ML20093E194

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Requests Exemption from Provisions of 10CFR50,App R,Section Iii.G, Fire Protection of Safe Shutdown Capability. Appropriate Procedure Will Provide Shifting of Battery Charger Leads to Spare Charger within 24 H of Fire
ML20093E194
Person / Time
Site: Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date: 07/10/1984
From: Murphy W
VERMONT YANKEE NUCLEAR POWER CORP.
To: Vassallo D
Office of Nuclear Reactor Regulation
References
FVY-84-85, NUDOCS 8407170409
Download: ML20093E194 (2)


Text

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I ' VERMONT YANKEE 3

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UCLEAR POWER CORPORATION

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FVY 84-85 RD 5, Box 169. Ferry Road, Brattleboro, VT 05301 ENGINEERING OFFICE 5

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1671 WORCESTER ROAD FRAMINGHAM. MASSACHUSETTS 01701 i

TELEPHONE 617-872-6100

,l July 10, 1984 U.S. Nuclear Regulatory Commission l '! 't,

Washington, D.C.

20555 a

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W Attention:

Office of Nuclear Reactor Regulation l 4 Mr. Domenic B. Vassallo, Chief

J Operating Reactors Branch No. 2 Division of Licensirg

References:

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

Letter, VYNPC to USNRC, FVY 81-117, dated 7/31/81 c

Letter, VYNPC to USNRC, FVY 82-72, dated 6/16/82 d)

Letter, USNRC to VYNPC, FVY 82-119, dated 11/12/82 j

e)

Letter, USNRC to VYNPC, NVY 83-05, dated 1/13/83

Dear Sir:

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Subject:

Request for Exemption - 10CFR Part 50, Appendix R. " Fire o

Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979

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In accordance with the provisions of 10CFR Part 50.12, Vermont Yankee

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. Nuclear Power Corporation hereby requests an exemption from the provisions of 10CFR Part 50, Appendix R, Section III.G, " Fire Protection of Safe Shutdown 1y**

Capability". Specifically, we are requesting exemption from the provision of

~ Section Ill.G.I.a to Appendix R.

Section III.G.1.a requires that, "One train of

' systems necessary to achieve and maintain hot shutdown conditions from either the contrul room or Emergency Control Station (s) is free of fire damage."

Our. App'endix R, Alternate Safe Shutdown System, which was designed to I

address a fire,in the Control Room, Switchgear Rooms and Cable Vault, and is

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described in detai1 in Reference b), includes instruments powered from the 24 Volt Bat *ary System located in the Reactor Building, which are used to achieve hot shutoown. To ad.fress the requirements of 10CFR 50.49, " Environmental Qualification of Safety-Related Electrical Equipment," it has become necessary to relocate the battery chargers for the 24 Volt Battery System from the Reactor Building to the Switchgear Rooms.

In the event of a fire in the Cable Vault, the 24 volt battery chargers would be disabled.

The associated batteries, which carry only post-fire loads, would be discharged in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, according to our calculations. To address tM loss of these battery chargers, we will install a spare battery charger in the Reactor Building.

Leads from the spare charger will be run to the distribution panel, be lugged, and taped back.

This installation will be completed during B407170409 840710 PDR ADOCK 05000271 F

PDR k$ D

  • a U.S. Nuclear Regulatory Commission July 10,1984 Pag 2 2 VIII(MONT YANKisit NUCLI? Alt Powlitt ColtI>oitATioN our 1984 refueling outage with the exception of one breaker which will not be delivered until September. Until the new breaker is installed, the existing breaker to one of the 24 volt battery chargers will be removed and used to supply the spare battery charger should it become necessary.

Because Section III.G.I.a does not allow for repairs to achieve and main-tain hot shutdown, we are requesting an exemption from this provision.

Appropriate procedures will be in place to provide for the shifting of the bat-tery charger leads to the spare charger and installation of the breaker within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of a tire in the Cable Vault.

Section III.G.1.0 allows repairs to achieve cold shutdown within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. We believe that sqifting battery charger leads is consistent with this philosophy.

Based on the time available to perform this action, and the availability of the spare battery charger, we believe that the public health andd safety is pro-tected in a fashion equivalent to that resulting from compliance with the tech-nical requirements of Section III.G.1.a of Appendix R.

We trust that this request is deemed acceptable; however, should you have any questions in this matter, please contact us.

Very truly yours, VERMONT YANKEE NUCLEAR POWER CORPORATION e

Warren P., Murphy Vice President and Manager of Operations WPM /dm STATE OF VERMONT) ss WINDHAM COUNTY Then personally appeared before me, Warren P. Murphy, who, being duly sworn, did state that he is Vice President and Manager of Operations of Vennont Yankee Nuclear Power Corporation, that he is duly authorized to execute and file the foregoing document in the name and on the behalf of Vermont Yankee Nuclear Power Co n and that the statements therein are true to the best of his know gehkMSGS S

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1-Diane M. McCue i

Notary Public On@d My Commission Expires February 10, 1987 1

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