ML20212H887
| ML20212H887 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 02/28/1987 |
| From: | Hukill H GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 5211-87-2047, NUDOCS 8703060251 | |
| Download: ML20212H887 (10) | |
Text
-
GPU Nuclear Corporation g
gf Post Office Box 480 Route 441 South Middletown, Pennsylvania 17057 0191 717 944-7621 TELEX 84 2386 Writer's Direct Olal Number:
February 28 1987 5211-87-2047 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Gentlemen:
Three Mile Island Nuclear Station Unit 1 (TMI-1)
Operating License No. DPR-50 Docket No. 50-289 10 CFR 50 Appendix R - Revised Ventilation Fxemptions This letter withdraws 10 CFR 50 Appendix R exemption requests for loss of ventilation in the control building, emergency feedwater pun rooms, diesel generator building, and decay heat removal and nuclear services closed cycle cooling pun room, previously submitted via GPUN letters dated February 2, 1987 (5211-87-2021 ) and February 11, 1987 (5211-87-2033).
Attached is an exention request to allow a 20-minute roving fire watch for those areas of the plant in which a fire could affect ventilation in the building / rooms identified above, and to allow credit for continuous fire watch for those areas which are normally occupied, as discussed with NRC representatives on February 13, 1987 and February 24, 1987.
The existing exemption request to allow manual actions to establish portable ventilation to ensure operability of safe shutdown cononents contained within ISPH-FZ-1 and ISPH-FZ-2 of the Intake Screen and Pump House remains valid as submitted in GPUN letter to NRC dated February 11, 1987 (5211-87-2033).
In accordance with NRC verbal request, GPUN confirmed that loss of ventilation flow in the Intake Screen and Pump House is alarmed in the control room. Emergency alarm response procedures for the Intake Screen and Pump House have been revised to instruct the operator to implement the manual actions to establish portable ventilation in ISPH-FZ-1 and ISPH-FZ-2 upon receipt of alarm in the control room indicating loss of ventilation flow in the Intake Screen and Pump House.
8703060251 870228 PDR ADOCK 05000289 F
eda b
o n
/ll GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation
_2 It is GPUN's intent to submit in the future revised exention requests for loss of ventilation in the control building, emergency feedwater pun rooms, diesel generator building, decay heat removal and nuclear services closed cycle cooling pug room, and the intake screen and pump house.
NRC review and approval of the attached exemption request and the existing exegtion request for loss of ventilation in the Intake Screen and Pug House, as clarified above, is desired prior to scheduled startup of TMI-l in mid-March 1987.
GPUN is prepared to meet with NRC representatives at your earliest convenience to discuss any of these exemption requests.
If any additional information is required, please contact us.
Sincerely,
. D. Hu ill Vice President and Director, TMI-1 DJD:jh:1983g Attachment cc:
J. F. Stolz, USNRC J. Thoma, USNRC T. Murley, USNRC Region I F. Young, USNRC TMI-1 Site D. Kubicki, USNRC PEISCB A. Krasopoulos, USNRC Region I
r Loss of HVAC Exemption Requested Exenption is requested from the requirenents of 10 CFR 50 Appendix R, Section III.G.2 to allow a 20-minute roving fire watch, in lieu of fire protection of ventilation system components, for those nornelly unoccupied areas in the plant where a fire could affect ventilation for the control building, energency feedwater punp roons, diesel generator building, and the decay heat removal and nuclear services closed cycle cooling punp room; and to allow credit for personnel in nornelly occupied areas as a continuous fire watch, in lieu'of fire protection of ventilation system components, in CB-FA-4b (control room), and the norna11y occupied areas of CB-FA-4a and CB-FA-1 where a fire could affect ventilation for tha above plant buil dings /roons. The areas which will be patrolled by the roving fire watch are: CB-FA-2a, CB-FA-2b, CB-FA-2d, CB-FA-2e, CB-FA-2f, CB-FA-3a, CB-FA-3b, CB-FA-3c, CB-FA-3d, CB-FZ-Sa, IB-FZ-3, IB-FZ-4, AB-FZ-7, and DG-FA-2.
