ML20196D733
| ML20196D733 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 11/30/1988 |
| From: | Cockfield D PORTLAND GENERAL ELECTRIC CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8812090177 | |
| Download: ML20196D733 (6) | |
Text
7 PoftlanciGonoral ElectricCoraxn/
David W. Coc:. field Vice President, Nuclear November 30, 1988 Trojan kuclear Plant Docket 50-344 Licenso NPF-1 U.S. Nuc) tar Regulatory Commission ATTN:
Document Control Desk l
Washington DC 20555
Dear Sirs:
Implementation of Fire Protection Modifications jt_oquired by Amendment No. 22 of the Trojan Facility Operatinr. License This lottor provides the results of a review by Portland Conoral Electric (PCE) of the status of the fire protection modifications comitted to be mado as referenced in Amendment No. 22 of the Trojan Facility Operating License. This meets a comitment made to the Hueloar Regulatory Comission (NRC) in a PGE lotter datad June 22, 1988. The latter was written in res-ponse to a Notico of Violation based on NRC Inspection Report 50-344/88-17 covering fire protection progran impler ontation.
As discussed in our Juno 22 letter to the NRC, PGE initiated a review of the status of the modifications committed to bo made as referonced in the Amendment No. 22 '1censo condition. Theso referenced modifications are those identified in Paragraphs 3.1.1 through 3.1.18 of the NRC's Firo Protection Safety Evaluation Roport (SER) dated March 9, 1978. PGE also included in this review those incompleto items identified in the March 9, 1978 SER (Items 3.2.1 through 3.2.7).
Closure of those items was addressed by Supplomontal SERs issued by the NRC on March 25, 1980 and October 6, 1980.
PCE's review of the Amendment No. 22 modifications has been completed.
Based on this review, all fire protection modifications were verified to be completed except as described in Attachment 1.
Attachment i describes how each exception has been or will be resolved, and providos justifications or corrective actions and schedulos, as appropriate.
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November 3C s 1988 Pane 2 In accordance with our June 22, 1988 letter comitments, PGE is submitting the attached justifications and modification plans for NRC review and approval. We would be pleased to discuss any questions you may have.
Sincerely,
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Attachment et Mr. John B. Martin Regional Administrator, Region Y I
U.S. Nuclear Regulatory Comission Mr. William T. Dixon State of Oregon Department of Energy Mr. R. C. Barr NRC Resident Inspector Trojan Nuclear Plant l
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O TrojanNaclearPlant Document Control Desk Docket 50-344 November 30, 1988 License NPF-1 AMENUMENT NO. 22 FIRE PROTECTION COMMITMFNTS THAT HAVE NOT BEEN IMPLEMENTFD Page 1 of 4 Safety Evaluation Pqort (SER)
Cortnitnent (Subject /Section)
F2ception Resciution 1.
Electrical Terminal Boxes
- ,ER Section 3.1.2.
The following termir.a1 boxes The identified teminal boxes were installed as part in the cable spreading room of a design modification that was inplemented subse-Temin41 boxes rated as NEM-1 by the are rated as NEM-1 and are quent to the SER. These terminal boxes will be up-National Electrical Manufacturers' Associa-not rain-tight: ATB-151, gras'ed to be rain-tight by (a) drilling a 1/4-inch tion (NEM) in the cable spreading room will NTB-103, NIB-105, NTB-106, weep hole in the bottan of each box to provide be upgraded to be rain-tight (5.13).
NTB-132, NTB-l't4, NTB-140, drainage and ventilation, and (b) sealing the temi-NT8-158, NTB-159, NTB-165.
col box covers with a sliicone s, range-rubber tape SER Sectioa 5.13.6(1):
gasket material, or material of egral or better quality, to prevent moisture from entering the boxes Upgrade NEM type NEM-1 teminal boxes to through the doors. These modifications will be com-provide protection against water damage frrun pleted by the end of the 1989 Refuelin2 Outage.
the deluge system actuation.
2.
Fire Detectors
$ER Section 3.1.3:
Fire detectors are not in-This exception was identliied in NRC Inspection Report stalled in the new and spent No. 50-344/88-17 and was the subject of a Notice of Additional fire detection sensors will be fuel pool areas.
Violation issued on May 23, 1988.
provided for various areas of the Plant (4.2), (5.6), (5.31), (5.13).
As described in PGE's response to the Notice of diola-tion dated June 22, 1988, the subject fire detectors SER Section 5.4.6:
were instal. A prior to the end of the 1979 Refueling Outage as required by Amendment No. 22 to the Oper-The ticensee has proposed the addition of ating License. The subject detectors were subse-two fire detectors to the new and spent quently removed in 1984. A fire detection system fuel pool areas.
survey perfomed by a licensed fire protection engi-neer concluded these detectors were in areas not required to achieve safe shutdown, did not comply with the spacing and location requirements of National Fire Protection Association (NFPA) 72E - 1984, "Automatic Fire Detectors", and if
Trojan Nucle r Plant Docament Control Desk' Dock 2t 50-344 November 30, 1988
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License NPF '
AMENDMENT No. 22 FIRE PROTFCTION ComI1MENTS THAT HAVE NOT BEEN IMPLEMENTfD Page 2 of 4 Safety Evaluation Reprrt (SER)
Cosumitment (Subject /Section)
Exception Resolution 2.
Fire Detectors (continued) installed per NFPA 72E, would not respond adequately to smoldering fires. Therefore, on the basis of this review, reinstallation of t.he subject fire detectors is not warranted.
3.
