ML20126F269
| ML20126F269 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 06/06/1985 |
| From: | Carey J DUQUESNE LIGHT CO. |
| To: | Varga S Office of Nuclear Reactor Regulation |
| References | |
| GL-85-01, GL-85-1, NUDOCS 8506170420 | |
| Download: ML20126F269 (5) | |
Text
~ __
b des
'Af Telephone (412) 393-6000 N."o'.'*BE[l"#
Shippingport, PA 15077-0004 June 6, 19_.
, Director of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Attn: Mr. Steven A. Varga, Chief Operating Reactors Branch No.1 Division of Licensing Washington, DC 20555
Reference:
Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 Appendix R - Fire Protection Gentlemen:
Based on the latest guidance drafted within Generic Letter 85-01, we are in the process of updating our circuit analysis previously submitted in our Fire Protection Appendix R Review Report dated June 30, 1982.
Our alternate safe shutdown procedure, for achieving shutdown from outside the control room, has been revised to reflect the latest NRC guidance, and we are presently conducting operator training and walk-throughs on the procedure.
The modi-fications previously committed to meet the requirements of 10CFR50 Appendix R criteria have all been completed within the scheduled time frame.
Enclosed is a summarized list of all proposed Appendix R modifications and the status of each item (See Table I).
As a result of our review of Generic Letter 85-01 and subsequent procedure revisions, we have identified additional support items that need to be installed. They are:
Additional Emergency Lighting Dedicated Communication System Since these items have only recently been identified, completion of these items by July of this year is not probable.
However, our plans call for completion by September 14, 1985, the date we believe to be consistent with the implementation schedule as set forth in the Rule and our June 30, 1982 submittal. The basis and justification for this date is as follows:
1.
The Safety Evaluation Report, dated January 5,1983, concluded that our proposed modifications and alternate shutdown capability com-plied with Sections III.G.3 and III.L requirements contingent upon the granting of the exemption to the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> cold shutdown require-ment.
This exemption was subsequently granted on March 14, 1983.
It is our understanding, based on conversations with your staff, that the March 14, 1983 document was the official approval date, and that the 30-month implementation schedule for modifications required for alternate shutdown capability should be from this date.
8506170420 850606 f
ADOCK 05000334 em y
i
i B av:r Vallcy Pow:r Station, Unit No. 1 D:cket NO. 50-334, Lic nse No. DPR-66 Appendix R - Fire Protection Page 2 2.
Emergency 8-hour lighting units have already been installed to accomodate the alternate safe shutdown procedure. However, in view of the changes to the procedure, specifically to address the poten-tial for fire-induced spurious operation of equipment and the associated circuits concerns, additional local manual operation of equipment became necessary and, therefore, additional emergency lighting units were identified.
3.
An independent / dedicated hard-wired phone system will be installed to enhance operator actions and to ensure adequate communications to achieve safe shutdown utilizing plant operators performing manual operations locally. Portable radios will be used as a backup to the primary phone system.
As part of the circuit analysis update, an associated circuits problem has been identified.
The emergency diesel generator building ventilation system review has disclosed a potential for loss of function of Diesel Genera-tor (DG) operability in the event of inadvertent C0 actuation.
Fire induced faults (hot shorts or ground faults) at the local ull station or intercon-necting cables in one DG room could inadvertently actuate the C0 system for 9
the opposite DG room resulting in isolation of the ventilation an(flooding of The local pull stations were recently installed as a the room with C0[n.
result of our App dix A review. The NRC review team, at that time, requested remote actuation stations located outside the affected DG room being protect-ed.
Relocating the actuation stations outside the building was a security concern and, therefore, the pull stations were located within the vital areas in opposite DG rooms.
Per discussions with your staff, it was determined that an alternate shutdown procedure for DG room fire could adequately address the concern.
Whereby, an operator will be dispatched immediately upon DG start or fire alarm event and manually take the necessary steps to mitigate the potential for loss of both DG's via inadvertent C0 actuation.
