ML19290E301

Forwards Review of Fire Protection SER Suppl Items.Requests Addl Info Re Fire Detectors,Fire Barrier Penetrations & Items Judged Unacceptable

ML19290E301
Person / Time
Site:	Crane
Issue date:	02/07/1980
From:	Reid R Office of Nuclear Reactor Regulation
To:	Arnold R METROPOLITAN EDISON CO.
References
NUDOCS 8003100175
Download: ML19290E301 (17)

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NUCLEAR REGULATORY COMMISSION 24e a

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February 7,1980 r-e Docket No 50-289 DocxErgo g.

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Mr. R. C. Arnold gW V

0 Senior Vice President

.MetropolitanfEdison Company 100 Interpace Parkway

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Dear Mr. Arnold:

We have completed our review of your letters listed in Enclosure 1 which you submitted to meet the requirements of license Amendment No. 44 for the fire protection program for Three Mile Island Unit No.1 (TMI-1).

The results of our review of these submittals are presented in detail in Enclosures 1, 2 and 3. gives the current status of the review by item numbers corres-pending to item numbers in Tables 3.1 and 3.2 of the fire protection SER supporting Amendment No. 44.

The supplementary items listed in Enclosure 2 require additional information in order that we may complete our evalua-tion. Enclosure 3 lists those items that are judged as unacceptable based on your submittals thus far.

For these unacceptable items, we have indicated staff positions that would resolve these issues.

You should address these items with a statement that you accept the staff positions or propese alter-nate solutions to resolve the concerns.

By your letter dated October 16,1979 (GQL 1265) the alternate shutdown capability Item 3.1.21 which you committed to complete by May 30, 1981 is the limiting item in completing the. modifications of your fire protection program.

In addition, your request by letter dated December 24, 1979 (GOL 1563) for extending the submittal date of the design for alternate shutdown station to March 15, 1980 does not appear to allow an adequate installation period and still meet the October 1980 schedule. Justification for the schedule submitted by letter dated September 29, 1978 for Item 3.1.21 is

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inadequate and does not meet our stated requirement that all fire protection modifications should be completed by October 30, 1980. We request that you submit details regarding the procurement of long lead items (i.e., purchase order dates, promised delivery dates, etc.) and a copy of your schedule (i.e.,

pert diagram giving, engineering design period, equipment procurement period

'and field installation, etc. ).

In order that the fire protection review schedule is maintained, we will schedule a meeting with you within 30 days from the receipt of this letter.

The agenda for this meeting includes all items listed in Enclosures 2 and 3.

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Mr. R. -C. Amold Furthemore, you should respond to our concerns listed in Enclosures 2 1

has been previously submitted you should provide letter submittal, dates.

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and 3 within 30 days from receipt of this letter.

If such documentation t=

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- If you have any questions on this matter, please contact the NRR Project E

Manager..lir. D. C. Dilanni on 301-492-7435.

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Sincerely.

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Robert W. Reid, Chief Operating Reactors Branch #4 Division of Operating Reactors

Enclosures:

1.

List of Submittal & Status of Associated Issues 2.

Evaluation of Supplement Items & Request for Additional Information 3.-

Evaluation of Supplement

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Items for which Proposal is Unacceptable cc w/ enclosures:

See next page

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RELATED CORRESPONDrNCy

- Dr. Walter H. Jordan

• 'etropolitan Edison Cormany-r a-881 W. Outer Drive

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.. Oak Ridge Tennessee 37830 ccw/erclosura(s):

Mr. Marvin I. Lewis Dr. Linda W. Little 5000 Hennitage Drive 6504 Bradford Terrace P,hiladelphia, Pennsylvania 19149 Raleign, North Carolina 27612 Walter W.' Cohen,' Cons mer Advocate Holly S. Keck

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Department of Justice m

Ant.i-Nuclear Group Representing o>

Si.rawberry Square'.14th' Floo e York

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~ Harrisburg, Pennsylvania 4

245 W. Philadelphia Street

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York, Pennsylvania 17404

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Robert L:.- Knuhi? Esq. -

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e ~ r Assistant' Solicitor M y

-11 John Le in, Esq. -['

PN Knupp and 'Andrews~ '-"R

. 96 $r3 Pennsylvania Public Utilities Com.

