ML20106C543
| ML20106C543 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 02/08/1985 |
| From: | Devincentis J PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| To: | Knighton G Office of Nuclear Reactor Regulation |
| References | |
| SBN-762, NUDOCS 8502120293 | |
| Download: ML20106C543 (8) | |
Text
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. M SEABROOK STATION Engineering Office February 8, 1985 PutAc Service of New M SBN-762 T.F.:
B7.1.2 Now Hampshire Yonkee Divlelen United States Nuclear Rt ulatory Commission Washington, D. C. 20555 Attention:
Mr. George W. Knighten, Chief Licensing Branch No. 3 Division of Licensing
References:
(a) Construction Permits CPPR-135 and CPPR-136, Docket Nos. 50-443 and 50-444 (b) PSNH Letter SBN-248, dated April 1,1982, "Seabrook Station Fire Protection Program", J. DeVincentis to F. J. Miraglia (c) PSNH Letter SBN-429, dated January 21, 1983, "Open Item Responses",
J. DeVincentis to G. W. Knighton (d) PSNH Letter SBN-714, dated September 14, 1984, "Seabrook Station Fire Protection of Safe Shutdown Capability (10CFR50, Appendix R); Revision 1", J. DeVincentis to G. W. Knighton
Subject:
Seabrook Station Fire Protection Program; 10CFR50, Appendix R Deviation Request
Dear Sir:
In Reference (d), we submitted our Revision 1 to the "Seabrook Station Fire Protection of Safe Shutdown Capability (10CFR50, Appendix R) Report".
Subsequent to that submittal, we have identified two additional deviations to the requirements of Appendix R.
Justification for these deviations is offered herein.
We have attached, for the staff's review, the fol. awing two proposed deviations:
I.
Attachment A.
Reactor Coolant Pump Lube Oil Collection System i
Deviation II.
Attachment B.
RWST Area Deviation in the form of marked-up Tabulation 3.1.4.55 of Fire Protection of Safe Shutdown Capability Report. This will be included in the next revision to the report.
Attachment C is FSAR Section 9.5.1.3 marked-up to provide a description of th'e Reactor Coolant Pump Lube Oil Collection System. This wi.11 be included in a future FSAR Amendment.
The contents of the proposed deviations have been discussed with the staff, and we expect that these deviations will be incorporated into a future supplement to the SER.
P.O. Box 300 Seabrook.NH03874
- Telephone (603)474-%21 N
8502120293 850200 PDR ADOCK 05000443 1
F PDR
.y iUnit'ed States Nuclear Regulatory Commission
~ Attention:
-Mr.. George W. Knighton Page 2 w'
r Should you have any questions regarding the proposed deviations, please do'not' hesitate.to contact us.
Very truly yours, UJ
, _ 4 ohn DeVincentis, Director Engineering and Licensing
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Attachment 3
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' Atomic' Safety'and Licensing Board Service List cc:
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tilliam S. Jordan, III
.Diann Curran Harmon, Weiss & Jordan Brentwood Board of Selectmen 20001 S Street N.W.
RED Dalton Road Suite 430 Brentwood, New Hampshire 03833 Washington, D.C.
20009 Robert'G. Perlis Office of the Executive Legal Director Edward F. Meany U.S. Nuclear Regulatory Commission Designated Representativq of Washington, DC 20555 the Town of Rye 155 Washington Road Robert A. Backus Esquire Rye, NH 03870 116 Lowell Street F.O. Box 516 Calvin A. Canney Mancehster NH 03105 City Manager City Hall Philip Ahrens, Esquire 126 Daniel Street Assistant Attorney General Portsmouth, NH 03801 Department of the Attorney General Augusta, ME 04333 Dana Bisbee, Esquire Assistant Attorney General Mr. John B. Tanzer Office of the Attorney General i
Designated Representative of 208 State House Annex the Town of Hampton Concord, NH 03301 5 Morningside Drive Hampton, NH 03842 Anne Verge, Chairperson Board of Selectmen Roberta C. Pevaar Town Hall Designated Representative of South Hampton, NH 03642
- the Town of Hampton Falls Drinkwater Road Patrick J. McKeon Hampton Falls, NH 03844 Selectmen's Office 10 Central Road Mrs. Sandra Gavutis Rye, NH 03670 Designated Representative of the Town of Kensington Carole F. Kagan, Esq.
