ML19323B473
| ML19323B473 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 04/28/1980 |
| From: | Frank L ENERGY, DEPT. OF |
| To: | Goodwin C PORTLAND GENERAL ELECTRIC CO. |
| References | |
| R-3-12-507, NUDOCS 8005120413 | |
| Download: ML19323B473 (3) | |
Text
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R 3-12-507 r
8005120%5
,m-.,. 3/:
]Q Department of Energy Syy 1.A80R & INDUSTRIES BUILDING, ROOM 102, SALEM, OREGON 97310 PHONE 378-4040 j
April 28,1950 Charles Goodwin, Jr.
Assistant Vice President Portland General Electric Company 121 SW Salmon Street Portland, OR 97204
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Dear Mr. Goodwin:
In a letter dated April 14, 1980, PGE forwarded to 000E Trojan License j
Change Application 59 which deals with a change to the license requirements regarding fire protection.
Specifically, the change i
involves fire protection measures in those areas that contain both trains of safety-related systems, that is the cable spreading room and some cabinets in the control roun. The purpose of this letter is to express 000E's disagreement with the proposed change and request PGE action to resolve this issue.
Background
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As a result of the fire at Brown's Ferry in 1975, beginning in 1976 PGE committed to implenent improvenents in the fire protection systen at i
Troj an.
In the cable spreading room, which contains cables from both trains of safety-related equipnent, either a deluge fire suppression system activated by fire detectors or an electrical systen to permit local operation of equipnent required to achieve and maintain a safe cold shutdown condition (referred to as a decouple systen) was to be installed. PGE originally stated a deluge system would be installed by 1979.
Later, PGE stated a decouple systen would be installed by 1979.
tiRC approved Amendnent 22 to the Trojan Operating License on March 9, 4
1978, which required the decouple systen to be implenented by the end of the second refueling outage and prior to return to operation for fuel cycle 3 (which was then thought to be June,1979, but is now scheduled f or July,1980).
In order to ensure no further slippage would occur, on February 8,1980, the Energy Facility Siting Council adopted the f ollowing rule:
" CAR 345-26-141 Fire Protection: The operatcr of a nuclear fueled tnamal power peant shall provide fire protection measures such that for rocms with both of two redundant safety systexs present, a postulated fire will be extinguished by a deluge system, or equivalent, cr otherwise provide assurance that an hg<f.,' O unmitigated fire will not prevent safe plant s hut down. For the Trojan Nuclear Power Plant, this rule will become effective at the end of the second refueling outage and prior to return to operation for f uel cycl e 3.
For all other nuclear fueled thermal power plants, this rule will become effective upon c
ion."
~
Charles Gcodwin, Jr.
April 28,1980 Page 2 Based on the current schedule for Trojan, this rule requires implenentation by about July,1950.
PGE Propasal PGE now proposes to install a deluge fire suppression systen in the cable spreading roan by November 1,1980 and a gas fire suppression system in some of the cabinets in the control rcom that contain both trains of saf ety-related equipnent bef ore the start of fuel cycle 1, which is currently scheduled for the spring of 1931.
PGE has determined that fire suppression systens of this fonn are preferrable to a fire mitigation system in the fcrm of a decouple system. However, PGE states that due to equipnent unavailability, the fire suppression systens cannot be installed by the current deadline. As a compensatory measure, PGE proposes to assign continuous fire watches in the cable spreading room ano control room beginning with return to operation af ter the ongoing ref ueling shutdown. PGE has yet to provide technical justification as to the equivalency of these fire watches compared to the fire suppression systems.
000E Ccements 000E coes not believe that the proposed continuous fire watches provide fire protection equivalent to that of the fire suppression systens and therefere that the proposal complies with the EFSC rule.
Specifically:
1.
The proposed fire watches may not provide an equivalent sensitivity for detecting fires. Due to the physical layout of the cable spreading room, it will be impossible for a fire watch stationed near the door of the room to visually observe the entire room.
The air currents associated with the ventilation system may prevent the fire watch frcm seeing or smelling the smoke associated with a small fire in the f er ucr.vrs of the room.
This weakness may be sccewhat improved by having the fire watch imediately alerted to any alarms f ran the installed 8 ionization-type fire detectors in the room.
However, PGE apparently believes the existing detection system is not adequate since the detection system that will activate the deluge system will involve an expanded network of fire detectors. With this expanded network, the sensitivity for detecting fires will be improved over the currently installed fire cetection systen and may be improved over that which would exist with the combination of a continuous fire watch and the currently installed fire cetection system.
For the cabinets in the control rocm, it will be even more difficult for a fire watch to detect a fire, particularly in its early stages due to the inability to sr.e inside the cabinets.
l
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i Charles Goodwin, Jr.
i April 28,1980 J
Page 3 i
2.
The proposed fire watches will not provide an equivalent fire i
suppression capability. For a small fire, the fire watches will have i
to ccmbat the fire with portabia fire extinguishers. The ability of j
the fire watch to effectively cmbat such fires will be diminished by the difficulty and associated time it requires to reach the fire site in the cable spreading room (possibly by crawling under or climbing over cable trays) and to identify the exact fire site.
For a large j
fire, the installed autcmatic sprinkler system in the cable spreading room should activiate. Mcwever, the sprinkler systen provides lower 1
water volune ficw rates and less complete coverage than the deluge system. For any size fire, the deluge systen would activate to
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provide large water volune flow rates and comolete coverage which will ensure quick and positive extinguishnent.
I In the control room cabinets, since the fire watch may have difficulty determining the exact fire site and the fire watch will I
rely upon portable fire extinguishers to ccmoat the fire, the same
)
arguments apply.
000E agrees with PGE that it is preferrable to suppress a fire rather than to mitigate the consequences of it.
Therefcre, it is 0002's position that PGE should take actions to install fire suppression systens in the cable spreading rocm and control room cabinets prior to operation j
following the current refueling snutdown.
j Given the clear direction and reasonable ccepliance period offered by 0AR 345-26-141 and the responsibility imposed by law to insure compliance with safety standards, PGE is directed to submit, by May 5,1980, a 4
written compliance schedule. This schedule should provide for the installation of a fire suppressicn systen either prior to operation or clearly document why the compliance period was not sufficient and justify the need for an extension and interim compensatcry measures that insure j
sufficient detection and suppression capabilities.
1 Sincerely, iff.D
'f8
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L' nn Franly Director LF /30:swd 7259A cc: Ed Whelan, PGE Robert Engelken, NRC, Region V Charles Trammell, NRC, ORBI i
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