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~P.O. Box P-

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Tf Box 3265 407 N. Front Street Harrisburg, Pennsylvania 17120 Harrisburg, Pennsylvania.1710

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cv Jordan D. Cunningham, Esq.

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John E. Minnich, Chairman Fox, Farr and Cunningham Dauphin Co. Board of Comissioners 2320 North 2nd Street Dauphin County Courthouse Harrisburg, Pennsylvania 17110 Front and Market Sts.

Harrisburg, Pennsylvania.17101 Theodore A. Adler, Esq.

WIDOFF REAGER SELK0WITZ & ADLER

• Atomic Safety and Licensing Appeal Board Post Office Box 1547 U.S. Nuclear Regulatory Comission Harrisburg, Pennsylvania 17105 Washington, D. C.

20555 Ms. Marjorie M. Aamodt

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• Atomic Saftty and Licensing Board Panel R.D. #5 U.S. Nuclear Regulatory Commission Coatesville, Pennsylvania 19320 Washington, D. C.

20555 Ms. Karen Sheldan

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• t Docketing and Service Section Sheldon, Harmon, Rc!sc:an & Weiss 1725 I Street, N. W.

U.S. Nuclear Regulatory Commission Suite 506 Washincton. D. C.

20555 Washington, D. C 20005 Robert Q. Pollard Earl B. Hoffman Chesapeak Energy Alliance Dauphin County. Cormissioner

'609 Montpelier Street Dauphin County Courthouse Baltimore', Maryland 21218 Front and Market Streets

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Chauncey Kepford tJudith H. Johnsrud Ell n Weiss, Esq.:

Shef' den $treet,N.W.

Environmental Coalition on Nuclear Power Harmon, Roisman & Weiss 1725 I 433 Orlando Avenue S, tate ' College, Pennsylvania 16801 5

$n n, D.C.

20006 Ms. Frieda Berrytiill, Chairman Mr. Steven C. Sholly Coalition for Nuclear Prwer Plant 304 South f*arket Street Postponement

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Mechanicsburg, Pennsylvania 17055 2610 Grendon Drive Wilmington, Delaware 19803 Mr. "Themas Gerusky Bureau of Radiation Protection Mrs. Rhoda D. Carr M02 Marene Drive Department of Environmental Resources P.O. Box 2063 Harrisburg, Pennsylvania 17109 Harrisburg, Pennsylvania 17120

Karin W. Carter, Esq.

505 Executive House P. 0. Box 2357 Metropolitan Edison Company

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Harrisburg, Pennsylvania 17120

. Honorable Mark Cohen 512 E-3 Main Capital Building cc w/ enclosure (s):

Harrisburg, Pennsylvania 17120 G. F. Trowbridge, Esquire Dauphin County Office Emergency Shaw, Pi ttman, Potts & Trowbridge ~~.

Pr.eparedness 1800 M Street, N.W.

20036.-[e

. j., --~. Court House, Room 7 Washington, D. C.

Front & Market Streets 7j -

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- 7.!!. 'GPU~ Service Corporation /j/

Harrisburg, Pennsylvania 17101 O.

i Richard U..Heward,. Pro,f ect Mana,ger,

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Mr. E. G.'Wallace ;

..~.N Department of Environmental Resdurces Licensing Manager ATTN:

Director, Office of Radiological 260 ' Cherry Hil1 Road Heal th Parsippany; New Jersey 07054.

Post Office Box 2063 N

Pennsylvania Electric Company

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17105',

Harrisburg, Pennsylvania ttr. R. W. Conrad Director, Technical Assessment Vice-President, Generation Division 1001 Broad Street Office of Radiation Programs Johnstown, Pennsylvania 15907 (AW-459)

U. S. Environmental Protection Agency Miss Mary V. Southard, Chairman Crystal Mall #2 Citizens for a Safe Environment Arlington, Virginia 20460 Post Office Box 405 Harrisburg, Pennsylvania 17108 Mr. Robert B. Borsum Babcock & Wilcox Government Publications Section Nuclear Power Generation Division State Library of Pennsylvania Suite 420, 7735 Old Georgetown Road Box 1601 (Ecucation Buf1 ding)

Bethesda, Maryland 20014 Harrisburg, Pennsylvania 17126

• Ivan W. Smith, Esq.

