ML12135A119

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OL - Draft Need for Clarification on Fire Protection Report
ML12135A119
Person / Time
Site: Watts Bar Tennessee Valley Authority icon.png
Issue date: 05/10/2012
From:
Office of Nuclear Reactor Regulation
To:
Division of Operating Reactor Licensing
References
Download: ML12135A119 (4)


Text

1 WBN2Public Resource From:

Poole, Justin Sent:

Thursday, May 10, 2012 3:07 PM To:

'garent@tva.gov' Cc:

WBN2HearingFile Resource

Subject:

DRAFT Need for clarification on Fire Protection Report Attachments:

WBN clarifying questions (5-10-12).docx

Gordon, In reviewing TVAs recent FPR submittal, the staff has come up with the attached questions. Please review to ensure that the questions are understandable, the regulatory basis is clear, there is no proprietary information contained, and to determine if the information was previously docketed. If further clarification is needed, and you would like to discuss the questions in a conference call, let us know. This email does not convey a formal NRC staff position, and it does not formally request for additional information.

Hearing Identifier:

Watts_Bar_2_Operating_LA_Public Email Number:

688 Mail Envelope Properties (19D990B45D535548840D1118C451C74DDFE83F8834)

Subject:

DRAFT Need for clarification on Fire Protection Report Sent Date:

5/10/2012 3:07:23 PM Received Date:

5/10/2012 3:07:24 PM From:

Poole, Justin Created By:

Justin.Poole@nrc.gov Recipients:

"WBN2HearingFile Resource" <WBN2HearingFile.Resource@nrc.gov>

Tracking Status: None

"'garent@tva.gov'" <garent@tva.gov>

Tracking Status: None Post Office:

HQCLSTR02.nrc.gov Files Size Date & Time MESSAGE 551 5/10/2012 3:07:24 PM WBN clarifying questions (5-10-12).docx 26460 Options Priority:

Standard Return Notification:

No Reply Requested:

No Sensitivity:

Normal Expiration Date:

Recipients Received:

May 10, 2012

1. The staff understands that (per FPR Part II section 12.1) the electric fire pumps start on actuation of suppression-related detection systems or manually, and the diesel fire pumps on low system pressure or manually. The staff is interested in the expected fire pump response in the following scenarios:

Manual actuation of a pre-action or deluge valve; Operation of a manual hose station; Operation of a yard fire hydrant.

2. Part VII, Section 2.9.7 and 2.9.8, both discuss embedded conduits with exposed junction boxes. Section 2.9.7 evaluates non-credited Thermo-Lag as a combustible whereas Section 2.9.8, does not discuss Thermo-Lag as a combustible. Confirm the staff interpretation that the Unit 1 Steam Valve Instrument Room A (discussed in 2.9.7) has Thermo-Lag installed and Unit 2 Steam Valve Instrument Room A (discussed in 2.9.8) does not. If the staff interpretation is not correct, please clarify the submittal.
3. Part VII, Section 2.9.9.2.b, states that... [S]ump pumps are not considered to be ignition sources (see 2.9.0 above). Upon NRC staff review of Section 2.9.0, there is no discussion of sump pumps. Provide a technical basis for sump pumps not being considered credible ignition sources.
4. In Part VII, Section 2.9.21.3.a, of the FPR, the first paragraph uses the word, required, in two different contexts. First, it states that: The FSSD analysis would require radiant energy shielding Second, near the end of the paragraph, it states, [T]herefore, the radiant energy shield is not required. This inconsistent usage of required is throughout Section 2.9 of Part VII. Resolve this inconsistent usage.

Typically, in licensing documents, required refers to licensee requirements, such as rules or license conditions. In this context, the first usage is consistent with this usage. The second usage would not be, since it is based on the analysis performed, and not an NRC rule or license condition.

5. The staff noted the following editorial issues:

Typo - Part VII - Section 2.9.11.2.c heading is missing.

Typo - Part VII - 2.9.11.3.a and 2.9.12.3.a, the abbreviation MRC should be MCR (main control room).

6. Part V, Section 2.2.2 of the FPR states:

Industry test data indicates that fire induced circuit failures will not occur immediately upon exposing cables to fire effects. Damage from an exposure fire to safe shutdown components or circuits is not expected to occur for at least 10 minutes after confirmation by plant personnel.

In the judgment of the NRC staff, this interpretation of industry test data is not supported by the test results, since fire exposure and damage cannot be generalized in such a manner.

The staff intends to specifically not endorse this statement in the Safety Evaluation.

7. Part III, Section 7.4.3 of the FPR states: Restoration procedures are provided for the three fuse columns in the unlikely event of the supply protective device tripping as the result of MHIFs. Clarify:

May 10, 2012 Are the actions for the restoration procedures taken in the main control room?

Are these restoration procedures considered operator manual actions?

What sort of procedures are they? (i.e., normal operation, emergency operation, etc.)

8. Part III, Section 4.1 of the FPR states: Procedural controls for isolation of all potentially spurious RCS letdown paths, including pressurizer PORVs and reactor head vents, provide assurance that isolation of normal and excess letdown paths will be achieved. Clarify:

Are the actions for the procedural controls taken in the main control room?

Are these procedural controls considered operator manual actions?

What sort of procedures are they? (i.e., normal operation, emergency operation, etc.)