ML20141K715

Forwards Request for Addl Info Re 950831,960110 & 1121 Ltrs Requesting Exemption for Brunswick Steam Electric Plant, Units 1 & 2 from Requirements of Sections Iii.G & Iii.L of App R to Title 10 of Code of Federal Regulations

ML20141K715
Person / Time
Site:	Brunswick
Issue date:	05/23/1997
From:	Trimble D NRC (Affiliation Not Assigned)
To:	Hinnant C CAROLINA POWER & LIGHT CO.
References
TAC-M93545, TAC-M93546, NUDOCS 9705290337
Download: ML20141K715 (7)

Text

May 23, 1997 Mr. C. S. Hinnant, Vice President Carolina Power & Light Company Brunswick Steam Electric Plant Post Office Box 10429 Southport, North Carolina 28461

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING REQUEST FOR EXEMPTION FROM 10 CFR PART 50, APPENDIX R, FIRE PROTECTION PROGRAM FOR NUCLEAR POWER FACILITIES - BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 (TAC NOS. M93545 AND M93546)

Dear Mr. Hinnant:

By letters dated August 31, 1995, January 10, 1996, and November 21, 1996, Carolina Power & Light Company requested exemption for Brunswick Steam Electric Plant, Units 1 and 2, from the requirements of Sections III.G and III.L of Appendix R to Title 10 of the Code of Federal Reaulations to permit the use of low pressure coolant injection and safety relief valves to achieve and maintain safe shutdown for fires where the reactor core isolation cooling system may not be free of fire damage.

As a result of our review, we have determined a need for additional information. The information required to continue our review is described in the enclosed request for additional information (RAI).

I Please provide your response within 60 days of the receipt of this letter.

l Sincerely,

)

(Original Signed By)

David C. Trimble, Project Manager Project Directorate 11-1 Division of Reactor Projects - I/II ,

Office of Nuclear Reactor Regulation l l

Docket Nos. 50-325 and 50-324 l

Enclosure:

RAI cc w/ encl: See next page hg  ;

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FILENAME - G:\BRUNSWIC\BR93545.RAI 0FFICE PM:PO!!-1 LA:bOII.1 0: Pott-1 A/

NAME Dirimble 2 E0trinington D MReinhart DATE 05/23/97 05/J3/97 05/7.h97 A copt (sbuo &iko -es/No f/ f Of s /

qu, oFig 13t3 RECORD COPY ,

9705290337 970523 o PDR ADOCK 05000324 P PDR

Mr. W. R. Campbell Brunswick Steam Electric Plant Carolina Power & Light Company Units 1 and 2 cc:

Mr. William D. Johnson Ms. Karen E. Long Vice President and Senior Counsel Assistant Attorney General Carolina Power & Light Company State of North Carolina Post Office Box 1551 Post Office Box 629 Raleigh, North Carolina 27602 Raleigh, North Carolina 27602 Mr. Jerry W. Jones, Chairman Mr. Robert P. Gruber Brunswick County Board of Comissioners Executive Director Post Office Box 249 Public Staff - NCUC Bolivia, North Carolina 28422 Post Office Box 29520 Resident Inspector U.S. Nuclear Regulatory Commission Mr. W. Levis ,

8470 River Road Director Southport, North Carolina 28461 Site Operations Brunswick Steam Electric Plant Regional Administrator, Region II Post Office Box 10429 U.S. Nuclear Regulatory Commission Southport, North Carolina 28461 Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, Georgia 30303 Mr. William H. Crowe, Mayor City of Southport -

Mr. Nel Fry, Acting Director 201 East Moore Street Division of Radiation Protection Southport, North Carolina 28461 N.C. Department of Environment, Health and Natural Resources Mr. Dan E. Summers 3825 Barrett Dr. Emergency Management Coordinator Raleigh, North Carolina 27609-7721 New Hanover County Department of Emergency Management Mr. R. P. Lopriore Post Office Box 1525 Plant Manager Wilmington, North Carolina 28402 Carolina Power & Light Company Brunswick Steam Electric Plant Mr. T. D. Walt Post Office Box 10429 Director Southport, North Carolina 28461 Operations & Environmental Support Department Public Service Commission Carolina Power & Light Corapany State of South Carolina 412 S. Wil 'ngton Street Post Office Drawer 11649 Raleigh, North Carolina 27601 Columbia, South Carolina 29211 Mr. K. R. Jury Mr. Milton Shymlock Manager - Ngulatory Affairs U. S. Nuclear Regulatory Commission Carolina Power & Light Company Atlanta Federal Center. Post Office Box 10429 61 Forsyth Street, SW, Suite 23T85 Southport, NC 28461-0429 Atlanta, Georgia 30303

