ML20147B021

Advises That Review of Fire Protection for Facility Noted Areas of Plant Where Fire Could Affect Safe Shutdown & Release of Radioactivity.Presents Different Points of View on Value of Supervision by Util

ML20147B021
Person / Time
Site:	Three Mile Island
Issue date:	09/01/1978
From:	Randy Hall BROOKHAVEN NATIONAL LABORATORY
To:	Ferguson R Office of Nuclear Reactor Regulation
Shared Package
ML20147A994	List: ML20147A988 ML20147A996 ML20147B005 ML20147B014 ML20147B021
References
NUDOCS 7810020204
Download: ML20147B021 (3)

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O BROOKHAVEN NATIONAL LABORATORY ASSOCIATED UNIVERSITIES, INC.

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Upton, New York 11973 (516) 345-2362 Department of Nuclear Energy -

Septed er 1, 1978 7

Division of Operating Reactors U.S. Nuclear Regulatory Comission "'

g Washington, D.C. 20555 I

- s Attention: Mr. Robert L. Ferguson .

Plant Systems Branch ,

SUBJECT:

Fire Protection in Operating Nuclear Power Stations - Three Mile ,

I Tsiand Unit 1 (TMI-1) Safety Evaluation Report Review _

The Safety Evaluation Report, as developed jointly by the NRC staff and Brookhaven National Laboratory, (BNL), adequately reflects the concerns and j recomendations of the consultants. Throughout the reevaluation of TMI-1, l there has been general agreement between the NRC staff and the BNL consultants. 1 Based on present data, the proposed fire protection, as set forth in the SER, will give reasonable assurance that the health and safety of the public is not endangered. The following exception represents a differing engineering point l of view that should be evaluated by the NRC staff.

Valve Supervision I

SER ltem 4.3.1.3 indicates that the licensee intends to control the po-sition of sectional valves on the loop main by installing tamper-proof seals on these valves, and inspecting them periodically. A recent Factory Mutual study found that most shut valves were closed for legitimate reasons, then forgotten.

SER Item 3.3.9 requires-that valves controlling the supply of water to sprinkler systems protecting the diesel generator rooms and the Control Building.be " properly supervised", but does not specify electrical super-vision. It is' especially important that valves such as these be kept open at all times, and such assurance cannot be 7rovided by valve sealing pro-grams alone. .The success of valve sealing programs depends upon ongoing administrative controls that are subject to human failure. In a recent study, Factory Mutual found that most shut valves were closed for legiti-mate reasons, about 80% of all shut valves directly controlled water to automatic . sprinklers, and that only 5 of all shut valves were electrically supervised.' In addition, management personnel at 79% of the plants where shut valves were found.were concerned over this serious breach in plant i

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fire protection. In spite of this concern, the valves were shut, indi-  ;

cating that concern alone is not sufficient. It is recommended that i electrical supervision be required on all control valves in the fire pro-tection systems protecting areas containing or exposing safety-related equipment.

The preceding statements are based on a detailed reevaluation of the fire l protection program as implemented by the Metropolitan Edison Company at the  ;

TMI-1 Nuclear Power -Station. The analysis covered a review of the fire pre- i vention, detection and suppression capabilities of the TMI-1 unit as interfaced i with the nuclear systems requirements. This was accomplished by utilizing a '

review team concept with, members from Brookhaven National Laboratory (BNL) and )

the Nuclear Regulatory Commission Division of Operating Reactors staff. )

The fire protection evaluation for the TMI-1 Plant is based on an andlysis i of documents submitted by the Metropolitan Edison Company to the Nuclear Regu-latory Commission and a site visit. The site visit was conducted by Mr. T. Lee and Mr. M. Virgillio-of the NRC; Mr. E. MacDougall of BNL; Mr. J. Kelvan of Rolf Jensen and Associates, Inc., under contract to Brookhaven National Laboratory; .

and Mr. J. Riopelle, consultant to BNL. Mr. Riopelle was under contract to BNL to review the manual fire fighting capabilities of the station along with ad-ministrative controls.

The TMI-1 review has been conducted under the direction of Mr. E. MacDougall -

and myself of the Reactor Engineering Analysis Group at BNL, and has had the following. major milestone dates.

1. On May 15, 1977, Metropolitan Edison Company submitted a Fire Hazards Analysis Report in response to NRC request of May 11 and September 30, 1976. This was received at NRC on May 16, 1977, and by the consultant on January 13, 1978.

2. By letter of April 17, 1978, Metropolitan Edison Company was provided with NRC requests for additional information and staff positions per-taining to fire protection at the Three Mile Island, Unit 1 facility.

3. On May 22-26, 1978, the fire protection Review Team visited the Three Mile Island, Unit 1 facility.

4. On May 26, 1978, a meeting was held at the plant facility at which the Review Team identified additional staff positions and requested the Metropolitan Edison Company's comitment to conform to these positions.

5. On June 12, 1978, Metropolitan Edison Company provided a submittal responding to NRC requests of April 17 and May 26, 1978.

6. By letter of June 28, 1978, Metropolitan Edison Company was requested by NRC to provide additional information and commitment to the staff posi:tions, pertaining to fire protection at the Three Mile Island, Unit 1 facility.

7. On July 14, 1978, Metropolitan Edison Company provided ad'd itional response to'the NRC request of April 17, 1978.

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8. On July.20, 1978, Metropolitan Edison-Company provided a submittal ,

1973 i responding to the NRC _ request of June 28, 1978. _;

9. On August 17,1978, _the NRC issued the draft Safety Evaluation Report on Three Mile _ Island: Power Station, Unit 1.

We have not as yet received the SER review from Mr. Riopelle and there-fore, his comments are not included. We will amend this report when we hear from Mr. Riopelle.

This review process has resulted in identifying areas of the plant.in thich a fire could have undesirable effects on safe shutdown of the reactor and on release of radioactivity to the environment. .The Utility's proposed

- modifications are significant steps in reducing the undesirable effects of -

a fire in this plant. ,1 Respectfully yours, h M .

Robert E. Hall, Group Leader Reactor Engineering Analysis EAM:kt 4

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