ML061140227

Amendment, Use of Fire Resistive Cable

ML061140227
Person / Time
Site:	Harris
Issue date:	05/01/2006
From:	Chandu Patel Plant Licensing Branch III-2
To:	Gannon C Carolina Power & Light Co
Patel C P, NRR/DLPM, 415-3025
Shared Package
ML061140258	List: ML061140227
References
TAC MC8134
Download: ML061140227 (11)

Text

May 1, 2006 Mr. Cornelius J. Gannon, Vice President Shearon Harris Nuclear Power Plant Carolina Power & Light Company Post Office Box 165, Mail Code: Zone 1 New Hill, North Carolina 27562-0165

SUBJECT:

SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 - ISSUANCE OF AMENDMENT ON USE OF FIRE RESISTIVE CABLE (TAC NO. MC8134)

Dear Mr. Gannon:

The Nuclear Regulatory Commission has issued the enclosed Amendment No. 123 to Facility Operating License No. NPF-63 for the Shearon Harris Nuclear Power Plant, Unit 1.

This amendment is in response to your application dated August 18, 2005, as supplemented by letter dated February 15, 2006, requesting changes to the Final Safety Analysis Report (FSAR) for Shearon Harris Nuclear Power Plant, Unit 1.

The amendment authorizes the use of fire-resistive electrical cables in lieu of the alternatives specified in Section C5.b.2 of Branch Technical Position Chemical Engineering Branch 9.5-1 (NUREG-0800), Guidelines for Fire Protection for Nuclear Power Plants, dated July 1981, for the volume control tank outlet valves 1CS-165 and 1CS-166 in Fire Areas 12-A-CR, 1-A-CSRA, 1-A-CSRB, 1-A-SWGRA, 1-A-SWGRB, and 1-A-BAL-B.

In addition, the NRC staff continues to review the changes proposed by you regarding revisions to the FSAR to reflect the use of fire-resistive electrical cable for other applications. Those changes will be covered under separate correspondence.

A copy of the related Safety Evaluation is enclosed. Notice of Issuance will be included in the Commission's regular biweekly Federal Register notice.

Sincerely,

/RA/

Chandu P. Patel, Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-400

Enclosures:

1. Amendment No. 123 to NPF-63

2. Safety Evaluation cc w/enclosures: See next page

ML061140227 NRR-058 OFFICE LPL2-2/PM LPL2-2/LA AFPB/BC OGC LPL2-2/BC NAME CPatel RSola SWeerakkody MZobler BMozafari for by memo MMarshall DATE 5/1/06 5/1/06 3/24/06 4 /27/06 5/1/06

Mr. C. J. Gannon, Jr. Shearon Harris Nuclear Power Plant Carolina Power & Light Company Unit 1 cc:

