ML20138J195

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Forwards Response to Telecopied Request for Info Re 830428 & 1026 App R Exemption Requests Concerning Svc Water Pump Room,Rhr Pump Zones & Auxiliary Bldg Fire Area & Summarizes 851126 Meeting W/Nrc at Facility
ML20138J195
Person / Time
Site: Point Beach  NextEra Energy icon.png
Issue date: 12/11/1985
From: Fay C
WISCONSIN ELECTRIC POWER CO.
To: Butcher E, Harold Denton
NRC, Office of Nuclear Reactor Regulation
References
CON-NRC-85-128 TAC-11079, TAC-11080, VPNPD-85-548, NUDOCS 8512170455
Download: ML20138J195 (9)


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\ l%sconson Bectnc com come 131 W. MICHICAN, P.O. 80X 2046. WithAUKEE, WI $3201 VPNPD-85-548 NRC-85-128 December 11, 1985 Mr. II. R. Denton, Director Office of Nuclear Reactor Regulation U. S. NUCLEAR REGULATORY COMMISSION Washington, D. C. 20555 Attention: Mr. Edward Dutcher, Acting Chief Operating Reactors, Branch No. 3 Gentlemen DOCKET NOS. 50-266 AND 50-301 APPENDIX R EXEMPTION REQUESTS POINT DEACll NUCLEAR PLANT, UNITS 1 AND 2 By letters dated April 28 and October 26, 1983, we requested exemptions from certain requirements of 10 CFR 50 Appendix R for the service water pump room, residual heat removal pump zones, and the auxiliary building fire area.

The subject exemption requests were discussed with members of your staff at a November 26, 1985 meeting at the Point Beach Nucicar Plant. A tour of the affected plant areas was also conducted. The following is a summary of our discussions during the meeting:

1. The service water pump room is described in Section 6.2 of our response to 10 CFR 50 Appendix R " Alternate Shutdown capability" which was submitted with our October 26 letter.

The partial height wall which separates the service water pumps will not be provided with a doorway as described in our submittal. The wall will be continuous from wall to wall and a separate entrance to the north half of the room will be provided. The altered configuration will provide more positive separation of the two groups of service water pumps. Figure 6-2 of our October 1983 submittal has been revised to show this improved configuration and is enclosed as Enclocuro 1.

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Mr. II. R. D:nton l

D:ccmber 11, 1985 Page 2

2. The automatic fire suppression system in the safety injection i pump room has been extended to provide total room coverage.

l This increased coverage provides a significant improvement

! in the fire protection for this room. Figure 6.4-2 of our

! October 1983 submittal has been revised to show this improvement and is enclosed as Enclosure 2.

3. The automatic fire suppression system in the component cooling water pump room has been extended south to the room boundary ,

and west to the hatch opening in the ceiling. no increased  :

coverage provides a significant improvement in the fire protection for this room. This improvement is also shown on Enclosure 2. .

4. Page 6-15 of our October 1983 submittal states that all components required for safe hot shutdown and cold shutdown in the auxiliary building are located on or below the 8-foot elevation. Mechanical piping, heat exchangers, and manually l operated valves for the component cooling water system are l located on the 26 and 46-foot elevations. Fire damage
sufficient to adversely affect the operability of these components

! is not assumed because of the mass of the components, the l

heat sink of water contained within, the absence of electrical controls, and the moderate combustible loading in these areas.

Although we evaluated cable and equipment in accordance

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with Appendix R, the statement and subsequent discussions l on page 6-15 demonstrate that circuits and instruments will

! be provided on the 8-foot elevation sufficient to permit safe shutdown electrically independent from higher elevations of the auxiliary building.

5. Prior to the meeting we received by telecopy a draft request i for information. This request was also discussed at the i meeting and a copy of the request and our responses is enclosed I

as Enclosure 3.

L l It is our understanding that the Staff has sufficient information

! to evaluate the subject exemption requests. Please call us if you have any additional questions.

Very truly yours,

! (,[/Y C. W. Fay

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Vice President Nuclear Power Enclosures Copy to NRC Resident Inspector  :

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o Enclosure 3 TELECOPIED REQUEST FOR INFORMATION

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APPENDIX R EXEMPTION REQUESTS POINT BEACH NUCLEAR PLANT 280.1 Request Provide fire loading per square foot in the service water pump room discussed on page 6-2.

Response

Firo loading in the service water pump room is 1.7 pounds or 13,600 BTU por square foot.

280.2 Request Verify that 1-1/2-inch hose from the hose rool stations located at the head of the stairway on olevation 8 ft. O in. (page 6-10) could reach the farthost RilR room after crossing the floor and the stairway down to elevation 19 ft. 3 in. Are thoro any other hose stations nearby that can?

Responso It was verified on November 11, 1985 that the hosus at the head of the stairway will reach the farthest RIIR room. There are no other hose rool stations nearby.

280.3 Roquest Verify that the walls botween tto RilR pumps (pago 6-11) of each unit are from floor to c . Aling and not open at the top similar to 17 ft. high wall shown in Figuro 6-3.

Rosponso All walla are floor to ceiling. Figuro 6-3 is meant to show a 4 ft. x 4 ft. access opening and not the top of a wall.

280.4 Re_quent Elaborato on what is moant by the term "combustibio pathway scalud" in Figuro 6.4-1. Does this torm imply a 3-hour fire rating of the zono/ aron boundary?