Justification A fire in the areas of the plant listed below could affect ventilation for the buildings or roons indicated:
Loss of Control Building Ventilation:
CB-FA-1, CB-FA-2a, CB-FA-2b, CB-FA-2d, CB-FA-2e, CB-FA-2f, CB-FA-3a, CB-FA-4a, CB-FA-4b, CB-FZ-Sa.
Loss of Emergency Feedwater Pump Room Ventilation:
IB-FZ-3, CB-FA-1 Loss of Diesel Generator Building Ventilation:
CB-FA-1, CB-FA-2d, CB-FA-2f, CB-FA-3d, CB-FA-4b, IB-FZ-3, IB-FZ-4, DG-FA-2.
Loss of Decay Heat Renoval and Nuclear Services Closed Cycle Cooling Pump Room Ventilation:
AB-FZ-7, CB-FA-1, CB-FA-2d, CB-FA-3b, CB-FA-3c, CB-FA-3 d, CB-FA-4b.
i
~._ _.
s r
i "
The inspection of each area shall verify that no abnornal condition exists which could result in fire (visual verification) and that there is no 1
'evidence of fire (visual).
If a fire or any abnornal condition is found, it is immediately reported to the. control room in accordance with Emergency Procedure EP-1202-31. Television monitor coverage is to be provided for AB-FZ-7 since entry into this area nay require a radiation worker permit j;
depending on plant condition. Monitors will be provided on the fire watch tour route for the firewatch to check. A 20-minute roving fire watch which patrols these areas provides sufficient assurance that a fire in one of these areas would be detected during the formative stages of the fire before _ damage to safe shutdown ventilation equipment would result and the fire brigade would be dispatched to complete fire extinguishment using manual fire fighting equipment. The attached drawings, which have been reviewed by the resident NRC. Region I inspector, illustrate the fire watch patrol route which covers the areas of the plant identified above. These areas' can be patrolled within 20 minutes.
This route has been verified by a walkdown in the-plant with the resident NRC Region I inspector.
i Plant procedures will require that the roving fire watch for these. areas of the plant be in effect for all plant operating modes except cold shutdown conditions. The procedure provides for recording to verify fire watch patrol coverage of the fire areas. Procedures will be provided on-site for NRC review. Fire watch personnel will be trained in accordance with TMI-1 Administrative Procedure No.1038, Administrative Controls - Fire Protection Program. Specific training includes the following items:
i instruction on the 20-minute tour procedure, Emergency / Alarm Response Procedures, Installed Plant Systems, Fire Behavior and Classification, Practical-Live Fire Training, and General Employee Training.
i l
Fire areas CB-FA-4a (instrument shop), CB-FA-4b (control room) and CB-FA-1 (HP Chem Lab) are normally occupied and therefore no separate fire watch check is necessary.
In addition, the HVAC panels in the control room are provided with detectors,. the false ceiling areas in the control room and the instrument shop contain essentially zero combustible loading, and the HP Chem Lab is provided with area wide fire detection above the false ceiling area and automatic suppression below the false ceiling.
V On this basis, it is concluded that a 70-minute roving fire watch for those areas of the plant identified above, and credit for the nanning and protection in CB-FA-1, CB-FA-4a and CB-FA-4b represents an equivalent level
{
of fire safety to that achieved by conpliance with 10 CFR 50, Appendix R, Section III.G.2.
.(
The underlying purpose of the rule is to ensure the safe shutdown capability during and after any postulated fire in the plant. The rule requires fire protection of circuits and components for safe shutdown systems. Protection of supporting systems, their conponents and circuits is required if the support is essential for the operability of a safe shutdown system.