Mr. David D..%xwell, Chaiman Atomic Safety & Licensing Board Panel Board of Supervisors U.S. Nuclear Regulatory Commis sion Lonconderry Township Washington, D. C.

20555 RFD*1 - Geyers Church Road fiiddletown, Pennsylvania 17057 U. S. Environmental Protection Agency Region III Office ATTN:

EIS COORDINATOR-Curtis Building (Sixth Floor)

Governor's Office of State Planning I

6th ana Walnut Streets and Development AUN:

t Philaoelphia, Pennsylvania 19106 Coordinator, Pennsylvania

• E State Clearinghouse

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nnsylvania 17120 Metropolitan Edison Company P. O. Sox 480 Middletown, Pennsylvania 17057 Ms. Jane Lee R.D. 3; Box 3521 Etters, Pennsylvania 17319

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THREE MILE ISLAND, UNIT 1 - FIRE PROTECTION SER SUPPLEMENT _

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LIST OF SUBMITTAL AND STATUS OF THE ASSOCIATED ISSUES SER Section Subject Issue ~

Submittal Status 3.1.1 Fim Detectors 3/16/79 (GQL 6393),

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5/18/79 (GQL 0{81) s.

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3.1. 3

' Auto._ Water Spray _Syj; tem..

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3.1. 4 Auto. Sprinkler or Cable Coating.

9/29/78 (GQL 1585)

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.4 3.1.9 Fire Barrier Penetrations -- c-6/12/78 (GQL 1068)

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8/27/79 (GQL 1004)

C 3.1.10 Thermal Insulation of Valves 3.1.11 Fire Barriers at Reactor Building Emergency Cooling Valves 8/27/79 (GQL 1097)

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'3.1.13 RC Pump Lube Oil Collection System 8/27/79 (GQL 1004)

I 3.1.21 Alternate Shutdown Ca,pability Not Received 3.2.1 Protection of Emergency FW Pumps 12/28/79 (GQL 2070)

R 3.2.2 Cable Separation 7/13/79 (GQL 0893),

9/14/79 (GQL 1164)

R 3.2.3 Effect of Water Spray 12/28/78(GQL2070)

I 3.2.4 Adequacy of Detector System Design 7/11/79(GQL0885)

I 3.2.5 Fire Protection Inside Reactor Building 10/5/78 (GOL 1593)

C 3.2.6 Unlabeled Fire Doors 9/29/78 (GQL 1585),

R 12/1/78 (GQL 1919),

3.1.8 6/7/79 (GQL 0713)

,3.2.7 Alam Circuit Supervis' ion 12/28/78 (GQL 2070)

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.3.2.8 Remote Shutdown Station 12/28/78 (GQL 2070)

C 3.2.9 Transient Combustible Stucy 11/1/78 (GQL 1791)

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. Enclosure 1 SER Station Subject Issue Submittal Status 3.2.10 Control Building HVAC Loss 12/28/78 (GQL 0842)

C 3.2.11 Interior Hose Station Standpipes 7/5/79 (GQL 0842)

C Less Than 4" Diameter

,,.,3..,3.2.12 Emergency Lighting 12/28/78(GQL2070)

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10/31/78 (GQL 1783)

R 3.2.13 Protection of Relay Room -

3.2.14 Fire Door Supervision 11/1/78 (GQL 1792)

I 3.2.15 Engineered Safeguard Cabinets 9/29/78 (GQL 1566)

I C - Completed I - Incomplete R - Requirement e

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.w THREE MILE ISLAND, UNIT 1 - FIRE PROTECTION EVALUATION OF SUPPLEMENT ITEMS FOR WHICH ADDITIONAL 7

.INFORMATION IS REQUIRED

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._.-. J.l.1 A. FIRE DETECTORS M o-- w _.. g e; ;. a u..,, y %,,

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'. 5.I. $ Sa'fety Evaluation Report (SER) Sections 3.1.1 indicates that fife" detectors

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.will be installed on all levels of the reactor building, in several areas r

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of the auxiliary building, in several areas of the intennediate building,

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in certain areas cf the fuel handling building, and in safety-related n

control cabinets in.the, control room.

