ML20070K361
| ML20070K361 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 12/21/1982 |
| From: | Carey J DUQUESNE LIGHT CO. |
| To: | Varga S Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8212300107 | |
| Download: ML20070K361 (15) | |
Text
~
'A@
Telephone (412) 4564000 Nuclear Division P.O. Box 4 December 21, 1982 Shippingport, PA 150774004 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 Leference:
Beaver Valley Power Station Docket No. 50-334, License No. DPR-66 Appendix R to 10 CFR 50 - Exemptions Centlemen:
By letter dated June 30, 1982, the Duquesne Light Company requested exemptions from Section III.G.of Appendix R to 10 CFR 50 for five fire a rea s.
By letter dated October 22, 1982, we provided additional informa-tion with regards to the subject exemptions. The NRC's draf t Safety Evaluation Report of these requests was received by Duquesne Light Company on November 30, 1982.
Based on the draft safety evaluation, the level of fire protection provided for the Reactor Containment (RC-1), Pipe Tunnel (PT-1), and Cable Tunnel (CV-3) was determined equivalent to the technical requirements of Section III.G of Appendix R and exemptions were granted by the NRC.
The remaining areas for which an exemption was denied are:
Control Room (CR-1)
Primary Auxiliary Building; Elev. 722 (PAB)
Additionally, our proposal to use portable, gasoline powered fans as a means of providing essential ventilation in certain areas identified in the report was denied based on the determination that use of the port-able ventilation equipment was considered a repair and not acceptable for hot shutdown related equipment.
Provided in the enclosure to this letter is information which will clarify and substantiate the subject exemptions. The information in this enclosure has been discussed with the NRC staff in conference calls held during December. We feel adequate documentation and technical justification is provided in the enclosure to establish our position that equivalent protec-ion is provided or alternative methe.s are available and, therefore, should be acceptable.
If the exemptions for the control room (CR-1), and PAB Elev. 722 (PA-lG), and our position on the portable ventilation to areas ES-1 and 2 (Emergency Switchgear Rooms 1 & 2), and areas PA-lg, lh & If (charging pump cubicles), are not granted, or found acceptable in the light of alternate methods proposed and described in this letter, this correspondence should then be considered notification for an appeal by Duquesne Light Company.
B212300107 821221 0
PDR ADOCK 05000334 F
1 Bhavar Vgilay Power Stcti:n, Unit Ns.1 Docket No. 50-334, Lic:nsa No. DPR-66 Appendix R to 10 CFR 50 - Exemptions Page 2 Table I is provided to summarize all the proposed modifications and commitments made by DLC with referenced documents noted in the table for-each item. Also, included in the table is the implementation schedule dates for the proposed modifications. The dates are consistent with our original Appendix R Review Report dated June 30, 1982, which was documented in Chapter 12 of the report.
The applicable notes identified for each item provides justification and the basis for the proposed scheduled dates.
Please contact us if additional information or clarification is necessary.
Ve ry ru y yours, J. J Carey Vic President, Nuclear Enclosures cc:
Mr. W. M. Troskoski, Resident 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 Of fice of Inspection and Enforcement Attn:
R. C. Haynes, Rcgional Director Region 1 631 Park Avenue King of Prussia, Pennsylvania 19406 U. S. Nuclear Regulatory Commission Division of Licensing Attu:
D. G. Eisenhut, Director Washingten DC 20555 U. S. Nuclear Regulatory Commission Of fice of Nuclear Reactor Regulation e
Attn:
S. J. Chilk, Secretary of the Commission Washington, DC 20555
TABLE 1 IMPLEMENTATION REFERENCE PROPOSED MODIFICATION SCHEDULE 4
1.
Section 6.2 Auxiliary FW System:
30 months after (App. R Report)
Install new Aux. FW Pump NRC Approval (NOTE 3)
L 2.
Section 6.11 (B.I.P) Backup Indication Panel (App. R. Report)
Install new instrument panel in and CV-2, East Cable Vault 12/10/82 letter Add source range monitoring to NRC indication capability and 30 months after T &T indication NRC Approval (NOTES 2 & 3) h c
3.
12/10/82 letter Add local steam pressure to NRC indication at PORV area where 30 months after manual control of steam pressure NRC Approval (NOTES 2 & 3) will be performed (per Alternate S.D. Procedure - Post fire shutdown, i
4.