It has been determined that a 20-minute roving fire watch for areas: CB-FA-2a, CB-FA-2b, CB-FA-2d, CB-FA-2e, CB-FA-2f, CB-FA-3a, CB-FA-3b, CB-FA-3c, CB-FA-3d, CB-FZ-Sa IB-FZ-3, IB-FZ-4, AB-FZ-7, and DG-FA-2, and credit for continuous fire watch in CB-FA-1, t
i 1983g
, CB-FA-4a, and CB-FA-4b since these areas are normally occupied, will provide adequate protection of safe shutdown ventilation equipment for the control building, emergency feedwater pump rooms, diesel generator building, and decay heat removal and nuclear services closed cycle cooling pump room, in lieu of providing fire protection for the ventilation system conponents. Thus, the underlying purpose of the rule is satisfied by allowing a 20-minute roving fire watch for the plant areas identified above and credit for personnel in normally occupied areas as a continuous fire watch in CB-FA-1, CB-FA-4a and CB-FA-4b. Therefore, the exemption being requested meets the special circumstances delineated in 10 CFR 50.12(a)
(2)(11), in that application of the regulation in this particular circumstance is not necessary to achieve the underlying purpose of the rule.
In addition, the special circumstances of 10 CFR 50 (a) (2)(111) apply in that providing additional protection features, required by the regulations, would not result in a significant increase in the level of protection provided and would result in undue hardship and cost significantly in excess of those incurred by others similarly situated.
These costs consist of engineering, procurement of materials, fabrication and installation costs.
l l
t 1983g
1 l
l I
I DG-2 DG-1 m
r u
O 1
6 8
8 8
o l
cm em U
b EVA = U l'
'n O
O
=
DG-FA-2 EG-Y-1B DIESEL BUILDING HVAC FIREVATCH l
P//A Ventilo.tlon Unit To Be Observed p-m----
t---
s-4-----ee
---~+
w.-----
m
w-
,,. - - ~ -
wwg--
,m-a-,--
m, m,
~m,e y
<- a
~
I 18_-3 7-7 O
/
- l m-1 ~_
4_
'ii' 2.5 (8-5 ElEV. 305' 4TERVEDIATE 3U LDI4G ELEV 295'/305'
- VAC 7 EWA~~C-7// Ventilation Unit To Be Observed 6
i
9 e
CB-5A C
y-/s is R.
o a-e E
G l
{
i 7-r1_r-I V
CB-FZ-5A CONTROL BUILDING HVAC FIREWATCH b((
Ventilation Unit To Be Observed t
I
7)/
n CB-3A i
0o
?
A~
a o
E.
aD 0
j CB-3B CB-3D' g
/
O e=:2o a u
(/,j 6
A E
g I
CB-3C gg e-s S
-J-_]
I
- ~""]
[
J g
g 0
a r, w 00 O_
1I CO \\ ~~RO._
3 J _J \\ G 338' E _EV.
1
- VAC R EWA~~C-
///
Cross Hatch Area Indicates Cable, Duct, t
And Vertical Duct Chase (CB-3A) To Be Observed.
e 6
w
.e.--,n.-,----..,---m--
,-r-,-.---w-
.m-
,-------~--,_-,.-~---n_,
m 73 J'c '
e
~,
\\
c/
((h
< S ' :,
Ei i
i 0 @
CB-2A
$g 7,
6@nCB
- 2 7 1 r t
g - }_
'd SB-2D r,
CB i.
c l)
[]
3 alim= g a o a C3-2Eg e u n
4...
L, E
a
[
CB
- 23 u
Efs e 3 as-2c
-s t
n,-
l
.,_]
[_
l g
ouu uu g
O u
i 4
.g d
= = '
nn-CO \\._,.R O 3.J LD N G
_.V.
3 22,
_1
- VAC
= R EWA~~C-l
///
Ventilation Fans To Be Observed 153? 5 TV Monitor To Observe AB-FZ-7 1
f
- _.