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By letter dated March 16, 1979, you provided six drawings showing the location-of the proposed detectors in the reactor building, the auxiliary building, the intennediate building, diesel generator buildings, the fuel handling b.

building, and the control room.

By letter dated May 18, 1979, you indicated that Nuclear Instrument and Reactor Protection System cabinets A, B, C and D will not be furnished with fire dete.ctors inside the cabinets. However, the drawirg referenced in your letter dated May 18, 1979 indicates that fire detectors are located in the areas near each cabinet, a point not clearly brought out in your letter.

If these fire detectors are located outside' each cabinet which can monitor E

the cabinet's exhaust air then this addition does satisfactorily resolve the staff.'s concern.

You are therefore requested to clarify the point of.your letter dated h

May 18,1979.

M 3.1.9 FIRE BARRIER PENETRATIONS f

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SER Section 3.1.9 indicates that various types of fire barrier penet*ations, including cable and pipe penetrations and building construction joints, will be sealed in various areas of the plant to provide appropriate fire resistance.

By letter dated June 12, 1979, you provided test reports and a NEL-PIA (now ANI) Certificate of-Approval for the cable and pipe penetration seal design to be installed at the plant. The test procedure met the staff's criteria for penetration seal fire tests, except that no pressure differential was applied across the seal. Your letter stated that no significant pressure differentials exist between various plant areas where those seals would be installed. We agree with your contention that the differential pressure is low. However, you should certify that the. penetration seals.will withstar.d the maximum expected differential pressure across the seals in the event of fire in the areas.

You should also provide information on the sealing of building construction joints where the fuel handling building walls abut the reactor building.

Specifically, you should verify that the proposed building construction joint seals have a fire resistance rating of three hours '(ASTM E-Il9), and flame spread and stoke development ratincs of 2S or less (ASTM E-Gol.

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3.1.13 REACTOR COOLANT pUHp LUBRICATING OIL' COLLECTION SYSTEM SER Section 3.1.13 indicates that the existing lubricating oil splash guard on each reactor coolant pump will be modified to enclose g.c the pump monitor and to drain the collected oil in a drain _ tank located,

.,_, m e. -,de the secondary shield.

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f By letter dated August 27, 1979, you submitted a drawing and several photographs of the proposed lubricating oil collection system for the staff's review and requested deletion of the requirement of SER Section 3.1.6 (cur 5s in reactor building and 3.10 (thermal insulation on valves).

Your satisfactory lubricating oil collection system will obviate the necessity for curbs specified in Section 3.1.6 of the SER. Your request

"-to waive the requirement for insulating the valves was discussed earlier in the staff's review of Section 3.1.10.

The drawings and photographs of the lubricating oil collection system showed its outline and design; but did not adequately describe the system. We cannot determine from the available information that all the potential leak points are enclosed by the system. Further, the seismic design criteria of the system are not known to the staff.

You should certify the following:

a.

The proposed system provides a complete enclosure for all potential leakage points, including lift pump and piping, external oil cooler, flanged connections, drain plugs, fill points, upper and lower reser-voirs, sight glasses, and overflow lines.

b.

During a safe shutdown earthquake, the effects of the seismic event on the system will not adversely affect plant safety.

Strainers or other means of preventing clogging of drain. piping are c.

provided.

d.

A stream of leaking oil from pressurized parts will not impinge on the ventilation louvers at an angle which permit the oil to escape.

We accept the design of the proposed lubricating oil collection systen subject to a satisfactory resolution of the staff's concerns identified acove.

'3.2.3 EFFECTS OF WATER SPRAY Our SER, Section 3.2.3 indicate that the 1.icensee will analyze the effect of water spray to ensure that both divisions of safety-related equipment will not be incapacitated by rupture or inacvertent operation of the fire

. water systen, or the application of fire hoses. Additional modificatio.1(s) will be provided as necessary.

, By letter dated December 28, 1978, you indicated that all plant areas con-taining safety-related equipment have been reviewed and with the exception of two areas, it was determined that water spray from fire protection sources will not. simultaneously affect divisions of safety-related equipment.

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. shields will be provided to preserve at least one division of electrical equipment in each of these two areas.

You confirmed by telecan on November 31, 1979 that your analysis has considered possible additions or modifications.of the fire water system identified in the fire protection SER.

