ML19327A418
| ML19327A418 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 06/30/1980 |
| From: | Linder F DAIRYLAND POWER COOPERATIVE |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-45FR36082, RULE-PR-50, TASK-EM-915-1, TASK-OS 45FR36082-50, LAC-6999, NUDOCS 8008060177 | |
| Download: ML19327A418 (5) | |
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- 2615 EAST AV SOUTH + LA CROSSE. W1SCONSIN M601 (608) 788 4 000 June 30, 1980 In reply, please refer to LAC-6999 DOCKET NO. 50-409 Secretary of the Commission to U. S. Nuclear Regulatory Commi:,3 ion (b
ATTENTION:
DOCKETING AND SERVICE BRANCH g
Washington, D. C.
20555 coCKETED y
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SUBJECT:
DAIRYLAND. POWER COOPERATIVE E
a 31980 >
9 LA CROSSE BOILING WATER REACTOR (LACBWR)
PROVISIONAL OPERATING LICENSE NO. DPR-45 Office of the SecetM.
Docket t & Sen COMMENTS ON PROPOSED APPENDIX R TO f
10CFR50 REGARDING FIRE PROTECTION m
References:
(1)
NRC Letter, Eisenhut to All Licensees with Reactor Operating Licenses Issued Prior to January 1, 1979, dated May 19, 1983.
(2)
NRC Letter, Eisenhut to All Licensees with Reactor Operating Licenses Issued, Prior to January 1, 1979, dated May 22, 1980.
Gentlemen:
Refe'rence 1, as modified by Reference 2, forwarded a proposed rule adding a new Section 50.48 and Appendix R to 10CFR Part 50 and requested comments.
LACBWR comments on specific sections of the proposed rule are forwarded as Attachment A to this letter.
Overall, the proposed Appendix R appears more general and less restrictive than Regulatory Guide 1.120 and Branch Technical Position APCSB 9.5-1, however, some sections of Appendix R are in-appropriate to this facility or were not previously required by the
.NRC's Fire Protection Safety Evaluation Report.
As described in Attachment A, certain provisions of the proposed rule should not be applied to LACBWR due to the plant's unique design and small size which make alternate _means of meeting fire protection objectives necessary.
General guidelines of Regulatory Guide 1.120 and Branch Technical Position APCSB 9.5-1 have been applied to the plant with a detailed and thorough review of plant-specific structures and systems by the licensee and the NRC.
This has resulted in a very detailed Safety Evaluation Report and extensive fire protection requirements.
A gg great effort has been made to satisfy all of these requirements, and 9
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7 Secretary of the Commission LAC-6999 U. E. Nuclear Regulatory Commission June 30, 1980 in spite of numerous other regulatory requirements associated with Three Mile Island, the Systematic Evaluation Program, the Security Program, and various I&E Bulletins, it is expected that all existing fire protection requirements will be implemented by November 1, 1980.
Based on past experience, it is apparent that development of official interpretations of Appendix R and determination of any plant specific actions to be required by Appendix R will in itself be a lengthy process which will probably extend past the November 1, 1980 deadline.
Implementation of any such new requirements prior to November 1, 1980 is clearly unrealistic.
If you have any questions regarding this submittal, please contact us.
Very truly yours, DAIRYLAND POWER COOPERATIVE Frank Linder, General Manager FL:FD:af i
Attachment cc:
J. Keppler, Reg. Dir., NRC-DRO III !
L
r ATTACHMENT A COMMENTS REGARDING PROPOSED APPENDIX R TO 10CFR PART 50 i
II.A.2.e.
I This section should be clarified as to whether it applies in cases where actuation of an automatic suppression system would disable a redundant system or component important to safe shutdown.
While we agree that any extinguishing agent which is required to control a fire should be used, even if this action places a redundant system out of service, we believe that any action which could incapacitate a safety system must be consciously taken by a trained operator and i
should not occur automatically.
Otherwise, actuation of such a suppression system could unnecessarily put a safety system out of service leading to a loss of redundancy and possibly causing an accident.
This concern regarding automatic suppression systems is consistent with IV.A.5 of Branch Technical Position APCSB 9.5-1.
