ML20207A963
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{{#Wiki_filter:. ((,pa no Io., w UNITED STATES NUCLEAR REGULATORY COMMISSION f/7 y a WASHINGTON, D. C. 20$66 1, 6 / 1PR 2 o 1948 Y L MEMORANDUM FOR: R. Wessman, Director Project Directorate I-3 Division of Reactor Projects - I, II FROM: Scott Newberry, Acting Chief Instrumentation & Control Systems Branch Division of Engineerine, & Systems Technology SUBJE(,r: REQUEST FOR ADDITIONAL INFORMATION ITEM 2.2 l (PART 2) 0F GENERIC LETTER 83-28 FOR PILGRIM STATION j 1 Plant Name: Pilgrim Stition, Unit 1 l Utility: Boston Edison Company i l Docket No.: 50-293 TAC No.: 53702 l Licensing Status: OR i Resp. PD: I-3 i Project Manager: D. Mcdonald i Review Branch: SICS l Review Status: Incomplete i i The licensee responded to the staff position of Item 2.2 (Part 2) "Vendor Interface (Programs For All Other Safety-Related Components)" of Generic Letter 83-28 by responses dated November 7,1983 and April 27, 1984. Our I review of these submittals discloses the need for additional information as described in the enclosed request for additional information. Scott Newberry, Acting Chi f j Instrumentation & Control Systems Branch Division of Engineering & Systems Technology
Enclosure:
As stated I cc w/ enclosure: S. Varga A. Thadani O. Mcdonald l"
Contact:
D. Lasher (SICB/ DEST) x10787 1 1 1 a f .h [ d 7 )Ch > ~[g ) p JhL
i ENCLOSURE 1 PILGRIM STATION, UNIT 1 DOCKET NO. 50-293 REQUEST FOR ADDITIONAL INFORMATION FOR GENERIC LETTER 83-28 ITEM 2.2 (PART 2) The licensee for the Pilgrim Station, Unit I responded to Item 2.2 (Part 2) of Generic Letter 83-18 by submittals dated November 7,1983 and April 27, 1984., The staff has reviewed these responses and finds additional information is 4 neededforsomepartsofItem2.2(Part2). The requested infomation guidelines used by the staff for this item are listed below, followed by a brief evaluation of the licensee' submittals, and a listing of what the staff I concludes is necessary to complete this item. PROGRAM DESCRIPTION Requested Information: The licensee response should describe their program for establishing and maintaining interfaces with vendors of safety-related components which ensures j that vendors are contacted en a periodic basis and that receipt of vendor equipment technical information is acknowledged or otherwise verified. This program description should establish that formal interfaces are established withthenuclearsteamsupplysystem(NSSS) vendor,aswellaswiththevendors of their diesel generators and safety-related electrical switchgear. In additicn the licensee should confinn that a program of informal contact has been established with the vendors of other key safety-related cceponents such j as auxilliary feedpumps, emergency core cooling system pumps, batteries, battery [ chargers, invertors and valve operators, to facilitate the exchange of current 1 (
\\* 1 technical infonnation. The description should verify that controlled procedures exist for handling this vendor technical information which ensure that it is kept current and complete and that it is incorporated into plant operating, maintenance and test procedures as is appropriate. Evaluation: The licensee responded to these requirements by submittals dated November,7 1983 and April 27, 1984 which included infonnation describing their current and past vendor interface programs. We have reviewed this infonnation and note the following concern. The licensee's response states that they actively participate in the Nuclear Utility Task Action Connittee (NUTAC) program. The Vendor Equipment Technical Infonnation Program (VETIP) was ceveloped by NUTAC. VETIP includes interaction with the NSSS vendor and with other electric utilities. The licensee stated that procedures to implement the NUTAC/VETIP program are in place, except for Secticn 3.2 of the program, "Recomended Enhancements of Existing Programs." These enhancerents are in the definition of component, improvement of the failure reporting guidance, improvement of the utility reports in clarity, followup infonnation and scope, and in reporting errors in equipment technical infonnation. Of this section, the licensee states that they will review these items and implement those judged to be beneficial.
