View source for 3F0997-05, Requests Exemption from 10CFR50,App R,Section Iii.O Requirements for Oil Collection Sys Capable of Collecting Potential Leakage from CR-3 RCP Motor Remote Oil Addition Lines

{{Adams
| number = ML20210S586
| issue date = 09/05/1997
| title = Requests Exemption from 10CFR50,App R,Section Iii.O Requirements for Oil Collection Sys Capable of Collecting Potential Leakage from CR-3 RCP Motor Remote Oil Addition Lines
| author name = Cowan J
| author affiliation = FLORIDA POWER CORP.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000302
| license number = 
| contact person = 
| document report number = 3F0997-05, 3F997-5, NUDOCS 9709110083
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 18
| project = 
| stage = Other
}}

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   - sa m September 5,1997 l            3F0997-05 U. S. Nuclear Ro0ulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 l

==Subject:==
10 CFR 50, Appendix R Section Ill.0, "Oll Collection System for i
Reactor Coolant Pump" Exemption Roquest for Crystal River Unit 3 (CR 3) Remoto Oil Addition Lines Under 10 CFR 50.12 (a) (2)

==Dear Sir:==

Florida Power Corporation (FPC) requests an exemption from 10 CFR 50, Appendix R, Section 111.0 requirements for an oil collection system capable of collecting all potential leakage from the CR 3 Reactor Coolant Pump (RCP) Motor Remote Oil Addition _ Lines (ROAls).         Details of this exemption request are provided in Attachment 2.
In 1985, CR-3 added ROALs to the original RCP oil filllines in order to eliminate the                             j need to shutdown the reactor, and to reduce personnel radiation and heat stress exposure during periodic RCP oil additions. The addition of the ROALs was datormined not to involve an Unroviewed Safety Question.                                                            )
Recently, FPC established a project team to review the RCP Lubo Oil Collection i            system and resolve the Appendix R Section Ill.O compliance issues. The regulatory                               '     '
review phase of this project concluded that the ROALs woro not a part of the
             " reactor coolant pump lubo oil systems" and did not qualify as leakage points "where such features exist on the reactor coolant pumps" under 10 CFR 50 Appendix R Section ll1.0 lt was further concluded that ROALs only contain oil CRYSTAL RIVER ENERGY COMPLEX: 18760 W Po Ine Cwd Rwm, Fwids 34428-4708
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U. S. Nuclear Regulatory Commission i
3F0997 05 Pago 2 porlodically (-3 to 4 hours por year during RCP motor oil addition), are drained and capped following uso, and are not in contact with lubo oil system pressuro during RCP motor operation. Those facts, along with a review of the original Statomont of Considerations for 10 CFR 50 Appendix R, Section Ill.0, resultod in the conclusion that the ROAls did not require a iubo oil collection system under current regulation.
Recent actions by the Nuclear Regulutory Commission (NRC) in granting exemptions - for ROALs at other plants, prompted additional review of FPC's position.
In keeping with FPC's commitment to compliance with Appendix R, Section 111.0, an exemption is requested, onder 10 CFR 50.12 (a) (2), from the requirement for providing a lubo oil coller tion system for the CR 3 RCP motor ROALs. As discussed in Attachment 2, this exemption is justified because the ROALs are a rugged look tight design, used only periodically, are controlled by plant procedure, and a hypothetical worst caso spill, with ignition assumed, does not impact post fire safe shutdown capability, in addition, as discussed in Attachment 2, FPC will provido additional Compensatory Measures to the RCP oil addition process and the restart containment inspection process.
Until such tlmo as this exemption is reviewed and acted upon, FPC will treat this as a degraded condition and establish a fire watch over the RCP motor oi! addition process. This will assure continued compliance with the CR 3 Fire -Protection Program until the NRC is able to review and act on this exemption request.
Attachment 1 is a listing of commitments modo in this letter, if you have any questions regarding this letter, please contact D. F. Kunsemillor, Manager, Nuclear licensing at (352) 563 4566.
Sincerely, jdk: $n> (-,~d John Paul Cowan Vico President, Nuclear Operations JPC/jnb Attachments xc:       Regional Administrator, Region 11 Senior Resident inspector NRR Project Manager
_______mm--__ -____._____--