ENCLOSURE REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OF NUCLEAR REGULATION DIVISION OF SYSTEMS SAFETY AND ANALYSIS PLANT SYSTEMS BRANCH BRUNSWICK STEAM ELECTRIC PLANT POST-FIRE SAFE SHUTDOWN LPCl/SRV l DOCKET NUMBERS 50-324 AND 50-325 1/ BACKGROUND -

To reduce its current requirements for fire protective wrap material, Carolina Power and Light

, Company (CP&L), licensee of the Brunswick Steam Electric Station Units 1 and 2, has identified certain n odifications which, when implemented, would reduce the amount of fire wrap material requiad in the plant. In support of this objective, by lotters dated, August 31, 1995, January 10,1990, and November 21,1996, CP&L requests an exemption from certain technical requirements o1 Sections Ill.G. and Ill.L. of Appendix R to 10 CFR 50 to permit use of safety relief valves (SRW) in conjunction with the Low Pressure Coolant injection (LPCI) mode of the Residual Heat Removal (RHR) system as a means of achieving and maintaining safe shutdown conditions in the event of fire in certain locations of the Unit 1 Reactor Building (Fire Area RB-1), and Unit 2 Reactor Building (Fire Area RB-2). The current, approved, post-fire safe shutdown strategy for these areas credits the high pressure Reactor Core Isolation Cooling (RCIC) system, which is a preferred method of shutdown for a B' oiling Water Reactor (BWR).

At the request of the NRC Office of Nuclear Reactor Regulation (NRR), Brookhaven National Laboratory (BNL) performed a technical review of the subject exemption request. Based on our review of information contained in the licensee's submittals, we request CP&L to provide the information requested below.

2. REQUESTED INFORMATION 2.1 Use of Low Pressure injection Systems to' Achieve and Maintain Post-fire Safe Shutdown Conditions Unlike RCIC, low pressure injection shutdown methodologies, such as the licensee's proposed use of LPCI in conjunction with safety / relief valves, are not capable of satisfying certain shutdown system performance criteria specified in Sections Ill.G and Ill.L of Appendix R to 10 CFR 50. Specifically, this approach:

(a) is not capable of achieving and maintaining hot-shutdown conditions, as specified in Sections Ill.G.1.a and Ill.L.1(c) of Appendix R to 10 CFR 50; and, (b) is not capable of maintaining the reactor coolant level above the top of the core, as required by Sections lil.L.1.b and Ill.L.2(b) of Appendix R to 10 CFR 50.

Consequently, by letters dated August 31,1995, January 10,1996, and November 21,1996, CP&L submitted a request for exemption from certain specific technical requirements of a

Sections Ill.G and Ill.L of Appendix R to 10 CFR 50, to permit the use of low-pressure injection systems as a means of achieving post-fire safe shutdown conditions in the event a fire in certain locations of reactor building fire areas RB-1(Unit 1) and RB-2 (Unit 2) causes

, RCIC to be unavailable. I The post-fire safe shutdown criteria of Section Ill.G.1 and Ill.G.2 are directed at ensuring that at least one train of redundant systems, capable of achievino and maintainino hot shutdown conditions, will remain operable in the event of fire in any plant area. Where the protection of systems capable of satisfying the hot shutdown performance criteria of these paragraphs is not assured, Section Ill.G.3 of the regulation requires an attemative or dedicated shutdown capability be provided which is independent (physically and electrically) of the fire area, room, or zone under consideration.

