ML20238C727
| ML20238C727 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 12/28/1987 |
| From: | Cockfield D PORTLAND GENERAL ELECTRIC CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8712310182 | |
| Download: ML20238C727 (14) | |
Text
_
L.
L*
m imums I__
_ PortlandGeneralElectricCcnr ing v
C__
David W. Cockfield Vice President, Nuciear December 28, 1987 Trojan Nuclear Plant Docket 50-344 License NPF-1 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk l
Washington DC 20555 1
'l
Dear Sir:
Response to a Notice of Violation 4
Your letter of November 25, 1987 transmitted a Notice of Violation based upon NRC Inspection Report 50-344/87-34, Fire Protection Program Imple-mentation. Our response to the Notice of Violation is provided in Attachment A.
In addition, our response to the issues raised in the' Inspection Report for which you desired a response are provided in Attachment B.
Sincerely, f
1 Attachments c:
Mr. John B. Martin Regional Administrator, Region V U.S. Nuclear Regulatory Commission
)
Mr. William Dixon State of Oregon i
Department of Energy l
Mr.
R..C.
Barr NRC Resident inspector l
Trojan Nuclear Plant
.j l
40 l l
8712310182 87122'8 J
PDR ADOCK 05000344 Q
DCD i
l l
1215 W Salmon Street. Portland, Oregon 97204 j
j
l' Trojan Nuclear Plant Document Control Desk Docket 50-344 December 28, 1987 License NPF-1 Attachment A Page 1 of 8 RESPONSE TO A NOTICE OF VIOLATION Violation No. 1 Contrary to Technical Specification 6.8.1, 6.8.2, and 6 5.3, and the'licen-see's QA Program Section 2.0, on September 25, 1987, adequate measures had not yet been established to ensure appropriate review of Fire Protection Program j
'l activities, in that:
The licensee's Nuclear Division Procedure 200-1, " Design Change Control",
referenced fire protection interface control.of Design Change Packages (DCPs), but did not require that personnel qualified in f. ire protection review proposed changes or modifications.to ensure inclusion of appropri-ate fire protection requirements.
The licensee acknowledged that'there was no consistent policy in place to require the review be performed by a fire protection engineer; the licensee also could not' demonstrate that a qualified fire protection engineer had reviewed all DCPs relating to fire protection.
This is & Severity Level IV violation (Supplement 1.D).
Portland General Electric (PCE) Response PGE acknowledges the violation.
i A.
The reason for the violation.
l Procedures implementing the design and review process did not specify the qualifications of personnel required to review changes and modifications related to fire protection. We have always used. qualified personnel for all design changes.
The notice of violation implies " qualified personnel".who are required to review new designs and Plant modifications (including fire protection
-systems) must be fire protection engineers. A careful: reading of the Technical Specifications and PGE-8010,'"PGE Nuclear Quality Assurance Program", do not explicitly require that a " fire protection engineer" review new designs and modifications. This position is substantiated'in PGE's original Topical Report PGE-1012, Trojan Nuclear Plant Fire Protec-tion Review, Section 1.1.2, wherein response to NRC Guideline Position Statement A.1 of Branch Technical Position (BTP) APCSB 9.5-1, states that
" recommendations on system layout, design of fire detection, suppression and extinguishing systems were reviewed by engineers within PGE's Elec-trical, Mechanical, Civil, and Nuclear Engineering Departments. The.
various members of the PGE engineering departments are knowledgeable in Fire Protection System design'and the requirements of nuclear plant safety."
-~
- - - - =
Trojan Nuclear Plant Document Control Desk Docket 50-344 December 28, 1987 Licenso NPF-1 Attachment A Page 2 of 8 l
Inasnuch as supervisors in the mechanical, civil and electr?. cal engineer-
)
ing disciplines mentioned above have reviewed detailed " Fire Protection i
Interface Review Form" checklists in accordance with NPEP 200-1, PGE is confident that the reviews performed-to-date have been performed by qualified individuals and that the Plant Fire Protection System has been designed appropriately.
i
)
1 B.
Corrective steps that have been taken and the results achieved.
A review of procedures which require review of Fire Protection Program j
changes or modifications was performed.to identify any weaknesses in specifying the qualifications of review personnel.