David T. Conley Mr. Robert J. Duncan II Associate General Counsel II - Director of Site Operations Legal Department Shearon Harris Nuclear Power Plant Progress Energy Service Company, LLC Carolina Power & Light Company Post Office Box 1551 Post Office Box 165, Mail Zone 1 Raleigh, North Carolina 27602-1551 New Hill, North Carolina 27562-0165 Resident Inspector/ Harris NPS Mr. Robert P. Gruber c/o U. S. Nuclear Regulatory Commission Executive Director 5421 Shearon Harris Road Public Staff NCUC New Hill, North Carolina 27562-9998 4326 Mail Service Center Raleigh, North Carolina 27699-4326 Ms. Margaret A. Force Assistant Attorney General Chairman of the North Carolina State of North Carolina Utilities Commission Post Office Box 629 Post Office Box 29510 Raleigh, North Carolina 27602 Raleigh, North Carolina 27626-0510 Public Service Commission Mr. Herb Council, Chair State of South Carolina Board of County Commissioners Post Office Drawer 11649 of Wake County Columbia, South Carolina 29211 P. O. Box 550 Raleigh, North Carolina 27602 Ms. Beverly Hall, Section Chief Division of Radiation Protection Mr. Tommy Emerson, Chair N.C. Department of Environment Board of County Commissioners and Natural Resources of Chatham County 3825 Barrett Drive P. O. Box 87 Raleigh, North Carolina 27609-7721 Pittsboro, North Carolina 27312 Mr. Chris L. Burton Mr. Christos Kamilaris, Manager Manager Support Services Performance Evaluation and Shearon Harris Nuclear Power Plant Regulatory Affairs PEB 7 Carolina Power & Light Company Progress Energy P. O. Box 165, Mail Zone 1 Post Office Box 1551 New Hill, North Carolina 27562-0165 Raleigh, North Carolina 27602-1551 Mr. David H. Corlett, Supervisor Mr. Eric McCartney Licensing/Regulatory Programs Plant General Manager Shearon Harris Nuclear Power Plant Shearon Harris Nuclear Power Plant Carolina Power & Light Company Carolina Power & Light Company P. O. Box 165, Mail Zone 1 P. O. Box 165, Mail Zone 3 New Hill, NC 27562-0165 New Hill, North Carolina 27562-0165 Mr. John H. ONeill, Jr.

Shaw, Pittman, Potts & Trowbridge 2300 N Street, NW.

Washington, DC 20037-1128

CAROLINA POWER & LIGHT COMPANY, et al.

DOCKET NO. 50-400 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 123 License No. NPF-63

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Carolina Power & Light Company, (the licensee), dated August 18, 2005, as supplemented on February 15, 2006, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is hereby amended. Therefore, paragraph 2.C.(2) of Facility Operating License No. NPF-63 is hereby amended to read as follows:

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, as revised through Amendment No. 123, are hereby incorporated into this license.

Carolina Power & Light Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. Deviation from the License Condition 2.F is authorized to reflect the utilization of fire-resistive electrical cable in lieu of the alternatives specified in Branch Technical Position Chemical Engineering Branch 9.5-1 (NUREG-0800), Guidelines for Fire Protection for Nuclear Power Plants, dated July 1981, for the volume control tank outlet valves 1CS-165 and 1CS-166 in Fire Areas 12-A-CR, 1-A-CSRA, 1-A-CSRB, 1-A-SWGRA, 1-A-SWGRB, and 1-A-BAL-B as set forth in the application for amendment dated August 18, 2005, as supplemented on February 15, 2006.

3. This license amendment is effective as of the date of its issuance and shall be implemented within 60 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA by B. Mozafari for/

Michael L. Marshall, Jr., Chief Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Date of Issuance: May 1, 2006

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 123 TO FACILITY OPERATING LICENSE NO. NPF-63 CAROLINA POWER & LIGHT COMPANY SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 DOCKET NO. 50-400

1.0 INTRODUCTION

The Nuclear Regulatory Commission (NRC) triennial fire protection inspection of the Fire Protection and Safe Shutdown (SSD) program at Shearon Harris Nuclear Power Plant, Unit 1 (HNP) identified findings that included postulated fires in several areas, which could result in damage to control wiring and subsequently could result in: (1) equipment mal-operation which was not identified in the Safe Shutdown Analysis (SSA), and (2) problems associated with the feasibility of operator manual actions described in the SSA and implementing procedures.

Several of these findings were related to the SSD functions of volume control tank (VCT) outlet valves 1CS-165 and 1CS-166 to the charging/safety injection pumps (CSIPs).