4 With regard te determining whether a shutdown capability is " redundant" (per Ill.G.1 and lli.G.2) or "altemative" (per Ill.G.3 and Ill.L), Generic Letter 86-10 provides the following guidance and staff positions:

1 (a) Response to Question 3.8.3:

"...lf the system is being used in lieu of the preferred system because the redundant components of the preferred system do not meet the separation criteria of Section Ill.G.2, the system is c~onsidered an attemative shutdown capability."(emphasis added)

. (b) Response to Question 5.1.2

"For the purpose of analysis to Section Ill.G.2 criteria, the safe shutdown capability is defined as one of the two normal safe shutdown trains..."

(emphasis added) 4 (c) Response to Question 5.2.3 "The only requirement for post-fire operating procedures is for those areas where attemative shutdown is required. For other areas of the plant, shutdown would be achieved utilizing one of the two normal trains of shutdown systems."

(emphasis added)

The normal, preferreo, method of shutdown in the event of fire in a BWR is through the use of High Pressure injection Systems (e.g., HPCI or RCIC). In its submittal dated January 10, 1996, the licensee appears to concur with this position, and states that the proposed approach (i.e., use of LPCI) will only be used "as an attemate shutdown system if a fire disables the normal RCIC shutdown capability" (emphasis added). Additionally, in its submittal dated November 21,1996, the licensee states: "Although the capability to maintain hot shutdown...cannot be achieved through the use of LPCI and the safety / relief valves, the performance functions outlined in Ill.L.2 can still be accomplished with the exception of core uncovery, by the use of this attemative shutdown approach"(emphasis added).

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2 The effect of fire on the availability of normal shutdown systems (i.e., Feedwater) has apparently not been evaluated by CP&L. Therefore, the licensee's safe shutdown analysis i appropriately assumes that these systems would not be available. In the absence of this i normal shutdown capability, the licensee recognizes that the oreferred method of shutdown is j through the use of high pressure injection systems to accomplish the reactor coolant makeup i and pressure control function.

}

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The currently approved post-fire shutdown strategy for reactor building fire areas RB-1 (Unit 1) and RB-2 (Unit 2) credits the use of the preferred, high pressure, RCIC system or l HPCI system (depending on fire location) as a means of accomplishing reactor coolant level j and pressure control functions (NRC letter titled " CLARIFICATION AND REVISION OF

SAFETY EVALUATION" dated December 6,1989, which clarified and revised safety

) evaluations provided in NRC letter titled " EXEMPTION FROM REQUIREMENTS OF l APPENDIX R TO 10 CFR PART 50, SECTIONS lil.G. AND J." dated December 30,1986).

j- In lieu of this approach, the licensee proposes to revise its post-fire shutdown strategy to i credit the use of Low Pressure Coolant Injection (LPCI) in conjunctior with three safety / relief j valves in the event of fire in certain locations of Unit 1 and Unit 2 reactor building fire areas.

j Specifically, this approach would be credited for achieving post-fire safe shutdown conditions l- in the event of fire in either:

i j 1. The ncrth side of the Reactor Building (Units 1 and 2); or

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l 2. The separat o'1 zone on the Reactor Building 20' elevation east and southwest (Unit 1 only).

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i l The 'icensee states that all other locations within reactor building fire areas RB-1 and RB-2 j j would rely on the use of RCIC to achieve and maintain hot shutdown conditions in the event

! l of fire. j g.

l The staff has approved the use of low pressure injection systems as a means of providing an j attemative shutdown capability (

Reference:

NRC Memorandum, L.S. Rubenstein to R.J. Mattson, dated December 3,1982,"Use of the Automatic Depressurization System l- (ADS) and Low Pressure Coolant Injection (LPCI) to Meet Appendix R, Altemate Shutdown Goals). The basis for this acceptance rests, in part, with the established principles of defense-in-depth for fire protection. Specifically, when an "altemative" shutdown capability is provided for a specific fire area, room or zone, the regulation (Section Ill.G.3 of Appendix R) imposes an additional requirement of fire detection and fixed fire suppression systems in all areas where the attemative shutdown capability is credited for accomplithing required l shutdown functions. These additional fire safety features serve to limit t le probability of fire growth and damage, thereby minimizing reliance on a "less-than-preferred" attemative capability to accomplish the required shutdown functions. I l