Design description of such drip shields should be submitted for the staff's review.- You should also provide ~infomation regarding the assumptions,

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method.and cr,i'.eria used in performing such study.

3.2.4 ADEQUACY OF THE DETECTOR SYSTEM DESIGN SER Section 3.2.4 indicates that the licensee will perform a study and/or testing to verify the adequacy of existing and proposed fire detector placement'and distribution.

By letters dated March 16, 1979 and July 11, 1979, you indicated that a study had been done which concluded that the existing fire detection system, when supplemented with the proposed additions, would be adequate to' detect a fire in a timely manner.

Your submittals did not include information on the parameters considered in the study nor the criteria specifted in your letter to Mr. R. M. Rogers for Mr. R. M. Klingman dated February 16, 1979.

You are requested to provide these parameters and criteria.

3.2.14 FIRE DOOR SUPERVISION SER Section 3.2.14 indicates that the licensee will provide a proposal with regard to fire door supervision. The staff agreed to address the accep-tability of the licensee's proposal upon completion of our review of the submittal.

By letter dated November 1,1978, you provided a list identifying those fire doors.that are electrically locked and alarmed, fire doors that are mechanically locked, and fire doors that are neither locked nor alarmed.

Your submittal, however, did not include any justification of the decision not to supervise those fire doors which are neither locked no~r alarmed.

Specifically, you did not describe the hazards (including combustibles and safety-related equipment or cabling) on both sides of each fire door that is not supervised, and the safety consequences of a fire communicating through these open doorways.

You are requested to provide justification (s) for not providing electrical supervision, or locking closed those fire doors that are neither locked closed nor electrically supervised.

Electrical supervision of fire doors should provide a time delayed alarm at a conscantly occupied area.

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. 3.2.15 ENGINEERED SAFEGUARD CABINETS Section 3.2.15 of the SER indicates that the licensee will perform a study to determine if safe shutdown of the reactor can be accomplished assuming loss of both engineered safeguards actuation (ESAS) cabinets in Fire Zone CB-3C.

If the study indicates that the capability for safe shutdown could be adversely affected, the licensee will propose fjadditional fire-protection measures.

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'Byletterdated'Septembeh 25,1978, you provided the results of

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your study concluding that the capability to achieve safe shutdown is not adversely affected by the loss of both ESAS cabinets.

The study is based

.on two major assumptions:.

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,,;.r The ESAS cabinets were totally disabled by an exposure fire such that they did not cause ' equipment to start or stca, and

' A LOCA neither preceeded, occurred coincident with, nor followed the postulated fire.

The latter assumption is acceptable because it is consistent with our guideline. However, you should justify your assumption that no equipment will be started or stopped by ESAS cabinets that are damaged by fire.

You should also describe means to achieve safe shutdown, in case of the loss of ESAS cabinets, and discuss if such means meets the minimum require-ment identified in our generic position for safe shutdown c-pability that was forwarded by our letter, dated September 11, 1979.

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THREE MILE ISLAND, UNIT 1 - FIRE PROTECTION EVALUATION OF SUPPLEMENT ITEMS FOR WHICH THE LICENSEE'S PROPOSAL IS UNACCEPTABLE 3.1.4 AUTOMATIC SPRINKLER SYSTEMS OR C0ATING OF ELECTRICAL CABLES

~ SER Section. 3.'l.4 indicatds that the licensee will install automatic sprinkler systens or apply'a flame retardant coating to protect electrical cables on Elevation 281 feet of the fuel handling building. This modification was to supplement protection offered by existing marinite board barriers between

- redundant cable trays. The adequacy of the marinite board barriers was to be demonstrated by tests or analyses (see Section 3.2.2).

On September 29, 1979, you requested deviation from the previous commitment in that-these sprinkler systems or the cable coating would be provided only if the results of the proposed marinite board barrier test does not establish that the fire protection afforded by the marinite board is adequate.

You have not demonstrated adquately the effectiveness of the marinite board Darriers (note Section 3.2.2) and the ability to suppress a major fire. We, therefore, request that you provide an automatic water fire suppression system or an application of a flame retardant coating to the electrical cables to pro-tect electrical cables in this area.

