ML20065Q114

Forwards Supplemental Info Per 821014 Discussion Clarifying Exemptions Previously Documented in Fire Protection App R Review,Section 11.2, Reactor Containment & Section 11.6, Primary Auxiliary Bldg

ML20065Q114
Person / Time
Site:	Beaver Valley
Issue date:	10/22/1982
From:	Carey J DUQUESNE LIGHT CO.
To:	Varga S Office of Nuclear Reactor Regulation
References
TAC-11111, TAC-49335, NUDOCS 8210260458
Download: ML20065Q114 (9)

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'Af (412)4564000 435 Sesth Avenue mowe. r. October 22, 1982 1$219 Director of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Attn: Mr. Steven A. Varga, Chief Operating Reactors Branch No. 1 Division of Licensing Washington, DC 20555

Reference:

Beaver Valley Power Station Docket No. 50-334, License No. DPR-66 Supplemental Information to Fire Protection -

Appendix R Review Report Centlement Based on discussions with your staff on October 14, 1982, the attached supplemental information is being provided to clarify certain exempsions previously documented as part of our Fire Protection Appendix R Review report dated June 30, 1982. Specifically, supplemental inform-ation is enclosed for Section 11.2 - Reactor Containment (RC-1) and Section 11.6 - Prima ry Auxiliary Building (PA-lG), Elevation 722-f t.

6-in., of our report.

Provided in the enclosures is additional information for the above exemptions previously requested to substantiate that the orig-inal justifications submitted in our report are still valid. The reactor containment instrumentation and equipment required for safe shutdown, which is listed in Section 11.2 of the report, was analyzed to the criteria set forth in Appendix R,Section III.G(2) d, e, or f for noninerted containments. Section 11.6 of oar report listed the equipment in the Prima ry Auxilia ry Building, Elevation 722, required to achieve safe shutdown, which was analyzed to the criteria set forth in Appendix R,Section III.G(2) .

Based on the NRC staf f reviewers interpretation of requirements for hot shutdown, our proposed modification to install r Backup In-dication Panel (Section 6.11) is revised to permanentl-f install and hardwire this Backup Instrumentation Panel into one train (Train B) of equipment. Key-lock switches for the transfer function will be provided.

In our discussions, the charging pump cubicle ventilation system and our proposed modification (section 6.4) to add th hour fire rated dampers was questioned by your review staf f. A detailed explanation is given in Section 3.4.14 " Charging Pump Cubicles (PA-1f, Ig, and lb)"

of our submittal and a sketch of the proposed modification is detailed 0210260450 821022 PDR ADOCK 05000334 p PDR

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Be: var V311cy P;wer Statien, Unit Ns. 1

. Docket Ns. 50-334, Lictnsa No. DPR-66 Supplemental Information to Fira Protection -

Appendix R Review Report Page 2 in Figure 6.4-1. We feel adequate documenation and technical justi-fication is provided to establish our position that equivalent pro-tection to that which would be achieved by conformance to Section III.G(2) is provided.

Please contact my staff if additional information or clarifi-cation is necessary.

~~lNT ruly yours c

J. J. Carey

\' - Vice President, Nuclear Division lid Enclosures cc: Mr. W. M. Troskoski, Resid3nt Inspector U. S. Nuclear Regulatory Commission Beaver Valley Power Station Shippingport, PA 15077 U. S. Nuclear Regulatory Commission c/o Document Management Branch Washington, DC 20555 U.S. Nuclear Regulatory Commission Office of Inspection and Enforcement '.

Attn: R.C. Haynes, Regional Direction Region I 631 Park Avenue King of Prussia, PA 19406 U.S. Nuclear Regulatory Commission Division of Licensing Attn: D. G. Eisenhut, Director Washington, DC 20555 l U. S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Attn: S. J. Chilk, Secreta ry of the Commission Washington, DC 20555

, 11.2 REACTOR CONTAINMENT (RC-1)

(Clarificatirn of ex2tption information)

A. The letdown orifice isolation valves [TV-CH-200A, B, C] were included in paragraph 11.2.3, but are not required for safe shutdown. These valves are addressed in Chapter 8 as part of the High/ Low Pressure interface review. In addition, the pressurizer pressure devices [PT-RC-444, 455, 456 and 457]

should be deleted from paragraph 11.2.3 as it is not an essen-tial meter for cooldown under natural circulation conditions.

B. Containment ventilation was previously included in our ex-emption request 11.2 to address the potential for deviating from the requirement t, maintain plant parameters within those precipitated by a loss of off-site power transient.