Ronp_onso "Combustibio pathway soaled" moann that penotration openingu through which exposed combustibio matorials are routed are provided with a 3-hour firo-rated ponotration seal. This does not imply that the untiro boundary is fire rated.

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280.5 Req 4est #

Vo'Effy if the charcoal filters (on pase 6-18) have a fixed

'firk' suppression system. If not, 'then has the NRC approved of itu' ai,sence ? .

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s Response -

. The service building exhaust charcoal filter referenced on page 6-18 does not have an automatic suppression system.

The August 2, 1979 Fire Protection _SER (paragraph 4.4.2) states that an automatic suppression system is not required.

280.0 Request Elaboiato on the safety significance of the red and blue instrument cabica requirsd in Room"159 (page 6-18). Are these cables required for hoc shutdown? What is the actual separation? Will one train be wrappdd? Does this concern exist elsewhere in the auxiliary building?

. Response The' red channel. instrument cables are the alternate shutdown cables for the spray additive tank room located on elevation 26 ft.'- 0 in. (pagu 4-4). 'The cables are required for

-6ct shutdown in the event of a fire in the control, cable spreading, or spray additiVO tank rooms. Red and blue channels are of the name train. Minimum separation is 12 inches.

Trays are totally enclosed and wrapping is not intended. A similar donfiguration exists in Room 166 for Unit 2.

280.7 Requent Describe the boundation of Rooms 157'and 158 as discussed on

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page 6-19. What is the firu rating of whils, floors, and ceilings?

Re_oponso ,,

The walls'which are.not show'nto be fire rated on Figure 6.4-2 are 12-inch-thick concrete construction. The concrete floor is resting on the ground and the ceiling is 3-hour

,. fire rated except for hatches in Room 157 which are fitted with concreto plugs. _

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Provide the design details of " Doorway cprinkler Protection" depicted in F.lgure 6.4-1. Are these sprinklers closed or open head typo and are they designed to NFPA 15?

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Response

The doorway sprinklers are designed to provide waterspray coverage for the doorways so that a fire will not propagate beyond the doorway. The design criteria for the nozzles were based upon fire tests conducted at Southwest Research Institute by Baltimore Gas and Electric to demonstrate the effectiveness of waterspray nozzles for doorway fire barrier protection.

The nozzles utilized are Grinnel EA-1 directional spray nozzles with a 175*F quartzoid fusible element. The nozzles are oriented similar to those used in the fire tests and are directed at approximately a 45* angle from a plane parallel to the plane of the. doorway. The nozzles are aimed at the door opening and are located to provide complete coverage of the door opening by the discharge pattern. Design of the supply piping for the door opening spray nozzles is based upon NFPA 13.

280.9 Request A statement is made on page 6-21 that the charging pump cables and local control station separation is described in " existing exemption request". What is the latest status of this exemption request?

Response

The referenced exemption was granted July 3, 1985.

280.10 Request Identify the location of safety injection pump room discussed on page 6-12.

Response

The safety injection pump roomiis identified on Figure 6.4-2 as Room 151.

i 280.11 Request Provide additional information on the fire configurations and fire zone boundaries of the CCW pump room discussed partially on page 6-22. Page 6-23'is missing.

Response

A copy of page 6-23 is attached for your information and use. An exemption request for the configuration of this room was granted July 3, 1985.

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-, t 2 80. l'2 ' Reque st Verify that the CCW pump motor and cables (page 6-23) and the RHR system (page 6-17) ,can be repaired by spare, parts

. within' the specified time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> fo'r cold shtitdown. Are these' spare parts covered by technical specifications? Are these parts.kept on site?

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Response

The s'are p CCW pump motor is on order but has not yet been delivered. This motor is slightly different from the existing motors and the replacement procedures will be prepared following receipt of the operating and maintenance instructions.- However,.we have in the past changed out CCW pump motors in a, time period of approximately 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

The spare. cables"are on site but have not been prepared for '

use since denial of our exemption request for the switchgear room mdy recult in a relocated alternate power source.for these systenis. The necessary procedures and cable preparation will(be-done following determination of the power supply location., Spare parts are not covered by technical specifications.

The parts will be tagged as dedicated?and kept on site.

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The component cooling water pump room is bordered on the west side by area 142A'which is described in subsection 6.4.2.1 above.

The combustible loading in the component cooling water pump room is 52800 Btu /ft2 Fire protection for this room includes four photo-electric smoke detectors, four 20 lb dry chemical portable extinguishers, four 1-1/2in. hose reel stations, and partial room automatic suppression.

The component cooling water pumps are located in a configuration which could be susceptible to damage from a single fire. The compone-t cooling water system is not required to achieve safe hot shutdown and. system repair is an acceptable means to satisfy the requirements of Appendix R. One component cooling water pump is required to achieve cold shut'down. A spare component cooling water pump motor and a dedicated set of cables are provided for this purpose.

Charging pump cable separation for Units 1 and 2 suitable to meet the Staff's concern is described in an existing exemption request from the requirement for full area automatic suppression.

Protection for the separation of Unit 1 cables is enhanced by the l

l safety injection pump room fire protection features described in

subsection 6.4.2.3 above. The charging pump alternate shutdown cables are normally de-energized and are required only in the event of a Cable Spreading Room or Control Room fire. Protection against simultaneous fires is not required. Protection of the Page 6-23 l

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