U. S. Nuclear Regulatory Commission 3Fd997 05 Page 3 Attachment 1 List of Regulatory Commitments The following table identifies those actions committed to by Florida Power .
Corporation in this document. Any other actions discussed in the submittal represents intended or planned actions by Florida Power Corporation. They are described to the NRC for the NRC's information and are not regulatory commitments.       Please notify the Manager, Nuclear Licensing of any questions regarding this document or any associated regulatory commitments.
1 I
ID NUMBER                      COMMITMENT                   COMMITMENT DATE A fire watch will be established during   Commence the RCP motor oil addition process        immediately t               3F0997 051          and will be in place until the RCP        and remain in motor Remote Oil Addition Lines are       effect   until drained and capped per procedure.-        exemption is granted.
incorporate Compensatory Measures provided in Attachment 2 to 3F0997-          December .
3F0997 05 2         05 into the RCP Motor Oil Addition           15,1997 procedure and the Restart Reactor Containment inspection Procedure
                                                                                               ..- j

U. S. Nuclear Regulatory Commission 3F0997 05 Pago 4 Attachment _2 Crystal River Unit 3 (CR 3) 10 CFR 50, Appendix R Section lll.0 l                                              "Oll Collection System for Reactor Coolant Pump" l
l                                         Exemption Request for Remote Oil Addition Lines (ROAls) l l                           Florida Power Corporation (FPC) requests an exemption from 10 CFR 50, Appendix l                           R, Section 111.0 requirements for an oil collection system capable of collecting all
                           .potentialleakage from the CR 3 Reactor Coolant (RCP) Motor Remote Oil Addition Lines (RO ALs).
Exe.cutive Summary in 1985, CR 3 added ROALs to the original RCP oil fill lines in order to eliminate the need to shutdown the reactor, and to reduce personnel radiation and heat stress exposure during periodic RCP oil additions. This exemption request describes the ROALs and their operation, the potential consequences of a leak or spill during oil addition, and a fire hazards analysis of a worst case fire.
The following descriptions and analyses contained in this exemption request   _
demonstrate that the ROALs are a rugged leak tight design, used only periodically, are controlled by plant procedure, and a hypothetical worst case spill, with ignition assumed, does not impact post fire safe shutdown capability, it is concluded that special circumstances exist: 1) granting this exemption will not present undue risk to the health and safety of the public, and 2) the addition of an oil collection system for the ROAls is not necessary to achieve the underlying purpose of the rule. Therefore, an exemptinn from the requirement for providing a lube oil collection system for the CR 3 RCP Motor ROALs is requested under the provisions of-10 CFR 50.12 (a) (2).
REMOTE Oil ADDITION SYSTEM DESCRIPTION Bemot_a Oil Addition Lines General Descriotion A typical flow diagram of the 1 A and 18 portion of the RCP motor ROALs is provided in Figure 1. This flow diagram is also representative of ROALs for the 1C 4

