ML19343C532
| ML19343C532 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/19/1981 |
| From: | Hukill H METROPOLITAN EDISON CO. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| L1L-077, L1L-77, NUDOCS 8103240449 | |
| Download: ML19343C532 (7) | |
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Division of Opera' ting Reactors s..%93.,JC p r.
Atta: Darrell G. Eisenhut, Director
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U. S. Nuclear Regulatory Cc:=is sica a n,a r t w r-me Washing:ca, D.C.
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Dear Sir:
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%: ) is Three Mile Island Nuclear Staticn, Unit 1 ( NI-1)
Operating License No. DPR-50 Docket No. 50-2o.
Respense to Appendix R to ICL. 50 The NRC divisica of Licensing issued a letter en Nevenber 24, 1950 identifring the provisicas of Appendix R thn: are applicable to the fire prctection fea:cres for TMI-1.
The letter establisned two categories. The first censists of provisiens described by Append.x R Sectica III G, J and 0 which are to be backfitted in their entirety. The second censists of requirenents cancerning the "cpen" itens of previous NRC staff fire protection reviews. A :ach ent 1 is our response to 10CFR 50.48 paragraph C concerning the backfi: iter:s and constitutes our initial response to the provisions of Appendix R to 103 50.
Attachnents 2 and 3 (SER Tables 3.1 and 3.2) outline the project status and (where applicable) the expectec cenpletien date for those itens which f all into the second category. Project cc pletion dates are within the dates outliced in 10CFR 50.48.
An updated sary of staff requirenents to resc1ve open itens, which was Enclosure 2 of the NRC letter of Ncvenbr r 24, 19S3, is included as Attachnents 2 and 3 to this letter.
As alleved by 10CFR 50.4S Section b, we subnit that the SER for IMI-l has been accepted by the staff in satisfying the provisicns of Appendix A to STF A?C33 9.5-1.
Attachnent 4 lists auz. ath. requests-to Appondix a w 13CFR-M.
We have reviewed 10CFR 50 Appendix R and have deternised that no additional
=cdifications are necessar-f to ensure adequate fire protection.
Sincerely, nl l L,
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. D Sekill Director, TMI-1
.5 EDH:DGM:l=a Attach ents vc== n e n,,v. n. n w w - S. n 8108240 %
Paga 1 of 2 Y
1.
Appendix R Section III C 1, 2 & 3 a) 'Our original Fire Hazards Analysis Report (FRAR) was prepared and submitted in accordacee with the requirements of APCSB BTP 9.5-1 dated August 23, 1976 and SRP 9.5-1 Rev. 1.
The requirements of Appendix R impose additional requirements that were not addressed by our FEAR.
Our plan la to complete and maintain a revised FRAR to ensure that IMI-1 syste=n 2nd subsequent modifications do not provide conditions that adversely affec: the capability to achieve a safe shutdown
--condition subsequent i:o a postulated single fire, including an exposure fire.
In addition we will review the revised FRAR and provide such modifi-cations as are required.co remove any iden ified noncompliance with provisions of this section of Appendix R.
Our schedule requires completing the revised FHAR, identifying any areas
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- of ' jeopardy and preparing design criteria for any modifications necessary to remove noncompliance with the provisions of Appendix R including the open SER items of Attachments 2 and 3 prior to September 15, 1981. We will
. submit this criteria and our schedule for engineering and installation Efor the identified modifications prior to 12/15/81.
- 2. - Appendix R Section III J. - Emergency Lighting-L
. As stated in Mr. R. Reid's letter of November 19,.1980, item 3.2.12 " Emergency
- Lighting" is resolved'pending 'the completion of modifications as noted in our
' letter of May 30, 1980;(TLL 243). These modifications have been installed and
' are' operational. _ (See Attachment'3).. The installed system' meets the i
Appendix.R Section III J requirements.-
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Paga 2 of 2 3.
Appendix R Section III O - Exemption Request The provisions of paragraph C6 of 10CFR 50.48 provides for exemption from the provisions of Appendfx R to 10CFR 50.
We are invoking these provisions relative to Section Ill 0 " Oil Collection System for Reactor Coolant Pump" based on our determination that compliance with the required modification wou'd not significantly enhance fire protection safety in the facility.
License Amendment 44 for the fire protection program at Three Mile Island UnAt 1 (TMI-1) included, in SER item 3.1.13 a requirement to demonstrate, "during a safe shutdown earthquake, the affect of the seismic event on the oil collection system will not adversely affect plant safety." The drain piping was installed per our specification S.P. 5578 for small bore piping which adequately addresses the seismic requirements for supporting this size pipe inside the containment building. The oil collection tanks installed at the 281' elevation of-the containment building were built to non-nuclear seismic I. specifications and meet ASME Section VIII and NFPA 30 requirements.
The pump itself is mounted to seismic I requirements and the unit including motor and oil spray shields was purchased as an integral unit. The spray shields and the associated drip pans are lightweight and are not considered to constitute a missle hazard during'a safe shutdown earthquake. These design criteria provide adequate assurance that during a safe shutdown earthquake the effects of the seismic event on the system will not adversely affect plant safety."