These procedures include Nuclear Division Procedure (NDP) 200-1, Nuclear Plant Engineering Procedure (NPEP) 200-1, " Plant Modification Fire Protection Interface Control", and Administrative Order (AO) 10-2, " Fire Protection".
Revi-sions are planned for NPEP 200-1 to specify the qualifications required l
for personnel to perform these reviews.
l C.
Corrective steps that will be taken to avoid further violations.
l Issue the procedure revision described above.
Reflect more specifically in the appropriate licensing documents, PGE's position as to What constitutes personnel qualified to review changes or j
modifications relating to fire protection.
Those requirements will be I
equivalent to those provided in BTP Chemical and Mechanical Engineering Branch 9.5-1.
D.
The date when full compliance will be achieved.
l April 1, 1988.
I Violation No. 2 Contrary to 10 CFR 50, Appendix B, Criterion XVI, and the licensee's Nuclear Quality Assurance program, Sections 16.0, and 2.0, Appendix A Paragraph h, as of September 25, 1987, adequate corrective action to Nonconforming Activity Report (NCAR) P86-123 was not accomplished to assure that the cause of sig-nificant conditions adverse to quality were corrected to preclude repetition:
All supervisors issuing welding and cutting permits had not beat trained to perform this activity in accordance with the corrective contained NCAR P86-123.
Furthermore, some untrained supervisors have regularly issued welding and cutting permits.
This is a Severity Level IV violation (Supplement 1.D).
Trojan Nuclear Plant Document Con 6rol Desk Docket 50-344 December-28, 1987 License NPF-1 Attachment A Page 3 of 8 j
1 PGE Response PGE does not consider this a violation for the reasons outlined below.
)
This alleged violation resulted from a lack of information provided by PGE to the NRC inspector PGE personnel responding to the inspector's request were not aware that the corrective action required by NCAR P86-123 was performed on j
December 12, 1986. Also, it was erroneously communicated to.the inspector
']
that Shift Supervisors are expected to inspect the area of concern and desig-nate job requirements prior to issuing welding and cutting permits. Although they have an approval block on the permit, Shift Supervisor approval is required to maintain overall cognizance of Plant operation, maintenance and safety activities. It is not for inspection and control of welding and cutting activities.
As outlined in Plant Safety Procedure (PS-7), " Welding and Burning Permits",
craft foremen are the supervisors responsible for initiating the permit, inspecting the area, and de ignating precautions prior to allowing welding and
~
cutting. These individuals were trained tc perform this activity as outlined I
in NCAR P86-123 on December 12, 1986.
j Subsequent to receipt of this inspection report, selected craft foremen who would normally initiate welding and burning permits were interviewed, and all
.j were appropriately knowledgeable of the requirements of'PS-7.
Violetion No. 3 Technical Specifications 6.2.2(F) and.6.4.2 require that a 5-man. site fire brigade be maintained onsite at all ' times and require termining-for the fire brigade to meet or exceed the requirements of National Fire Protection l
Association (NFPA) 27-1975. Contrary to-the above, as of September 25, 1987, the licensee's training program for fire protection had not been maintained so that the brigade's ability to perform the operations they are expected to carry out is maintained as follows:
1.
The site fire brigade receives no training in fighting internal structural fires.
2.
Because the licensee discontinued the site fire brigade's extinguishment of external structural fires during outside practice sessions, the fire-brigade no longer receives this training.
l 3.
The outside fire department has received no. tours of Plant vital areas to.
f;miliarize themselves with the Plant layout and simulate the use of fire-shting equipment in support of the site fire brigade.
1 I
l
l l
4 Trojan Nuclear Plant Document Control Desk Docket 50-344 December 28, 1987 License NPF-1 Attachment A Page 4 of 8 4.
The offsite fire department had not been educated in the operational pre-cautions and specific radiological conditions that might be present during abnormal conditions While supporting fire brigade firefighting activities in various areas of the Plant.
5.
Despite an offsite fire department agreement that has been in force since February 6, 1974, specifying that all offsite fire department personnel assisting in firefighting activities at the site be provided with security clearances to gain access to the site, offsite fire department personnel have received no security clearances or site access badges. This has rr ulted in continuous denied or late site access to offsite fire depart-1;.st personnel in responding to site fire emergencies.