RFD 1 Atomic Safety and Licensing Board Panel
-East Kingston, NH 03827 U.S. Nuclear Regulatory Commission
-Jo Ann Shotwell, Esquire Assistant Attorney General Mr. Angie N6chiros Environmental Protection Bureau Chairman of the Board of Selectmen Department of the Attorney General Town of Newbury One Ashburton Place, 19th Floor Newbury, MA 01950
. Boston, MA 02108 Town Manager's Office Senator Gordon J. Humphrey Town Hall - Friend Street U.S. Senate Amesbury, Ma.
01913 Washington, DC 20510 (Atta: Tom Burack)
Senator Gordon J. Humphrey 1 Pillsbury Street
' Diana P. Randall Concord, NH 03301 70 Collins Street (Attn: Herb goynton)
SEabrook, NH 03874 Richard E. Sullivan, Mayor Donald E. Chick City Hall Town Manager Newburyport, MA 01550 Town of Exeter 10 Front Street Exeter, NH 03833 i
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SBN-762.
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ATTACHMENT A 4
.. ' REACTOR COOLANT PUMP LUBE'0IL COLLECTION SYSTEM DEVIATION iDescription
' Seabrook Station has :four reactor coolant pumps per Unit. The seismically-
- designed lube oil collection system for these. pumps has been designed with two l
! collection' tanks. Two pumps drain to each tank. Each of the two tanks has Jbeen sized to.contain 125% of the oil inventory of one pump. Therefore, each itank;will-not protect against the consequence of simultaneous failure of the
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- two reactor coolant pumps for'which it collects oil. This design does not n'et<the guidance on interpretation of Section III.0, " Oil Collection Systems e
- for Reactor Coolant Pump", as delineated in IE Information Notice No. 84-09,-
Lessons Learned from NRC Inspection'of Fire Protection Safe Shutdown Systems J(10CFR50, Appendix R).
? Justification "The NRC' staff position on the capacity of a reactor coolant pump oil
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collection system which meets Section -- '.0 of Appendix R to 10CFR50 is:
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'One'or.more tanks need to be provided with sufficient capacity
' to collect the total-lube oil inventory from all reactor coolant pumps: draining to the container.
IEach Seabrook Station ' react'or coolant pump contains approximately 240 gallons
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fofUoil. Each' collection tank has a capacity.of 320 gallons. The tanks were
- 'j sized to hold the-entire inventory of one pump plus 25%. However, if the lube
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' oil systems for two pumps'were-to fail simultaneously, there would-be an
> excess! of 160 gallons of oil per ' tank.
In order to contain this excess oil, a seismically' designed dike willJbe built'around the tank. The tanks and their dikes are -located such that the excess oil does not present a fire hazard to l'
c:any safety-related equipment. Additionally, there is no ignition source near 3
- ,Z " the diked. area.-
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- We-believe this' design. is' a suitable alternative to that required. in Section.
~ ~ - 'III 0'of Appendix R,'and this deviation'will not decrease =the fire safety of:
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Page 1 of 2 7
M SBN-762 February 8, 1985
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ATTACHMENT B
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TABULATION-3.1.4.55 TANK FARM (RWST)
FIRE AREA:
TF-F-1-0
'A.
EQUIPMENT AND CABLES LOCATED IN THE FIRE. AREA l
Train A Train B Description Equip.
Cable Description Eauio.
Cable Valve CS-LCV-112D X
X Valve CS-LCV-112E X
X B.' - ' ANALYSIS The tank farm refueling water storage tank (RWST) area contains redundant valves CS-LCV-112D and CS-LCV-112E for the lines to the charging pumps to provide make up-to the reactor coolant system when going to cold
-shutdown.
The tank-farm RWST area is approximately 65 ft long by 48 ft wide by 60 feet high with a concrete dike 22 ft above the grade Elevation 20'-0".
(T There are no in situ combustibles in the area. All cables, including safe shutdown cables, are routed in conduit. The closest tray to the Train B conduits has a horizontal separation of 20' with an intervening
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E concrete dike. The redundant valves-are separated by approximately h.