This function is covered by the inclusion of fans [VS-F-1A, B, and C] and the associated cooling water valves [TV-CC-110A, B, C, D and E3].

We have included Figures 11.2-12 and 11.2-13 and various electrical drawings which further detail the spatial separ-ation of the component relating to this function.

If this function was lost, the stations capability to main-tain ho shutdown or the eventual maintenance of cold shut-down would not be lost. The equipment located inside contain-ment required to achieve these conditions are qualified by virtue of conformance to IE Bulletin 79-01B to a more severe t ransient than tha t resulting from a loss of containment vent-ila tion.

A review of the referenced figures indicates that the contain-ment recirculation fans meet the requirements of III.G(2) given that the only instance where the power leads come within 20 ft.

of each other, at least one lead is encapsulated in conduit which qualifies as a noncombustible radiant energy shield.

Failure of the associated control cabling can be tolerated because the breakers, located in the Emergency Switchgear Rooms [ES-1 and 2], can be manually positioned.

Cabling associated with the cooling water valves [TV-CC-110A, B, C, D and E3] over a significant amount of their routing inside containment run in the same tray. Inspection of Figures 11.2-12 and 11.2-13 reveals that the cooler isol-ation valves [CC-110A, B, C] are widely separated while the containment teolation valves are located at the same elevation within appro.'wately 8-10 ft. All these valves are air oper-a ted and fait ctosed.

To preclude any 30tential long term loss of this function would require modifyi, the cooler isolation valves to fail "as is" (open) and to modify the containment isolation detail to one allowed by Gene ~sl Design Criterion 57 (closed systems) re-sulting in single isolation valves per header located outside con ta inment .

11.2 REACT MrSONTAINMENT..(RC-1)

Paga 2 St-ict conformance with GDC 57 for missle protection would be doubtful because of the scope and location of the containment piping runs.

An alternative would be to redesign the penetration in a way which would violate CDC 65. This would entail replacing i the inside containment isolation valve on the supply header with a spring loaded isolation valve and moving the inside containment isolation valve on the return header to a loca-I tion outside containment in series with the existing valve.

j We have not proposed these modifications due to the resultant decrease in the containment isolation design, the large expense involved to accomplish this modification, the low combustible loading in the pipe penetration area, the low i probability of utilization, and ultimately, that sufficient

!- qualified equipment will be available to the operators to i maintain shutdown conditions without containment cooling i available.

C. We have enclosed the following routing descriptions and re-

ferenced drawings to clarify the previously submitted infor-

[' mation relative to the actual routing and protection insido i conta inment.

1. PRESSURIZER POWER OPERATED RELIEF VALVES PCV-RC-455C D AND 456 NOTE: SOV-RC-544 is included due to its associated circuit f status.

i j The routings for [PCV-RC-455C, D and 456] and [S0V-RC-544] are shown on drawing 11700-RE-34AK, 46A, 46E and 46F which are 7

labeled [PCV-RC-455C, D, 'and 456), sheets 1 through 4. The Train A and Train B control cables for [PCV-RC-455C, D and 456]

are run from the valves (located above the pressurizer cubicle)

! in conduit, to points just outside the crane wall.

j Outside the crane wall, the control cables enter trays which run to the penetration area on either side of column 10 k. The

{ control cables then drop down at the penetration area and -are i separated by approximately 25 feet. The cables are also separa-ated by a fire barrier and a fire detection and suppression system.

The associated circuit. [SOV-RC-544] Train A control cable, runs in conduit from the solenoid to trays in the penetration area. The control cable does not run close to the above PCV control cable until the penetration area, and at that time, only .

l in the vicinity of Train A.

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11.2 REACTOR CONTAINMENT (RC-1)

• (Cicrifiestion of cxarption information)

Pag 2 3 These valves have been considered in the analysis because of in-clusion in 'the High/ Low Pressure . Interface discussion. (Chapter 8) of our initial submittal. See the following section covering the blocking valves for additional justification of the' existing lay-out.

2. PRESSURIZER RELIEF BLOCKING VALVES-The routings of the ' power and control cables for [MOV-RC-535, 536 and 537] are depicted on (2) two drawings RE-34AK and RE-46A, labeled as [MOV-RC-535, 536 and 537] sheets 1 and 2 re-spectively.

The power cables for both Train A & B are run in conduit, from

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the motor operated valves located in the pressurizer cubicles to the penetration area at column 10\. In this area the cable enters tray which is separated by a fire barrier and are pro-tected by a fire suppression and detection system.'

