ML19340B389
| ML19340B389 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 10/17/1980 |
| From: | Wilverding G POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | Ippolito T Office of Nuclear Reactor Regulation |
| References | |
| JPN-80-46, NUDOCS 8010220413 | |
| Download: ML19340B389 (9) | |
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4 POWER AUTHORITY OF THE STATE OF NEW YORK to Cotuusus CIRCLE NEW YORK. N. Y.10019
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opsR4 TING OFFICER JOHN W. SOSTON JOHN S. DYSON or was opsnavsoMS
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October 17, 1980 g,cl;;r, iaaacia' rarosaica n. cuan c JPN-80-46 y,,,,,
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Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Connission Washington, D.C.
20555 Attention: Mr. Thomas A. Ippolito Operating Reactors Branch No.2 Division of Licensing
Subject:
James A. FitzPatrick Nuclear Power Plant Docket No. A50-3 Fire Protection System
Dear Sir:
This letter provides an updated status on the implementation of those modifi-cations and procedural changes required by the JAF Safety Evaluation Report (SER) supporting Amendment No. 47 to facility Operating License No. DPR-59, dated August 1, 1979.
Addit.ionally, as clarified below and in Attachment 3, this letter requests an extension for certain modifications of the October 31, 1980 completion date.
The Authority has been engaged in a maximum effort to complete the fire protec-tion modifications by the October 31st deadline. This has been made much more diffi-cult by other NRC mandated modifications which we have been implementing in parallel.
These modifications include those mandated by the NRC as a result of TMI Lessons Learn-ed, and as a result of the Mark I Containment Program.
l As an illustration of the magnitude of the effort, there presently are a total of l
468 craft personnel at the FitzPatrick site of which 394 are dedicated to Fire Protec-l tion System Modifications. During the past refueling outage, which extended from mid-1 l
May thro. ugh mid-August, over 1,000 craft personnel were on site,-of which approximate-ly 425 were dedicated to installing NRC mandated modifications. We believe that pro-vision of additional personnel would not improve the expected completion dates as out-lined in Attachment 3.
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Mr. Thomas A._Ippolito.
In order to support the effort of completing the fire protection modifications by the NRC mandated deadline of October 31st, the Authority has been proceeding on the assumption that all of the modifications still requiring NRC approval would re-ceive that approval.
It is the Authority's understanding, based on telephone conver-sations held on A.ugust 25, 1980 and October 3, 1980 that: SER items 3.1.8, 3.1.17, 3.1.18, 3.1.19, 3.2.2, 3.2.3, 3.2.4, 3.2.5, 3.2.6, 3.2.7, 3.2.9, 3.2.10 and 3.2.11 are closed; SER items 3.1.9 and 3.15 are unresolved and require NRC action; SER item 3.1.20 is open pending NRC receipt of additional administrative information; and SER items 3.2.1 and 3.2.8 are unresolved and require further discussion between the Au-thority and NRC staff.
' lists those SER items that have been completed as of October 13,1980. lists those SER items or portions thereof that will be completed by Oct-ober 31, 1980. Attachment 3 lists those SER items which will not be completed by Oct-ober 31, 1980, the reason for the delays and the request for the new completion dates.
For these items the Authority will provide covering watch or alternate manual fire fight-ing capability where applicable until completion.
A few modification segments, as described in Attachment 3, require shutdown for completion. The Authority requests that these installations be postponed until the late February-early March,1981 snubber inspection outage.
To more clearly explain our requests for completion date extensions and also to finally resolve those items still open, the Authority requests that a meeting be ar-ranged and held as soon as possible between the appropriate NRC staff members and Authority personnel.
Very truly yours, he/2fNY George M. Wilverding Manager-Nuclear Licensing l
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4 ATTACHMENT-1 AMENDMENT 47, SER ITEMS COMPLETED AS OF OCTOBER 13, 1980 A.
Table 3.1 Modifications Completed ITEM NO.
TITLE 3.1.2 Valve Supervision 3.1.3 Manual Fire Fighting Equipmetic 3.1.4 Self-Contained Breathing Apparatus
- 3.1.5 Administrative Controls 3.1.6 Emergency Lighting 3.1.7 Fire Doors 3.1.8 Ventilation System - Safety Related Pump Rooms 3.1.10 Exterior Hydrant Hose _ Houses 3.1.11 Post-Indicator Valve Wrenches 3.1.12 Post-Indicator Valve Labeling 3.1.13
' Fire Brigade Leader Training 3.1.14 Control of combustibles 3.1.16 Fire Alarm Annunciation in the Control Room 3.1.21 Ventilation Duct Penetrations B.,
Table 3.2 Studies-and Modifications-(if applicable) Completed 3.2.4 Diesel Fire Pump Room Sprinkler Head Spacing
.3.2.7 Fire' Pump Performance 3.2.9 Testing of CO2 Fire Suppression Systems 3.2.11 Cable Flame Tests f
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' AMENDMENT 47, SER ITEMS (C3 PORTIONS) TO BE COMPLETED BY OCTOBER 31, 1980 ITEM NO.
