ML19257B268
| ML19257B268 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 01/08/1980 |
| From: | Lentsch J PORTLAND GENERAL ELECTRIC CO. |
| To: | Trammell C Office of Nuclear Reactor Regulation |
| References | |
| JWL-0580, JWL-580, NUDOCS 8001150444 | |
| Download: ML19257B268 (7) | |
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4 January 8, 1980 Trojan Nuclear Plant JWL-05-80 Mr. C. M. Trammell Operating Reactors Branch #1 Division of Operating Reactors U. S. Nuclear Regulatory Commission Washington, D. C.
20555
Dear Charlie:
Attached for your use and information are our comments on your proposed rule on fire protection for nuclear power plants. This rule is being proposed as Appendix R to 10 CFR 50.55a entitled,
" Fire Protection Program for Nuclear Power Plants Docketed Prior to July 1, 1976".
Following review of our comments, we would be glad to discuss any questions you may have.
Sincerely, l N W
J. W. Lentsch Manager of Generation Licensing & Analysis Generation Engineering-Construction Division JWL/GAZ/SML/4mg3A6 Attachment 1749 306 footo 6 sh 6
p 8001230 fp
COMMENTS ON PROPOSED APPENDIX R TO 10 CFR 50.55a
" Fire Protection Program for Nuclear Power Plants Docketed Prior to July 1, 1976" 1.
Appendix R to 10 CFR 50.55a,Section II.B, Fire Detection and Suppression and Fire Barriers
" Automatic suppression systems shall be provided to control large fire hazards or to protect redundant systems or components associ-ated with assuring safe shutdown."
Not Presently Required Present Requirement - Appendix A to Standard Review Plan (SRP) 9.5.1 Section C.3.(d)
" Interior manual hose installation should be able to reach any location with at least one effective hose stream,..."
Comments - The new requirement does not allow credit for manual suppression in safety-related areas where combustible loadings are insufficient to warrant sprinkler or deluge systems. Definition of
" redundant system" is also needed. It may be interpreted as all control and power cables associated with a redundant safety system.
2.
Appendix R to 10 CFR 10.55a,Section II.A "Other water systems (such as screen wash pumps in the main cooling water pump house) used as a fire water supply shall be permanently connected to the fire main system and shall be capable of automatic alignment to the fire main system. Such alternate pumps and their associated controls and power supplies shall satisfy the requirements of the main fire pumps.
Not Presently Required Comments - This design requirement appears unnecessary.
It would seem sufficient to provide "a fire water supply capable of being connected to the fire main system within 10 min of the loss of the normal water supply or pumps."
If alternate pumps are used, they probably do not meet the exact requirements of the fire pumps. A fire simultaneous with loss of both the electric and diesel-driven fire pumps must be postulated to require use of additional pumps.
This seems excessive.
3.
Appendix R to 10 CFR 50.55a,Section II.B, Manual Fire Suppression
" Standpipe and hose systems shall be installed so that at least one effective hose stream will be able to reach any location that contains or could present an exposure fire hazard to, safety-related equipment. For PWR containments and similar BWR containments, stand-pipe and hose stations shall be inside the Containment."
1749 307
Present Requirement - NRC Staff Position Received February 14, 1979,, Section 3.2.6(b)
"To provide the capability to suppress fires in electrical cable trays and residual oil at the reactor coolant pumps, manual fire hose stations should be provided inside Containment. These may be provided by hose connections to an existing water system if fire water demands will not degrade capability of this system to meet safe shutdown demands."
Comments - It appears that the new requirement makes no distinction between fire water standpipes inside Containment and other in-Plant standpipes. For existing facilities, this new requirement appears unrealistic.
4.
Appendix R to 10 CFR 50.55a,Section II.H.5, Administrative Controls
"...a separate permit shall be issued for each area where work is to be done and if work continues over more than one shift, the permit shall be valid for not more than 24 hr."
Present Requirement - NRC Staff Position Received August 19, 1977 "All cutting, welding, grinding or open flame work should be author-ized by the responsible foreman or supervisor through a work permit."
Comments - Currently, a start and completion date are designated by the worker or his supervisor on any authorized cutting, welding, grinding or open flame work permit. Requiring a 24-hr validation appears unrealistic because of the additional time required to process the additional work permits or extensions.
5.
Appendix R to 10 CFR 50.55a,Section II.H.8
"...all combustible materials shall be removed from the area immedi-ately following the unpacking. Combustible material shall not be left unattended during lunch breaks, shift changes or other similar periods."
Present Requirement - NRC Staff Position Received August 19, 1977
" Administrative controls should be established to govern the removal of all waste, debris, scrap, rags, oil spills or other combustibles resulting from the work activity in the area following completion of the activity or at the end of each work shift, whichever is sooner."
Comments - The requirement to remove combustible materials prior to lunch breaks appears excessive and unrealistic.
6.
Appendix R to 10 CFR 50.55a,Section II.H.12c "Most favorable direction from which to attack a fire in each area in view of the ventilation direction, access hallways, stairs and l749 308
doors which are most likely to be fire-free and the best station or elevation for fighting the fire. A epecific identification system shall designste all hallways, stairs, doors, fire equipment and system control locations and other items described in fire fighting procedures. This identifications should be used in the procedures and the corresponding Plant items should be prominently marked so that they can be recognized in dim light. All access and egress routes that involve locked doors should be specifically identified in the procedure with the appropriate precautions and methods for access srecified."
