ML20054F994
| ML20054F994 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 06/15/1982 |
| From: | J. J. Barton GENERAL PUBLIC UTILITIES CORP. |
| To: | Snyder B Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20054F995 | List: |
| References | |
| 4400-82-L-0102, 4400-82-L-102, NUDOCS 8206180314 | |
| Download: ML20054F994 (9) | |
Text
.
GPU Nuclear g
g{
P.O. Box 480 Middletown, Pennsylvania 17057 717-944-7621 Writer's Direct Dial Number.
June 15, 1982 4400-62-L-0102 TMI Program Office Attn:
Dr. B. J. Snyder, Drogram Director U. S. Nuclear Regulatory Commission Washington, D.C.
20555
Dear Sir:
Three Mile Island Nuclear Station, Unit 2 (TMI-2)
Operating License No. DPR-73 Docket No. 50-320 Fire Protection Program Evaluation This letter supercedes CPU letter dated May 4, 1982 (4400-82-L-0073) which submitted the containment portion of the revised Fire Hazards Analysis (FHA) and a clarification of GPU's request for exemption from the implementation schedule of Appendix R to 10CFR50 specified in 10CFR50.48c.
Accordingly, the enclosed Revision 1 to the TMI-2 Fire Protection Program Evaluation (FPPE) is being submitted in response to your l
letter of May 7, 1981 which requested that GPU update the FHA (see ).
This document is also being provided to support NRC's evaluation of GPU's Appendix R schedule exemption request.
(The FPPE consists of three basic parts, General Information, the BTP APCSB 9.5-1 Appendix A Comparison, and the FHA). The revision to the program evaluation reflects the presently existing conditions at D11-2.
l l
In addition, a brief listing of the implementing procedures and the b ekground information used in determining conformance to Branch Technical Position APCSB 9.5-1 is provided as Attachment 1.
This information is provided to reaffirm GPU Nuclear's previous submittals on this subject I
and to provide an outline of the Dil-2 Fire Protection Program Evalu-l ation references.
Dbof c
As part of the evaluation effort, GPU has determined that certain new modifications are required to maintain and monitor the plant in its current mode.
These modifications are discussed in Sections E.l(d),
E.4, and F.14.
However, a schedule for implementation of these modifi-cations has not been completed. GPU will provide the implementation for these items by July 15, 1982. GPU has also determined that certain SER 8206180314 820615 PDR ALOCK 05000320 F
PDR GPU Nuclear is a part of the General Pubhc Utihties System
.D
Dr. B. J. Snyder 4400-82-L-0102
)
modifications are no longer required for the maintenance and monitoring of the cold shutdown reactor at TMI-2.
A summary table of these modifi-cations and their disposition is provided as Attachment 2.
The table also addresses the justification for not completing the SER modifications with the present plant condition.
One area of TMI-2 fire protection not specifically identified in the attachments or the FPPE is the on-going fire protection requirements for TMI-2 and the methods used for continuing to meet those requirements.
The fire protection features of TMI-2 arc essentially the same now as they were prior to the accident. The installed fire protection equipment is still in place along with the inspection and testing requirements. The fire protection organization is still in place, including the required QA/
QC support. These areas are described in both Attachment 1 and in the FPPE, although not under one specific requirement or section.
One area not fully described in the FPPE is the fire protection input to the recovery modification and work activity review process.
The recovery modification and work activity process will make changes to TMI-2 that affect fire protection and/or the fire hazards within the plant.
The recovery modification and work activity is governed by two basic mechanisms, the Engineering Change Memorandum and the Technical Evaluation Report.
Both these mechanisma have provisions to ensure fire protection is addressed during the review process. That ensures the ongoing recovery effort fire protection requirements are met.
In a letter dated March 24, 1981, an exemption was requested from the completion time requirements of 10CFR50.48c for certain parts of Section III of Appendix R to 10CFR50 as well as open SER items.
Specifically, the intention of this letter was to request an exemption under 10CFR50.48c(6) for Sectica III G " Fire Protection of Safe Shutdown Capability",
Section III O " Oil Collection System for Reactor Coolant Pump", and the open SER items outlined in the subject letter.