Justification is 2
provided below:
1.
The likelihood of a fire-induced spurious operation producing inadvertent C0 discharge in the opposite DG room is remote given the physical characteristics of the pull stations, their location in the rooms and the associated cabling totally routed in conduit.
2.
A fire event in any one DG room will not produce a " total loss of power" event as assumed in the Appendix R scenario event.
This would allow the plant staff to achieve safe shutdown without the emergency DG's.
3.
The operator dispatched from the control room would have ample time to take the necessary manual actions since makeup to the steam generators would be supplied by the steam-driven auxiliary feedwater pump and decay heat removal would be accomplished via the code safety valves.
i Beaver Valley Power Station, Unit No.1 Docket No. 50-334, Licenso No. DPR-66
-Appendix R - Fire Protection Page 3 Since the emergency diesel generator rooms are provided with a fixed auto suppression and detection system, these fire areas meet Section III.G.3, Appendix R criteria.
Please contact my staff if additional information or clarifications are necessary.
Ver tr ly yours, Carey Vice President, Nuclear Attachment cc: Mr. W. M. Troskoski, Resident Inspector U.S. Nuclear Regulatory Commission Beaver -Valley Power Station Shippingport, PA 15077 U. S. Nuclear Regulatory Commission c/o Document Management Branch Washington, DC 20555 Director, Safety Evaluation & Control Virginia Electric & Power Company P.O. Box 26666 One James River Plaza Richmond, VA 23261 U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement
-Attn: Dr. Thomas E. Murley, Regional Director Region 1 631 Park Avenue King of Prussia, PA 19406 Mr. ~ Peter Tam, Project Manager U. S. Nuclear Regulatory Commission Phillips Building
-Washington, DC 20555 Mail Stop - 438 y
p
- 4 1
TABLE I Appendix R Modifications tiodification Status References 1.
New Auxiliary.Feedwater Pump Completed 4R Section 6.2 of App. R Report 2.
Fire' Dampers in Charging Pump Completed 4R Section 6.4 of App. R Report Cubicle Ductwork & Seal Open-
-ings 3.
Portable Gasoline Motor-Driven Completed 3R Sections 6.5, 6.6, 6.7 of Fans App. R Report 4.
Halon System for Cable Tunnel Completed 3R Section 6.8 of App. R Report 5.
Relocated D.G. River Water Completed 3R Section 6.9 of App. R Report Valve i
6.
Diesel Generator Circuit Modi-Completed 4R Sections 6.10 of App. R ifications Report 01/14/85 Submittal 7.
Containment Air Recire. Fans Reanalysis Section 6.10 of App. R determined not Report required 01/14/85 Submittal 8.
Backup. Indicating Panel Completed Section 6.11 of App. R June 1985 Report 12/10/82 Submittal 01/12/84 Submittal 9.
Emergency Motor Control Centers Completed 3R Section 6.12 of App. R Report 04/18/83 Submittal 05/20/83 Submittal
- 10. Support Cradles for Main Steam Re-evaluation 10/28/82 Submittal Lines determined not required 12/16/83 Submittal
" TABLE I
' Appendix R Modifications Page 2 Modification-
-Status References 11.
"B" Charging Pump Cable Wrap Section 11.20 of App. R-Report
- PAB 722' Completed 3R 12/21/82 Submittal
- PAB 735' Completed 4R 01/14/85 Submittal.
- 12. Additional-Emergency Lighting Projected Section 10.2 of App. R Completion Date -
10/28/82 Submittal September 14, 1985 04/18/83 Submittal 06/06/85 Submittal
- 13. Dedicated Communication System Projected 06/06/85 Submittal Completion Date -
September 14, 1985 NOTES:
3R 3rd Refueling Outage (June 10 thru September 25,1983)
=
'4R' = 4th Refueling Outage-(October 11, 1984 thru January 4,1985)
~ ~..