3.1.11 FIRE BARRIERS AT REACTOR BUILDING EMERGENCY COOLING VALVES SER Section 3.1.11 indicates that additional fire barriers will be installed to reduce the possibility of the loss of function of the reactor building emergency cooling valves due to a fire.

By letter dated August 27, 1979, y~ou stated that fire protection for this area had been reviewed and that the proposed barriers were found to be unnecessary because:

Safe shutdown can be achieved using the normal reactor building cooling a.

system.

b.

A fire detection system was to be installed in the area.

Subsequently on November 30, 1979, you have verified by telecon, that although equipment and cabling of the normal reactor building cooling system are located outside this area the system cannot be operated on emergency on-site power.

Consequently, the two systems are not equal.

We conclude that your request for deviation is not acceptable and require that you protect these reactor building emergency cooling valves as originally committed by you.

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. 3.2.1 PROTECTION OF EMERGENCY FEEDWATER PUMPS SER Section 3.2.1 indicates that the licensee will analyze the fire hazards in the emergency feedwater pump area and will propose additional modifi-cations necessary to preserve the safe shutdown capability.

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By let[er dated December 28, 1978, you stated that fire protection in this

s. area.was. evaluated and it was concluded that no additional protection is

' necessary for two' reasons. First, because the motor-driven and turbine-driven pumps are separated by more than 35 feet of spa'ce and interposing partial _ barriers. Second, because the detection system, portable extin-guishers, and fire hoses provide adequate protection for this area of low combustible loading.

You did _not provide any analysis of fire hazards in this area to support your conclusion that a rated fire barrier is not required between redundant pumps.

We conclude from our evaluation of information submitted to date that there is not positive evidence to justify your contention that at least one emergency feedwater pump would be available for shutdown in the event of a fire in this area. We reauest that you provide analysis of fire hazards (i.e., lube oil of the turbine drive, pump and transient combustibles) in this area to support your conclusion and give positive evidence to justify your contention that at least one emergency feedwater pump would be available for safe shutdown in the event of a fire in th.is area.

3.2.2 CABLE SEPARATION SER Section 3.2.2 indicates that the licensee will perform a study and/or testing to verify the effectiveness of the asbestos board barrier design in preventing the spread of a tray fire to nearby trays with or without the presence of interposing non-safety-related cables, and in preventir.g damage to redundant cables from a possible exposure fire. Where the stua' indicates that the present design is inadequate, corrective modification

- will be proposed.

By letters dated July 13, 1979 and September.14,1979, you provided results of your review of the cable installation in various plant areas. The following assumptions are implicit in this review:

a.

A 3' horizontal separation, or less if approved by ENGINEER, between redundant engineered safeguard (ES) cable trays is considered adequate to preserve safe shutdown.

b.

Marinite board barrier of the existing design and construction provides adequate protection for redundant ES cable trays less than 3' apart.

c.

Six incnes spatial separation between conduits, concaining cables from different enannels, is considered adequate.

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Separation of ES cable trays with non-ES trays is adequate even though the spatial separation could be as little as l'-3".

Separation of other safety-related cables than ES cables need not be con-e.

sidered.

We request that you provide justification for assumptions a, c, d and e above. As for Assumption b, we find it unacceptable because we disagree with your conclusions given by letter dated September 14, 1979 regarding the adequacy of the marinite board barrier in protecting ES cable trays 2 less'than.3' apart.*

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a We disagree"with your conclusion regarding. marinite board fire barrier tests results in your report titled ". Cable Raceway Fire Barrier Tests, Three Mile Island Nuclear Station Unit 1" because the final test con-figuration and test conditions were in our view not conservative on several counts.

Ventilation - The test chamber had a large opening at the top that a.

allowed air to be vented which does not adequately represent fire areas in the plant.

Fire dampers in the ventilation ducts serving fire areas at the plant close when the upper room air temperature approaches 200*F and the ambient temperature in the vicinity of the fire will be well above this value (200"F).

In our opinion, the test chamber ambient temperature did not reach the maximum temperatures that can be expected at a fire in the plant because of the large opening at tne top of the tes,t chamber.

b.

Cable Trays - Your test procedure called for the cables to be randomly laid in tne cable tray (i.e., Section 4-5 Page 3).

In our opinion, the cable trays were neatly packed solid with cables which would reduce air circulation between cables.thus resulting in nonconservatism regarding to maximizing the burning rate.