Portable Fire Extinguisher _s SER Section 3.1.6:
A portable extinguisher was Portable extinguishers were added to one hose house not provided in Hose House near the RW5T and in the vicinity of safety-related Portable extinguishers will be added to No. 10. It is unknown panels in response to the SER commitment. These the two hose stations near the refuellog whet.ser the extinguisher additions were confirmed as part of the NRC's water storage tank (fud5T) and at remote was ever added. Portable verification of the Amendment 22 license condition safety-related panels (4.3.3),
extinguishers are provided per NRC Inspection Report 50-344/90-21, dated in the vicinity of, but not September 17, 1980.
- at", remote safety-related panels.
To reverify the provision of portable extinguishers in accordance with the license condition, a survey SER 5ection 4.3.3:
was conducted of the portable extinguisher coverage provided near the lud5T and for all remote safety-The licensee has prorssed to add portable related and safe shutdown-related panels. Portable l
entinguishers to the.w6 hose stations near extinguishers currently provided were verified to I
the refueling water s orage tank and at he adequate except in three locations: A portable remote safety-related panels.
extinguisher was not provided in Hose House No. 10, and insufficient extinguishers were provided in the
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control room and the facade area (45-foot Elevation) l adjacent to the Main Steam Srpport Structure. To correct these deficiencies, a portable extinguisher has been added to Mose House No. 10, two Halon extinguishers will be added in the control room, and one dry chemical extinguisher will be added on the 45-foot levet of the facade area. ihese additional extinguishers ul11 be installed by March 15, 1989.
With these additions, the commitment is met.
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TrojanNuclearPlant D N t Control Desk
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Docket 50-344 November 30J 1988 License NPF-1 AN NOMENT No. 22 FIRE PROTECTION CDPU41TMNTS THAT HAVE NOT BEEN IW1EMNTED Page 3 of 4-i Safety Evaluation Repc-1 (SER)
Caunitment (Subject /Section) facept on Resolution 8
4 Rerouting of Electrical Cables SER 5ection 3.1.13:
Conduits were not rerouted In lieu of rerouting conduits and replacing cable tray and cable tray not replaced with conduit, marinite board barriers and rammni Two conduits will be rerouted and an open by condult.
blankets were installed, as described in Appendix C of cable tray will be replaced by conduit to the original PGE-1012 submittal, "Trojan Nuclear Plant eliminate cable crossings where redundant Fire Protection Review". NRC concurrence with these safe shutdown equipment may be affected by modifications is documented in an SER dated March 25, a fire (5.7), (5.15).
1900. These marinite board barriers and F e l blankets are currently maintained as descritnd in the original PGE-1012 sutanittal, even though they are not credited in the Appendix R analysis as documerated in the current PGE-1012 document, "Trojan Nuclear Plant Fire Protection Plan".
SER Section S.7.6 (6):
Reroute Conduit A8811X away from Cable Tray 88T12X which both contain redundant aunillary feedwater pump autostart circuits.
SER Section 5.15.6:
The licensee has proposed to reroute the pump power cables, and place the cabling associated with service water booster puups and service water pump fans in conduit, so that they are no longer jeopardized by a single fire. He also proposes to add smoke detectors to facilitate fire brigade response.
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5rojan Nuclecr Picnt Document Control Desk g
Dockst 50-344 Novem6er 30,1988 License NPF-1 AMENDMENT NO. 22 Attaciument 1 O E PfiOTECTION COMMITMENTS THAT HAVE NOT BEEN IMPLEMENTED Page 4 of 4 e
Safety Evaluation Report (SER)
Comunitment (Subject /section)
Excettion Resolution j
5.
Water $hiciding
$LR 5ection 3.2.4:
Piping supplying water to subsequent to completion of the referenced study in j
the sprinkler heads in the July 1979, as extensive re-review of suppression In areas where fire suppression piping is shift Supervisor's office effects was conducted as part of the Appendix R re-routed in proximity to safety-related equip-was not disconnected.
view. The purpose of this review was to identifw ment which may be damaged by water spray redundant trains of systems required for hot shutdown from pipe cracks, shielding will. e provided located in the sme fire area that were subject to i
around such piping [4.3.1.(7)]. PGE will damage from fire suppression activities or rupture provide the result of their study to deter-or inadvertent operation of fire suppression systems.
eine the need for shleiding by the date This review was performed for every fire area in the indicated in Table 3.2.
Plant, and included, in addition to safe shutdown equipment, review of all safety-related equipment.
5[R supplanent 1 (Section 3.2.4):
The results of this review are documented in PGE Cal-culation No. TM-110, and are sumanarized in PGE-1012 Pipin2 will be disconnected which supplies "TrojanNuclearPlantFireProtectionPlan." The water to the sprinkler heads in the Shift review confirined that there are no instances where Supervisor's office and corridor outside the redundant trains of safe shutdown equipment are sub-control room.
ject to damage from fire suppression activities or from the rupture or inadvertent operation of fire suppression systems. The review also confirined that no safety-related equipment or safe shutdown equip-mcst would be damaged from a pipe rupture or inad-vertent actuation of the suppression systess in the Shift Supervisor *s office. Therefore, it is not necessary to disconnect the water supply to this suppression system.
DR5/sr Calculation No. TM-110 also identified one area where 26F3W.1188 water spray could damage safety-related equipment, but where no protection was provided. The area in ques-tion contains the charcoal heaters for the emergency control room ventilation sy-tem. Because this equip-j ment is not required for safe shutdown following a fire event, protection of this equipment against water spray effects is not necessary to meet Appen-dix R requirements. Nevertheless, NRC approval of this configuration is requested.
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