6.
The offsite fire department's copy of the site prefire plans was outdated and there was no licensee system in place to promptly update the plans to ensure that the offsite fire department was kept abreast of changes to the l
plans as they occurred.
]
l 7.
The offsite fire department agreement with the site did not clearly I
specify the responsibilities and expectations of both parties.
This is a Severity Level IV violation (Supplement 1.D).
PGE Response PGE acknowledges the violation.
i A.
The reason for the violation.
I The items delineated above generally persisted due to a lack of management attention to proper fire brigade training and support from offsite fire departments.
Training on firefighting actual internal structural fires originally occurred at a City of Portland Fire Bureau training structure until scheduling and budget concerns caused the city.to cancel the arrangement.
Subsequently, PGE purchased and renovated a trailer and conducted that training onsite.
Due to less than adequate equipment and scheduling problems, the training ceased in 1985. Training on extinguishment of actual external fires was halted in 1986 when it was determined that the l
onsite training area did not meet all Environmental protection Agency and Oregon Department of Environmental Quality requirements relating to j
i groundwater or river contamination.
Although this lack of compliance was.
documented in memorandums to Plant management, nothing was done.
l L_______--_-____
s
Trojan Nuclear Plant Document Control Desk Docket 50-344 December 28, 1987 License NPF-1 Attachment A Page 5 of 8 The lack of compliance with regard to internal structural firefighting training persisted due to a misunderstanding among PGE's Quality Assurance personnel as to what the training requirements were. A0 9-5, " Fire Bri-gade Training", requires a " practice program fire" be provided annually so that each fire brigade member experiences fighting an actual fire. What constitutes a " practice program fire" was considered to mean only extin-guishment of external fires by pCE's Quality Assurance Department. Thus, while recommending that actual internal firefighting situations be con-sidered as part of the training program, the QA Audit of December 8-12, 1986 did not consider the lack of such training to be a nonconforming activity.
It should be noted that NFPA 27-1975, " Private Fire Brigade",
only states that "the brigade's ability to perform the operations they are expected to carry out", and does not specifically mention internal struc-i tural firefighting. At that time, the training records for the " practice program fire" correctly indicated performance of the external firefighting situations.
B.
Corrective steps that have been taken and the results achieved.
1 and 2.
l In light of the lack of experience in fighting actual fires in the j
past one-to-two years, PGE evaluated the current level of fire brigade training and experience.
PGE determined that fire brigade personnel received comprehensive l
classroom training and simulation exercises in fighting internal and l
external structural fires during the time period of concern, including:
Use of self-contained breathing apparatus (SCBA).
+
Use of fire hoses.
+
Rescue training.
+
Communications.
I Fire preplans /firefighting strategies.
+
Emergency fire procedures (to achieve safe shutdown).
+
Quarterly fire drills,
+
Entry into a smoke house with SCBA and appropriate firefighting equipment.
Other training as outlined in the Fire Brigade Training Manual.
I
Trojan Nuclear Plant Document Control Desk Docket 50-344 December 28, 1987 License NPF-1 Attachment A Page 6 of 8 Due to low turnover, the majority of the current fire brigade members have previrusly received training by PGE in fighting actual internal' and external structural fires. Of the 15 security personnel who also serve as fire brigade members, only 3 have not been part of the bri-
.gade for at least 2 years.
Of the 35 Operations Department personnel who serve as fire brigade members, 15 have not been part of the bri-gade for at least 2 years.
In addition, all but 3 Operations Depart-ment fire brigade members have U.S. Navy firefighting training experience.
AO 9-5 requires significant classroom instruction, practice in using firefighting equipment, and fire drills be performed on a continuing basis. To verify the capability of the fire brigade members to com-petently fight an internal or external structural fire, a QA Audit' completed on December 11, 1987 looked closely at the depth and quality of that classroom training and simulation exercises.
That review indicated that the classroom training and fire drills outlined in A0 9-5 are being conducted satisfactorily.
PGE is confident that the training required therein conforms to the intent of NFPA 27.