U. S. Nuclear Regulatory Commission 3F0997 05 Page 5 and 1D RCP motors. The ROAls are constructed of 1/2" stainless steel tubing with swagolok unions resulting in a minimum pressuro rating of 3000 psi. The ROALs transition to 1/2" stainless steel flexible metal hose (3000 psi rating) with compression type swagelok fittings at the point where the lines pass through the Service Water (SW) D Ring (shield wall section shaped like a "D" containing the two RCPs and a Steam Generator) ponotrations and at the attachment to each RCP motor reservoir. The floxiblo hose ensures that ROAls are not subjected to mechanical vibration and thermal stress at the D Ring SW penetrations and at the point of connection to the original RCP Motor lube oil fill linos. Connectione to the original RCP lubo oil fill line are above the maximum oil level of the upper and lower i
reservolts. The RCP lubo oil collection system providos collection coverage for the original oil filllinos and the ROAL connection at the reactor coolant pump motor.
The operating pressure of the ROALs is 30 psig or loss. The original post installation functional tests on the ROALs included a leak test of the tubing (50 psig) with no visible leakago detected.       The past 12 years of performance and recent walkdowns of the ROALs have not Indicated any problems with lookage.
Damage to the ROAls will not occur during power operation because Reactor Building access and work activities are limited during this time. Containment close-out visual inspections will be conducted at the end of each refueling outage to assure the integrity of the ROALs.
Figure 2, shows a plan view of the routing of the ROALs from each of the two pumping station manifolds located on the outside of Secondary Shield Walls through the SW piping penatrations in the D Rings. Both pumping station manifolds are at a lower elevation than the RCP lube oil reservoirs and the oil addition tubing is sloped to ensure no trapped oil remains in the lines following drain down after completion of the oil transfer operations. The pumping station manifold for the RCP 1 A & 1B motors is located just inside the Reactor Building
{
Personnel Access Hatch on the northeast end of the 119' olevation. The pumping         '
station manitcid for the RCP 1C & 1D motors is approximately 30 feet away from the 1 A/B manifold and is located on the D Ring wall across from the Reactor Building elevator on the northwest end at the 119' elevation. Four quick disconnect fittings with caps are provided at each pumping station manifold for connection of the flexible hose from the discharge of the portable oil metering pumps.

U. S. Nuclear Regulatory Commission 3FO'997-05 Pago 6 Hamo.te_Oll Addition Lines - Routing Q. 'LEolantialignlilon_Snurras Oil loakage from the ROAls is not expected to occur during oil transfer operations.
Tho 3000 psi minimum design pressure of the ROALs and the very low lino pressures (under 30 psig at the metering pumps down to atmospheric pressure at the motors) makes leakage a very remoto possibility.
l         Outside the Secondarv Shield Wall: The ROALs do not travel over any hot main coolant pipes or steam lines outsido of the Secondary Shield wall, hence if a leak were to occur in this area, the oil would pool on the floor and have no opportunity for ignition.
HCP-1 A Inside the D-Ring: Insido the D Ring, the ROALs to the RCP 1 A motor travel over a main steam line, over/along steam generator insulation at their high point near the motor, and over the 1 A pump casing before attaching to the original oil fill lines. The 1 A pump casing insulation is non absorbing mirror type inrulation, with surface temperatures well below tho ignition temperature of the oil, and would not be a potential ignition source in the unlikely event thero is a leak in this area during an oil transfer. The insulation on the main steam line and the steam generator is stainless stool encapsulated mineral wool insulation. The exterior surface temperature is well below the ignition temperature of the oil. In the unlikely event that an oil leak developed during an oil transfer at one of these locations, it is expected that the oil would travel down the stainless steel exterior of the insulation to the floor. The construction of this stainless steel encapsulated mineral wool insulation is physically similar to the construction of the mirror typo insulation. This construction makes it highly improbable that oil could migrate between the seams or make contact with the encased mineral wool. Hence a fire in these areas involving oil soaked mineral wool insulation is highly unlikely. There are spot-typo heat detectors located in this general area which can provide early warning to the control room in the event of a fire.
RCP-1B Inside the D Ring: Insido the D Ring, the ROALs to the RCP-1B motor travel over the 1B pump casing before attaching to the original oil filllines. The 1B pump casing insulation is non-absorbing mirror type insulation and would not be a potential ignition source in the unlikely event there is a leak in this area during an oil transfer.
RCP-1C Inside the D-Ring: Inside the D Ring, the ROALs to the RCP-1C motor travel over the 1C pump casing before attaching to the original oil fill lines. The 1C pump casing insulation is non-absorbing mirror type insulation and would not be a 1
o