== Conclusion:== We conclude that the licensee's response regarding program description is satisfactory with the exception of their response to the reconmended enhancements in Section 3.2 of the NWC/VETIP report. We require the licensee to address these enhanc w nt, end implement those that are applicable to the licensee.
O 7590-01 UNITED STATES or AMERICA d NUCLE 4q ornut4 Tony cnMNi3:703 In the matter of ) Docket No. 50-193 ) 90STON EDISON COPPANY ) ) ) (P!LGRIM NUCLEAR DOWER STAtt0N) ) i EXEwoTION [ t l I. i l The Boston Edison Company (BEco), the licensee, is the holder of Operatino License No. OPR-35 which authorizes operation of Pilgrin Nuclear i { ocwer Station. The license provides, among other things, that the Pilgrim Nuclear Pnwer Station is sub.iect to all rules, reculations, and Orders of the (, omission now or hereaf ter in effect. The olant is a boilina water reactor at the licensee's site located in l Plymouth County, Massachusetts. i I i On November 19, 1980, the Corrission published a revised Section 50.48 and i a new Aependix R to 10 CFR Part 50 regarding fire protection features of ) nuclear power plants (45FR7660?). The revised Section 50.48 and Appendix 8 becare effective on February 17, 1981. Section !!! of Accendix R contains 15 subsections, lettered A th-ough 0, each of which soecifies requirements for a i particular aspect of the fire protection features at a nuclear power plant. y9e of4::e ee:ectir:,
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.~_ g. }, h -PSection !!!.G.1 of Appendix R requires fire protection features to be provided for structures, systems, and components important to safe shutdown and capable of limiting fire damage so that: a. One train of systems necessary to achieve and maintain hot shutdown conditions from either the control room or emergency control station (s) I is free of fire damage; and I I Systems necessary to achieve and maintain cold shutdown from either the b. I control room or emergency control station (s) can be repaired within 72 hours. i j -_) Section !!!.G.2 of Appendix R requires that one train of cables and equipment I t necessary to achieve and maintain safe shutdown be maintained free of fire l f damage by one of the following means: Separation of cables and equipment and associated nonsafety circuits of l a. i
- redundant trains by a fire barrier having a 3 hour rating.
Structural steel fcnning a part of or supporting such fire barriers shall be protected l to provide fire resistance equivalent to that required of the barrier. i l j b. Separation of cables and equipment and associated nonsafety circuits j of redundant trains by a horizontal distance of more than 20 feet with i f no intervening combustibles or fire hazards. In addition, fire detectors and an automatic fire suppression system shall be installed in the fire l area. l l
3 r .0 l c. Enclosure of cable and equipment and associated nonsafety circuits of one redundant train in a fire barrier having an 1-hour rating. In ad don, fire detectors and an automatic fire suppression system shall be installed in the fire area. i -plf the above conditions are not met, Section. !!!.G.3 requires that there be 1 i alternative or dedicated shutdown capability independent of the fire area of concern. It also requires that fire detection and a fixed suppression system I be installed in the fire area of concern. These alternative requirements are i i not deemed to be equivalent; however, they provide equivalent protection for I those configurations in which they are accepted. i i -pBecause t is not pcssible to predict the specific conditions under which fires may occur and propagate, design basis protective features rather than the design 4 i basis fire are specified in the rule. Plant-specific features may require protection different from the measures specified in Section !!!.G. In such I a case, the licensee must demonstrate, by means of a detailed fire hazard l analysis, that existing protection or existing protection in conjunction with propcsed modifications will provide a level of safety equivalent to the technical j j requirements of Section III.G of Appendix R. l I i i l tin sumary, Section !!!.G is related to fire protection features for ensuring 4 that systems and associated circuits used to achieve and maintain safe shutdown l' j are free of fire damage. Fire protection cotifigurations must meet the specific requirements of Section !!!.G or an alternative fire protection configuration i i )
