ML20086H033

Requests Review & Concurrence W/Listed Changes to Info Reflected in Amend 43 to License DPR-28

ML20086H033
Person / Time
Site:	Vermont Yankee
Issue date:	07/13/1995
From:	Reid D VERMONT YANKEE NUCLEAR POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
BVY-95-77, NUDOCS 9507170387
Download: ML20086H033 (3)

Text

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" VERMONT YANKEE ,

NUCLEAR POWER CORPORATION  :

w Ferry Road, Brattleboro, vT 05301-7002 acety to j

ENGINEERING OFFICE 580 MAIN STREET BOLToN. MA 01740 (508)779-6711 ~

July 13,1995 BVY 95-77 United States Nuclear Regulatory Commission ATTN: Document Control Desk  !

Washington, DC 20555 ,

References:

(a) License No. DPR-28 (Docket No. 50-271)  ;

(b) Letter, USNRC to VYNPC, NVY 83-5, Safety Evaluation to Appendix R to - >

j 10 CFR 50 items lil.G.3 and Ill.L, dated January 13,1983 l (c) Letter, USNRC to VYNPC, Amendment 43 to Facility Operating License, dated January 13,1978 '

(d) Letter, USNRC to VYNPC, NVY 90-213, Alternative Testing Method for Cable Vault CO2 Fire Suppression System for Vermont Yankee Nuclear Power Station (TAC NO. 75502), dated November 29,1990

Subject:

Removal of Fire-Rating on Control Room (Floor)/ Cable Vault (Ceiling) l Electrical Penetration Barrier, Re designation of Control Room, Cable j Vault, and Battery Room into Single Fire Area  ;

1 The purpose of this letter is to request NRC review and concurrence with the following -

changes to information reflected in Amendment 43 to the Facility Operating License  !

[ Reference (c)): }

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1) Redesignation of the Control Room, Cable Vault, and Battery Room as a single fire i area i

2) Delete the requirement to maintain the electrical penetration seal between the Control Room and Cable Vault as a rated fire barrier Technical justification is provided in this letter to support the above changes, as well as, the i re-classification of the barrier, in Vermont Yankee procedures, to an " Appendix A" barrier  !

[ Reference (b)], as an interim measure.

7 NCO' j; 95o71703s7 950713 PDR ADOCK 05000271 )6 1

i VERMONT YANKEE NUCLEAR POWER CORPORATION United States Nuclear Regulatory Commission July 13,1995 '

PageS Room, Cable Vault, or Switchgear Room-West. That being the case, no additional safety benefit is achieved by maintaining the Control Room, Cable Vault, and Battery Room as separate fire areas.

Based on the above, Vermont Yankee wishes to re-designate the Control Room, Cable Vault, and Battery Room as a single fire area, but separated into three zones. There are fire detection systems in all three locations, and automatic suppression capabilities currently exist in the Cable Vault and Battery Room.

The most significant single program change associated with this re-designation is that the Control Room Floor / Cable Vault ceiling will no longer be maintained as a rated fire barrier.

The barrier will be maintained as a smoke / gas seal to ensure no negative effects on the design of the Cable Vault CO2 Suppression System or on Control Room habitability. The capability of the installed configuration to perform as a smoke / gas seal was demonstrated by testing at Vermont Yankee in 1989, and the test results have been reviewed and accepted by NRC Staff, [ Reference (d)).

Vermont Yankee is requesting NRC review and concurrence with the above described change.

Upon receipt of NRC concurrence, applicable Vermont Yankee documents, (i.e. Fire Hazards Analysis and Safe Shutdown Capability Analysis as well as applicable operating and surveillance procedures) will be revised to reflect the new fire area designation and barrier classifications. In the interim, an hourly fire watch for the Control Room barrier is being maintained in accordance with plant procedures.

Should you have any questions regarding this request, please do not hesitate to contact us.

Sincerely, VERMONT YANKEE NUCLEAR POWER CORP.

i Donald A. Reid Vice President, Operations cc: USNRC Region I Administrator USNRC Resident inspector - VYNPS USNRC Project Manager - VYNPS l

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VERMONT YANKEE NUCLEAR POWER CORPORATION l United States Nuclear Regulatory Commission

! July 13,1995 Page 2 l.

b BACKGROUND During a recent once-per-cycle surveillance of Vital Fire Barrier penetration seals, as required by Technical Specification Section 4.13.E.1, some electrical penetrations in the fire barrier between the Control Room (floor) and Cable Vault (ceiling) were determined to not conform with a fire tested configuration. The barrier was declared inoperable and compensatory actions were initiated. The barrier had been conservatively classified as a 10 CFR 50 Appendix R barrier in plant procedures, and as such, a continuous fire watch was established.

During the evaluation of potential repair options, an assessment of the effect on safe shutdown capability was performed assuming a non-rated barrier between the Control Room i and Cable Vault. The assessment confirmed the barrier is not required to ensure compliance {

with Appendix R. The Safety Evaluation for Appendix R, issued to Vermont Yankee in i January 1983 [ Reference (b)], was also reviewed as part of the assessment. As a result of i the assessment, the applicable plant procedures were revised to change the barrier classification to an " Appendix A" [ Reference (c)] barrier, and the compensatory fire watch <

was subsequently reduced to an hourly watch.

1 JUSTIFICATION The original Vermont Yankee Fire Hazards Survey (1977) listed designated fire areas, taking credit for installed walls and floors as adequate separation. The 1978 NRC Fire Protection Safety Evaluation, provided to Vermont Yankee, via Reference (c), added requirements for upgrading some penetration seals in certain barriers between the areas. The barrier between the Control Room and the Cable Vault contained penetration seals requiring an upgrade.

Subsequent to the 1978 Safety Evaluation,10 CFR 50, Appendix R was issued, applying additional requirements and requiring a Safe Shutdown Capability Analysis. l A specific requirement of Appendix R Section Ill.G is to provide "... separation of cables and l

equipment and associated non-safety circuits of redundant trains by a fire barrier having a 3-hour rating." Based on the conclusions in the Vermont Yankee Safe Shutdown Capability Analysis, and the design of the installed Alternate Shutdown System, the equipment affected by a fire in the Cable Vault or the Control Room is the same (not redundant); therefore, a 3-hour rated barrier between these rooms is not required. The Battery Room is considered part of the Cable Vault for purposes of the Safe Shutdown Analysis.

The Safe Shutdown Capability Analysis, accepted in the 1983 Safety Eva!uation to Appendix R [ Reference (b)], describes the use of an Alternate Shutdown System to bring the plant to l cold shutdown following a fire in the Control Room, Cable Vault, or Switchgear Room-West. l The High Pressure Coolant injection System is used should a fire occur in the Switchgear i Room-East. The effects on safe shutdown capability are the same for a fire in the Control

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