10/28/82 letter Provide support cradles for main steam to NRC lines to support vater solid 30 months after operation (per alternate S.D.
NRC Approval (NOTE 3)
Procedure - Post fire shutdown) 5.
Section 6.9 CO St rage /PG Pump Room:
2 (App. P. Report)
Relocating river water valve 3:' Refueling Outage (NOTE 7)
MOV-RW-ll3D from this area (Ocheduled June, 1983) i 6.
Section 6.10 Normal Swgr. - (NS-1), Cable Spreading 18 months from NRC Approval' (App. R Report)-
(CS-1),. Inst. Rack Room (CR-4), Relay (NOTES 1 & 7) i (CR-3), Control Room Air Cond. Room (CR-2):Modifications of the #2 DG control circuit and wiring 7.
Section 6.12 Motor Control Centers (480V) E-MCC's 3rd Refueling Outage (App. R Report)
Modify circuits (provide current (Scheduled June,~1983) limiting devices for the control transformers).
TABLE 1,.(Continued) 1 IMPLEMENTATION REFERENCE PROPOSED MODIFICATION SCHEDULE 8.
Section 6.8 Cable Tunnel (CV-3):
3rd Refueling Outage (NOTE 5)
(App. R Report)
Install Halon System (Scheduled June, 1983) i 9.
Section 6.4 Charging Pump Cubicles (PA-lg, if, lh) 12 months from NRC Approval (App. R Report)
Install fire dampers between (NOTES 4 & 6) cubicles in the ductwork and seal B cubicle opening 10.
Sections 6.5 Portable ventilation capability for 3rd Refueling Outage (NOTE 8) 6.6 PA-1g, lh, if (Scheduled June, 1983) 6.7 ES-1 & 2 (App. R Report)
CR-2 11.
Draft SER from NRC PAB Elev. 722 3rd Refueling Outage (NOTE 8) dated 11/22/82 Install 1 hr. cable wrap on (Scheduled June, 1983)-
the B Charging Pump power lead i
i Ref: 10 CFR 50 Appendix R i
Alternative shutdown capability is provided by rerouting, relocatin;;, or modification of existing j
systems.
- Dedicated shutdown capability is prwided by installing new structures and sv tems for the function of post-fire shutdown.
1 j,
i l
TABLE 1, (Co'ntinued) t NOTES:
1.
The 18-month interval is for final design and procurement of the modification. Installation will be performed during the first outage following the 18-month design and procurement interval.
2.
Installation requires an outage to perform instrument loop testing and verification.
3.
Implementation in accordance with 10 CFR 50.48 (Scheduling for dedicated shutdown equipment).
4.
Installation requires an outage to conform to ALARA constraints in high radiation areas.
5.
Installation deferred to an outage to minimize construction activity in CV-3 during power operations.
6.
Installation will be performed during the first refueling outage following the 12-month design-and procurement interval.
7.
Installation requires an outage as the modification will require the protracted outage of an emergency diesel generator.
8.
Installation. predicated upon NRC approval of proposed modification..
ATTACHMENT I
, Control Room (CR-1)
The exemption for the control room (CR-1) was denied because alternate shutdown capability independent of _this area was not pro-vided. This was resolved at the November 30, 1982 meeting between Duquesne Light Company and the NRC staff reviewers and documented in our December 12, 1982 letter. Whereby, the determination was made that the design capability to achieve cold shutdown using the water solid steam generator heat removal method could be accomplished in approx-imately 127 hours0.00147 days <br />0.0353 hours <br />2.099868e-4 weeks <br />4.83235e-5 months <br /> following reactor trip and that the availability of a water supply for the auxiliary feedwater system would be sufficient over this time period. Therefore, the control room (CR-1) does comply with Section III.G because provisions have been made for an alternate shutdown capability independent of the area.
The draf t SER stated that physical isolation does not exist between the common ventilation duct work between the control room (CR-1) and area CR-4 (Process Instrument Room). A sketch of the ventilation duct work denoting fire-rated dampers is attached to show the automatic physical isolation capability between the control room and the surround-ing per.imeter areas.
l(
,f 3
f E E C
2b oO ~g A
m 1bn9g p~
Ry 6 3 I
99 g J
l O
D0 7
R 4
9 SS L
E VV E
T
)[v O
Og L
N S
2D o@N F
- g t
g p~
L O
p ir-i.