' GENERAL. TITLE AND SPECIFIC PORTION 3.1.1 Interior Hose Stations 100% complete 3.2.3
. Fire' Water Piping System 100% complete 3;1.19'
- Exposed Structural-Steel 100% complete
-3.2.1-
. Fire Hazard Analysis-(Structural Modifications) a) Concrete hatch cover - 100% complete b). Motor Control Center. Barrier - 100% complete c) Fire Dampers - 100%.complet'e d) Motor-Operated Valve-Enclosure with exception of fire' door 100% complete 3.1.20 Electr'ical-Cable Penetration Qualification Of the approximate 5200 penetrations, approximately 80% will be completed.
3.2.2 Pipe. Penetrations Of the 613 penetrations, approximately 85% will be completed.
3.1.18
. Fire Det'ection and Signaling System
.The additionallrequired detectors '(not dependent on other installations)- will be installed and locally. terminated and operable.
Termination to remote fire' panel will.be in progress.
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3.2.5 JPi're Door Supervision The additional required door switches (not dependent on"other installations) will be~ installed and-connected to their~ local multiplexers.
Termination to.the. remote: fire-panel will be in progress.
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' 3. 2. 6 -
. Signaling Circuits Supervision l Rewiring of local. panels will be in progress.
Installation of break l glass supervision will be
- about 50% complete.
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$. 2 '.1 Fire Hazard' Analysis'(Electrical Modificatione)-.
With the exception of lateLdelivery. cabling, the rerouting of. conduit-and cabling required to meet-the minimum requirements of the FitzPatrick Fire Hazard Analysis will be com-
. pleted.with final terminations in progress.
1 3.~2.10-Crescent-Area Fire Protection a) HPCI-Barrier 100% complete b) RCIC Cnclosure i -
The physical enclosure (walls and roof will be approximately 50% complete.
3.1.17 i
Total Flood ng CO2 Suppression System -
Ventilation Systems Modifications were completed on all areas except the relay-room during FitzPatrick's last refueling outage.
The_ relay room interlock must be made in the new fire protection panel which is due for shipping October.18, 1980.
This item will be completed by October 31,,1980.
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Oh vy 4-ATTACHMENT'3 ARENDMENT 47, SER ITEM
. FINAL ~ COMPLETION DATES AND REASONS FOR' EXTENSION ITEM NO.
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3.1'.9 &:
Alternate-Shutdown-Capability - Relay Room =
3 ~.1.~ 15 Alternate Shutdown Capability
-Cable Spreading Room-TheseLtwo items are unresolved witn'the Commission's Staff. ' The Authority's - position 'is that these
. items =were adequately resolved by-FitzPatrick's PF-llL (Fire Hazard ' Analysis) study and resultant i.
modifications.
It is requested that these items remain open_pending final resolution at the
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meeting requested in the cover letter.
3.1.18 Fire' Detection and Signaling S'ystems 3.2.5 Fire Door Supervision c
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'Sicnaling Circuits Supervision 1
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_The. modifications-associated with these items are inter-related due to a common termination within a single new fire' protection panel.
These modifications have been. continually hindered due to the sheer magnitude of the project (over-270 additional-smoke detectors, over 20,000 feet of additional conduit, and over 30,000. feet of new i
cable).- The delivery of the _ new fire protection panel slipped:from mid-August, to mid-September i
'and presently is scheduled to be shipped October.18.
Installation of the break glass stations.is being slowed-to expedite operability of the-fire protection panel and/ newly' installed detectors.
Due to the late arrival _of the panel, the Authority requests i
that the. completion date of these SER items be
--extended'io-December 15, 1980.-
3.1.20 Electrical Cable Penetration ~ Qualification The penetrations;that will not.be completed by
. October 31,11980 primarily involve secondary con-4 tainment,1whichtmust be slowly done under careful
. controls to ensure containment integrity, involve.
penetrations located it. high voltage areas (i.e.,.
electrical! panels); which require a ' shutdown for-installation and/or involve-penetrations.whose cable density' prohibits. utilization of the Lprocess. presently being used (complete removal of.
