ML20086C822
| ML20086C822 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 11/21/1983 |
| From: | Lundvall A BALTIMORE GAS & ELECTRIC CO. |
| To: | John Miller Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8311290159 | |
| Download: ML20086C822 (12) | |
Text
,
o BALTIM O RE GAS AND ELECTRIC CHARLES CENTER.P.O. BOX 1475 BALTIMORE, MARYLAND 21203 ARTHUR E. LUNDVALL. JR.
" ["'U" November 21,1983 s
Director of Nuclear Reactor Regulation Attention: Mr. 3. R. Miller, Chief Operating Reactors Branch #3 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555
Subject:
Calvert Cliffs Nuclear Power Plant Units Nos.1 & 2; Dockets Nos. 50-317 and 50-318 Request for Exemption from Fire Protection Requirements Gentlemen:
The Baltimore Gas and Electric Company has closely monitored ongoing regulatory activities related to the implementation of fire protection requirements at operating nuclear power plants. We are aware that you have received a substantial number of requests from licensees for granting relief under the requirements of Appendix R to 10 CFR Part 50.
In reviewing the subject matter of these exemption requests and the results of NRC fire protection audits recently conducted at other operating nuclear power plants, it has come to our attention that there are a number of areas where the manner in which we have implemented fire protection requirements at Calvert Cliffs may differ slightly from the current NRC staff interpretation of Appendix R criteria.
In view of the upcoming fire protection audit at Calvert Cliffs, we believe that it is in our best interests to ensure that protective features in place at Calvert Cliffs are either in strict conformance with Appendix R, or, where strict conformance is not practical (or where recent NRC staff interpretations appear to expand upon those previously accepted), that the NRC staff has reviewed and accepted our methods for satisfying the requirements on an alternate basis. Consequently, the Baltimore Gas and Electric Company hereby requests exemption from certain of the requirements contained in 10 CFR 50, Appendix R, as described below.
- 1. FIRE DOOR ASSEMBLIES An exemption is requested to credit the use of two existing watertight doors and one water curtain in lieu of rated fire door assemblies.
Discussion In Reference I the NRC granted BG&E an exemption from the requirements of Section III.G of Appendix R to the extent that it requires approsed fire door 8311290159 831121 005 PDR ADOCK 05000317 F
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Mr. 3. R. Mill r November 21,1983 assemblies.
With that exemption, specific non-rated watertight doors, bullet-proof doors, and water curtains (dedicated sprinklers) were approved for use in lieu of rated fire door assemblies.
Justification for the exemption was provided by BG&E in Reference 2, which contained the results of a Southwest Research Institute (SWRI) test report.
Similarly, exemptions are hereby requested for the following fire barrier penetrations:
- a. Emergency Hatches Nos. 3 & 4 These watertight doors allow passage between Service Water Pump Room No. 226 and East Penetration Room No. 227 (Unit 1), and between Service Water Pump Room No. 205 and East Penetration Room No. 206 (Unit 2), all on Elevation 5'-0".
Separation between the service water pump rooms is provided by these hatches as required to support the Interactive Cable Analyses (ICA's) for Unit I and Unit 2 (References 3 and 4). The distance between the hatches is in excess of 400'.
The watertight door tested by SWRI measured 3'-0" by 7'-0".
Emergency Hatches No. 3 and 4 measure 3'-0" by 3'-0" and were constructed in accordance with the same basic specifications as the test door, except for
- size,
- b. Unrated Metal Emergency Hatch Supplemented by Dedicated Water Curtain We propose to install a dedicated sprinkler head (water curtain) to provide three-hour protection for an unrated metal emergency hatch between Corrioor No.110 (Eley. - 10'-0") and Reactor Coolant Make-Up Pump Room No. 216A (Unit 2, Elev. S'-0"). Room 216 A is presently provided with sprinkler protection.
This sprinkler system will supply a dedicated sprinkler head on the Room 216A side of the hatch. On the Cerridor No.
110 side of the hatch, a dedicated sprinkler head will be supplied from the Room No.106 sprinkler system. The hydraulic capacity of the sprinkler systems supplying these dedicated heads is sufficient to ensure a water curtain density on both sides of the hatch consistent with that used in the SWRI test (see Reference 2).
Justification
'Ihe ability of Emergency Hatches Nos. 3 and 4 and the proposed water curtain to function as fire barriers in accordance with an equivalent ASTM E-Il9 three-hour test has been substantiated by the referenced SWRI testing; therefore, granting this exemption will not represent a significant hazard to the public health and safety.
