ML20050B906

Forwards Step 1 Submittal of Reassessment Info Consisting of Fire Hazards Analysis,Per 10CFR50.48 Fire Protection Mods. Exemptions from App R Requirements Requested as Listed

ML20050B906
Person / Time
Site:	Point Beach
Issue date:	03/31/1982
From:	Burstein S WISCONSIN ELECTRIC POWER CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML20050B907	List: ML20050B906 ML20050B909
References
NUDOCS 8204070542
Download: ML20050B906 (3)

Text

_ _ _ .

1 -

Wisconsin Electnc m come 231 W. MICHIGAN, P.O. BOX 2046. MILWAUKEE, WI 53201 March 31, 1982 s N Mr. H. R. Denton, Director 'b Office of Nuclear Reactor Regulation d U. S. NUCLEAR REGULATORY COMMISSION 4 F,Q y A Washington, D. C. 20555 op1 gC Attention: Mr. R. A. Clark, Chief o% 'S Operating Reactors, Branch 3 @ N 1>

g Gentlemen: ro  %

cot \ "9 DOCKET NOS. 50-266 AND 50-301 FIRE PROTECTION MODIFICATIONS POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 This is to provide our Step 1 submittal of Point Beach Nuclear Plant reassessment information in fulfillment of Section 1.A of our January 29, 1982 letter of request for exten-sion of certain of the schedule dates in Paragraph (c) of the 10 CFR Part 50.48 fire protection modifications. Reassessment of the cable spreading and control rooms is not included in this submittal. While normal hot shutdown system control circuits are routed in the cable spreading and control rooms, the loss of such control circuits will not disable the required hot shutdown systems. We have determined that a complete reassessment submittal including associated circuits evaluation would be more appropriate for these rooms. Therefore, the reassessment of the Point Beach cable spreading and control rooms will be included in our Step 2 submittal.

Completion of the multi-phase reassessment described in our March 18, 1981 letter has verified that many areas of Point Beach Nuclear Plant either do not contain either redundant circuits or equipment required for hot shutdown or are in compliance with the separation requirements of Appendix R,Section III.G.

These areas include the diesel generator rooms, containments, containment facades, and the auxiliary building elevation 46'-0" and above. We also determined that redundant hot shutdown circuits and equipment are located in some areas of Point Beach Nuclear j cog Plant which are not in verbatim compliance with the separation [

criteria in Appendix R,Section III.G.2. These are as follows: 5 ou sWG

/k

~~

sS*78Ef0$88Sh o

F r

e

Mr. H. R. Denton March 31, 1982

1. Fire Zone 1 - Unit 1 Motor Control Center Room

2. Fire Zone 2 - Safety Injection, Containment Spray Pump Room

3. Fire Zone 3 - Component Cooling Water Pump Room

4. Fire Zone 4 - Unit 2 Motor Control Center Room

5. Fire Area 5 - Auxiliary Feedwater Pump Room

6. Fire Area 6 - 4160V Switchgear Room

7. Fire Zone 7 - Monitor Tank Room A quantitative fire hazards analysis was performed for each of the above listed plant areas. In this analysis, the existing room geometry of each specified plant area is evaluated and the fire plume impingement and radiant energy effects of an exposure fire upon redundant circuits and equipment are considered. The analysis also evaluates the effects of ceiling heat stratification. Enclosure 1 contains the assumptions, methodology, and specific quantitative fire hazards analysis for each plant area.

A specific requirement of Section III.G.2 of Appendix R is the provision of 20 foot horizontal separation without intervening combustibles. In a ceiling stratification evaluation, the heat from a fire is distributed uniformly over the ceiling area and specific horizontal separation is of no consequence.

If the passive fire protection provisions of a specific plant area were modified to a degree that the limiting fire damage effects would be those resulting from ceiling stratification, the area would be protected in a manner equivalent to the 20 foot horizontal separation requirement of Appendix R,Section III.G.2.

The modifications necessary to achieve this condition for each plant area analyzed are contained in Enclosure 1. Additional or alternative modifications which could be implemented to achieve verbatim compliance with the 20 foot horizontal separation requirement of Appendix R would not enhance fire protection safety at Point Beach Nuclear Plant. We, therefore, propose to implement the modifications specified in Section 4 of Enclosure 1 for each plant area analyzed, which will provide fire protection equivalent to Appendix R,Section III.G.2.

Based upon.the results of the evaluations in Enclosure 1, we request the following substantive exemptions from the require-ments of Appendix R:

1. That Fire Zone 1 (Unit 1 Motor Control Center Room) be exempted from the 20 foot horizontal separation and automatic fire suppression requirements of Section III.G.2.b.

o

~

Mr. H. R. Denton March 31, 1982

2. That Fire Zone 2 (Safety Injection, Containment Spray Pump Room) be exempted from the 20 foot horizontal separation and automatic fire suppression requirements of Section III.G.2.b.

3. That Fire Zone 3 (Component Cooling Water Pump Room) be exempted from the 20 foot horizontal separation and automatic fire suppression requirements of Section III.G.2.b.

4. That Fire Zone 4 (Unit 2 Motor 3ntrol Center Room) be exempted from the 20 fo-* _cizontal separation and automatic fire suppre.. an requirements of Section III.G.2.b.

5. That Fire Area 5 (Auxiliary Feedwater Pump Room) be exempted from the 20 foot horizontal separation requirements of Section III.G.2.b.

6. That Fire Area 6 (4160V Switchgear Room) be exempted from the 20 foot horizontal separation requirements of Section III.G.2.b.

7. That Fire Zone 7 (Monitor Tank Room) be exempted from the 20 foot horizontal separation and automatic fire suppression requirements of Section III.G.2.b.

We also request that the schedule requirements for modifications proposed in Section 4 of Enclosure 1 be tolled until final ~

Commission action on the above listed requests for exemption in accordance with 10 CFR Part 50.48 Paragraph (c) (6) .

We anticipate that the modifications proposed in Enclosure 1 can be implemented within nine months following Commission approval of the requests for exemption.

Please be advised that items 3.B, 3.C, and 3.E of our January 29 letter have been completed. Installation of item 3.D is continuing.

Please advise us if you have any questions regarding this submittal or require additional information at this time.

Very truly yours, C5 Exec tive Vice President Sol Burstein Enclosure Copy to NRC Resident Inspector

.e _ _ 4 i i-t "

j <

I 1

1 f

P e, -

.I k

i.

f.'

4 i i l

i n'

t h

3 i

\

~,

L-b L '-

% s_.m.

- - - - - - - - - -