Eunqualified-urethane foam and installation of
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. approved material).. A different process haa been in development by;our vendor for well over eight months-to protect these high density penetrations.
This new method was-finally successfully tested and approved by American Nuclear Insurers on September
.11, 1980. -Material is due for shipment October 15, 1980 with installation personnel qualification yet to be done.
The Authority requests a com-pletion date extension to November 30, 1980 for those penetrations not requiring'a shutdown.
The iuthority further requests that those penetrations requiring a shutdown be F.ene during an outage as requested in the' cover letter.
3.2.10 Crescent Area Fire Protection' The work on this modification could not begin due to physical interterence, until the completion of those MARK 1 containment modifications required for installation this past summer.
Material deliveries have been a consistent. problem for some time.
High strength concrete blockr required for the the seismic wall did not arrive as L.:heduled in mid-August due to a vendor error.
The 1.arliest rescheduled date would have been early Oc ober.
This late date required an engineering ;edesign to accept standard concrete blocks, which-also requires con-siderably more installation time.
Additional late deliveries are:
- 1) seismic qualified ventilation fan - due November 21, 1980 - required for RCIC operation upon completion of enclosure and 2) fire rated doors - due November 3, 1980.
Upon completion of the physical enclosure, the structural steel can be fire-proofed, smoke detectors installed, and the fire door supervision switch installed.
Due to the late deliveries and lengthy installation time, the Authority-requests a completion date extension to December 15, 1980 with final fan electrical and fire door operation delays until December 31, 1980.
3.2.2 Pipe Penetrations This modification has been hindered due to material availability and lack of vendor supplied installation machines to allow multi-crew work schedules.
It was originally anticipated.to complete this work by October
~1, 1980; however, delays in the arrival of a lead elastomer machine, in the availability of the lead. elastomer material itself and delays in the installation due to administrative controls involved with secondary containment integrity, will push the completion date into mid-November.
We p.osently are assessing the material availability impaet; consequently the Authority requests a completion date extension to' November.30, 1980.
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'3.2.1
. Fire Hazard Analysis- (structural) a). Additionally, the circular stairwell enclosure had to be re-engineered.due to.the high strength Leoncrete block; material design problem described in Item 3.2.10.above. ' Installation of the l
enclosure physically interferes with access for performing the RCIC enclosure modification; therefore, although work is progressing',.com-
.pletion'cannot occur until substantial com-pletion of-the RCIC enclosure.
Consequently, the Authority requests a completion date extension to-December 15, 1980.
b)
The fire door for the motor operated valve enclosure is not scheduled for delivery until December 4, 1980.
The Authority, therefore, requests a final completion date extension to December 31, 1980.
3.2.1 Fire Hazard Analysis (Electrical)
The study has.been completed with numerous modifi-I cations identified.
This item is still unresolved l
with the Commission's Staff.
As discussed in recent l
telephone conversations, there appear to be some l-significant techrical differences between the Staff and the. Authority over the-analysis and resulting modifications.
Although the analysis was submitted in December of 1979, the Authority did not receive notice of this disagreement until August 25,-1980.
As a result of a phone conversation on October 3, 195v it is evident that this issue-must be resolved l
by a follow-on technical meeting.
Although pre-implementation approval had not been given, the Authority decided to begin the installation of these modifications to meet the October 31, 1980 date, but, has been hindered'by engineering design and material. procurement problems.
Presently, cable. deliveries to-support this modification are due October 13, 1980 and November 10, 1980.
Conduit ~is presently being installed to be followed by cable installation and final termination.
With the exception of the cable due November 10, 1980, the conduit and cable required to meet the minimum requirement of this item should-be done by October 31',- 1980-with final terminations in progress.
These terminations have to beldone in slow, carefully controlled manner during plant operation; i.e.,
surveillance tests have to be run, safety related
' " components secured and tagged, and post termin-ation surveillance tests conducted to return components to service.
Additionally, some terminations can only be done with the plant chutdown.
The Authority requests a completion date extension to December 31, 1980 for those circuits not requiring a shutdown; which hope-fully will also allow sufficient time to resolve the open issues on this item with the Staff.
For those few circuits requiring a shutdown, the Authority requests that they be done during an outage as requested in the cover letter.
3.2.8 Fire Pump Capacity The study has been completed with no modification identified.
This item however, is still open with the staff.
It is evident that a meeting will have to be conducted to finally resolve this issue.
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