References
- 1. NRC letter from R. A. Clark to A. E. Lundvall, Jr., dated August 16, W82.
- 2. BG&E letter from A.
E.
Lundvall, Jr. to R.
A.
Clark, dated February 18,1982.
- 3. BG&E letter from C.
H.
Poindexter to D.
G.
Eisenhut, dated September 30,1981 (enclosed Interactive Cable Analysis, Unit 1).
~
Mr. 3. R. Miller November 21,1983
- 4. BG&E letter from C.
H.
Poindexter to D.
G.
Eisenhut, dated January 29,1982 (enclosed Interactive Cable Analysis, Unit 2).
- 2. OIL COLLECTION SYSTEMS FOR REACTOR COOLANT PUMPS An exemption is requested from the physical protection requirements of 10 CFR 50, Appendix R, paragraph 111.O., Oil Collection Systems for Reactor Coolant Pumps, specifically as to the capacity of collection tanks.
Discussion and Justification
'Ihe list of references below provides a chronological listing of correspondence dealing with the oil collection system for reactor coolant pumps for Units I and 2.
Prior to publication of Appendix R, the Calvert Cliffs Fire Protection Safety Evaluation Report (FPSER) contained Unresolved Issue 3.3.4 which identified additional protection requirements for RCP lube oil collection (Reference 1).
In Reference 2, BG&E provided a description of the proposed modification to resolve SER Item 3.3.4.
In subsequent correspondence, (see References 3, 4, 5, 6 and 7) the SER items appear to have been resolved. After Appendix R was published (Reference 8), and following a review of Section III.0, BG&E requested an exemption for the fact that the collection tanks were not seismically qualified, although they were seismically supported (see Reference 9). In Reference 10, you advised us that the lube oil collection system met Section III.O requirements and that an exemption was not required. Subsequent correspondence (see References 11,12 and 13) confirmed the design criteria, installation and completion of modifications required for the oil collection system.
On March 31, 1983 the NRC promulgated information (see Reference 14) relative to inspection modules used by I&E to verify conformance with Appendix R, Sections III.G, III.3 and III.O. Subsequently, BG&E became privy to the results of some I&E inspections which identified various nonconformances to Appendix R requirements.
Specifically, some operating reactor licensees were cited for having lubricating oil collection systems not sized to hold the entire lubricating oil system's inventory. The cited system is similar in some respects to the systems installed at Calvert Cliffs (see References 2,5 and 12).
We request an exemption to permit the use of the present design consisting of two collection tanks in each containment sized to accomodate the largest potential oil leak. Each tank services two reactor coolant pump motors. This exemption request is based on the following justification:
- a. An oil spillage protection system has been provided for each reactor coolant pump motor. He system consists of encapsulating devices installed around all potential leakage points. Drain lines are sized and arranged to accommodate the maximum
- leak,
- b. 'lhe reactor coolant pump and associated tube oil collection systems with the exception of the oil collection tanks, have been designed and qualified to withstand the safe shutdown earthquake. The oil collection tanks, located on the containment floor, are not ASME Code qualified and are not seismically qualified.
They are, however, supported and restrained to prevent movement during the Design Basis Earthquake, thus providing assurance that they will perform their function during and following a Safe Shutdown Earthquake.
- c. All Lube Oil Collection Tank vents are equipped with U/L-approved flame arrestors.
.4 Mr. 3. R. Miller November 21,1983 t
- d. A surveillance procedure (O.P. #6) has been established to demonstrate that the oil collection systems remain functional, as follows:
- 1. At each refueling outage a visual examination of the encapsulation devices, drain piping, and oil collection tanks is performed prior to startup.
- 2. Prior to startup, the oil collection tank level is checked routinely in accordance with the procedure.
- e. The Lube Oil Collection Tanks are U/L - approved 275 gallon fue', oil tanks. The RCP motors have an upper bearing oil pot capacity of 200 gallons and a lower guide bearing oil pot capacity of 25 gallons. The reactor coolant pumps are separated by a horizontal distance of twenty-five feet and are seismically supported. 'Ihus, it is very unlikely that a seismic event would result in the e multaneous failure of both of the RCP lube oil systerr. i being served by the same oil collection tank. The total lube oil inventory of 225 gallons is accommodated by the capacity of the oil collection tank.
