ML20206F146

Requests Exemption from Automatic Suppression Sys Requirement Described in Section III.G.3.b of App R for Component Cooling Water HX & Boric Acid Tank Room & Computer & Instrument Rack Room.Fire Hazards Analysis Encl

ML20206F146
Person / Time
Site:	Point Beach
Issue date:	06/11/1986
From:	Burstein S WISCONSIN ELECTRIC POWER CO.
To:	Harold Denton, Lear G Office of Nuclear Reactor Regulation
References
NPD-86-51, VPNPD-86-244, NUDOCS 8606240263
Download: ML20206F146 (7)

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l%sconson Elecinc rom cwmr 231 W. MICHIGAN, P.O. BOX 2046, MILWAUKEE, WI 53201 VPNPD-86-244 '

NPD-86-51 ,

June 11, 1986 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U. S. NUCLEAR REGULATORY COMMISSION Washington, D. C. 20555 Attention: Mr. George Lear, Director PWR Project Directorate 1 4

Gentlemen: i l

DOCKETS 50-266 AND 50-301 l 10 CFR 50 APPENDIX R EXEMPTION REQUESTS l POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 l I

, our June 30, 1982 letter, as supplemented by letters of April 28 and October 26, 1983, requested'an exemption from the requirements of Appendix R for the containment spray additive and

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monitor tank area which contains redundant trains of safe shutdown' instrument cables for each unit. The subject cables are required to provide indication in the control room. Our October submittal proposed alternate shutdown capability independent of the zone of concern. The exemption was granted July 3, 1985.

The implementation of TMI-related modifications subsequent to our 1983 submittals has included the rerouting of several of the safe shutdown instrument cables from the monitor tank area through the component cooling water heat exchanger and boric acid tank room and the computer and instrument rack room to the control room.

The previously proposed alternate shutdown capability is also

+ independent of the revised cable route. The modified installation, however, is not in verbatim compliance with Appendix R. Therefore:

Per the provision of 10 CFR 50.12, Wisconsin Electric Power-Company requests exemption from the automatic suppression system requirement, as prescribed in Section III.G.3.b of Appendix R for:

B606240263 860611 d8r PDR ADOCK 05000266 '

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Mr. Harold R. Denton June 11, 1986 Page 2

1. The component cooling water heat exchanger and boric acid tank room.

2. The computer and instrument rack room.

A fire hazards analysis in support of this exemption request is contained in Enclosure 1.

Please call us if you have any questions regarding this exemption request.

Very truly yours, -.- ,

Mb v'

so l rs ein Vice Chairman of the Board Enclosures Copy to Resident Inspector 1

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. l Enclosure 1 EXEMPTION REQUEST AND ANALYSIS Introduction i

Our June 30, 1982 letter, as supplemented by letters of April 28 and October 26, 1983, requested exemption from the automatic fire suppression requirements of Appendix R,Section III.G.3.b for the containment spray additive and monitor tank area. The " Response to 10 CFR 50. Appendix:R Alternate Shutdown' Capability" enclosed with our October letter described. alternate shutdown capability for process monitoring instrumentation located in the control room, cable-spreading room, and the containment spray additive and monitor tank area.

Subsequent to our 1983 submittals, a new computer, new control room indicating panels,'and new instrument racks have been installed at the Point Beach Nuclear Plant. Consequently the routing of some process monitoring instrument cables _has been changed to pass through the following rooms:

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1. Component Cooling Water Heat Exchanger and Boric Acid Tank Room.

2. Computer and Instrument Rack Room.

Although alternate shutdown capability is being provided, these '

two areas do not comply with the automatic fire-suppression requirements of Appendix R,Section III.G.3.b. On the basis that modifications required to provide verbatim compliance with i

Appendix R would not enhance fire protection capability above that which already exists, exemption from the above requirements is requested for each room. The following fire hazards analysis is presented for each room.

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Enclosure 1

'Page 2 Fire Zone 237 Component Cooling Water Heat Exchancer and Boric Acid Tank Room 4

< EXEMPTION-REQUEST Per the provisions of 10 CFR 50.12, Wisconsin Electric Power Company requests exemption from the automatic suppression system requirement as prescribed'in Section III.G.3.b of Appendix R.

Fire Zone Description-This fire zone is located on the 46-foot elevation of the auxiliary building. The zone is separated from other areas by two-foot thick non-fire-rated concrete walls on three sides and one eighteen-inch thick wall on the west side. All walls, the ceiling, and the floor are provided with three-hour fire-rated penetration seals. The zone is accessed from the west through one 3 foot x 7 foot and one 12 foot x 13 foot doorless entranceways and from the 26-foot elevation via an open stairway.