O <-
M
)
S 4
. ~ E' n
l O
)
2-3, G
.3 a
R O
2, L (f
I
=
- O 1
R yw CF 3Y w M
C p
Sl
=
Av t
M e
Ek ru F
0 s
t R
0MN
=
AS E
- C E
0 5RF
]g
/
1 0
T E-1 LH 2
S S
T 6
(5 T
0 M 0O X OA N
y R
E U
0 F f
ar U
4 4
0A0 FO N
RE P
N4 l-1 C
1 3
0F0 T
Y c
T-1 t
5;TI FNr S
F. B
- Y t
AE F.
2H N A 2
7
=
OS s
3 3 s0 OL M
SOO
~
VCT TV v
3X 3 v4
(:
h,
- E ITL e
l l
f A
A,.
=
j M
+
Lt L'
YY
)0 g I i Fh
~
L L A0 P
TS
.(
E 3
Y 0
P F I
1 0T N
f L
C.By
(
E 3
N l
g (4 (4 PRSO0 5
8 H
o' 0 N A
7 O
R-UEE S.TLW4 V P ABF p
I 4' R T
T V l
d 4. O 4
A. 0 A 5
op
~
C y
p
- FE y
- M 0 6 y V v\\
Ss Y.
r.
F g
S5 F
vv E
V vg gU [r h o
- m t
c P
5 M
2 i.
D "6
i L
4
,,i E
R A
i, E
0 P
'Z T
p P R T )P C
Y 3
7 0
T IL 0
0 C
f O
A Y 5 AA (T P N I
F Y
g 0L D
5 F
J 5P 3 5 I. T N
L 4
T 2
0 I
9g 3 2g L(
V 3P 3 v
L O R R E
o 67 0
~
4g L
3U F
E E tte E
P P r
EE O.
S i E
M O O 6
/
0p pr g SS 1
l U
S5 R
3 o
yv VV i
D 5$
L T T vy h,
L w
OO O I
G R-
~
V M M g@l p
E i
l g
F
.g 9
s yl go$
i F
2- -
C I
A F
l 8 R
- [h' i
P) f -
E L R ql l
] q
}1,I h^
r E
S S L
L A
DI 0
3 g
7VV d
l t
W F
A E
0 f
/
I U
L U
8 LD TE g
,e j l/-\\
R OR H
TS A
CH OS 9
l gS T
r T
BE(
fS B
T -
O A P P
R L g4 89 L 7lg_
. A PP O O A
C l
u M B
E EMP S
]N M A o
I j
H D
7 p
'6 D
uOUn V
DOO C
A C E E 9
C
'3 E
9
AF D
0 g-OEF F 7
RPS dS 95
~
L N
1 5
tM V 5 4l O
9 EOU 2
V v
r E
2 y, C'._
]'$
0o~
7 1
3 5
RIP 7
FA&
l 4
g-
_Oh L
sT F7 C
R-f E
L D RU L
7 Pg-H5N 7
o$-
b O
F 4
[
3IC
[l L
i gj ilI }
- j
.i
" L 3E o'
_s k[l-li[
r Ih,
[ [ E y-
,g w Eil_
m c,.
I 1
I I
J P i
i i i er rtrH702P (TOP EL.731;C)
,=,
f t
l C@-16
'~
ITH70lP~
(EL.W-C)
NDCT b h
I a
tWw tt 0 Pot EL.73t*-6')
1TH700P[EL75t*-C)
- tTH700P (EL.7 37-d l
1TH703P 0
l 3
( EL73ct-Ci Der.c A
IFHilb POf.
l
-L
(" '33
- i 1
1 mi CHARGING PUMP CH-F-1B CABLE ROUTING AUX BLDG EL. 722'-6" PAGE 1 0F 4
t_
l 0
o.
c.
6 O C :-
d I J
o.o
@2 C
4 i<
's
=s.
~e o
c3 r0 r-r j
J W
W h
r J
p W
N
-.C
- a. '. S Oo.
Am a;
??