- f. Finally, the consequences of a simultaneous release of all the oil from two RCP motors would not be significant from a fire standpoint. Ignition of the oil is very unlikely, particularly with the encapsulation system in place, since the oil would remain within the collection system and would not come in contact with hot coolant piping, hangers or equipment. If the oil collection tank were to overflow, the oil would merely flow from the tank vent line down to the floor, an area free of ignition sources, then eventually flow to the containment sump.
References 1.
NRC letter from R. W. Reed to A. E. Ltmdvall, Jr., dated September 14, 1979 -
(enclosed Fire Protection Safety Evaluation Report).
2.
BG&E letter from A. E. Lundvall, Jr., to R. W. Reed dated November 13,1979.
3.
NRC letter from R. A. Clark to A. E. Lundvall, Jr., dated May 19,1980.
4.
BG&E letters from A. E. Lundvall, Jr., to R. A. Clark dated May 23, June 20 and September 26,1980.
5.
NRC letter from R. A. Clark to A. E. Lundvall, Jr., dated October 2,1980.
6.
BG&E letter from A. E. Lundvall, Jr., to D. G. Eisenhut dated January 30,1981.
7 NRC letter from R. A. Clark to A. E. Lundvall, Jr., dated February 10,1981.
8.
10 CFR 50.48, Fire Protection (45 FR 76610,11/19/80).
9.
BG&E letter from A. E. Lundvall, Jr., to D. G. Eisenhut dated March 19,1981, t
ir
- 10. NRC letter from H. R. Denton to A. E. Lundvali, Jr., dated June 30,1981.
o
- 11. NRC letter from R. R. Keimig to A. EcLut.dvall, Jr.,
ted September 2,1981.
- 12. BG&E letter from A. E. Lundvall, Jr., to R. A. Clark dated November 6,1981.
o
Mr. J. R. Miller November 21,1983
- 13. NRC letter from R. A. Clark to A. E. Lundvall, Jr., dated March 18,1982.
- 14. NRC letter from T. T. Martin to A. E. Lundvall, Jr., dated March 31,1983 (provided Temporary Instruction 2515-61-032 Oil Collection System for Reactor Coolant Pump).
/
- 3. PARTIAL SPRINKLER COVERAGE An exemption is requested from the automatic suppression system requirements of Section III.G of Appendix R to 10 CFR Part 50 to allow partialcoverage in Fire Areas 10 and 11. Rooms included in the areas are shown on Attachment 1.
Equipment and cables necessary~to achieve hot and cold shutdown located in these rooms are indicated in our Unit I and Unit 2 Interactive Cable Analyses (References 1 and 2).
Further information relating to Areas 10 and 11 follows:
Discussion and Justification
- a. Area 10 All rooms in this area, with the exception of Rooms 104,108,110 and 111, contain automatic suppression systems. All rooms contain automatic detection systems.
Area 10 does not contain equipment or cables for both trains of redundant shutdown systems. Area 10 is separated from adjacent areas by a combination of 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and 1-1/2-hour rated fire barriers.
All rooms whose walls, ceiling, or floor form boundaries with adjacent fire areas and are rated for 1-1/2 hours are equipped with automatic suppression systems throughout the room. Additionally, automatic suppression is provided in the adjacent area. The four rooms which are not equipped with automatic suppression systems carry a 3-hour rating for all barriers which separate Area 10 from adjacent areas.
2 The fixed fire load in these four rooms ranges from 1300 BTU /ft to550p 2
BTU /ft. Average fixed fire load throughout Area 10 is approximately 2350 BTU /ft.
This represents an equivalent ASTM E-119 fire of less than five minutes. Administrative controls are in effect to carefully control transient combustibg loading introduced into work areas. An additional transient load of approximately 7x10 BTU (equivalent to over 88,000 lbs. of ordinary combustibles or 4600 gallons of lubricating oil) would have to be added to this area to provide the fuel to support an equivalent ASTM E-Il9 fire of one and a half hours (the minimum barrier rating separating this area from adjacent areas).
This extremely, low fire loading, when considered with the fact that automatic detection systems are provided throughout the area, and that three-hour barriers are provided for. non-protected rooms, obviates the nead for additional automatic suppression systems in Area 10.
- b. Area 11 Rooms 107,109,112,116, 211, 214, 218, 220, 221, 308, 313, 314, 319, 320, 321, 322, 323, 324, 325,326,410 and 411 do not contain automatic suppression systems.