II.A.2.f.
This requirement has been addressed by the licensee in " Analysis of the Ability of LACBWR to Achieve Cold Shutdown in the Event of a Fire",
i presently under review by the NRC.
The license believes that plant construction and operating procedures, with modifications described in the Safe Shutdown Analysis, insure the ability to reach cold shut-down._ The specific actions required by II.A.2.f are unworkable at this plant, but the objectives of this paragraph are attainable by other means.
III.B.
Sectional Control Valves The proposed Appendix R requirement that " sectional control valves...
shall be provided" should be revised to read, " sectional control valves...should be provided" as previously required by IV.C.2. (a) of Branch Technical Position APCSB ' 9.5-1 and by C. S.b. (1) of Reg. Guide 1.120.
Sectional control valves to isolate only a part of the fire main are not necessary at LACBWR due to the small size and character-istics of the system described in "LACBWR Fire Protection System, Combined Water Demand Analysis", presently being reviewed by the NRC.
III.E Hydrostatic Hose Tests The test pressures specified in this section are excessive and should be changed to comply with National Fire Protection Association Stan-dard 198.
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4 ATTACHMENT A - (Con t' d)
III.G.
Protection of Safe Shutdown capability This section appears consistent with previous requirements.
Some parts of Section III.g, such as Table 1, did not exist in earlier regulatory positions, and either a plant-by-plant detailed appli-cation of this section er some statement of the acceptability of analyses and modifications already completed or in progress will be needed from the NRC.
Due to the generality of this section, no further comment can be made without a detailed plant specific interpretation.
III.H.
Fire Brigade The five man fire brigade has been the size for nuclear plants since the inception of fire protection rules.
It does not differ-entiate between small and large sites or single and multiple unit facilities even though there is a great variance in risk.
Pre-viously, the assignment of two operational personnel to the fire brigade was required.
The suggested Appendix R to 10CFR50 raises this number to three without statement of reason.
There is no reason to increase this drain on operational personnel.
One knowledgeable person is adequate to direct the fire party (which is fully trained in fire area's safety related equipment anyway).
The addition of a second operations department member adds total backup for incapacitation of the principle member.
The addition of a third member from the operations department adds nothing signifi-cant to the knowledge or competence of the fire party, particularly on a small single unit site.
It does, however, mandate the removal from the control room of another skilled individual.
This proposed rule should be changed to require only two operations personnel to be members of the fire party.
It should also carefully consider why 5 people are required in the fire party of a small single unit site.
If this degree of hazards reduction is required, then signifi-cantly larger numbers of people would be required to attain the same degree of safety for larger or multiple unit sites.
Most fire companies consist of either 3 or 4 personnel attached per unit.
If j
this represents adequate coverage for large industrial fires, it is more than adequate for a small nuclear plant.
III.I.3.d.
Further interpretation of the requirement for drill critiques by qualified individuals independent of the licensee's staff every 3 years is necessary.
It is recommended that this independent critique cover one drill chosen at random by the qualified inde-pendent individuals and not require critiques of every fire brigade and each brigade member due to the unwieldy scheduling problems this would create. !
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ATTACHMENT A - (Cont'd)
III.K.5 Hot work and any appropriate precautions are presently controlled under Special Work Permits which also include radiological, plant safety, and personal safety.
LACBWR believes this system satisfies the NRC and NFPA objective of adequate administrative controls of hot work and that Section III.K.5 of the proposed Appendix R would only add to the proliferation of forms and paperwork and would be ineffective in accomplishing its objective.
III.P.
Reactor Coolant Pump Lubrication System This section includes requirements for oil collection systems to drain to a vented closed container and that either the oil collection system or the lube oil systam be able to withstand a Safe Shutdown Earthquake.
These requirements were not included in Branch Technical Position APCSB 9.5-1, Reg. Guide 1.120, or in the plant specific Fire Protection Safety Evaluation Report.
The impact of these proposed requirements has not yet been evaluated, and implementation prior to November 1, 1980, would be impossible.
Design details of an oil collection system already installed by LACBWR are presently being reviewed by the NRC.
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