U. S. Nuclear Regulatory Commission 3F0997-05 Page 7 potential ignition source in the unlikely event there is a look in this area during an oil transfer.
BCP-1D inside the D-fling: Insido the D Ring, the ROALs to the RCP-1D motor travel ovor/along steam generator insulation at their high point noar the motor and over the 1D pump casing before attaching to tho original oil fill lines. The 1D pump casing insulation is non absorbing mirror type insulation and would not be a potential ignition source in the unlikely event thoto is a leak in this area during an oil transfer. The insulation on the steam generator is stainless stool encapsulated mineral wool insulation. The exterior surfaco temperature is well below the ignition temperature of the oil. In the unlikely event that an oil leak developed during an oil transfer at this location, it is expected that the oil would travel down the stainless stool exterior of the insulation to the floor. The construction of this stainless steel encapsulated mineral wool insulation is physically similar to the construction of the mirror type insulation. This construction makes it highly improbable that oil could l              migrato betwoon the seams or make contact with the encased mineral wool.
l              Hence a firo in this area involving oil soaked mineral wool insulation is highly l              unlikely. There are spot type heat detectors located in this general area which can l              provido early warning to the control room in the event of a fire.
P_ottable_ Oil Matathig Pump Skid and Tanka The portable oil motoring pump skid, two portable tanks, and associated high pressure flexible hoses are transported to containment only during the transfer operations. Power to the pump skid is provided via a local power rocoptacle near each of the pumping station manifolds. Connection of the pump dischargos to the permanently mounted ROAls is via high pressure flexible hose with quick disconnect fittings.
The oil addition pump skid is on a cart comprised of two small motoring pumps with valv:ng, piping, and high pressure floxiblo hoses necessary to safely accommodate the transfer operations. All piping components associated with the suction and dischargo of the portable oil transfer pump skid are appropriately rated for .he service conditions.
Each motoring pump is provided with a rollef valvo located adjacent to the pump discharge. The oil motoring pump is adjustable up to a maximum flow rato of approximately 0.5 gpm. The rollef valve is set to operato slightly above the maximum expected working pressure of the system (~ 30 psig) which is well below the rated pressure of the ROALs (minimum 3000 psi) and pump skid components.

4 U. S. Nuclear Regulatory Commission 3F0997 05 Page B The relief valve is arranged to discharge to the portable tank (suction supply) to ensure that oil discharged from the relief valvo is captured and contained.
The oil supply tanks for each of the oil metering pumps are portable containers which meet the requirements of CR 3's Administrative Instructions regarding the
           - use of flammable or combustible liquids inside plant areas.
The design of the portable pump skid and- tanks minimizes the potential for inadvertent spills or leaks and provides safe reliable control over the oil addition process.
l-           RCP. Motor 011 Reservoir lostrumeritation and Overview of the Remote Oil Additlen Procana Each of the four General Electric (RCP) Motors has an upper oil reservoir for the-thrust bearing containing 175 gallons of oil, and a lower bearing oil reservoir containing 15 gallons of oil. Both reservoirs ' are vented to the containment atmosphere which assures they are not pressurized during oil addition operations.
The upper and lower oil reservoirs have oil fill lines at the motors which are contained by the RCP motor lube oil collection system. These original oil fill lines were used to add oil to the motors until 1985 when the ROAls were added. A "Magnetrol" Level Switch which annunciates in the control room on "Hi" and
             " LOW" level and a "Drexelbrook" capacitance probe which provides digital level indication in the Intermediate Building are provided on the upper and lower lube oil reservoirs. The amount of oil between the HI and LOW level alarms in the upper reservoir-is approximately 16 gallons and approximately 1 gallon on the lower reservoir.
Prior to beginning oil additions, e 'eview of oil level instrumentation readings is conducted w determine the amount ,,f oil to be'added to each RCP motor reservoir.
The portabw oil metering pump skid and oil addition tanks are brought into containment and hooked up to a pumping manifold. Communications are
            - established between the pumping station in the Reactor Building and the personnel    !
            ' monitoring the RCP reservoir level instrumentation before oil addition begins.-
Before-oil is transferred to an RCP motor reservoir, the connected ROAL is filled with'the metering pump and the line walked down on the 119' elevation (from the pumping station to the entrance into the D ring SW Penetration)- to check for leakage. After this walkdown of the ROAL on the 119' elevation, oil addition to the motor reservoir can begin. Digital level indication is continuously monitored to assure that .a gradual oil level reservoir increase is occurring. This controlled addition process provides sufficient control and time to determine that appropriate