Additionally, no automatic suppression is provided on elevation 69'-0". All other rooms in this area are protected by automatic suppression systems.
Automatic detection is provided throughout this area.
Mr. J. R. Miller November 21,1983
(
Two of three power feeds from the emergency diesel generators to Unit 2 are located in the overhead of Room 419 (cask loading area - elevation 45'-0"), south and west of the spent fuel pool. He third power feed for Unit 2 is located in the overhead of Room 523 (Corridor - Elevation 69'-0"). Room 419 is protected by automatic suppression and detection systems.
Room 523 contains automatic detection.
The floor slab separating these rooms is constructed of reinforced concrete 2-1/2 feet thick. His slab constitutes a 3-hour rated barrier east of the spent fuel pool. Although of similar construction, the slab west of the spent fuel pool is penetrated by a large hatch. He hatch is closed by a class "A" rated rolling door. De door, however, is installed horizontally (an untested position), therefore no credit is taken for this section of floor slab.
De path which must be utilized for a fire to communicate with diesel generator power feeds is from Room 419 through the hatch, across a horizontal distance cef more than 40 feet free of combustibles (this distance includes the spent fuel popl) and into corridor 523. Fixed fire load in corridor 523 is extremely low,600 BTU /ft. The combination of a low fire load, adequate horizontal separation, a convoluted fire propagation path, and the presence of automatic detection and automatic suppression systems in Room 419 obviate the need for automatic suppression systems throughout Area 11.
With the exception of the diesel generator power feeds described above, no fire damage within Area 11 can render all trains of redundant shutdown systems inoperable.
Area 11 is separated from adjacent areas by a combination of 3-hour and 1-1/2 hour fire rated barriers. All rooms whose walls, ceiling, or floor form boundaries with adjacent fire areas and are rated for 1-1/2 hours are equipped with automatic suppression systems throughout the room.
Additionally, automatic suppression is provided in the adjacent area. Rooms which are not equipped wit's automatic suppression systems carry a 3-hour rating for all barriers which separate area 11 from adjacent areas.
Fixed fity load in non-prgtected rooms within this area ranges from essentially 0 BTU /ft to 10,000 BTU /ft. Average fire load in area 11 is approximately 2
5000 BTU /ft. This represents an equivalent ASTM E-Il9 fire of less than 5 minutes.
Administrative controls are in effect to carefu'.ly control transient combustible !gading introduced into work areas.6An additional transient load of approximately 9.5 x 10 BTU (equivalent to over 1.2 x 10 lbs of ordinary combustibles or 62,000 gallons of lubricating oil) would be necessary to support the equivalent of an ASTM E-Il9 l-1/2 hour fire, the minimum rating of fire barriers separating this from adjacent areas.
He physical separation of redundant c:bles within this area, when considered in conjunction with the presence of automatic detection, extremely low fixed fire loads, and 3-hour fire rated barriers in non-protected rooms, obviates the need to install additional automatic suppression systems in Area 11.
References
- 1. BG&E letter from C. H. Poindexter to D. G. Eisenhut, dated September 30,1981 (enclosed Interactive Cable Analysis, Unit 1).
- 2. BG&E letter from C. H. Poindexter to D. G. Eisenhut, dated January 29,1982 (enclosed Interactive Cable Analysis, Unit 2).
l Mr. 3. R. Mill:r November 21,1983 If you should have any questions concerning these exemption requests, please do not hesitate to contact us.
BALTIMORE GAS & EIECTRIC COMPANY Jl d, f( "! e.f y,L rt l f
~
1
(
By:
A. E. LuMyall, Jr.
Vice President - Supply STATE OF MARYLAND :
TO WIT:
CITY OF BALTIMCRE Arthur E. Lundvall, Jr., being duly sworn, states that he is Vice President of the Baltimore Gas and Electric Company, a Corporation of the State of Maryland; that he executed the foregoing for the purposes therein set forth; that the statements made therein are true and correct to the best of his knowledge, information, and belief; and that he was authorized to execute the same on behalf of said Corporation.
WITNESS My Hand and Notarial Seal:
/[ r<'b' rd
('
Notary Public AEL/PEK/RPH/BSM/vf Attachments cc: 3. A. Biddison, Jr., Esq.
G. F. Trowbridge, Esq.
Mr. D. H. Jaffe, NRC Mr. R. E. Architzel, NRC
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