ML19330B042

Comments on Proposed Rule 10CFR50:re Fire Protection Installation of Stand Pipe & Hose Station Inside Containment Presents Potential Safety Concern Re Boron Dilution in Event of Pipe Rupture

ML19330B042
Person / Time
Site:	Fort Calhoun
Issue date:	06/25/1980
From:	William Jones OMAHA PUBLIC POWER DISTRICT
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-45FR36082, RULE-PR-50, TASK-EM-915-1, TASK-OS 45FR36082-47, NUDOCS 8007300078
Download: ML19330B042 (3)

Text

. . . _ ... . .___ -- . _ _ _ .. _. _. - _ .._ _ . _

E F '

O naha Public Power District .  ;

1623 MARNEY S OMANA. NEBRASM'. 68102 3 T E l.E P M O N E S 36 4000 AREA CODE 402 June 25, 1980 00CY.E1 nuMca NOMED gutE b DOCKETED

~$0 (45 FR 3&0frR) 5esetary of the Commission --

usse

_g U. S. Nuclear Regulatory Commission Washington, D. C. 20555 5'

JUL 81980 > -

cmca of the se:ntan 1,

Docketing & Sendes /]0 Attention: Docketing and Service Branch Brand

Reference:

Docket No. 50-285

' \ i Gentlemen:

The Federal Register, Thursday, May 29, 1980, included a notice of proposed rulemaking regarding " Fire Protection Program for Nuclear Power Plants Operating Prior to January 1,1979". The Omaha Public Power District has reviewed the proposed rule and provides the fol-lowing comments.

(1) Requirement D, Manual Fire Suppression, requires stand pipe and hose stations to be installed in containment.

It is the District's position that inst >ilation of a stand pipe and hose station inside containment presents a potential safety concern involving boron dilution in the event of a pipe rupture. Other measures to mitigate the potential for fire hazards inside containment, in-cluding a reactor co-lant pump lube oil collection sys-tem or sprinkler syst m, administrative controls to re-duce combustibles in the area and the availability of ample portable fire extinguishers, should be consider 2d sufficient to preclude the need for hose stations.

(2) Requirement F, Automatic Fire Detection, requires a de-tection system be installed in areas containing com-bustibles and safety-related systems or components.

However, no consideration is given to areas where the need for an automatic fire detection system is unneces-sary due to the low fire loading.

(3) Requirement G, Protection of Safe Shutdown Capability, does not define conditions under which an exposure fire should or should not be considered. Based on the guide- J lines of IEEE-384-1977 a Regulatory Guide 1.75, it is a the District's opinion tnat an exposure fire need not '

be considered credible when the following conditions (1 exist: ,

4knwhhen/ xd. 7.. R..r.n.:.; cud;;

80 07 3 0 OC)[ ~

=

o Secretary of the Commission '

June 25, 1980 rll Page Two (a) Fire 'oading is limited to cable insulation only (except where a large concentration of cables exist such as cable spreading room). g (b) Fire .iazards are limited to failures or faults internal to the electrical equipment or cables. g s

(c) The area contains none of the following:

open flames and welding operations, s (i) liquids which are classified as flammable (ii) or combustible per NFPA 321-1973, except ~

small quantities of lubrication oil, and (iii) solids (except cables) exhibiting flame spread classification of less than 26 per ASTM E84-1975.

(d) Administrative controls provide suppression measures for temporary ignition source use or the introduction of the materials listed in item (c) above is temporary or limited to an acceptable quantity.

(4) Note 2 of Table 1 of Requirement G states that the requirement for a fixed suppression system may be waived if the only in-situ combustible is cable insulation, measures are provided to retard p c.pagation, and separation between redundant systems is at least 10 feet horizontal and vertical of clear air soace. It is the District's position that, if barriers de-signed '.n accordance with IEEE-384-1977 have been provided, separation of less than 10 feet should be acceptable. Ad-ditionally, in areas where a cable enclosed in a rigid conduit j is routed close to two redundant sets of trays and tray 1 separation of 10 feet or more exists, or a fire barrier in accordance with IEEE-384-1977 is provided when tray separation ,

is less than 10 feet, then separation between the cable and the tray should be considered acceptable. Both ends of the conduit should be sealed with properly qualified sealant to avoid spreading of fire from one tray to the other. Conduit may require additional protection if the cable is required for safe shutdown.

(5) Requirement H, Fire Brigade, states that the brigade leader shall be an operations personnel competent to assess potential safety consequences of a fire and advise control room per-sonnel as necessary. However, the same re;utre. ment also

' specifies that the shift supervisor shal' not be a member of the fire brigade. It is the District's opinion that to ex-clude the shift supervisor from acting as < member of the fire brigade, specifically as brigade leader, severely hinders the quality and effectiveness of the fire brigade. The knowledge and experience of the shi t supervisor allows him to provide the direction and coordination of fire fighting activities necessary to minimize the consequences of a fire.

v., ,- .

Secretary of the Comission June 25, 1980 Page Three (6) Requirement H also requires drills to be performed at regular intervals not to exceed three months for each shift brigaoe.

The District considers this requirement to be excessive and unnecessary in. light of the requirement that quarterly meet-ings be conducted for all members of the fire brigade as well as the requirement that each brigade member participate in at least two drillt per year. These two requirements should provide sufficient opportunity for fire brigade members to demonstrate and maintain proficiency. Additionally, the requirement that at least one drill per fire brigade be performed on a back shift should be in the form of a recom-mendation.

(7) The wording in Item 1 of Requirement L, Alternate Shutdown Capability, requiring hot standby conditions be maintained for at least 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and achieve cold shutdown within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is confusing. Additionally, Item 3 requires that hot standby conditions must be capable of being maintained for a period of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> with no mention of cold shutdown, while Item 4 re-quires cold shutdown be achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The Dis-trict reccmmends that the wording in Items 1, 3, and 4 be consistent so as to eliminate any confusion.

(8) Item 3 of Requirement L also requires that at least one means to achieve hot standby be undamaged by any fire anywhere in the plant. The term "any fire anywhere" is extremely vague and, as such, subject to interpretation. It is the Dis.rict's opinion that consideration should be given to clearly icentify-ing the meaning of the proposed requirement.

(9) Finally, the proposed fire rule fails to give any consider-ation to the results of previous " plant specific" reviews and analyses which may have allowed for variations from the pro-posed rule. Failure to consider such items can result in a significant as well as unnecessary burden and expense to operating facilities and may, in fact, serve to degrade e' .blished levels of fire protection.

Sincerely, j/7

./.,

W.

//kr0

. Jones Division Manager Production Operations WCJ/KJM/BJH/PRT:jmm cc: LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, N. W.

Washington, D. C. 20036

~

E