ML20147A702
| ML20147A702 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/28/1978 |
| From: | Herbein J METROPOLITAN EDISON CO. |
| To: | Reid R Office of Nuclear Reactor Regulation |
| References | |
| GQL-1451, NUDOCS 7809050139 | |
| Download: ML20147A702 (8) | |
Text
$
(.
o o
mee
^* f&
?,8% M
'M
/
mu nw mm 78 AllG -1 P411 METROPOLITAN EDISON COMPANY SUBSIDIARY OF GENERAL PUBLIC UTILITIES CORPORATION POST OFFICE BOX 542 REA0 LNG, PENNSYLVANI A 19603 TELEPHONE 215 - 929 3601 August 28, 1978 GQL lh51 Director of Nuclear Reactor Regulation Attn:
R. W. Reid, Chief 1
Operating Reactors Branch No. 4 U. S. Nuclear Regulatory Commission Washington, D. C.
20555
Dear Sir:
Three Mile Island Nuclear Station, Unit 1 (TMI-1)
Operating License No. DPR-50 Docket No. 50-289 Fire Protection - Additional Information In response to your letters of August b and August 17, 1978, and the telecons of August 18, 21, 22 and 2L, 1978, the folleving additional information is hereby submitted.
Austust h,1978 1.
The fire protection measures proposed for the Relay Room (ref. your response to Item 8.C(2), Met-Ed letter of July 20, 1978) are not acceptable because they do not meet the requirements set forth in Appendix A to Branch Technical Position APCSB 9.5-1 for areas of this type, i.e. a Cable Spreading Room.
Such conformance can be provided either by installing a manually operated fixed water suppression system or by coating all cables in this area with an approved flame retardant coating.
You are requested to indicate your commit-ment to provide one of these additional measures to provide the needed degree of fire protection and conformance with the provisions of the Branch Technical Position.
Met-Ed Response:
Met-Ed vill identify those areas of the Relay Room where adequate hose suppression capability does not exist.
For those areas identified, Met-Ed will provide a manually operated fixed water suppression system or vill coat the cables with an approved flame retardant coating.
702430082
]gnoson
%)
m
Director of' Nuclear Reactor Regulation-. August 28, 1978 GQL 1451 2.
Pursuant to the provisions of 10 CFR 50, Appendix A, Criterion 3, you are requested to indicate your commitment to provide fire detectors in each of the'following areas containing safety related equipment:
(a) ' Decay Heat Removal Pump Pits, (b) Decay Heat Closed Cooling Pump and Nuclear Service Closed Cooling Pump Areas, and (c) MCC.1A and 1B areas.
Met-Ed Response:
Met-Ed vill provide fire detectors in each of the areas containing safety related equipment identified above.
Installation of these detectors will be included under the scope of the detector installations identified in the FEA.
3 The following instrumentation inside containment is required for safe shutdown of the' reactor:
(a) Pressurizer level instrumentation, (b) Reactor coolant system temperature, and (c) Neutron instrumentation.
Describe:
(1) the minimum size fire (dimensions and heat output) that could disable the sensors for all of the channels of each of the above types of instrumentation,(2) the fire hazards in the vicinity of these sensors, and (3) your basis for concluding that these hazards could not disable all the sensors of a given type (if this is your conclusion) or your proposed corrective action to prevent loss of all the detectors of a given type.
Met-Ed Response:
(a) The pressurizer level sensors (RC-1-LT1, LT2, and LT3) are located outside of the secondary shield (elevation 281'),and as stated in the FHA, the combustibles in this zene (RB-lb) are negligible.
The instrumentation viring is in metallic conduit and passes through containment penetrations
- 205E (LT3) at 298' elevation gnd 179 15' coordinate, and #313 (LT1 and LT2) at 298' elevation and 183 21' coordinate.
These instrumentation conduits are phycically separated from the pressurizer heater power cables (algo in gonduits) which pass through penetrations at 32S' elevation and 109, 11h, and 118 coordinates.
Since there are no fire hazards in the vicinity of the pressurizer level sensors inside containment, these sensors vill not be aisabled by fire.
d Director of Nuclear Reactor Regulation August 28, 1978 GQL 1h51 (b) The reactor. coolant system temperature sensors. (RC-5A-TEl, TE2, TE3, and TEh and RC-5B-TEl, TE2,'TE3, and TEh) are located inside of the secondary shield (elevation 281') and as stated in the FEA, the combustibles in these zones (RB-1d and RB-le) consist of reactor coolant pump motor lub-rication system oil and. cable insulation. Due to the physical separation between-the four (4) cold leg branches, a single fire could not disable more than four (h): of the eight (8) temperature sensors.
(c) The neutron instrwnentation is located inside of the primary shield.