Based on additional review it has been determined that:
GPU's exemption request for Appendix R Section III G remains unchanged o
from the March 24, 1981 request.
Although the existing emergency lighting units are acceptable per the o
SER, they do not satisfy the new Appendix R Section III J requirem2nts.
However, GPU believes the installed units in the facility, as described in the FPPE, are of sufficient capacity for current plant shutdown conditions.
In addition, also described in the FPPE, there are portable,
Dr. B. J. Snyder 4400-82-L-0102 battery powered lights available to back up the installed lighting as necessary. Therefore, this request for exemption from the schedule implementation requirements of Appendix R Section III J is submitted as provided for in 10CFR50.48c6 where " required modification would not enhance fire protection safety in the facility...". This request supercedes the status specified in both Met-Ed letter dated March 24, 1981 (LL2-81-0084) and GPU letter dated May 4, 1982 (4400-82-L-0083).
o The existing RCP Oil Collection System satisfies the new Appendix R Section III O requirements. Therefore, the exemption requested for Section III O in Met-Ed letter dated March 24, 1981, is with-drawn.
/
P"p*cc' l3
\\j W
J arton ng Director, TMI-2 JJB:SDC:djb Attachments:
1.
Fire Protection Program Evaluation, Implementing and Background Information List 2.
Fire Protection Program Evaluation, Table of Modifications and Disposition of Modifications 3.
TM1-2 Fire Protection and Program Evaluation, Revision 1 cc:
L. 11. Barrett, Deputy Program Director - TMI Program Office
4400-82-L-0102 ATTACHMENT 1 TMI-2 Fire Protection Program Evaluation Implementing and Background Information List 1.
Background / Implementing Requirements on file with the NRC:
1.
TMI-2 Final Safety Analysis Report 2.
TMI-2 Fire Protection Program Plan TLL-322 3.
TMI-2 Fire Protection Program Evaluation (Rev. 0) 4.
TMI-2 Emergency Plan 5.
TMI-2 Technical Specifications 2.
Background / Implementing Requirements not on file with the NRC:
1.
Burns and Roe, Inc. Appendix A to BTP APCSB 9.5-1 Comparison dated 3/17/77.
2.
Burns and Roe, Inc. TMI-2 Fire Hazards Analysis Update, W.O. 3682-01 3.
TMI-2 /.dministrative, Operations, Emergency and Maintenance Procedures 4.
Emergency Plan Implementing Procedures
4400-82-L-0102
-Piga 1 of 4 ATTACHMENT 2 TMI-2 Fire Protection Program Evaluation Table of Modifications and Disposition of Modifications Report Section Subjec t/ Modification Disposition E.l(d)
Fire Detection /
Detection will be added, add detection to Chemical Cleaning Bldgs.
E.3(c)
Hose Standpipe System /
1.
Control Building 351' elev.
install 14 hose stations required
- not presently required by the SER.
- see notes 1,2,3,4,5 & 7 2.
Control Building 351' elev.
- not presently required
- see notes 1,2,3,4,5 6 7 3.
Control Building 280' elev.
- not presently required
- see notes 1,3,4,5,6 & 7 4.
Control Building 280' elev.
- not presently required
- see notes 1,3,4,5,6 & 7 5.
Auxiliary Building 328' elev.
- not presently required
- see notes 1,2,3,4,5,6 & 7 6.
Auxiliary Building 305' elev.
- not presently required
- see notes 1,2,3,4,5,6 & 7 7.
Auxiliary Building 305' elev.
- not presently required
- see notes 1,3,4,5,6 & 7 8.
Auxiliary Buidling 280' elev.
- not presently required
- see notes 1,3,4,5,6 & 7 9.
Control Building Area 282' elev.
- not presently required
- see notes 1,4,5 6 7 G
4400-82-L-0102 Prg; 2 cf 4 7
ATTACHMENT 2 (Cont'd)
Report Section Subject / Modification Disposition 10.
Diesel Generator Bldg. West
- not presently required
- see notes 1,3,4,5,7,8 & 9 11.