i 1 i -f-i J must be justified by a fire hazards analysis. Generally, the staff will accept an alternative fire protection configuration if: The alternative ensures that one train of equipment necessary to achieve ( i hot shutdown from either the control room or emergency control station (s) I j is free of fire damage. 1 1 ] l k The alternative ensures that fire damage to at least one train of equipment { i \\ l necessary to achieve cold shutdown is limited so that it can ce repaired i i within e reasonable time (minor repairs using components stored on the site). i t t t Fire-retardant coatings are not used as fire barriers. j Modifications required to meet Section !!!.G would not enhance fire { I protection safety levels above that provided by either existing or proposed f 4 t f alternatives. l 1 i Modifications required to meet Section !!!.G would be detrimental to j overall facility safety. i 1 4 I f I i i l I l i _ _. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ~. -.. _
f J3. i ._p By letter dated August 10,1987(BEco87-135)thelicensee,BostonEdison Company, requested three exemptions (Nos. 15, 18 and 22) from the technt:a1 provisions of Section !!!.G of Appendix R to 10 CFR 50. - A Request No. 15 is for an exemption from the requirement to install full area fire detection and automatic suppression in the Radwaste and Control Building between Corridor f137 on elevation 23 feet and Corridor #49 on elevation (-) 1 foot containing, respectively, redundant Division A and Division B, safe shutdown cables. t o J 9 Request No. 18 is for an exemption from the requirement that no intervening ] combuttible be present between two redundant safe shutdown systems located in the same fire area. In this instance a single cable tray is located between redundant trains of the Reactor Building Closed Cooling Water System (RBCCW) i ] and the Salt Service Water System (SSW) in the water treatment area of the 4 Reactor Building. i ---PRequest No. 22 is for an exemption from the reoutrecent for fire detection and MAh automatic fire suppression for Torus Water Level indication ives455 ment +4ed l cable locatwd in the Reactor Building. ) i d by be,II M % #4Ab ) +4s M.QnrA.2.b%& W,( that full area fire detection and automatic fire suppression would be required i for the area between Corridor #137 (centaining Division A safe shutdown circuits) on elevation 23 feet and Corridce f49 (containing redundant Division B safe shutdowncircuits)onelevation(-)Ifoot. 1
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The licensee has identified a condition where redundant safe shutdown conduits t are not separated by a 3-hour fire rated barrier but are separated by more than j 20 feet horizontally, but without area wide fire detection and automatic fire suppression provided. Another consideration, in addition to simple spatial j j separation, is that the redundant safe shutdown conduits are located on / l different lecels in the Radwaste and Control Building. i j + Train A conduits are located in Corridor No. 137 on Elevation 23 feet. i j Redundant Train B conduits are located in Corridor No. 49 on Elevation (-) 4 1 foot. The floor on Elevation 23 feet, separating the two elevations and the redundant safe shutdown conduits is of reinforced concrete construction that exceeds the 3-hour fire rating. However, an open stairway (Stairwell ( No. 6) comunicates between Elevations (-) 1 foot and 23 feet. Thus the i 1 b ] potential exists for a single fire on either elevation to damage the ca' oles { in both of these safe shutdown conduits. The licensee has evaluated the i potential for fire to spread either way between Corridor Nos. 49 and 137 and has concluded that the risk is atot sufficiently great to require the installation of automatic fire detection or suppression capability in this generai area. j f In order for fire to spread from Corridor No. 49 on Elevation (-) I foot to e Corridor No. 137 on Elevatioa 23 feet, it could have to travel by one of two l paths. One path is up the open Stairwell No. 6 to Elevation 23 feet, across i i the Health Physics access area which is protected by smoke detectors and full I automatic sprinkler coverage, through Corridor No.138 and into Corridor No. f l 137. f I l i i I I l t r d l J \\
7 -A-The second potential pathway for fire from Corridor No. 49 is up through the open Stairwell No. 6 past Elevation 23 feet into Elevation 51 feet. At Elevation 51 feet, the fire would have to traverse approximately 30 feet of open area into Fan Room No. 2 and then proceed down through the ventilation duct space into Elevation 23 feet to Corridor No. 137. h The reverse of these two pathways would be necessary for fire to travel from Corridor No.137 on Elevation 23 feet to Corridor No. 49 on Elevation (-) 1 foot. y Three mechanisms exist for fire growth and propagation to othar combustible materials. --f> The first mechanism, conductive heat transfer (including direct fl.ime impingement) is unlikely for either of the above pathways because there is no continuity of combustibles. --P Radiant heat transfer (the second mechanism for fire growth) depends on direct. line-of-sight geometry which does not exist for either of the above described pathways. Therefore, this method of fire propagation is not of concern.