To address the findings of the Fire Protection and SSD program, by letter dated August 18, 2005, as supplemented by letter dated February 15, 2006, the Carolina Power & Light Company (the licensee) submitted a request for deviation from its approved Fire Protection program for HNP. Specifically, the licensee proposed to use fire-resistive electrical cable produced by Meggitt Safety System, Inc., for the cables associated with the VCT outlet valves 1CS-165 and 1CS-166 to the CSIPs. The licensee proposed the use of these fire-resistive electrical cables in lieu of the alternatives specified in Branch Technical Position Chemical Engineering Branch 9.5-1 (NUREG-0800), Guidelines for Fire Protection for Nuclear Power Plants, dated July 1981 (BTP 9.5-1). In addition, the licensee proposed changes to the Final Safety Analysis Report (FSAR) for HNP to reflect the use of fire resistive cable in other applications after appropriate evaluation to demonstrate that the cable is acceptable for the specific application. This evaluation only addresses VCT outlet valves 1CS-165 and 1CS-166.

The February 15, 2006, letter provided clarifying information that did not change the initial proposed no significant hazards consideration determination.

2.0 REGULATORY EVALUATION

Section 2.F of the HNP Facility Operating License No. NPF-63 states, in part, that Carolina Power & Light Company shall implement and maintain in effect all provisions of the approved fire protection program as described in the FSAR for the facility as amended and as approved in the Safety Evaluation Report (SER) dated November 1983 and Supplements 1 through 4, and the Safety Evaluation dated January 12, 1987. . .

Section III.G.2 of Appendix R of Title 10 of the Code of Federal Regulations (10 CFR), Part 50, provides fire protection requirements for electrical cables located within the same fire area whose failure could cause the mal-operation of redundant trains of systems necessary to achieve and maintain hot shutdown conditions. These areas are required to have protection features such that one of the redundant trains will be free of fire damage in the event of a fire.

Two of the methods described in Section III.G.2 of Appendix R for ensuring compliance with this requirement are (1) to enclose the cable and equipment and associated non-safety circuits of one redundant train in an electric raceway fire barrier (ERFB) system having a 1-hour rating.

In addition, an area-wide automatic fire suppression and detection system shall be installed in the fire area, and (2) to enclose the cable and equipment and associated non-safety circuits of one redundant train in an ERFB system having a 3-hour rating.

HNP was licensed to operate after January 1, 1979, and thus is not directly subject to Appendix R. However, HNP must follow certain requirements of Appendix R to the extent incorporated into its approved fire protection program via BTP 9.5-1.

The licensee has proposed to use fire-resistive stainless steel jacketed electrical cables in lieu of fire barrier systems having 3-hour rating described in Section C5.b.2 of BTP 9.5-1.

The NRC staff reviewed this issue with respect to determining that the fire-rated cables would be capable of providing an equivalent level of protection as would be provided by a 3-hour rated fire barrier as described by BTP 9.5-1.

3.0 TECHNICAL EVALUATION

A postulated fire in Fire Area 12-A-CR, 1-A-CSRA, 1-A-CSRB, 1-A-SWGRA, 1-A-SWGRB, or 1-A-BAL-B could effect the safe shutdown of the plant. A fire in these areas could cause hot shorts in the control power cables associated with volume control tank outlet valves 1CS-165 and 1CS-166. This could cause a spurious actuation of the valves, which could adversely impact the safe-shutdown equipment.

The licensee has proposed to use fire-resistive stainless steel jacketed electrical cables in lieu of 3-hour rated fire barrier systems described in Section C5.b.2 of BTP 9.5-1. The fire-resistive electrical cables have been tested in accordance with American Society for Testing Materials (ASTM) E-119, Standard Test Methods for Fire Tests of Building Construction Materials, for 3-hour fire test. The licensee provided copies of the fire test reports 14980-117047 (Revision 1) dated July 7, 2004, and 14980-121039 dated February 23, 2005, in its submittal dated August 18, 2005.

The control cables at HNP for valves 1CS-165 and 1CS-166 are rated 600 volts alternating current (VAC). The cable test reports, listed above, include the fire test performance

results for 4 conductor #8 American Wire Gauge (AWG), 8 conductor #12 AWG, 7 conductor

1. 14 AWG, and 7 conductor #10 AWG Meggitt Safety Systems electrical cables with factory splices and several support systems and attachment methods. The licensee stated that the support systems and attachment methods for the cables associated with VCT outlet valves 1CS-165 and 1CS-166 will be bounded by the test configurations.