Diesel Generator Bldg. East
- not presently required
- see notes 1,3,4,5,7,8 & 9 12.
River Water Pump House
- not presently required
- see notes 1,3,4,5,7 & 8 13.
River Water Pump House
- not presently required
- see notes 1,3,4,5,7 & 8 14.
Control Building 305' elev.
- not presently required
- see notes 1,5 & 7
- the safety related room on this elevation has a Halon suppression system installed.
E.4 Halon Systems /
For fire areas with installed Halon address corrosion characteristics Systems the corrosion characteristics of Halon will be addressed.
F.l(a)
Containment /
The 280' elevation hose reels are hose reels in service during not presently in service. When maintenance activities.
Reactor Building conditions permit these hose reels will be put in se rvice.
F.6 Remote Safety Related Panels /
See E.3(c) hose reel protection F7 Station Battery Rooms /
See E.3(c) se reel protection F.9 Diesel Generator Area /
The SER required sprinkler systems required sprinkler system from in the Diesel Generator Building SER Basements, however these sprinkler g
systems are not required presently for the-following reasons:
4400-82-L-0102 P; g 3 of 4 ATTACHMENT 2 (Cont'd)
Report Section Subject /Modificatior.
Disposition 1.
The Diesel Generator Bldg.
305' elevation has an installed deluge.
2.
The basements are separated by a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated wall.
3.
Outside hydrancs with stocked hose houses are available for additional fire suppression.
4.
A detection system is installed.
S.
Loss of one Diesel Generator does not affect the ability to maintain safe shutdown conditions.
F.11 Safety Related Pumps /
See E.3(c) hose reel protection F.14 Radwaste Buildings /
1.
Chemical Cleaning Building, 1.
Chemical Cleaning Building Chemical Cleaning Air Filtration Modifications Room and TV Monitor Control Building will have a Detection 2.
Address fire related radia-System installed, tion releases 2.
Radiation releases due to fire in Radwaste Buildings will be addressed.
FA-026 Diesel Generator Bldg. #2/
See F.9 sprinkler FA-027 Diesel Generator Bldg. #1/
See F.9 sprinkler PA-058 Chemical Cleaning Building /
See F.14 detection FA-059 Chemical Cleaning Air Filtration See F.14 Roem/ detection e
-4400-82-L-0102 Pag 2 4 of 4 ATTACHMENT 2 TMI-2 Fire Protection Program Evaluation Table of Modifications and Disposition of Modifications Report Section Subject / Modification Disposition FA-060 TV Monitor Control Building /
See F.14 detection FA-045 Cable Room /
Alternate Shutdown Modifications Alternate Shutdown Modifications are not presently required since local control of'the SPC system is available to maintain plant safe shutdown conditions.
FA-058 Chemical Cleaning Building /
1.
See F.14 1.
Detection 2.
See F.14 2.
Radiation Releases FA-059 Chemical Cleaning Air Filtration 1.
See F.14 Room /
1.
Detection 2.
See F.14 2.
Radiation Releases FA-060 TV Monitor Control Building /
1.
See F.14 1.
Detection 2.
See F.14 2.
Radiation Releases Review of Ventilation Systems /
See F.14 Radiation Releases Review of Drainage Systems /
See F.14 Radiatian Releases l
[
0 I
-4000-82-L-0102 ATTACHMEhT 2 NOTES 1.
General area fire detection installed.
2.
Nearby filter banks have deluge systems.
3.
Nearby electrical equipment is in separate 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated enclosures.
4.
Loss of an individual fire area will not affect plant conditions.
5.
Time is available for running additional hoses, fire extinguishers are immediately available.
6.
The hose stations are back up only.
7.
Fire Brigade preplans and strategies will reflect necessary additional equipment and techniques.
8.
Outside hydrants with stocked hose houses available.
9.
Deluge protection installed.
e
t AllACHMENT i
l k
f i
_-____------_.-.-,-.--.-.-.,_.,...._.,.._-___,,._,_,n,,-.-,-,-
~
--