Since there are no combustibles in this area the neutron instrumentation vill not be disabled by fire.
August 17, 1978 l.
(P10) Regarding the response to position P10, given in your letter of June 12, 1978, indicate your commitment to provide manual hose stations at each level inside the reactor. building near the personnel air lock, if the results of the study you have committed to provide by December 31, 1978 indicates this is possible.
In addition, you should commit to provide equivalent protection from portable' systems if the staff review of your study concludes that it is impractical to install hose stations inside containment.
Met-Ed Response:
Met-Ed vill provide manual hose stations at each level inside of the reactor building,:if the results of the study to be provided by December 31, 1978 in-dicate that it is possible to do so and NRC grants approval of the modifications based upon their review of the study and its results.
Should NRC, upon review of the study, find it or the proposed modifications unacceptable, Met-Ed would at that time expect additional NRC guidance.
2.
' (P9, Pll) Regarding the responses to Positions P9 and Pil given in your letter of June 12, 1978, we do not understand why these submittals cannot be made earlier than.the indicated date of July 15, 1979 Therefore, indicate your commitment to provide these submittals by February 15, 1979 or provide a detailed justification for submitting these studies at a later date.
Met-Ed Response:
As discussed-during the August 22, 1978 telecon, due to the time involved in preparing specifications for testing, soliciting bids, evaluating bids, awarding contract, scheduling laboratory for testing, evaluating test data, and submitting results and proposed modifications if necessary, it is not possible to provide these.submittals prior to July 15, 1979 r
+
Director of Nuclear Reactor Regulation h-August 28, 1978 GQL 1h51 3
Indicate your commitment to. demonstrate by July 1,1979, that all
-interior hose stations served by standpipes that are less than four
. inches;in diameter (ncminal pipe size) are capable of delivering a minimum of 100 gym at a residual pressure of 65 psig at the outlet of-the hose station.
Met-Ed' Response:
' Met-Ed v111' verify either by testing or by calculation that all interior hose stations (serving safety related areas) supplied by standpipes that are less than four (h) inches in diameter (ncminal pipe size) are capable of delivering a mintmra of 100 gpm at a residual pressure of 65 psis at the outlet of the hose station.
h.
(PS) ~Regarding the response.to Position P5 given in your letters of June 12 and July 20, 1978, indicate your commitment that all fire doors except the two fire doors in series between the Turbine Building and the Control. Building vill, by January 1,1979, be electrically supervised, vith a time delay alarm in a constantly occupied area, or vill be locked closed.
Met-Ed Responsei Met-Ed has in place administrative controls which provide assurance that fire doors are kept closed when not in use.
It is Met-Ed's position that to lock all fire doors not only inconveniences normal plant operations but could sub-
-)
stantially jeopardize the fire fighting effort should a fire occur in a locked fire area. Met-Ed vill by October 31, 1978, identify, 1) fire doors which are electrically locked and alarmed; 2) fire doors which are mechanically locked closed when not in use; and 3) fire doors which are neither locked nor alarmed but which are kept closed when not in use.
If upon review of the doors identi-fled, NRC does not accept Met-Ed's position, Met-Ed vill at that time discuss alternate positions.
5 Indicate your commitment to remove stored combustibles from the Control Building, elevations 306' and 332', and other areas containing safety-related equipment and to keep such areas free of stored combustibles in the future.
Met-Ed Response:
As stated in the FEA, Section 2.2.2 d, maintenance and operating supplies are-required-for normal operations.
These supplies are transient and the quantities may vary 1vith time. Met-Ed vill include in the administrative controls for transient combustibles, guidelines to limit the amount of maintenance and operating supplies to approximately a one-week supply.
w Director of Nuclear. Reactor Regulation' August 28, 1978 GQL lh51 6.
Indicate your commitment to repair the small air compressor diesel engines located in the diesel generator rooms to correct the present oil leakage.
Met-Ed Response:
The oil leakage as described abcVe has been corrected.
~
7 Confirm your coenitment to provide supervision for the presently unsupervised supply valve to the. automatic water suppression system serving elevation 306'
~
of the Control Building, and the supply valves to the automatic water supprescion systems in the two diesel generator rooms.
Met-Ed Response:
The supply valve (FS-V268)to the automatic water fire suppression system serving elevation 306' of the Control Building and the supply valves (FS-V152,153,154, 155, 156 and 157) to the automatic water fire suppression systems serving the Diesel Generator Building are currently supervised.
8.
Indicate your commitment to provide by December 31, 1978:
(a) A list of the system (s) served by the cables routed through the area between the fuel pool and the Control Building; and (b) An analysis demonstrating that a fire in this area vould not affect the ability to safely shutdown the reactor.
Met-Ed Response:
Met-Ed vill provide the above requested additional information by December 31, 1978.