Not Presently Pequired Comments - The value of such a new system is questionable, since Flant f amiliarity is a requirement for Plant operators and security personnel. Considering the large number of fire areas, many of which do not have more than one access path, there is little benefit in analyzing ventilation direction or alternate attack paths. Upon notification of a fire, the control operator will generally isolate those ventilation systems affecting the fire area.
Floor elevation numbers and exit signs have been labeled on all stairwell doors to facilitate access by responding outside fira companies. Plant personnel will accompany offsite fire-fighting personnel at all times to aid in equipment location and access and cgress.
7.
Appendix R to 10 CFR 50.55a,Section II.H.12.(h)
" Ventilation system operation that assures desired plant pressura distribution when the ventilation flow is modified for fire contain-ment or smoke clearing operatico."
Not Presently Required Comment - This requirement dses not differentiate letween portable fire fighting ventilation systems or permanent vent ilation syst ems.
Pressure distribution will most likely change during any additional ventilation system operation. Emphasis should be : hat pressure fluctuations will not violate the c;ntrolled plant areas and will maximize personnel habitability.
8.
Appendix R to 10 CFR 10.55a,Section II.I "If the configuration of fire protection features and the separation (by distance, shield or barrier) between redundan~ shutdown systems in a fire area does not provide..."
Comment - The NRC should define the acceptable separation distance (3 ft?), shield or fire barrier rating (1 hr, 2 hr, 3 hr).
9.
Appendix R to 10 CFR 50.55a,Section II.I "Both of the following design conditions shall be accommodated:
(1) offsite power is available; and (2) offsite power is not available."
3_
1749 309
Present Requirement - Appendix A to SRP 9.5.1, Position A.4
" Postulated fires or fire protection system failures need not be considered concurrent with other plant accidents or the moet severe natural phenomenon."
Comment - Loss of offsite power concurrent with a fire is not presently a design requirement.
10.
Appendix R to 10 CFR 50.55a,Section II.I "If there are several such areas, the combinations of systems which provide the shutdown capability may be unique for each criti-cal area; however, the shutdown capability provided for each such area shall be able to achieve and maintain suberitical reactivity conditions in the reactor, maintain reactor coolant inventory, achieve and maintain hot standby conditions for a PWR (hot shutdown for a BWR) for at least 72 hr, achieving cold shutdown conditions within 72 hr and maintain cold shutdown conditions thereafter."
Present Requirement - NRC Safety Evaluation Report Position 3.1.12, Remote Shutdown Capability
" Isolation switches will be added at local control stations for components required to achieve safe shutdown. These modifications will allow safe shutdown to be accomplished without the use of cable spreading room and the control room equipment and cables."
Comments - No time requirements have previously been placed on the changing of modes from hot standby, to hot shutdown to cold shutdown conditions. This requirement appears restrictive and should allow greater operation flexibilty. The operator should be allowed to choose the safest mode of operation for the particular equipment he has available.
11.
Appendix R to 10 CFR 50.55a,Section II.I
" Equipment and systems used prior to 72 hr af ter the fire should be capable of being powered by both onsite and offsite electrical power systems, or by onsite power systems that are independent of the onsite and offsite electrical power systems; equipment and systems used af ter 72 hr may be powered by of fsite power."
Not Presently Required Comments - Does this mean that the ECCS and Fire Protection System must be able to operate without onsite and offsite power for 72 hr?
This requirement needs clarification of terminology.
12.
Appendix R to 10 CFR 50.55a,Section II.K
" Areas protected by automatic total flooding gas suppression system should have electrically supervised self-closing fire doors."
) f k ) I] (i Not Presently Required Comments - There is no existing requirement for areas protected by total flooding Halon systems to have self-closing fire doors.
Considering the existing electrical supervision and the various administrative controls, including locked doors, as part of the security plan and frequent security patrols, existing requirements appear sufficient.
13.
Appendix R to 10 CFR 50.55a, II.L, Reactor Coolant Pump Lubrication System "To provide adequate protection for an SSE, one of the following should be provided:
A.
The lube oil system components whose failure could result in leakage should be designed to withstand an SSE without leakage, and the dropping of oil collection system compon-ents during an SSE should not cause loss of operability of safety-related equipment; or B.
The oil collection system should be designed to withstand an SSE and continue to be able to collect and drain a leakage that may occur during an SSE.
In this case, the oil collection system should be adequate to collect oil from any external lube oil piping not designed to withstand an SSE in addition to leakage from points identified above."
Present Requirement - Appendix A to SRP 9.5.1, Position A.4
" Postulated fires or Fire Protection System failures need not be considered concurrent with other Plant accidents or the most severe natural phenomenon.
,Present Requirement - NRC Staff Position Received February 14, 1979, Section 3.2.6, Containment Fire Suppression "A.
To preclude the potential for a large oil fire which could not be promptly suppressed as required by BTP 9.5-1 and Appendix A, one of the following should be provided at the reactor coolant pumps:
3.
... an oil collection system to collect leakage at potential leakage points and drain oil to a closed container. Potential leakage points to be protected should include:
flange connections, drain plugs, fill points, upper and lower reser-voirs, site glasses, ?ift pump, and external oil coolers."
Comments - It has not been a requirement that the oil collection system be designed to meet SSE requirements.
The oil collection system components have been designed such that should an SSE occur,
}[49 ) falling parts will not damage the operability of safety-related equipment in the same area. As noted in Appendix A to SRP 9.5.1, a fire does not have to be considered simultaneous with an SSE; therefore, the above requirement is unrealistically conservative, the mutual occurrence probability is extremely small. 1749 3 2 SML/sa/4mg3A7 }}