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--P The third method, convection beat transfer, is theoretically possible but as 4 a practical matter is of little concern. In the first pathway, the fire would have to heat up the air volume in Corridor No. 49 (Elevation (-) I foot), i rise through open Stairwell No. 6, travel east across the health physics i access area (Elevation 23 feet) which is protected by smoke detectors and 1 q. ] automatic sprinklers, and travel south into Corridor No. 137. Similarly in i the second pathway, the fire would have to heat up the air volume in Corridor No. 49 (Elevation (-) I foot), rise through open Stairwell No. 6 past Elevation l t ] 23 feet to Elevation 51 feet. From there, the heated air would have to travel I east across about 30 feet of epen space, raise the temperature of the room { I volume sufficiently to be able to breach the ventilation duct in Fan Room No. j a j 2, then travel back down to Elevation 23 feet and proceed south into Corridor No. 137 to damage the redundant train of safe shutdown conduits. Again, for f fire to originate in Corridor No. 137 on Elevation 23 feet and travel to j; Corridor No. 49 on Elevation (-) I foot so as to damage redundant safe shutdown 1 i cables located in conduits in the two corridors it would have to travel the f I ( ) same 1utes dascribed above but in the reverse directions. These two paths, l 1 j considering the lack of continuity of combusLibles and the presence of automatic l detection and suppression capability in the Health Physics access area on [ l Elevation 23 feet argues against convective heat transfer as a viable means of l fire propagation between these two corridors, j I j l l I 1 i I l h I
9 Q Based on the above evaluation the staff concludes that the existing physical arrangement, consisting of (1) redundant safe shutdown conduits located on two different levels (Elevation (-) I foot and 23 feet), (2) separated by more than 20 feet in horizontal distances. (3) lack of continuity of combustibles between the redundant safe shutdown conduits, and (4) the presence of automatic detection and suppression protection in the Health Physics access area on Elevation 23 feet, make unlikely a single fire damaging redundant safe shutdown cables contained in conduits located in Corridor Nos. 49 and 137 located respectively on Elevations (-) I foot and 23 feet. Yu 'A.e G M %C-t.R.4As.AN Q M n y J cbA h J A E p %Sw MCkt n.qq a us7ad26.ls~ 4: A N' %,D q nrcr,2,b fa %h A MK ' J-i i - k, 13 h_o A 1 0s 4 4 W & p _u w o>'Izr,q 2.6 b % W=A .kAs% r or fire hazards are to be located between two redundant safe shutdown systems located in the same fire area. The subject of this exemption request is a I i single cable tray located 13 feet above the floor on Elevation 23 feet that is located between the Train A and Train B Reactor Building Closed Cooling Water (RBCCW) rooms. e
9 The Train A RBCCW room is located in Fire Zone (FZ) 1.21 and the Train 8 RBCCW room is located in FZ 1.22. Both are located on Elevation 3 feet, are adjacent to each other, and are separated by a two-foot thick unrated wall runing east-west between column lines 2.5 and 5 about midway between column lines L and M. The wall is full height between the floors on Elevations 3 feet and 23 feet and is constructed of solid concrete blocks. The other 10 feet of the wall is supported on a reinforced concrete beam and the blocks are fully grouted. The lower 10 feet of the wall is constructed without grout (the blocks are simply set in the wall) so as to be easily removable if open access is required into FZ 1.21 which is located south of the wall from FZ 1.22 which is located north of the wall. A rolling fire door, which is supported independently from the lower part of the wall is installed in the east end of the wall to provide nonnel access between the two fire zones. An equipment hatchway is located just north of the wall and providea access from FZ 1.29 on Elevation 23 feet into FZ 1.22. The redundant systems located in FZs 1.21 and 1.22 include the RBCCW, Salt Service Water (SSW) and the Diesel Generator Fuel Oil Transfer system. 4 The redundant trains of these systems are separated by (1) horizontal distances greater than 20 feet. (2) the above described 2-foot thick wall (which is unrated because the blocks in the lower 10 feet are not grouted) constructed of solid concrete blocks, and (3) the floor at Elevation 23 feet which is constructed of 12-inch concrete slab cn metal deck.