I FJ c,_. _ _ _
_-e CliARGING PUMP 611-P-1B CABLE ROUTING (SECTIONS)
PAGE 2 0F 4 w
1
V ws l
l I
~ P1PE TabuseH 4
I 7 E r
=
~ '""8000'
~
ITu701P gyggp
+
11T4721P F
9'-O' H OET.B E L.7 5 5'-C 1FH1fbPOP_--II II I1 EL 733-b EL.~f 3,7-i
?
I 1TH7oop I
I ITM70SP EL73dd t
DET,C CllARGING PUMP CH-P-1B CABLE ROUTING (DETAILS)
PAGE 3 0F 1.
.* 7 "-
I NOTES 1.-
THE POWER CABLE 1CHSDPII300 FOR CHARGING PUMP CH-P-1B IS ROUTED OUTSIDE THE CHARGING PUMP CUBICLE TO THE 735'-6" ELEVATION OF Ti!E AUXILIARY BUILDING VIA RACEWAYS 1WH110P01, 1TH700,1TH703 AND 1Fil116P02.
2.
NO OTHER CABLES ARE ROUTED IN THE RACEWAYS LISTED IN NOTE'1.
3.
DATA ON RACEWAYS OF NOTE 1 RACEWAY SIZE LENGTH CROSS-SECTION MARK NO.
(in)
(ft)
( sq.~in. )
1WH110P01 4
2 12.74 CAB-10 1FH116P02 4
9 12.74 CAB-10 1TH700P 3X6 30 18 DHB-01 1Tl!703P 3I6 2
18 DHBf.01 4.
EXPLANATION OF MARK NO OF NOTE 3.
CAB-10 4" rigid steel conduit zine coated 4" diam.
DHB-01 6" ladder type cable tray 3" deep aluminum. 3" deep - 6" vide.
P-CHARGING PUMP CH-P-1B CABLE ROUTING (NOTES)
PAGE 4 0F 4
[
~
ATTACHMENT 2 Primary Auxiliary Building (PA-lG)
(Elev. 722)
The following clarifying information is offered for your con-sideration in your review of our request _ for ~ exemption to the require-ments of Appendix R relative to fire area PA-1G.
Redundant functions potentially lost.
1.
Charging capability (CH-P-1A,1B, IC)
The raceways associated with CH-P-1B as shown on the attached sketches will be separated from the general fire area PA-lG by a one-hour fire barrier to protect it from "an exposure fire of moderate duration (5-10 minutes)" as noted in your draf t SER.
See attached sketches (pages 1 through 4) for description of cable routing and details.
2.
Containment Ventilation MOV-RW 106 A & B (N.O.); MOV-RW 114 A & B (N.O. ) ; MOV-RW 116 (N.S. ) ; MOV-RW 117 (N. S. ). As previously stated in our exemption request, these valves are all functionally associated with supplying a backup cooling medium to the containment air recircu-lation coils. These valves and associated conduit are located in close proximity to the floor and could be directly involved in a fire generated by some transient combustible. However, given the limited duration of any conceivable fire in this location, these valves could be manually repositioned prior to the containment exceeding _135'F (containment temperature above which equipment degradation is assumed). The temperature drif t from 105'F to 135'F would take approximately 30 minutes. This includes a very conser-vative assumption for reactor coolant or steam leakage in the con-tainment atmosphere.
3.
Backup Water Supply to the Anx. Feedwater Pumps (MOV-RW 103 C & D) stated in our exemption reluest, MOV-RW 103C and MOV-RW 103D are only required as an emerge acy backup water supply to the auxiliary feedwater pumps. The primary source of auxiliary feedwater will not be lost in this area and the plant will have the additional capability of feeding the steam generators from existing yard tank-j age via a new auxiliary feedwater pump described in Chapter 6, Section 6.2.
l 4.
Charging Pump Suction Valving MOV-CH 115 B & D.
These normally shut parallel valves are interposed between the charging pumps i
and the RWST.
If these valves are rendered inoperable by virtue of a fire in PA-lG, an alternate flow path as detailed on the attached sketch will be available. The charging pump would draw suction from the RWST through the idle low head safety injection pumps Sl-P-1A, IB.
The only action required of the control room operator to make thus flow path available would be to open MOV-SI 863A or B located on Benchboard A, or, locally if necessary.
l
_, (Continued)
Based upon the above clarifica' tion and the-information previoisly provided, it is our belief that subsequent to completion of the proposed modifications this area will be covered by an equiv-alent level of fire protection to that required by Appendix R to 10 CFR 50.