Although multiple stacked trays above and/or below horizontal fire barriers is rather comon in the plant, you chose to test the barrier with only one tray above and one tray below. Stacked trays not only contained a larger numoer of combustible cables, but such an arrangement generally results in a more severe fire. You have not provided any infomation to support the claim that the test configuration represents the most conservative condition found in the plant.

'The staff'also has reservations regarding the effect of the relative location of the test trays with respect to the floor and the ceiling.

These test trays werelocated approximately 10 feet above the ficor and five feet below the ceiling. You have not provided any information to confim that all cable trays in the plant are at least 10 feet from the floor and at least.

five feet below the ceiling.

Cable Tray Fire - Your test procedure callid for a well developed fire c.

in tne cable tray to demonstrate the fire retardant capability of the marinite board. This was not achieved by your tests because an ignition was not' attained in the actual test in the cable trays configured in the test chamber.

- E3 In summary,'we cannot agree with your conclusion that these test results demonstrated that the existing marinite board barriers provide adequate separation of redundant cables to preserve safe shutdown capability of the plant.in the event of a major cable tray or exposure fire.

We request that, you provide in all fire areas containing redundant cables needed for safe shutdown, either one division of these cables be enclosed by 3-hour (or lower rating if it can be justified) fire barriers, or alternate shutdown capability independent of the area.

You may also provide adequate w.

justification to resolve our concerns discussed above. However, if you consider a re-run of the fire board test as part of justifying our concerns, then your. schedule _for re-running such a test should not jeopardize the completion of the plant modifications by October 1980.

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3.1.8 UNLABELED FIRE DOORS SER Sections 3.1.8 and 3.2.6 indicate that the licensee will establish the adequacy of the fire resistance of pr

'tly unlabeled fire doors and frame assemblies.

If the adequacy of the i resistance of such assemblies cannot be established, they will be replaced by properly rated fire door assemblies.

Your response of December 1,1978 (GQL 1919) indicates that several doors and frames /will be replaced with Class A labeled doors and frames, and that some additional frames only will be replaced.

However, you proposed to retain many unlabeled doors on the basis that they are either oversize or identical in construction to Class A or B labeled fire doors and. _ _ _..

therefore testing and labeling is not required. You consider as adequate engineering drawings and purchase order documentation specify a labeled fire door in the particular doomay. You also proposed to lea.ve in place one door frame which 'is tack-welded to the three hour rated metal wall in which it is installed, and an oversize rolling steel door in whicn is installed a pedestrian door.

Fire door test furnaces can accommodate doors up to 12 feet in height or width.and up to 120 square feed in ar.ea.

Larger doors cannot be tested and are termed " oversize." Undemriters Laboratories (UL) can frnish Certificate of Inspection stating that an oversize door, except for its

- size, othemise complies with all requirements for design, materials, and construction ef a labeled fire door. A label indicating that a certi-ficate has been is.:ued is attached to the door. This label is the only way to identify the acceptability of " oversize" doors.

Engineering drawings and purchase order documentation, in and of themselves, only indicate that a door of certain design was to be procured for instal-lation.in a given doomay. They do not demonstrat.e that the intended door was, in fact, installed. The door should be uniquely identified in a way which associates it with the design drawings and test results. The Ut or FM label on a door is the commonly accepted form of unique identi-fication.

Unless some other form of permanent identification is found on an o:nerwise unlabeled door, there is no obvious indication of the fire resistance rating of the door.

Fire door frrr.es should likewise be tested and labeled, except that frames constructed in accordance with the provisions

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of UL Standard 63 may be labeled without further testing. Again, a UL or FM label is an indication that the construction of the frame conforms to an acceptable design.

1979 telecon with the staff, you conducted Pri r to the Janum 29 a fkeld survey ano provided another submittal on January 7,1979, in which the ratings of several doors were corrected and the roll-up door was

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proposed to be replaced with a rated door and fraine essembly and a suitably constructed wall. However, you did not propose to replace any of the other. doors on which there were questions of fire resistance i

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7+ ' ' ? rating, nor.'did.yotr provide the technical basis;,for pemitting;;these

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doors to remain..in place.