Safe Shutdown Equipment The zone contains the component cooling water heat exchangers and redundant channels.of required primary and secondary instrumentation for both units.

Fire Protection Systems The zone is provided with six photoelectric smoke detectors

' scitably located within the room. There is no automatic suppression system. Two 1-1/2 inch hose reel stations are located outside the room near the west wall entranceways for manual fire suppression capability. Portable fire extinguishers suitable for the hazards present are also available.

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Enclosure 1 Page 3 Fire Hazards Analysis A summer 1986 modification will increase the number of component cooling water heat exchangers from three to four. Normally one 1

heat exchanger is used for cold = shutdown of each unit. One heat exchanger can, however, provide cold shutdown capability for both units over.a longer period of time. The two outermost heat exchangers are separated by a center-to-center distance of 21'6".

> The combustible in the zone is cable insulation comprising an approximate fuel load'of 22,500 BTU /sq.ft. The heavy metal section of the component cooling water heat exchangers and piping and the thermal capacity of-the contained water are sufficient to ensure the safe shutdown capability of the system.

The redundant instrument cables rise through the floor from the

- containment spray additive and monitor tank area and exit through

' the east wall to the computer and instrument rack room. Cables of each train for each unit are routed in separate conduits.

,' conduit separation, however, is.not in compliance with the 4 requirements ^of Appendix R.

Proposed Modifications Section 4.3.2 of our October report describes modifications to provide safe shutdown monitoring instrumentation independent of the control room, cable-spreading room and containment spray additive and monitor tank area. These modifications have been implemented for Unit 1 and will be implemented for Unit 2 by the i

endofthefall1986refuelinjoutage.- These modifications will also provide alternate shutdown capability independent of the component cooling water-heat exchanger and boric acid tank room, and .no additional modificatioris are proposed.

conclusion Based on the above evaluation, Wisconsin Electric believes that the existing fire protection features, together with alternate

- shutdown capability for the component cooling water heat exchanger and boric acid tank room, provide a level of fire protection equivalent to the technical requirements of Section III.G.3.b of Appendix S. This exemption should, therefore, be granted. ,

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e Enclosure 1 Page 4 Fire Zone 336 Computer and Instrument Rack Room EXEMPTIOli REQUEST Per the provision of 10 CFR 50.12, Wisconsin Electric Power. Company requests exemption from the automaticssuppression, system requirement as prescribed in Section III.G.3.b of Appendix R.

Fire Zone Description  ;

This fire zone is located on the 60-foot elevation of the control The zone boundaries are reinforced concrete walls, building.

floor, and ceiling. All boundaries are provided with three-hour fire-rated penetration seals. The zone is accessed from the north and south through Class-A. fire doors.

Safe Shutdown Equipment The zone contains cable and instrument racks for redundant channels of required primary and secondary instrumentation for both units.

Fire Protection Systems The zone is provided with eight photoelectric smoke detectors suitably located within the zone. There is no automatic suppression system. - Hose reel stations are located at the foot of the stairway on the 46-foot elevation for manual fire suppression capability. Portable fire extinguishers suitable for the hazards present are also available.

I Fire Hazards Analysis l

The redundant instrument cables enter the zone through the west wall ~and are routed to the instrument racks in rigid steel conduits across the ceiling. They are, however, exposed for a

'short distance in cable trays above the instrument racks. Cable c

tray and instrument rack separation is not in compliance with Appendix R. Combustibles in this fire zone are cable insulation and paper products, which present a fuel load of approximately 1 20,000 BTU /sq. ft.

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Enclosure 1 Page 5

. Proposed Modifications Section 4.3.2 of_our' October report describes modifications to provide safe shutdown monitoring instrumentation independent of the control room, cable-spreading room, and the containment spray additive and monitor tank area. These modifications have been implemented for Unit 1 and will be implemented for Unit 2 by the 4 end of the fall 1986 refueling outage. .These modifications will

also provide alternate shutdown capability independent of the computer and instrument rack room, and~no_ additional modifications are proposed.

Conclusions Based on the above evaluation, Wisconsin Electric believes that the existing fire protection features, together with alternate shutdown capability for the computer and instrument rack room,

, provide a level of fire protection equivalent to the technical This exemption requirements of Section III.G.3.b of Appendix R.

should, therefore, be granted.

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