ML20006F625

Forwards Request for Exemption from Requirements of 10CFR50 App R Re Configuration of wide-range Nuclear Instrumentation Cables in Fire Area 34B

ML20006F625
Person / Time
Site:	Fort Calhoun
Issue date:	02/21/1990
From:	Gates W OMAHA PUBLIC POWER DISTRICT
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LIC-89-1203, NUDOCS 9002280238
Download: ML20006F625 (4)

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Omaha Public Power District 1623 Harney Omaha, Nebraska 68102-2247 402/536 4000 February 21, 1990 LIC-89-1203 U. S. Nuclear Regulatory Commission Attn: Cocument Control Oesk Mail Station P1-137 Washington, DC 20555

References:

1. Docket No. 50-285

2. Letter from NRC (R. E. Hall) to OPPD (T. E. Short) dated August 23, 1978

3. Letter from NRC (E. J. Butcher) to OPPD (R. L. Andrews) dated July 3,1985

4. Letter from NRC (L. J. Callan) to OPPD (K. J. Morris) dated December 7, 1988 Gentlemen: .

SUBJECT:

Exemption Request for Fire Area 34B Omaha Public Power District (OPPD) requests exemption from certain requirements of 10 CFR 50 Appendix R regarding the configuration of the wide range nuclear instrumentation cables in Fire Area 34B (upper electrical penetration room). In accordance with Reference 4, OPPD reviewed prior commitments to determine whether conditions or requirements exist that would require an exemption request for cables in this area. This review determined that an exemption is required regarding the capability to monitor reactor neutron level during a post-fire safe shutdown.

Enclosed please find OPPD's Exemption Request for Fire Area 34B.

This request is being submitted under oath pursuant to 10 CFR 50. If you should have any questions, please contact me.

Sincerely, LS

& AV. Y W. G. Gates I So Division Manager w Nuclear Operations

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No- c: LeBoeuf, Lamb, Leiby & MacRae O R. D. Martin, NRC Regional Administrator, Region IV A. Bournia, NRC Project Manager P. H. Harrell, NRC Senior Resident Inspector k\

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.o UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )

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Omaha Public Power District ) Docket No. 50-285 (Fort Calhoun Station )

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W. G. Gates, being duly sworn, hereby deposes and says that he is the Division Manager - Nuclear Operations of the Omaha Public Power District; that as such he is duly authorized to sign and file with the Nuclear Regulatory Commission the attached information concerning an Exemption Request pursuant to 10 CFR 50.12 for Fire Area 34B; that he is familiar with the content thereof; and that the matters set forth therein are true and correct to the best of his knowledge, information, and belief,

w. 22 k W. G. Gates Division Manager Nuclear Operations l STATE OF NEBRASKA) ss COUNTY OF DOUGLAS Subscribed and sworn to before me, a Notary Public in and for the State of Nebraska on this 2hr day of February, 1990.

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Fire Area 34B Exemotion Reauest A. Description Fire Area 348, Upper Electrical Penetration Room, is located in the southeast end of the auxiliary building on the ground floor (elevation 1013 feet). This room contains safe shutdown motor control centers and associated cables. This area contains redundant cables for the wide range reactor power channels. The redundant cables are separated by more than 20 feet, but the area contains intervening combustible materials, and no division is completely enclosed in a 1-hour rated fire barrier. The area is not equipped with an area-wide automatic fire suppression system but does have an area wide fire detection system.

B. Exemption Recuest Pursuant to 10 CFR 50.12, OPPD requests ar. exemption from the requirements .

of 10 CFR 50.48 regarding Section Ill.G.2 of Appendix R. Specifically, this exemption request for the wide range reactor power channel cables is based on Section Ill.G.2.b of Appendix R. This section specifies that redundant trains of systems necessary to achieve and maintain hot shutdown conditions be separated by more than 20 feet with no intervening combustibles and that fire detectors and an automatic fire suppression system be installed.

These requirements are unnecessary for OPPD to assure the capability to safely shutdown the plant in the event of any credible fire in this fire area for the following reasons:

(1) The cables of concern in this area are for channel 1: EA3015. EA3016 EA3017, and EA3018 and for channel 3: EC3022, EC3023, EC3024, EC3025, EC3026, and EC3027. All of the cables for each channel are routed in steel conduit and the conduits are separated by approximately 34 feet at their closest point of approach.

(2) This area is equipped with an area-wide ionization type fire detection system which alarms and annunciates locally (via an alarm lamp) and in the control room. Extinguishers are located within the area and are available from adjacent fire areas. A fire hose cabinet is located within 12 feet of the north entrance to this fire area.

(3) The combustible material in this area is primarily IEEE-383 rated cable in cable trays and conduits with negligible concentrations of

) cable in the vicinity of the wide range reactor power channel cables ,

under consideration.

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(4) Actions described in Emergency Operating Procedures (EOPs) and Abnormal Operating Procedures (A0Ps) required to maintain safe shutdown of the plant will not be negatively affected by the potential loss of core monitoring capability due to a fire in the upper electrical penetration room. Control Element Assemblies (CEAs) will have been previously inserted and emergency boration/ safety injection may be in process or completed if the Reactor Coolant System (RCS) parameters dictate, and monitoring of the core power level will not be a significant factor. Once negative reactivity insertion has taken place or is underway the plant will meet or exceed the Techn cal Specification 2.10.2(1) shutdown margin requirement of 4% '{/k under any analyzed reactivity excursion. The capability to monitor the core power level will not affect the analyzed ability to remain shutdown.

Based on the above, OPPD requests an exemption from the requirements of those portions of Section III.G.2 of Appendix R which require that additional fire protection features be provided for Fire Area 348 at the Fort Calhoun Station. Additionally, it should be noted that the NRC has granted a similar exemption for Fire Area 34A as described in the NRC's Safety Evaluation Report (SER) of Reference 3.

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