IIII i
U. S. Nuclear Regulatory Commission 3F0997-05 Page 9 level-increases are occurring and to take action if unusually low level increase is observed. Following the addition of the proper amount of oil, the ROAL is drained either by gravity or by reversing the pump suction and discharge connections and pumping down the line. After the ROAL is drained, the quick disconnect at the pumping station manifold is capped, in the event that a digitallevelinstrument is out of service, oil addition to the upper
         - reservoir is limited to 10 gallons until such time that the LOW level alarm clears.
This assures that the oil transfer is going to the upper reservoir and limits a potential spill Inalde the D Ring to 10 gallons plus the con:ents of an ROAL (~2 l
gallons). If digital level instrumentation is out of service on the lower reservoir, an oil addition limit is not required since it only takes a few quarts to clear the LOW level alarm and there is only one gallon between the LOW and HI level alarms.
Hence a potential spill from the lower reservoir would be small and is bounded by the spill assumed for the upper reservoir. No oil will be added if both types of level instrumentation are out of service on a reservoir. This condition would require repair of one type of levelindication before oil addition can be made.
CONSEQUENCES OF A FIRE The Crystal River Unit 3 Firo Hazards Annlysis divides the containment building into four separate fire areas. The fire areas are divided based upon the presence of non-rated concrete barriers of substantial construction with limited unprotected openings and the nature of the comt.ustible materials present. The ROALs are routed through Fire Areas RB 95 300 and RB-119 302 which are evaluated in this exemption individually. Fire Areas RB 95 301 and RB-160 303 are not evaluated since the ROALs are not routed within these areas.
As concluded earlier, the high design pressure of the ROALs, low pressure in the lines inside the D Rings, short duration that oil is in the line, and the limited annual frequency for making oil additions make the probability of a fire extremely small.
However, worst case lube oil fires have been evaluated for containment fire areas that contain ROALs.
The walkdown performed after the initial fill of the ROALs assures the integrity of lines such that the potential worst caso spill resulting from oil addition activities will be less than the contents of the longest ROAL-(worst case less than 2 gallons) for the 119' elevation outside the secondary shield wall. This limited worst case spill ensures migration of oil cannot occur, either down to the 95' elevation or between-unprotected redundant safe shutdown equipment, inside the secondary shield wall the worst case oil spill will be less than 12 gallons' based upon the contents of the

