ML20093E458
| ML20093E458 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 07/16/1984 |
| From: | Oneill J CAROLINA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| OL, NUDOCS 8407170561 | |
| Download: ML20093E458 (6) | |
Text
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i July 16, 1984 DOCnrico U%Rc "
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'g4 JJL 17 go:44 BEFORE THE ATOMIC SAFETY AND LICENSING BOARDb N
l.
In the Matter of
)
)
CAROLINA POWER & LIGHT COMPANY
)
Docket Nos. 50-400 OL and NORTH CAROLINA EASTERN
)
50-401 OL MUNICIPAL POWER AGENCY
)
)
(Shearon Harris Nuclear Power
)
Plant, Units 1 and 2)
)
1 APPLICANTS' MOTION TO AMEND EDDLEMAN CONTENTION 116 Applicants Carolina Power & Light Company and North Carolina Eastern Municipal Power Agency hereby petition the Board to amend Eddleman Contention 116 by replacing the lan-guage adopted by the Board in its Memorandum and Order dated January 17, 1983, with the following text:
l The fire hazard analysis of section 9.5A (Appendix) in the FSAR does not ad-dress the availability of control and power to the safety equipment.
In establishing fire resistance ratings of fire barriers with respect to fires in cable trays, Ap-
[
plicants have not established that qualifi-cation tests represent actual plant condi-tions or comparable conditions.
Another-vague statement is that fire barriers are used "where practical" without defining practical or stating the criteria to decide where a fire barrier is or is not practical (and what type of fire barrier should be i
used).
FSAR 9.5.1.1.1.
The " analysis" of Appendix 9.5A does not-demonstrate, as 9.5.1.1.1 claims it will, the adequacy of other fire protection measures in all cases.
Rather, it estimates the BTU of 8407170561 840716 PDR ADOCK 05000400 0
PDR 4
e combustible material, smoke generation and removal rate from the area, gives usually a qualitative description of some measures to mitigate or reduce fire effects, and as-sumes that the fire will be promptly de-tected (usually, no analysis of location of detection instruments, etc.) and the fire brigade will respond rapidly and put out the fire, or the automatic equipment will work.
These assertions are made despite the time it takes to get people into the containment and to the fire (not well ana-lyzed).
Further, the " analysis" of what happens if the fire spreads is generally a rationalization that it can't spread much, not an analysis.
- See, e.g.
" Analysis of Effects of postulated fires."
The effect of a fire in a fire area or a fire zone with a combustible loading greater than 240,000 BTU /sq. ft. doesn't get dealt with in realistic terms.
The plant firefighting capability for simultaneous fires is inade-quate, or at least unanalyzed.
This amended text reflects certain modest agreements reached between Mr. Eddleman and Applicants as a result of dis-cussions regarding the scope of Eddleman Contention 116.
Mr.
Eddleman requested that Applicants state for the record, as part of this Motion, that his agreement te withdraw certain al-legations regarding Applicants' ability to deal with fires in containment was based on Applicants' representatiol.s regarding the ability of the fire brigade to enter containment through an air lock, if accessible, or, if containment were inaccessible (e.g. due to high radiation levels) to activate the containment spray system after isolating the sodium hydroxide system.
\\
Applicants are authorized to represent that Mr. Eddleman and the NRC Staff concur with this Motion.
Res' ctullysubmikted,
)
~
<j p
(,,f(, fA
,[f.
f p-p Thomas A.
- Baxter, P.C.
1John H. O'Neill, Jr., P.C.
$ HAW, PITTMAN, POTTS & TAOWBRIDGE 1800 M Street, N.W.
Washington, D.C.
20036 (202) 822-1148 Richard E. Jones Samantha Francis Flynn CAROLINA POWER & LIGHT COMPANY P.O. Box 1551 Raleigh, North Carolina 27602 (919) 836-7707 Counsel for Applicants Dated:
July 16, 1984
t UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
CAROLINA POWER & LIGHT COMPANY
)
Docket Nos. 50-400 OL and NORTH CAROLINA EASTERN
)
50-401 OL MUNICIPAL POWER AGENCY
)
)
(Shearon Harris Nuclear Power
)
Plant, Units 1 and 2)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Motion to Amend Eddleman Contention 116" were served this 16th day of July, 1984, by deposit in the U.S. mail, first class, postage prepaid, upon the parties listed on the ttached S vice$ List. )
t gL) i h
x John H. O'Neill, Jr.,
. C/.
.)
Date:
July 16, 1984
i i
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
CAROLINA POWER & LIGHT COMPANY
)
Docket Nos. 50-400 OL and NORTH CAROLINA EASTERN
)
50-401 OL MUNICIPAL POWER AGENCY
)
)
(Shearon Harris Nuclear Power
)
Plant, Units 1 and 2)
)
SERVICE LIST James L. Kelley, Esquire John D.
Runkle, Esquire Atomic Safety and Licensing Board Conservation Council of U.S. Nuclear Regulatory Commission North Carolina Washington, D.C.
20555 307 Granville Road Chapel Hill, North Carolina 27514 Mr. Glenn O. Bright M.
Travis Payne, Esquire Atomic Safety and Licensing Board Edelstein and Payne U.S. Nuclear Regulatory Commission P.O. Box 12607 Washington, D.C.
20555 Raleigh, North Carolina 27605 Dr. James H. Carpenter Dr. Richard D. Wilson Atomic Safety and Licensing Board 729 Hunter Street U.S. Nuclear Regulatory Commission Apex, North Carolina 27502 Washington, D.C.
205.55 Charles A.
Barth, Esquire Mr. Wells Eddleman.
Janice E. Moore, Esquire 718-A I Office of Executive Legal Director Durham,pedell Street North Carolina 27705 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Docketing and Service Section Richard E. Jones, Esquire Office of the Secretary Vice President and Senior Counsel U.S. Nuclear Regulatory Commission Carolina Power & Light Company Washington, D.C.
20555 P.O. Box 1551 Raleigh, North Carolina 27602 Mr. Daniel F. Read, President Dr. Linda W. Little CHANGE Governor's Waste Management Board P.O. Box 2151 513 Albemarle Building Raleigh, North Carolina 27602 325 North Salisbury Street Raleigh, North Carolina 27611
t-Bradley W. Jones, Esquire U.S. Nuclear Regulatory Commission Region II 101 Marrietta Street Atlanta, Georgia 30303 Steven F.
Crockett, Esquire Atomic Safety and Licensing Board Panel l
U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Mr. Robert P. Gruber Executive Director Public Staff - NCUC P.O. Box 991 Raleigh, North Carolina 27602 Administrative Judge Harry Foreman Box 395 Mayo University of Minnesota Minneapolis, Minnesota 55455
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