The main control room does not'have to be evacuated for a fire in this
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g area and other than the RWST valves, no safe shutdown equipment is pSe affected by a fire in this area. <,
Valves CS-LCV-112D and CS-LCV-112E are required to be operated for Safe Shutdown. However, these valves are not needed for at'least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> into the event and can be opened manually, if required.. Based on'the length of time before manual' operation is required, no emergency'
' lighting'is provided.
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EVALUATION YS dnA The Safe Shutdown requi cments are satisfied. Ie/gotteertBM
" { Appendix R, Paragraph [III. J. emergency lighting 77,eso requirements exists in the tank farm. -T.h.Fe deviation '
us ified
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based on the above analysis and our assertion that addit onal g;
- modifications would not enhance fire protection safety.
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,;f ATTACHMENT B
- Tabulation 3.1.4.55 c.s
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. Insert:al-Because the area is surrounded completely by the 22:'ft. dike, l& '.
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there is no traffic'through 'the area, and'no>b'uild-up of trash.
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The'most likely place for.a fire to occur would be in the valve
- motors themselves'.- Thepositionof'theRhSTvalvesare~
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' : monitored by. three electrically, independent circuits. The primary means of' indication is the valve position lights
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located'on;the main control board and powered-by the valve y
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~ control-ciruit._ Secondary indication is provided by. valve ft '
2open'and. valve closed monitoring lights.ontthe control board.;
- Addtionally, the computer monitors the valve position and alarms on'. valve not fully. closed. Fire induced failures.that'
.cause repositioning of val've'will be evidenced by a status change of the indicating light circuits. Failures which I
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~ result :in loss of-power will also be indicated by an absence R
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- of~ indication on'the' main' control board.
. 1 JInsert b'-- Valve positiion indication Iis.provided.in the Control-. Room.
~ Valves CS-LCV-.112D and' CS-LCV-112E are required to be operated
'for safe shutdown.+ However, they_are no required for at.least
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8l hours, and can be'openef, manually if required.
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JATTACHMENT C age 1 of 2
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SB l.& 2 Amendment 53
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February 8,1985
- FSAR, August 1984 g
1.
All fire protection systems in areas containing safe shutdown equip-ment are preaction systems to preclude inadvertent system trip.
Piping in the safe shutdown equipment areas is seismically supported.
Drains are provided in these areas to conycy any fire protection 53 water away from the fire zone.
The status of all fire detection circuits is provided at the control m.
console in the control room and on a local control panel. Alarm, l
derector malfunction, or detector removal are annunciated for operator v5
- action, The plant communication system is available to alert personnel of l
n.
A a fire, its location, and remedial action required.
53 7
A failure modes and effects analysis for the systems and components o.
is described in Table 9.5-4.
9.5.1.4 Inspec tion and Testing Requirements a.
Preoperational Testing 1.
Automatic systems (wet pipe sprinkler, preaction sprinkler, deluge water cpray) are inspected and tested using the general guidelines of NFPA-13 and 15.
33 2.
Yard piping, standpipes and hose stations (excluding the hoses) are hydrostatically tested to a pressure of 200 psig for a period of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> using the general guidelines of NFPA-13 and 14.
Fire hoses will be tested and maintained using the general guidelines of NFPA-198.
3.
Fire pump field acceptance tests are performed using the general guidelines of NFPA-20.
4.
Halon 1301 systems are tested and inspected using the general guidelines' of NFPA-12A.
53 5.
Final inspection and tests of completed installations are made in the presence of the ANI representative.
h.
Su rve illance Inspection of fire protection equipment will be made with filled out reports reviewed by the fire protection engineer and filed for examination by an ANI representative.
53 Y i 9.5-10
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Page 2 of 2 ATTACHMENT C
. FSAR Section 9.5.1.3
- Insert a --
- p.
The reactor coolant system has four reactor coolant pumps.
- The seismically designed lube oil collection system for these pumps has been designed with two collection tanks. Two pumps drain to each tank. Each of the two tanks has been sized to
~contain-125% of the oil inventory of one pump. A seismically-
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designed-dike has been provided around each tank. Each
. tank in combination with its associated dike has been sized to contain the entire inventory of two pumps. The tanks I
and the dikes'have been located such that the excess oil
/.oes not present.a. fire hazard to any safety-related equigment.
--Additionally, there is'no ignition source near the-diked area.
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