1 U. S. Nuclear Regulatory Commission 3F0997 05-Page 10 longest ROAl. (~2 gallons), the maximum oil addition allowed by procedure assuming digital level instrumentation is out of service (10 gallons), and because the ROALs inside the D Rings are not walked down before oil is transferrced to the motor reservolts (hl0 h radiation area). The post fill walkdown is not conducted
        -inside the secondary shield wall because of radiological concerns. The following Fire-Hazards Analyses address the potential consequences of these worst case spills.
Fire Hazards Analysis (FHA). RB 95 3QO Reactot. Building Inside The BacoM= v l         Shield (All Elevational - FIGURE.3 ATTACHED Dancrintion Fire Area RB 95 300: Fire Area RB 95 300 includes the RC Pumps and Motors, Steam Generators, Pressurizer, and attendant instrumentation and piping.
The compartment is open to the reactor building dome area. The RCP Motors are installed inside the D Ring area which is separated from other Fire Areas in the building by massive concrete barriers forming primary containment. Each group of two RC pumps is separated from the other group by the Reactor Vessel and its concrete compartment. The walls of the Reactor Compartment are four (4). feet
        ' thick concrete and extend above the 180' elevation.
The floor of Fire Area RB 95 300 is two-(2) feet thick concrete and covers approximately 4226 square feet. At floor level the area is open on the east and west sides between the north and south D Rings. On_ the east side, a curb is provided which will prevent the spread of oil between the D Rings at this location.
Floor drains (with appropriately sloped floors) are provided below each of the D-Rings, in combination, the slope of the floors and drains will prevent any leakage from the ROAls from spreading between the north and south D Rings. The floor drains discharge to the Reactor Building Sump.
No permanently installed ignition sources are located at the 95' elevation,         in
         . general,.no equipment or piping is installed at the floor level except for the base of the Steam Generators.
The CR 3 FHA describes the design basis fire for Fire Area RB 95-300 as a."...last burning fire that reaches a maximum temperature of 1450*F and would involve oil" This design basis fire in the FHA bounds any potential fire that could result from a leak in an ROAL.- Oil is added when the RCP motor reservoirs are low, hence the
         - additional oil from the transfer is already included in the fire load. The FHA fire-loading data for Fire Area RB 95-300 is summarized as follows:
      =             _              _.

U. S. Nuclear Regulatory Commission 3F0997-05 Page 11 Firo Loading                    25674.12 BTUs/sq.ft.
Firo Loading - Max. Permissible 40000 BTUs/sq.ft.
Firo Duration                   0.32 hrs.
Area size:                      4226 sq.f t.
Eiro Protection Equinrncut in Fire Arna RB-95-300; Linear and spot typo thormal detectors are located in this area to provido an early warning alarm in the control room. Thoro is no manual fire fighting equipment located in the area.
Canacquentes of a Fire in RB-95 300: The Crystal River Unit 3 10 CFR 50 Appendix R Fire Study identifies the Appendix R equipment and functions which will be lost or romain functionalin the event of a fire in any plant Fire Area or Zono containing equipment requir-d to moot Appendix R requirements. In the caso of l
RB 95-300, the fire is rostricted to either the north or south end of the Fire Area l
given the amount and location of the combustibles. In the event a fire occurs, the CR 3 Firo Study identiflos the potentialloss of the following functions:
p           Fire in North End of RB 95 3DO ("A" D-Ringl
* Loss of Train 1 RC System Temperature Instruments RC 4A TE1 (RC to STM GEN 1 A) and RC 5A TE2 (RC Loop A from STM GEN 1 A).
* Loss of       RC 2 TE1  (Pressurizer Water Temperature) and redundant component RC 2 TE2 (Pressurizer Water Temperaturo). (An alternative method for determining uncompensated pressurizer levelis available).
Fire In South End of RB-95 3OO ("B" D Ringl
* Loss of Train 2 RC System Temperaturo Instruments RC-5B-TE4 (RC Loop B from STM GEN 1 A) and RC-4B-TE4 (RC to STM GEN 1B).
The loss of those components is acceptablo because redundant components are available. The geometry of the area and lack of sufficient intervening combustibles, precludes the possibility of a fire originating on one sido of the conterline from traveling to the other sido.
In conclusion, a fire involving lubrication oil from the ROALs is bounded by the existing CR-3 Fire Hazards Analysis and Appendix R Fire Study for Fire Area RB 95-300.
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U. S. Nuclear Regulatory Commission 3F0997 05 Page 12 Elis_ Hazards _ Analysis. RB 119 302        -
Ranc10L Bulldlag EL 119 _Outalde The Secondary _Shinid_ Wall     F_lCtuRE 3 ATTACHED Dnscrintion Fire Aron RB-119.aQ2a             Firo Area RB 119 302 is cylindrical, encompassing the Reactor Building betwoon olevations 110' 0" and 160' 0", with the exceptions of the reactor compartment, D Rings, and the fuel handling area.
On the north, west and south sides, the rono is bounded by the reactor building wall, 3 1/2 feet thick concreto.       The northoast section contains the personnel hatch; and the southwest section has the equipment hatch. Separating this zono from the reactor compartment is 4 feet thick concreto. The north wall of the fuel handling aron is 3 foot thick concreto, while the south wall it. 4 foot. Those walls separato the fuel handling area from this zone.
The floor and ceiling are both 2 foot thick concroto with open ponotrations for stairwells and equipment hatchos. Fire Area RB 119-302 is a relatively largo area of approximately 8474 square foot. In general, the combustibles in the area are limited to IEEE 383 qualified cabling. Significant ignition sources are not present because of the use of stainless stool encased insulation on heated piping, the use of electrical boxes and cabinets which are qualified for harsh environment, and IEEE 383 qualified electrical cabling is not considered to be a crediblo ignition source.
The CR 3 FHA currently describos a design basis firo for Fire Area RB 119 302 as a: ...last burning fire that reachos a maximum temperature of 15009 and would involve cable."      and "The design basis fire is conservatively based on the simultaneous total combustion of all combustibles in the area."
This design basis fire in the FHA bounJs any potential fire that could result from a leak in an ROAL, or a leaklspill at the Pumping Manifolds and Portablo Motoring Pump Skid. The Fire Loading data for Firo Area RB-95 302 is summarized as follows:
Fire Loading                      43880.34 BTUs/sq.ft.
Fire Loading (Max. Permissible) 60000 BTUs/sq.ft, Fire Duration                     0.55 hrs.
Area Size:                        8474 sq.ft.
The addition of a worst case leak or spill of 12 gallona of oil to this area results in an insignificant increase in fire load and the existing FHA is bounding with respect to firo loading and duration.