I The licensee's proposed use of low pressure injection systems (LPCI) to perform the reactor coolant make-up function does not appear to satisfy the hot shutdown performance criterion of Section Ill.G. Additionally, it appears the proposed approach (LPCI) is being used in lieu

of preferred systems (RCIC) because redundant components of the preferred system do not meet the separation criteria of Section Ill.G.2. Therefore, please address the following:

1. In the proposed approach, low pressure injection systems appear to be serving as an

attemative shutdown capability (as defined in Sections Ill.G.3 and lil.L of the regulation) for certain locations of Fire Areas RB-1 and RB-2. However, the proposed LPCI approach does not appear to satisfy the " hot shutdown" performance criterion of Section Ill.G.1, Ill.G.2, and Ill.G.3 of Appendix R to 10 CFR 50. Additionally, Generic Letter 86-10 provides further clarification and staff positions with regard to defining "altemative" and " redundant" shutdown capabilities. In light of these requirements, it appears the proposed LPCI approach would be providing an attemative shutdown .

capability for certain locations of fire areas RB-1 and RB-2 (i.e., the north side of the Reactor Building Units 1 and 2 and the separation zone on the 20' elevation of Unit 1 Reactor Building east and southwest), where the preferred shutdown method (i.e.,

RCIC) may be unavailable due to fire damage. Please confirm that the proposed  ;

, LPCI approach is an attemative shutdown capability for these locations, as defined in  !

Sections Ill.G.3 and Ill.L of the regulation, l

2. As discussed above, and in accordance with the defense-in-depth philosophy fc; fire  !

protection, one reason the use of low pressure injection systems has been accepted i as an altemative shutdown capability is that the regulation (Section Ill.G.3) requires I fire detection and fixed fire suppression systems in the area under considerat.on.

However, the CP&L submittals do not describe the fire safety feat 0res, combustible {

loadings, or fire hazards in the areas for which the exemption is requested. l Therefore, please provide information which (a) describes the combustible loadings, or -

fire hazards in the areas for which the exemption is requested; and (b) demonstrates that the fire protection features (detection anri suppression systems) provided for Reactor Building fire areas RB-1 and RB 2 are equivalent to that required b/ Section  !

i lli.G.3 of the regulation, or provide technical justification where this level of pmtection l

Is not provided and LPCI is identified as the post-fire safe shutdown capability.

3. In Enclosure 1 of CP&L letter to NRC dated August 31,1995, several documents and  !

calculations are referenced which were not included as part of the submittal currently being evaluated. Therefore, to facilitate our review, we request copies of the 3

following:

(a) GE Calculation EAS-61-0989; (b) Altemative Shutdown Capability Assessment Report for Brunswick Steam Electric

Plant

i. 4. If not included as part of information requested in item 4 above, provide a more detailed description of fire areas RB-1 and RB-2. As a minimum, this description should: (a) describe the physical arrangement of the fire areas, (b) identify specific locations of post-fire shutdown equipment and cables (include components / cables f associated with both the current RCIC approach and the proposed LPCI approach),

(c) provide an analysis of fire hazards in these areas, (d) describe fire protection l features (detection and suppression) provided for these areas, and (e) include l

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i. i simplified plant lay-out drawings, similar to those provided in the August 31,1995

' submittal describing Fire Areas RB1-6 and RB2-6.

5. Provide a listing and description of the specific components that will be relied on to 4 {

accomplish the proposed LPCI shutdown methodology. Include simplified drawings i

depicting major components and system flowpaths, and provide a detailed description

- of the proposed shutdown strategy.

6.

l Provide information which demonstrates t'hat components associated with the p

' roposed LPCI approach have been evaluated and found to be adequately protected {7 l from the effects of postulated fires in reactor building fire areas RB-1 and RB-2 where j their use may be relied on to achieve and. maintain post-fire safe shutdown conditions.

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7. Provide a copy of the emergency or abnormal operating procedures developed to implement the proposed LPCI approach in the event of fire in the identified locations y

! of the reactor bu!! ding. For the purpose of our review, a draft version of this j t procedure would be acceptable. If such procedures have not yet been developed, j provide a detailed description of the shutdown methodology to be implemented by

] operators in response to fire in the identified locations.

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