ML20148T449

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Application for Amend 61 to License DPR-54,reflecting Changes to Table 3.1 of Fire Protection Safety Evaluation
ML20148T449
Person / Time
Site: Rancho Seco
Issue date: 12/01/1978
From: Mattimoe J
SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:
References
NUDOCS 7812050146
Download: ML20148T449 (5)


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SACRAMENTO MUNICIPAL UTILITY DISTRICT O 6201 S Street, Box 15830 Sacramento, California 95813;(916) 452 3211 December 1, 1978 Director of Nuclear Reactor Regulation Attention:

Mr. Robert W.

Reid, Chief Operating Reactors, Branch No. 4 U.

S. Nuclear Regulatory Commission Washington, D.

C.

20555 DocketNo. 50-312 Rancho Seco Nuclear Generating Station, Unit No. 1 Proposed Amendment No. 61

Dear Mr. Reid:

Amendment No. 19 to Facility Operating License DPR-54 dated February 28, 1978, requires the completion of the moolfications listed in Paragraphs 3.1.1 through 3,.l.40 of the NRC's Fire Protection Safety Evaluation (SE) on a timetable specified in Table 3.1 of the SE.

Table 3.1 identifies twenty items to be completed by the end of the 1978 refueling outage which is currently in progress.

The District proposes to complete three of these items at a later date, as discussed below by paragraph number, and hereby requests.an additional amendment to Facility Operating License DPR-54 to reflect these changes to Table 3.1 of the SE.

Since this request is being made to clarify an amendment previously issued by the NRC, it is not subject to the fees specified in 10 CFR 170.22.

Paragraph 3.1. 33 (1) - Reactor Building Fire Barriers:

" Provide all cable trays which cross or which can propogate a fire across a fire zone line with a fire barrier."

Comments:

Table 3.1 requires that 50% of the required fire stops be installed by the end of the 1978 refueling outage.

However, due to a shortage of electricians, the craft required to install the fire stops and the fact that the work can only be done during the 28-day outage, the District will be capable of installing only 30 percent of the required fire stops by the end of the 1978 refueling outage.

Therefore, the District requests that Table 3.1 in the SE be modified to (0

indicate for Paragraph 3.1.33 the following:

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)Cr. Robert W. Reid December 1, 1978 "3.1.33 Reactor Building 30% by end of 1978 r.o.;

70% by end of 1979 r.o."

The District's analysis indicates that with the measures listed below that have been taken inside the reactor building, a design basis fire is ex-tremely remote and that no credible fire could pre-vent safe shutdown and cooldown.

Therefore, having 30 percent instead of 50 percent of the reactor building fire stops installed during 1979 will not present an undue risk to the health and safety of the public.

Listed below are the existing' design i

features and modifications that justify the above:

a.

The oil catch basins on the reactor coolant pumps which remove a large source of com-bustibles from a possible fire.

b.

The flame retardant cable used in the reactor building which prevents cable tray fires from propogating.

(Refer to District's fire test report submitted March 1, 1978.)

The fire stops installed during the 1978 c.

refueling outage will be installed on verti-cal trays first, if possible, d.

The existing ionization detectors in the build-ing which will provide incipient fire warning.

e.

Installation of fire hoses in the reactor building to effect rapid suppression of fires.

Paragraph 3.1.39 - Radio Communications Reactor Building:

I "The licensee has proposed to provide capability to communicate to the control room from the reactor building using portable radio communications units."

Comments:

This task _also requires a large number of electricians and can be accomplished only during the 28-day outage.

However, with the current shortage of electricians in the Sacramento area, the District has not been able to assemble a crew large enough to complete this task n

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Mr. Rober W.

Reid December 1, 1978 4

during the 1978 refueling outage.

Therefore, the

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District requests that the listing in Table 3.1 for paragraph 3.1.39 be modified as listed below:

"3.1.39' Radio. Communications - Reactor Building... end of 1979 refueling outage."