The staff reviewed whether the fire-resistive electrical cables would be capable of providing equivalent level of protection as would be provided by 3-hour fire barrier systems, based on the following factors:

3.1 Megger Testing and Leakage Current Data The fire-resistive electrical cables were megger tested at 500 volts direct curent (VDC) for use in control circuits and at 1000 VDC for use in power circuits, to obtain conductor-to-conductor and conductor-to-ground insulation resistance values. The meggering was performed during the prefire test, during the fire test, and after the hose stream test. The test method used met the fire Megger testing guidelines of Generic Letter 86-10, Supplement 1, Fire Endurance Test Acceptance Criteria for Fire Barrier Systems Used to Separate Redundant Safe Shutdown Trains Within the Same Fire Area.

The cable samples were meggered repeatedly throughout the duration of the fire tests.

According to the test report 14980-121039 dated February 23, 2005, for the control cables, the lowest 0.19 Meg-ohm megger reading was recorded in the case of the 40 foot length sample of 7/C #10 fire-resistive cable of which 22.1 feet was subjected to the elevated temperatures of the test furnace. Neglecting the insulation resistance (IR) of the portion of the cable sample that was outside the furnace during the fire test, this equates to 4.199 Meg-ohms per foot of cable exposed to the fire test. Assuming that the control circuit voltage is 132 VAC for conservatism, this would result in leakage current of 0.03144 milliamps (ma) per foot of conductor.

Based on the meggering result, the staff concluded that fire-resistive cable was not shorted during the fire test. The leakage current value is further evaluated in the following section.

3.2 Control Circuit Evaluation In its letter dated February 15, 2006, the licensee provided a control circuit evaluation for valves 1CS-165 and 1CS-166, based on worst case leakage current due to a reduced IR of control cables during the fire test. For valve 1CS-165, based on number of conductors and length of control cables, the worst case leakage current due to a reduced IR of control cables during fire was calculated as 34 ma. The current should not be enough to spuriously pick up a contactor (which requires 1845 ma) or to keep an energized contactor from dropping out (which requires 145 ma). Also, it was evaluated that the control power fuse rated at 3 amps can withstand the additional 34 ma of potential leakage current without adverse impact. Similarly, for valve 1CS-166, based on number of conductors and length of control cables, the worst case leakage current due to a reduced IR of control cables during fire was calculated as 21 ma. The current should not be enough to spuriously pick up a contactor (which requires 1845 ma) or to keep an energized contactor from dropping out (which requires 145 ma). Also, it was evaluated that the control power fuse rated at 2 amps can withstand the additional 21 ma of potential leakage current without adverse impact.

Based on above analysis that demonstrates that the leakage current due to reduced IR of control cables during a fire will not adversely impact the control circuits of valves 1CS-165 and 1CS-166, the staff concludes that valves 1CS-165 and 1CS-166 will not malfunction during a fire.

3.3 Circuit Separation Separation of safety related circuits should be maintained in accordance with Regulatory Guide 1.75, Physical Independence of Electric Systems. Separation is necessary to maintain independence of Class 1E circuits and equipment so that the protective functions required during any design basis event can be accomplished.

During the fire testing, approximately 1.5 inches of cable jacket separation distance was maintained between the four cable samples tested. At the end of the 3-hour fire test, there was no adverse interaction identified between cable samples or between cables and support structure. The fire tests demonstrated that the electrical continuity of the cables was maintained during and after the fire test.

Based on the fire test results, the staff concludes that the steel jacket of the fire-resistive cable can provide the requisite physical separation between redundant class 1E circuits for protection against fire.