Il m 4 Penetrations through this concrete floor from FZ 1.29 consist of a manhole access (equipped with steel cover) into tne Acid Neutralizing Sump in FZ 1.21 and an equipment hatch (equipped with 12-inch thick concrete plug) into FZ 1.22. Fire protection in FZ 1.29 consists of area wide automatic detection and automatic sprinkler suppression. In addition, hand held extinguishers and mar.ual hose stations are available for use by the plant fire brigade. The only intervening combustibles between the two redundant trains that are separated as described above, is a single cable tray running east to west, approximately 13 feet above the floor in FZ 1.29 (Elevation 23 feet). -A-There are three possible methods, as sequences, whereby a single fire can t damage both redundant trains of safe shutdown equipment in FZs 1.21 and 1.22. ~)- In the first sequence, a fire starts in FZ 1,29 (water treatment area Elevation 23 feet), in either the cable tray which is located 13 feet above the floor, or in the waste oil station located approximately eight feet west of the equipment hatch into FZ 1.22 and approximately 22 feet north of the manhole into FZ 1.21. The waste oil station tanks are enclosed in a 3-foot high dyke capable of containing the entire contents of the tanks. The fire would havo to go undetected by the automatic detection system and exceed the capability of the automatic sprinkler system, and then spread down through the openings in the Elevation 23 feet concrete floor into both FZs 1.21 and 1.22 with sufficient intensity to damage both redundant trains. --> In the second sequence a fire starts in FZ 1.21 (the acid Neutralizing Sump in Elevation 13 feet), and forces up through the manhole access into and across 1
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FZ 1.29 and then down through the equipment hatchway into FZ 1.22. Such a fite is unlikely since no combustible materials are located in the sump except for safe shutdown cables in question, and these are all run in conduits. In addition, FZ 1.29 is protected by area wide detection and automatic sprinkler i suppression, and the equipment hatchway into FZ 1.22 is closed with a removable concrete plug when not in actual use for moving equipment into or out of these rooms. l @ The third sequence is the opposite of the second one, i.e., fire starts in FZ 1.22 on Elevation 13 feet, forces up through the sealed equipment hatchway l into and across FZ 1.29 on Elevation 23 feet and then down through the manhole I access into the acid neutralizing sump to damage the safe shutdown cables that are located in conduits. All three of these sequences are considered unlikely because: re is no continuity of combustible fuels between FZs 1.21 and 1.22g 2) J r i i V FZ 1.29 is protected with area wide detection and automatic sprinkler I ] suppression 3 i 't A concrete plug seals the equipment hatchway into FZ 1.22 except when equipment is actually being moved through it. I i I 4
I o -i > Based upon the above evaluation the staff concludes that a single fire capable of simultaneously damaging both redundant safe shutdown trains of RBCCW, SSW and emergency diesel fuel oil transfer pump systems located in FZs 1.21 and 1.22isunlikely,andthatremovingtheonlyinterveningcombustible(asingle i cable tray located 13 feet above the floor on Elevation 23 feet in FZ 1.29) would not enhance fire safety.W Therefore, it is unnecessary to remove this cable t " W h r "J" M :f~ r ;tt-h " r -" g - <_d ObfL R& /)l.s 2 ~2, M;J bA \\ m :_ow -% N g 7It.Gi. 3 ' M %w [w detection and automatic suppression for redundant safo shutdown equipment (in i i this case the nomal torus water level indication cables) located in the same fire area when alternative safe shutdown capability is provided, f l i T All of the Torus Water Level Indication circuits leave the torus in fire z l.30A and all are run in metal conduits. Train A cables leave the torus in the southeast quadrant. Train B leaves the torus about 120' away in the northwest quadrant and the alternative cables leave the torus in the southwest quadrant about 85' from Train B and 155' from Train A. The alternative train