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With the existing bell and sound-powered telephone j

systems, closed circuit television in the area of the i

reactor coolant pumps and the items discussed in the requested extension for paragraph 3.1.33 (1), not com-pleting this modification until the 1979 refueling outage will not present an undue risk to.the health and safety of the public.

Paragraph 3.1.37 - Smoke Detectors:

J "The licensee has proposed that smoke detectors be in-stalled so that detectors are located in all safety related areas containing combustibles..."

l Comments:

1 In a June 19, 1978 letter to the NRC, the District supplied information on Paragraph 3.1.37 which indica-1 ted that the District's design would install ioniza-tion detectors in all creas that have (1) combustibles and (2) equipment and/or cable required for safe shut-down and cooldown except for the turbine building (Fire Area 71), the diesel generator rooms (Fire Areas 37 and

38) and the reactor yard area (Fire Arca 69) in which i

we proposed alternative prstective measures.

The NRC's September 21, 1978 letter accepted the Dis-trict's alternative protective measures proposed for 4

Areas 37, 38, 69 and 71; however, the NRC requested installation of detectors in all areas that contain combustibles and safety related equipment or cables (with exceptions as noted) instead of all areas that contain combustibles and equipment or cables required for safe shutdown and cooldown.

The NRC based this i

request onLits interpretation of BTP 9.5-1, Appendix A.

i The District's November 14, 1978 letter indicated that j

our design was in agreement with Appendix A of BTP 9.5-1.

However, the installation of the ionization _ detectors in all areas that contain combustibles and safety re-lated equipment would improve the design and add a G

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Mr. Robert _W. Reid December 1, 1978 degree of conservative margin.

Therefore, the

' District agreed to install detectors in these areas except for Fire Areas 37, 39, 69 and 71.

As stcted in our November 14, 1978 letter:

"This agreement to install ionization detectors in all areas that contain safety related equipment and/or cable will require' additional modifications that were i

not considered in the District's February 1, 1978 letter to the NRC detailing the schedule that would be followed for installation of fire protection modifica-tions.

This letter was used as a reference in provid-ing the schedule in the NRC's fire protection safety evaluation attached to Amendment No. 19 for Item 3.1.37 which requires this work to be completed by the end of the 1978 refueling outage.

However, this new commit-ment will require installing additional detectors in rire Areas 34, 35, 39, 40 and 42."

.It is not possible at this time to purchase the necessary equipment and have it installed and tested by the end of the 1978-refueling outage.

Therefore, the Dis-trict requests that a schedule be accepted by the NRC to have these detectors installed as soon as possible but not later than the end of the core four refueling which is scheduled for late 1979 or early 1980.

Fire Areas 34, 35,.39, 40 and 42 contain combustibles and safety related cables required for the boric acid 4

l heat tracing.

In all areas except Fire Area 39, only one channel of the safety related cables are in the area.

In Fire Area 39 the redundant circuits are'from a section of pipe that connects the boric acid mix tank T-703 with the concentrated boric acid storage tank T-704.

Loss of this heat tracing will not prevent a safe shutdown and cooloown or safe operation of the plant under design basis accident conditions.

There-

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fore, the requested extension for completing this modification as soon as possible but not later than the end of the 1979 refueling outage will not present an undue risk to the health and safety of the public.

Your letter of February 28, 1978 requested that we propose technical specifications related to facility s

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-., a Mr. Robert W. Reid December 1, 1978 1

modifications for fire protection.

The modifications being implemented during this outage do not represent any system additions and, therefore,swe are not pro-posing any technical specification revisions at this time.

Respectfully submitted, k.$

i John J. Mattimoe e

Assistant General Manager i

j and Chief Engineer I

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3 Subscribed and sworn to before me this first day of December, 1978 4

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tty Mattiet, Notary Public in f.;r g c,s'uro coje'~~ ',,f.

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e My Commission Expires January 12, 1980 J

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