Will comply.
III.J.
Emergency Lighting Will comply.
III.K Administrative Controls Will comply.
III.L Alternative and Dedicated Compliance with this requirement Shutdown Capability was discussed in the April 26 meeting between NRC and CEI on the analysis performed to evaluate compliance of PNPP design with Section III.G criteria. Also, for the fire in the control room, loss of two of the four Reactor Protection System cabinets does not prevent loss of function of the manual SCRAM. Loss of two ofthesecabinets,althoughunlikely[45 is postulated because there is only feet between the cabinets in each pair
III.L Alternative and Dedicated of cabinets. There is over 27 Shutdown Capability feet between each pair of cabinets.
Additionally, upon evacuation of the i
control room due to fire, procedures (Con't) will require verification that electrical power is removed from the scram inlet and. discharge l
solenoids..
Should a fire in the control room disable the diesel generator starting panel, operator action would be required at the diesel generator room to transfer control to the local panel. The control room circuits are isolated after control-is transferred to the local panel.
III.M Fire Barrier Cable Penetration Will comply.
Seal Qualification III.O.
Oil Collection System for Do not comply; a lube oil fire hazard Reactor Recirculation Pump for the reactor recirculation pumps does not require an oil collection system since the pump motor lube oil systems are contained within a metal motor housing and the pump is water lubricated and cooled; thus, an engineered oil leak collection system for the reactor recirculation pump is not necessary.