The Fire Safety Evaluation Report, Supplement 4, dated September 19, 1980 included, "furthermore, as a result of our review of the license's proposed
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design of the reactor coolant pumps lubricating oil collection system we find that this proposed system meets the requirements of the modification
-to improve the fire protection program in Amendment 44, Section 3.1.13 titled, ' Reactor Coolant -Pump Lubricating 011 Collection System. ' We find this item of the program acceptable." We submit the foregoing as being ample justification of-a sound -technical basis for our assertion for an exemption request in'accordance with the regulation.
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Page 1 of 2 SER TABLE 3.1 ITEM STATUS 3.1.1 Fire Detectors Installed /Under test System installation - 100%
expected operational 11-1-81 System being tested and undergoing minor detector sensitivity adjustments 3.1.2 Manual Hose Stations Installed / Operational 3.1.3 Automatic Water Spray System Under Installation System under installation expected operational 11-1-81 System scheduled for test 5-1 3.1.4 tatomatic Sprinkler Systems or III.G Coating of Electrical Cables Partial Modification accepted Under Installation
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by the NRC for 281' Fuel Handling expected operational 11-1-81 Bldg. Sprinkler System 3.1.5 Halon Extinguishing System in Installed /Under Test Computer Room expected operational 11-1-81 3.1.6 _ Curbs in Reactor Building Deleted 3.1.7 Fire Dampers Installed /Operu?fonal 3.1.8 Fire Doors Completed 3.1.9-Fire Barrier Penetrations Completed 3.1.10 ' Thermal Insulation on Valves Deleted 3.1.11 Fire Barriers at R.B. Emergency-Deleted Cooling Valves 3.1.12-Fire Later Valve Seals Completed 3.1.13 Reactor Coolant Pump Lube 01.*
III.0 Collection System 3.1.14 Separation of Computer Room
-Completed From Control Room 3.1.15 Electrical-Cable Penetration Seal-Completed 3.1.16-Battery Room Ventilation Air.
Completed.
Flow Monitor 3.1.17 Fire Fighting Plans-Completed 3.1.18. Smoking Completed
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1 3.1.19l Control of Combustibles Completed
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' 3.1.20-' Backup Manual Hose Coverage Installed / Operational 1
3.1.21 : Alternate Shutdown III.G 3.1.22 Brigade Training Completed s
3.1.23 Communication Cable Penetrations.
Completed i
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Attachmant 3 Page 1 of 1 TMI-1 TABLE 3.2 SER ITEMS STATUS Protection of Emergency Feedwater Pumps Complete 3.2.1 3.2.2 Cable Separation" III.G 3.2.3 Effects of Water Spray III.G 3.2.4 Adequacy of Detector System Design Complete 3.2.5 Fire Protection Inside the Reactor Building Complete 3.2.6 Unlabeled Fire Doors Complete 3.2.7 Alarm Circut* Supervision Complete 3.2.8 Remote Shutdown Stations Complete 3.2.9 Transient Combustible Study III.G 3.2.10
_ Control Building HVAC Loss Complete
'3.2.11 Interior Hose Statiot. Standpipes Less Complete 3.2.12 Emergency Lighting Installed / operations.l -- III.J 3.2.13 Protection of Relay Room (Cable Spreading Room)
Complete-3.2.14.
Fire Door Supervision 7 Complete 3.2. 15 Engineered Safeguards Cabinets Complete-
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Attachm:nt 4 Pago 1 of 1 EXEMPTIONS This attachment contains the e;.emptions from Appendix R to 10CFR 50.
Item 1:
Section N states: " Areas protected by automatic total flooding gas suppression systems shall have electrically supervised self-closing fire doors or...
shall be kept closed and electrically supervised at a continuously manned location."
a.
This requirement was not identified in any previous issue of Appendix R made available for comment. The four options listed in 5ection N are considered adequate to provide protection and our responses to these four options, providing administration controls and locking of doors with some doors supervised (security), were accepted by the NRC in lieu of supervision.
This position was accepted by the Commission specifically in IMI-1.
To implement this requirement we would have to supervise the following:
- 1) 3 doors in Relay Room
- 2) Old Chem Supervisor's Office
- 3) AIT (Air Intake Tunnel)
-Our basis for exemption is that our options for supervision were accepted by the Commission, this reqtirement is excessive, and most importantly, was not in any proposed rule made available for review.
Item 2:
Section E states: " Fire hose shall be tested at a pressure of 300 psi or 50 psi above. maximum operating pressure, whichever is greater."
The 300 psi value was not in any proposed rule made availa' ale for comment.
a.
In the comment resolution section describing the develo,e.ent of the ruling, the NRC states that the 300 psi limit comes from NFPA Fa. 196 2 Standard for Fire Hose. They have incorrectly quoted the stan".ard.
Volume II of the 1980 Codes Section 1961 does give the 300 psi vrAue for-hydros but as an acceptance test by fire hose manufacturers. The correct code is NFPA
_1962 for-service test hydrostatic pressures.
In accordance with this code, TMI has procedures in place to annually hydro all fire hose in use to 250 psi. According to Section E of Appendix R, we will relax the test frequency for hose stored inside to once per three years.
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