These blocking valves [NOV-RC-535, 536 and 537] would be used to isolate a leaking or stuck open Power Operated Relief Valve

[PCV-RC-455C, D and 456). Each PCV is blocked by an MOV of the opposite train. As can be seen by the referenced drawings when-ever these trains are routed in accessible areas they are sep-arated by approximately 25 f t. and protected by a suppression system, or they are enclosed in conduit (PZR cubicle). In the one area where they run together in close proximity, they are routed at least 20 f t.' off the floor in covered tray.

Based on the above layout and -previously provided justification, we contend that this layout affords an equivalent level of pro-tection to tha t required by III G-2 of Appendix R.

3. PRESSURIZER HEATERS A, B, D, AND E The routing for pressurizer heater power cables for heaters A and C (Train A) and B and D (Train B) are depicted on the fol-lowing three drawings: 11700-RE-34AK, 11700-RE-34AS and 11700-RE-34AG (labeled Pressurizer Heaters, sheets 1 through 3).

The power cables of those Train A and Train B heaters run m tirely in tray from the pressurizer cubicle to either side of i column 10 k, as shown on the drawings. The trays run parallel i to each other at a height of 20 feet, in close proximity until they reach either side of column 10 k. At this point, the

cables turn down in to four trays which run vertically, and j are separated by 18 feet. The traverse runs of tray above the

, operating floor are covered trays.

i Based upon the routing demonstrated by the referenced drawings and the previous justification presented in paragraph 11.2.3, this function is covered by an equivalent level of protection to tha t required by Appendix R to 10 CFR 50.

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11.2 REACTOR CONTAINMENT (RC-1)

, (Clarification of cxImption information)

Peg 2 4 -

4. STEAM GENERATOR LEVEL The routing of the ' Steam Generator Level transmitter cables are depicted on drawings RE-57U, Q, R. S and T labeled as sheets 1 through 5, respectively.

The instrument cables for channels I, li and III are run in separate conduits from the penetration area where the trays are protected by suppression and detection. The conduit runs around the containment and returns to the penetration area from opposite directions; Channels 1 and III from the north, and Channel II from the south.

We consider this layout acceptable because the routing pro-vides the minimum separation and shielding requirements of paragraph III.G(2) of Appendix R to 10 CFR 50. Regardless of the area chosen at least one channel of Steam Generator Level indication will be available based on the criteria of III.G(2).

5. PRESSURIZER LEVEL TRANSMITTERS LT-RC-459 and 460 The routings for level transmitters [LT-RC-459 and 460] are de-picted on drawings 11700-RE-57Q, S, and 57U, which are labeled (LT-RC-459 and 460], sheets 1 through 3.

As shown on sheets 1 and 2, the instrument cables for the two transmitters are in close proximity. The valves are er. closed in conduit at these critical points and continue in conduit with increasing separation. The cables eventually enter trays in the penetration area which are separated by a fire barrier at column 10 \, and are protected by a fire detection and suppression system. We consider this routing acceptable based on our prior justification and our above review, which shows that when the two functions are in close ,roximity, each is enclosed in a separate ccnduit.

6. REACTOR COOLANT HOT AND COLD LEG TEMPERATURES TRB-RC-410, 420, 430, 413, 423, 433 The routing for the TRB's is depicted on drawings RE-57Q, R, S, T, and U sheets 1 through 5.

These TRB's are separated into (2) two instrument channels.

Hot leg instruments comprise channel I while cold leg instru-ments comprise channel II. The conduit system for each channel approaches the penetration area f rom a dif ferent direction.

The individual channels run around the containment to local pull boxes. From these boxes separate conduits continue to the TRB's.

Additionally, the remaining neutral temperature indication from the RTD bypass manifold is routed in conduit from each loop to the penetra tion area.

11.2 REACTOR CONTAINMENT (RC-1)

(C1crificatien cf sx:cptien information)

P ga 5

7. CONTAINMENT RECIRCULATION FANS VS-F-1A B, and C The routing of power cables for [VS-F-1A, B,' and C] is shown on drawings RE-34AK, AG, AU, and RE-46C, E, F and are labeled as sheets 1 through 6 respectively.

The power cables for [VS-F-1A, B and C] are run from the fans in conduit.

The power cables for [VS-F-1A and IC] enter trays near the orange side or the north side of the penetration area. The power cables for [VS-F-1B] enter tray on the purple or south side of the penetration area.

ht the point outside the penetration area where the three (3) fan power cables are closest proximity, between columns 7 and 8 on RE-46C, [VS-F-1A and IC] are enclosed in conduit.