3.4 Mechanical Damage Protection The 3-hour rated ERFB systems are tested in a furnace compliant with ASTM E-119, Standard Test Methods for Fire Tests of Building Construction and Materials, and subject to a hose stream test that ensures the raceway and the barriers will stay in place following a fire exposure. HNP tested the fire-resistive electrical cables in a furnace and subjected the cables to a hose stream. The licensees letter dated August 18, 2005, stated that some areas that require a fire barrier with a 1-hour rating (where the fire-resistive electrical cables are routed) are also provided with automatic fire suppression and detection systems. The licensee stated in its letter dated February 15, 2006, that the fire-resistive electrical cables will be installed to meet the HNP routing requirements for Class 1E cable protection from physical hazards, such as installing the fire-resistive cables as high as possible (along the ceiling) in the fire area. The fire-resistive electrical cables will be only routed in safety related Class 1 structures, and will be seismically supported.

Based on review of the fire tests meeting the requirement of ASTM E-119, and the cable installation methods explained in the licensees letter dated February 15, 2006, the staff concludes that there will be adequate protection from mechanical damage to the fire-resistive electrical cables for the specific application at HNP.

3.5 Galvanized Supports When in contact with galvanized supports, fire-resistive electrical cable produced by Meggitt Safety Systems, Inc., experienced degradation due to liquid metal embrittlement as reported in fire test report 14980-117047 dated July 7, 2004. This degradation occurred at the positions where the galvanized supports came in direct contact with the stainless steel cable jacket. The

later test (Report 14980-121039 dated February 23, 2005) successfully used stainless steel support materials. The licensee stated in its letter dated February 15, 2006 that Meggitt cable is required to be installed in such a manner that it does not come in direct contact with any galvanized materials. The licensee further stated that the specific installation requirement that Meggitt cable jacket not be allowed to come in contact with galvanized materials will be incorporated into HNP drawing 6-B-060 Sheet 0007J by plant modification EC 52769, specifically, the Fire Rated Cable Installation Notes and Details, Note 13 on 6-B-060 Sheet 0007J.

Based on the review of successful fire test report 14980-121039 dated February 23, 2005, and Cable Installation and Notes provided in the licensees letter dated February 15, 2006, the NRC staff concludes that the concern with galvanized supports for fire-resistive cable is adequately addressed.

3.6 Defense-in-Depth Section II, General Requirements, of Appendix R to 10 CFR Part 50 states that the fire protection program shall extend the defense-in-depth concept to fire protection in fire areas that are important to safety including providing protection for structures, systems, and components important to safety so that a fire that is not promptly extinguished by the fire suppression activities will not prevent the safe shutdown of the plant. The licensee has demonstrated by test and analyses that the Meggitt Safety Systems fire-resistive electrical cables are a suitable alternative to the three-hour rated fire barrier systems. Based on the fire-resistive electrical cables being a suitable substitute for 3-hour rated fire barrier systems, the NRC staff concludes that defense-in-depth per Appendix R is maintained.

4.0

SUMMARY

Based on the above review, the NRC staff finds that the licensee has adequately demonstrated that the protection provided by the fire-resistive electrical cable, in the specific application of Meggit Safety Systems cables for control circuits, associated with the volume control tank outlet valves 1CS-165 and 1CS-166, is equivalent to the protection provided by a 3-hour rated fire barrier systems. The NRC staff concludes that the deviation from fire protection program requirements in License Condition 2.F in Facility Operating License NPF-63 for HNP is acceptable for using fire-resistive electrical cable in lieu of the alternatives specified in Section C5.b.2 of BTP 9.5-1, for the VCT outlet valves 1CS-165 and 1CS-166 in Fire Areas 12-A-CR, 1-A-CSRA, 1-A-CSRB, 1-A-SWGRA, 1-A-SWGRB, and 1-A-BAL-B.

5.0 STATE CONSULTATION

In accordance with the Commission's regulations, the State of North Carolina official was notified of the proposed issuance of the amendment. The State official had no comments.

6.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is

no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (70 FR 67745). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

7.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: R. Wolfgang V. Goel Date: May 1, 2006