U. S. Nuclear Regulatory Commission
      ' 3F0997 05 Pago 13 Fire Protacilon Equinment in Fire Ataa RB 119 302: Linear Thormal Detectors are located in this aron to provido an early warning alarm to the control room,         in addition, a Class 111 standpipe is located in the firo croa.
C.onacauentos of a Firo in RB 119-302; As discussed in the FHA, a fire would be rostricted to either the north or south end of the Firo Area due to the geometry of the area and the lack of interconnecting combustibles, in the event a fire occurs the CR 3 Firo Study identillos the potentialloss of the following funcans:
Firo in North End of RB 119 302
* RB Air Handling Fans Soo Noto 1 Below Instrument SP-6A PT1 (Steam Generator A Pressure)
* Loss of         RC 2 TE1 (Prossurizer Water Temperature) and redundant l               component RC 2 TE2 (Pressurizer Water Temperature). (Alternativo method for datormining uncomponsated pressurizer levelis availablo),
}
j            e  Mako-up and Purification System Valvos MUV-40 (Lotdown Isolation), MUV-41(Lotdown isolation), MUV 505 (Lotdown Isolation Suction from BWST)
* Reactor Coolant System Instruments Soo Noto 2 Bolow
* Loss of all Secondary Plant System Instruments except; SP 22-LT (dTM GEN 1B High Rango Lovel, Channel B)
SP 23 LT (STM GEN 1B High Range Lovel, Channel C)
SP-30 LT (STM GEN 1B Low Range Level, Channel B)
SP-31 LT (STM GEN 1B Low Rango Level, Channel C)
Firo in South End of RB-119-302 Reactor Building Air Handling Fans - Soo Note 1 Below Instrument SP 6B PT1 (Steam Generator B Pressure)
* Roactor Coolant System Instruments - Soo Note 2 Below
* Lots of Secondary Plant System Instruments SP 21 LT (STM GEN 1B High Range Lovel, Channel A)
SP-22 LT (STM GEN 1B High Rango Level, Channel B)
SP-23 LT (STM GEN 1B High Range Level, Channel C)
SP-24 LT (STM GEN 1B High Range Level, Channel D)
SP 29 LT (STM GEN 1B Low Rango Lovel, Channel A)
SP 30-LT (STM GEN 1B Low Range Lovel, Channel B)
SP 31 LT (STM GEN 1B Low Range Lovel, Channel C)
SP-32-LT (STM GEN 1B Low Range Lovel, Channel D) i