Within the penetration area [VS-F-1A and IC] power cables are separated from [VS-F-1B] power cables by approximately 20 feet.

They are also separated by a fire barrier and protected by a fire suppression and detection system.

We consider this acceptabla based on [VS-F-1C] being run in conduit and over its entire distance other than in the pene-tration area where it is protected by suppression and detec-tion.

11.6 Primary Auxilicry Building PA-1G El 722 f t. 6 in.

'(C1.Orificati ns to cxstption information)

A. The temperature monitoring system referenced in section 11.6.5(k) of our initial submittal is comprised of an array of thermo-couples (for indication) and electronic temperature switches (valve actuation only) . These devices are installed in se-1ected areas of PA-lG, PT-1, CV-1, and CV-2. Their placement in PA-lG is shown ca Figure 11.6-6. The thermocouple design is delineated on Figure 11.6-7. These thermocouples have a time constant of approximately 4 seconds and meet ISA cali-bration requirements.

These ~ thermocouples, noted on Figure 11.6-6 as T/C's, provide input to microprocessor (DL-MS100) in the control room. Thair ala rm setpoint for all the thermocouples is 105'F. High energy line valve closure at 110*F is precipitated by the temperature switches, annotated on Figure 11.6-6 as TS's, the temperature switches provide no control room indication.

With no alarms present, an hourly log is printed containing the following data for each T/C: T/C number location, low temper-ature for the hour, high temperature for the hour average temp-erature for the hour, and T/C status. Status ie indicated as normal or disabled.

If any T/C exceeds the alarm setpoint, the microprocessor com-mences an a ccident log. The temperature readings of all T/C's are recordcd at 5 second intervals and are printed out every 10 minutes. These temperature logs will be printed every 10 minutes or until the end of the accident.

B. As noted in paragraph ll.6.3b, there are no intervening com-bustibles permanently installed between equipment of interest.

There are, however, cable trays on this elevation as denoted on Figure 11.6.1. This is in contradiction to the statement made in paragraph 11.6.5.1 that all cable on this elevation is con-tained in conduit. Cable location in tray accounts for 5,520 2

lbs. of insulation resulting in a fire loading of 7.745 BTU /FT .

The cable trays run along the perimeter of the general access area with the exception of the trays which contain the charging pump motor feeders. These trays are shown in Figure 11.6.1, Revision 1 and are further described in section C. The charging pump feeders are three conductor cables in an interlocked steel armor construction. One train of these functions which require short term actuation or implementation (charging pumps and the charging pump interface with the RWST) has at least 20 feet separation with no intervening combustibles from the cable trays located on this elevation (See Figure 11.6.1, Rev.1 of this submitted, and 11.6.2, of the original submitted report).

C. The routing paths in the auxiliary building for the power cables f rom cha rging pumps [CH-P-1A, CH-P-1B and CH-P-1C) to the point where the cables leave the building, are shown on Figure 11.6.1, Revision 1 with dark heavy lines, and are described below:

11.6 Primary Auxilisry Building PA-1G El 722 f t. 6 in.

, (Clarificatien of cximption information)

P:gs 2

1. CH-P-1A, in cubicle PA-1F:

The interlocked steel armor cables run from the charging pump to tray 1TH7240 on the 722 f t-6 in level. The cables travel up to the 735 f t-6 in level through tray 1TH7250.

On elevation 735 ft-6 in, they are routed through tray ITH7260, then pass through floor tieeve 1FH125002, back to the 722 f5-6 in level. Tray ITH7040 takes the cables to the north wall of the auxiliary building, where the cables pass through wall sleeve IWH102022, into the service building.

2. CH-P-1B, in cubicle PA-1G:

The interlocked steel armor cables run from the charging pump on the 722 f t-6 in level in tray ITH702P, to tray 1TH701P and through cubicle wall sleeve 1WH110P01. The cables continue on this elevation in tray 1TH700P to tray 1TH703P. At this point, they are routed to the 735 f t-6 in level through floor sleeve 1FH116P02, then run west through tray 1TH721P to tray ITH720P, and into the cable vault through wall sceve IWH156P01.

3. CH-P-1C, incubicle PA-1H:

The interlock steel armor cables run from the Jrc.rging pump on the 722 f t-6 in level in tray 1TH714G, through the cubicle's north wall via wall sleeve IWH171G01 and continues north on the 722 ft-6 in level in tray 1TH501G. They pro-ceed through wall sleeve 1WH170C01 into tray 1TH7050, and into the service building via wall sleeve 1WH101G08.