14 S d-ttei cables are fully protected by a 1 hour. rated fire wrap (the Torus Instrumentation i Cables were the subject of Exemption Request No. 5 which was granted partly l on the basis of separation with over 100_ feet between Train A and Train B cables and the alternative instrumentation cables). After leaving the torus. J the Train A water level cables rise directly into Fire Zone 1.9 (Elevation 1 23 feet). The Train 8 cables rise into Fire Zone 1.10 (Elevation 23 feet), l ~ l l turn east and cross into Fire Zone 1.9 then turn south to the vicinity of the i Train A cables. From there on both Train A and Train 8 travel together through Fire Zone 1.9 into Fire Zone 1.11 (Elevation 51 feet), turn east through the l J fire wall at Column line 17 across a small portion of Fire Zone 1.23 and l I through another fire wall at Column line 18.5 into Fire Zone 3.4 still on j Elevation 51 feet. From there these cables turn down through the floor into 8 i Fire Zone 3.11 on Elevation 37 feet and then turn south through the fire wall into the Control Room, l i ] p.After leaving the southwest quadrant of the torus, the alternative train j l cables run north along the wall on Column line 5 and then turn up through the l ceiling into an alternative safe shutdown station located in Fire 7 me 1.10 on Elevation 23 feet in the Reactor Building. Automatic detection and suppression is not provided in Fire Zones 1.23, 3.4 and 3.11 where both Train A and Train i i i B cables are located. Although these zones are part of Fire Area 1.10, which j also includes the alternative torus water level cables, they are located on i i 4 l the opposite side of the torus and separated by reinforced concrete floor j (Elevation 51 feet) and walls. Because of the lack of continuous combustibles. spatial separation and the above mentioned reinforced concrete barriers between a f-f the redundant nnel enrus level indicator systees and the redundant systems, 1 j autos'atic fire detection and suppression in Fire Zones 1.23, 3.4 and 3.11 l would not enhance safe shutdown of the plant.
19 i -.-) Based upon the above evaluation, the staff concludes that it is not necessary to install area wide detection and automatic suppression capability in the vicinity of the redundant normal Torus Water Level Indication cables where they are located in Fire Zones 1.20, 3.4 and 3.11, %I h N W M u m % y & p m -{p a.,e$.r & w 2k.pt. % As aA k c IV. Accordingly, the Coneission has determined, pursuant to 10 CFR 50.12(a), that j II) the exemption as described in Section 111 is authorized by law, will not present [ an undue risk to the public health and safety and is consistent with the consrcn I defense and security and (?) in this case, special circun. stances are present in that l application of the regulation is not necessary to achieve the underlying purpose of Appendix R to 10 CFR Part 50. Therefore, the Coenission hereby grants the exemption j from the requirements of Section !!1.G.3PtB of Aopendix R to 10 CFR Part 50 regardit.9 h) ' k fack of fire detection and automatic fire suppression in the area Y J between Corridor Nos. 49 and 137 containing redundant safe shutdern p i "?. ... /. %. gi 4.
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A - ,'n. ,ra M i j Presence of a single cable tray (r.ombustible material) that is located between two redundant safe shutdown trains that are separated by a EkeM.C horizontal distance greater than 20 feat s. e g o I.2t g. e o-I F.2 W j j Q p 1Q Lack of fire detection and automatic fire suppression in areas { i containing both redundant normal safe shutdown trains when an { [ alternative safe shutdown train is provided. Mi M l.*L) j 3,4 a M 3.II C A.III'. G, 3 ). 1
1 l \\ l 1 Pursuant to 10 CFR 51.32, the Coasnission has determined that the granting, of this exemotion will not result in any significant environmental impact ( M *4hMe4 ). A copy of the licensee's request for exeeption dated 10P7 is available for public inspection at the Comission's Public Documnt Room 1717 H Street, NW, Washington, D.C. and at the Pl pouth Public Library, l 11 North Street, Pi pouth, Massachusetts 02360. Copies may be obtained upon written request addressed to the U.S. Nuclear Regulatory Coreission, Washington, D.C. 20555, Attention: Director, Division of Reactor Projects I/I!. This Esemption is effective upon issuance. Dated at Rockville, Maryland, this day of Ir h FOR THE NUCLEAR REGULATORY COPNIS$10N h :: '.
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