I i
t e
Te RcuTw Cc,ch -
S.
c, i
7-y 7
/ ~..
.I _ _.
N v i, _
e }, 7 g @'j j ' s'c n p. t k
'c* i
.e
' - +' ^ t i
'b 5
g ( c u r. :.;, a., j (I)'f f(t1...,_. t u s m t
s ea.
5. *}
i e
l
}
ves -, 6's - vs >,
7.A' <
t-
\\
v21
.iv t A :
i t
l pov.c-}ss_)a<1, 4;_
f-a..
c.ur:
,,, / '
'e fg
$N'[j6'D AOx U AR
~
T
-- g ~. s: - c -1.cs a - c> 2 go s,..~.,
s.. n Moy-SI-9GBA L RC PIPE 6 g-u%58 vz7 - - 4... l,-. 7 mas s
- TUNNE L-E@
r vu.1 - ]ac.e.g.r.--aAm_
r, x
CL*736 3.O
" 6,SI-40-153 +Q ?
\\ 'e! '7303
\\
f".SZ. %.yg3 p t-
'=^ f. ' Q
/
q ewA 3 V(.
~5
, _ it"- s: -i-t53 W-4 3 V'7
/
--- Y e A 3.,. c.
d R c P,ps bad A c e%
p
(
( LMSI)
II-P-lA
!.ovo Hrno sarcTY IcJecitop SI-P-li,__ e.1736 - 4,,[T p) 7 j
pumps
(
1 MOV-SI 2GO P --
- nov-5IE60E V30$ ^ C vs P
R v_
yA LJ t~
q3 1
rm m
a i
v.r 3 Z _"_
r go vt qa F
sc c om J/n y
t ym t
\\
/
\\
il!C V-Sf 8bE A l M G..5.[ ? ! 2 2 NLiiRNATE
^ Flou) ?/TTII 'To ~THE C#4dt C, /N G PU m P 3 o c non i
^ *
- j o
ATTACHMENT 3 Portable Ventilation In several areas, we proposed to use portable gasoline powered fans as a redundant means of supplying essential ventilation to the charging pumps, emergency switchgear rooms and the control room air conditioning space, if the normal HVAC equipment is damaged by a fire.
The portable fans would be placed in ' position and operated by the plant fire brigade. The movement and use of portable equipment was considered a repair, and was not acceptable for hot shutdown related components.
Emergency Switchgear (ES 1 & 2)
If one makes the conservative assumption that the heat load during the fire condition is equivalent to that dissipated during the design condition (approximately 80,000 BTU /hr) areas ES 1 & 2 would heat up from 80*F to 120*F in approximately 30 minutes. This heatup rate is predicated solely upon the heat capacity of the air intrapped with the room volumes with a credit taken for structural heat sinks.
If the volume of NS-1 is assumed available to act as a heat sink, then the transient would extend to 1 - 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> depending upon the effectiveness of the thermally driven airflow through the interconnecting doorway shown on Figure 3.4-1 of our Appendix R sub-mittal report.
Charging Pump Cubicles (PA-lg, lh, if)
With the access hatch open to the charging pump cubicle sufficient natural circulation will exist to allow for the continuous short term operation of the pump.
It is anticipated that given a load of 97,000 BTU /hr, the cubicle temperature will heat-up to approximately 145'F within one hour. This transient will prematurely age the pump motor
-but it will not preclude the short term operation of the unit. Within the hour, the portable emergency ventilation equipment discussed in Chapter 6 of our Appendix R report would be operative reducing the cubicle temperature into its normal range of 80 - 104*F.
In both of the tbove areas, there is sufficient time available to place the emergency ventilation into operation without predjudicing the availability of equipment required for hot shutdown.
This same equipment could be used to ventilated areas CR-1, 2, 3 1
or 4.
However, by virture of our commitment to installing the Backup Indicating Panel described in Chapter 5 of the Appendix R report, BV-1 has an alternative means of maintaining shutdown conditions assuming a loss of these areas.
In lieu of the above, ventilation 'of these spaces is not required to meet the requirements of Appendix R since alternative shutdown capability has been provided external to the control room area.
1 l
l
-