9 Because.some of the redundant components of the Heating, Ventilating and
-Air Conditioning (HVAC) system serving the Control Building are situated in close proximity, there is the possibility that a single fire could disable the system.
Indicate your ccamitment to provide the following by December 31, 1978:
(a) An analysis of the effect of loss of normal and emergency HVAC services on the ability to safely shutdown the reactor; (b) If the above analysis. indicates that such loss could preclude safe shutdown, an. analysis of the susceptibility of the HVAC system to being
-disabled by a single fire; and (c). If indicated by (a) and (b) above, your proposed corrective action.
1 Met-Ed Resronse:
Met-Ed vill provide the above requested additional information by December 31, 1978.
1
-Director of Nuclear Reactor Regulation August 28, 1978 GQL 1h51 10.
Indicate whether safe shutdown of the reactor could be accomplished if there were an exposure fire involving the' electrical (Engineered Safety Features Actuation) cabinets in Fire Zone CB-3C, and the cir-cuitry and controls in 'these cabinets were disabled or inaccessible.
If the ability to achieve safe shutdown could be adversely affected, indicate your-commitment to extend the autcmatic water suppression system in this area to provide coverage to the exterior of these cabinets and to provide spray shields to protect the interior of the
- cabinets from the effects of water spray from either fixed water suppression systems or manual hoses.
Met-Ed Response:
Met-Ed vill perform an evaluation to determine whether safe shutdown of the reactor can be accomplished assuming loss of both ES Actuation cabinets in Fire Zone CB-3C.
This evaluation vill be completed by September 30, 1978.
If the results of the evaluation indicate that the ability to achieve safe shutdown is adversely affected, Met-Ed vill provide el early warning de-tection system and manually operated water suppression for this area, and spray shields for the ES Actuation cabinets.
11.
Because prompt notification of the occurrence of a fire is Laportant in assuring prompt control, indicate your commitment to provide for the Control Building, elevation 306', either a fire detector which alarms in the Control Room or a flow alarm in automatic suppression system for this area.
Met-Ed Response:
The automatic suppression system for the Control Building, elevation 306',
does include a flow alarm via the system supply valve, FS-V268.
This flow alarm annunciates in the Control Room.
1 Furthermore, in response to the August 21, 1978 telecon, the automatic suppression system for the River Water Intake Structure does include flow alarms via the system supply valves, FS-V2h6 and FS-V2hT.
These flow alarms annunciate in the Control Room.
i Miscellaneous Additional Concerns 1.
Describe the composition of the cable penetration fire barrier seals.
Met-Ed Response:
When' the' eable penetration fire seal upgrading program is ccmpleted, all penetrations vill be sealed as described in our response to Position F1 in our letter of June.1;2, 1978 (GQL 1068).
The seals will consist of 100% foam
Director of Nuclear Reactor Regulation
-T-August 28, 1978.
GQL lh51 except where the damming material has been left in place.
However, the damming material left in place vill have a flame spread rating of less than 25 Furthermore,.the fire' barrier rating vill be entirely based on the foam.
2.
Commit to provide rated fire dampers in ventilation ducts between Relay Room, ESAS Room,' and Switchgear Room at elevation 338' 6",
and in ventilation ducts between the Control Building and the Fuel Handling Building at elevation 306'.
Met-Ed Response:
Met-Ed will provide rated fire dampers for'the ventilation ducts indentified above.
i 3.
Our inspection of TMI-1 indicated that one of the doors of the double door in the corridor outside the two diesel generator rooms was unlabeled with regard to fire protection rating. You are requested to indicate your commitment to include the unlocked door in the upgrading program committed to in your response to Position F13 contained in the Met-Ed letter of July 20, 1978.
Met-Ed Response:
As stated in our letter of July 20, 1978 (GQL 1250), Response to 8.b (P13),
"All unlabeled fire doors and frames vill be replaced by fire door assemblies having an appropriate rating, or the adequacy of the fire resistance of the door assemblies vill be established through tests, or other acceptable means."
h.
You are requested to commit to installation of fire detectors in the following additional areas:
(a)
In each Makeup and Purification Pump cubicle; (b)
In the valve gallery area; (c)
In the general area east of the Makeup and Purification Pump cubicles (the Fuel Handling Building, elevation 281').
Met-Ed Response:
Met-Ed vill install fire detectors in the following additional areas:
i Director of Nuclear Reactor Regulation August 28, 1978 GQL 1451 (a) Makeup and Purification Pump cubicle; (b) Valve gallery area; (c) The area directly east of the valve gallery area (Fuel Handling Building, elevation 281').
Installation of these detectors will be included under the scope of the detector installations identified in the FEA.
Sincerely,
/
/
. G. Herbein j
. Vice President-Generation JGH:RJS:dkf