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We request that you resolve the staff's concerns discussed above or replace

.all unlabeled fire doors and frame assemblies with those having a proper fire label. This position is based on the lack of informat'on needed to.

establish the. fire resistance rating of these doors.

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3.2.9 TRANSIENT COMBUSTIBLES SER Section 3.2.9 indicates that the licensee will conduct a study to detennine the effect of transporting transient combustibles through zenes that were not previously analyzed for their presence. Corrective modi-fications will be provided as needed.

In your response dated November 1,1978, you indicated that a 55 gallon

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drum of oil or 1,000 pounds of Class A transient combustibles were postu-lated in each area, but the fire loading in each area still remained within the rating of the surrounding fire barriers.

You did not consider the zone of influence of fires involving transient combustibles.

The transient contustible study was intended to determine the maximum amounts of combustibles that could be brought into or through each plant area and the effects of fire involving such combustibles on systems and com-ponents important to safety within the fire area.

Because such a fire would be concentrated and localized, it is meaningless to only consider the increase in fire loading caused by the transient combustibles. The fire loading.is the average heat content per square foot, assuming that all combustibles are evenly distributed over the entire floor area of the fire area under consideration. The fire loading has little significance in evaluating the consequences of fire on adjacent redundant systems or components.

w-Without analyses of the localized effects of such fire, we find that you lack justification in contending that at least one division of redundant safe shutdown equipment or cabling located in the same fire area would be preserved in the event of a major fire in that area. We therefore request that in those plant areas that contain redundant equipment required for safe shutdown, provide an alternate means of performing the function of such equipment independent of the area containing the equipment, or to separate one division of such equipment from its redundant counterpart by a three hour fire barrier.

The areas in which these modifications 'should be required include, but are not limited to:

The auxiliary feedwater pump area (see SER Section 3.2.1).

E3 Decay heat closed cycle cooling water pump a -d nuclear service closed cycle cooling water pump area.

Engineered safeguard MCC. area.

3.2.12 EMERGENCY LIGHTING The SER, Section 3.2.12, indicates that the licensee has connitted to conduct a survey to determine if adequate emergency lighting ~is provided P.

C for shutdown operation and fire fighting activities in safety-related areas.

By letter dated December 28,197EL you submitted the results of such-survey acknowledging that there are potential problems if a fire takes

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place in the vicinity of the distribution panel or certain main lighting circuit feeders. You contend that:

(1) the plant could be shutdown from the control room regardless of the fire, (2) a fire in these areas does not affect the ability to bring the plant to safe shutdown, and (3) adequate lighting to fight fire can be provided by portable hand lights.

Additional modification, therefore, is unnecessary. You, however, did not provide any basis to substantiate your contentior. on safe shut-down.

The staff disagrees that portable hand lights can provide adequate lighting

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for fire fighting.

Portable lanterns are required to back up fixed lighting for defense-in-depth; but they provide much less lumen compared,

with fixed lighting units.

Relying solely on hand lights for fire fighting will also force fire fighters to carry additional loads that the on-site fire brigade with limited manpower can ill afford.

We requert you to either (1) provide, where necessary, fixed sealed-beam emergency lighting units with self-contained 8-hour rated batteries, or (2) modify the lighting distrib~ution systems; so that access to all safety-related areas, and certain locations where local operation may be necessary during emergency shutdown, can be assured of adequate lighting during and following any fire. emergency.

3.2.13 PROTECTION OF RELAY ROOM SER Section 3.2.13 indicates that the 1.icensee will identify those are..s

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in the relay room where he proposes to provide a manually actuated fixed water suppression system or will coat the electrical cables with an appropriate flame retardant coating.

This is in addition to the licensee's other commitment to:

' eplace unlabeled doors and upgrade barrier penetration seals to R

provide a three hour barrier snclosing the room.

rovide manual hoses to reach all points of the room effectively.

• o Provid6 a shutdown capabiliv.y independent cf cabling and equipment in this area.

By letter dated October 31, 1979, you requested a deviation from this commitment and indicated that no additional protection for this room is planned, but did not provida any justification for such request.

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We request you to provide adequate justification for the deviation requested by letter dated October 31, 1979 or apply a suitable flame retardant coating b

to all cables in the relay room. The staff's bases for such requirement E

were discussed in our SER Section 5.11.

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