             - U. S. Nuclear Regulatory C&nmission
* 3F0997-05 Page 14 Note 1, Reactor Building Air Handling Fans:
AHF-1 A la functionalif fire is in south half of the Reactor Building.
AHF-1B is functional unless fire is ni the immediate area of RB Penetration
                       #126.
AHF-1C is functional unless firo is in the immediate area of RB Penetration
                      -#309.
Note 2, Reactor Coolant System Pressure:
At least one of tha four RC Pressure transmitters (RC 3A-PT1, RC-38-PT1, RC-158 PT, or RC-159 PT) will remain functional. The specific transmitter which will be available is dependent on the fire location. For RC Temperature Lindication, either Normal Hot Leg and Cold Leg Indication will be available or Indication from the Incore Thermocouples will be available. The specific indication which will be available is dependent on the fire location.
t The loss of these components is acceptable because redundant components are available. The geometry of the area, the separation of redundant or alternative components / equipment, and the lack of sufficient interconnecting combustibles, prevents a fire from impacting safe shutdown capability.
4 In conclusion, a fire involving lubrication oil in the ROALs, Pumping Manifold, or Oil 4 Metering Pump Skid. is bounded by the existing Fire Hazards Analysis and the Appendix R Fire Study for a fire in Fire Area RB-119-302.
COMPENSATORY MEASURES In order to minimize the potential for an oil fire due to a leak from the ROALs, the following actions will be taken during oil additions:
: 1) Continuous communications will be maintained between the transfer operations in the Reactor Building and the personnel monitoring the RCP reservoir level instrumentation.
: 2) The oil pumping process will be continuously attended / monitored during oil transfers.
: 3) The connected R06L' will be filled with the metering pump and the line walked down on the 119' elevation (from the pumping station to the entrance into the D-Ring SW Penetration) to check for leakage prior to commencing fill of the RCP
_. Oil Reservoir.
: 4) If it is determined during the transfer process that the oil transfer 'is not occurring correctly, as determined by the LO'N lovel alarm not clearing or digital '
b

t j                -
U. S. Nuclear Regulatory Commission
* 3F0997 05 -
Page 15 reservoir level indication not increasing, the process will. be terminated and evaluation of the problem resolved prior to continuing with the addition.
: 5) Following an oil transfer, the ROAL will be drained'and capped.
: 6) Prior to leaving containment, following completion of oil addition (s), the areas around the oil pumping manifolds will be verified to be free of oil.
: 7) A_ visual inspection will be _ conducted following refueling outages to assure the integrity of the ROALs.
CONCLUSIONS ~
A's discussed in this Attachment, this exemption is justified because the Remote Oil-Addition Lines are a rugged leak tight design, used only periodically, are controlled
      - by plant procedure, and a hypothetical worst case spill and ignition does not impact L       _ post fire safe shutdown capability!
It is concluded that special circumstances exist: 1) granting this exemption will not-present undue risk to the health and safety of the public, and 2) the addition of an oil collection system for the ROALs is not necessary to achieve the ' underlying purpose of the rule. Therefore, an exemption from the requirement for providing a lube oil collection system for the_CR-3 RCP Motor ROALs is requested;under the provisions of 10 CFR 50.12 (a) (2).
1

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Page 16                                                                                                            SERVICE WATER SS                       HOSE FIGURE 1 TYPICAL REMOTE OIL ADDITION FLOW DIAGRAM FOR D-RING PENETRATIO''
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'e U. S. Nuclear Regulatory Commission 3F0997-05 Page 18 FIGURE 3 FIRE HAZARDS ANALYSIS DRAWING SHOWING FIRE AREAS RB-119 302 AND RB-95-300
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