Th.cfore, due to the training and the experience level of the indi-vidual fire brigade members, PGE concluded that the fire brigade is i
capable of responding to actual Plant fires.
3.
The process of providing unrestricted access to the Plant for the three paid members (chief officers) of the offsite fire department is in progress. Volunteer members of the offsite fire department will not be badged for unrestricted; access; however, this will not irhibit their entry during actual fires or scheduled drills.
4.
Subsequent to the inspection, PGE contacted the offsite department fire chief to determine the nature of the perceived inadequate radio-logical training. Although the fundamental radiological training is considered adequate, application of that knowledge to situations within the Plant requires strengthening. A revision to the existing training is in progress.
5.
The interests of sound Plant security and fire protection conflict and make it difficult to provide rapid Plant access during any given time.
However, denied or late site access has only occurred when responding to a drill or if the emergency situation has been terminated prior'to arrival of offsite assistance.
Plant A0 8-14 " Suspension of Safe-guards Measures During Emergencies", has always allowed for the prompt admittance of offsite fire department personnel and equipment if res-ponding to an emergency.
In an actual medical emergency during the 1987 refueling outage, Where the offsite fire department had to res-pond, Plant access was granted immediately.
Yet, in the event a fire
Trojan Nuclear Plant
' Document' Control Desk Docket.50-344 December 28, 1987 License WPF-1 Attachment A Page 7 of 8 is extinguished prior.to their arrival, normal access requirements'are
. implemented for admission. Thus, entry to perform post-fire inspec; tions may be delayed.
To avoid access delay of the offsite fire department personnel and; equipment into the Plant during scheduled fire drills,.A0 8-14 was revised on October 12, 1987-to permit modification or suspension of normal security measures. The procedures recommended in Regulatory ~
Guide 5.65, " Vital. Area Access Controls, Protection of Physical Security Equipment,'and Key and Lock Controls", will be.followed, j
6.
Three copies of the most recent revision of the'prefire plans are being printed to be provided to the offsite fire department.
The 1
offsite fire department chief has acknowledged, by letter fto imple-ment the advice of Region V's fire protection inspector.and have one set of prefire plans remain at'the fire, station and place each of the.
3 other. sets in the' emergency response vehicles.
7.
The offsite fire department chief has requested, by letter, clari-fication of responsibilities and expectations of both parties. PGE has contacted the fire chief for limited discussions and is preparing u
a response to that letter.
C.
Corrective steps that will be taken to avoid further violations,and dates'
]
When full compliance will be achieved.
i i
1 and 2.
h i
PGE has solicited. proposals'from offsite agencies'to provide training.
of fire brigade, members in firefighting actual'in" carnal andLexternal fires. An accredited. training site at a' community college has been' identified which should meet the criteria of National Fire Protection Association (NFPA) 27.
An inspection of the facility and training' curriculum by. PGE and one of the offsite. fire department chief' offi- '
I cers is scheduled for early 1988 to verify adequacy of the site.
PGE anticipates commencing the firefighting' training during the first 1
quarter of 1988. Training of all fire brigade members willlbe.com-j pleted as soon as possible thereaf ter.f subject to the' availability of the facility, but should be completed no later than June 1,;1988.
AO-9-5 will be revised to'specify'that fire brigade members wii1; i
receive training by extinguishment 1of actual ~1nternal and"externall structural fires, rather than " practice program fires", LThis~will-occur by March 31,-1988.
s i
I a
Trojan Nuclear Plant
. Document Control Desk Docket 50-344 December 28. 1987 N
License NPF-1 Attachment A-Page'8 of 8-3.
The badging process will be completed by March 31, 1988'. : The, chief officers will be given tours of the appropriate vital areas by-April 30, 1988 (a Containment tour is dependent upon Plant-shutdown-for refueling as scheduled).
]
Videotapes of these same vital areas will be made and utilized to train other offsite department members with the Plant vital areas and fire equipment by June 30, 1988.
4 As part of the vital area familiarization outlined in Item 3 above, training on which areas have the potential for radiological hazards---
will be provided. Specific operational precautions and radiological conditions will'be described.where appropriate. This will be com-pleted by June 30, 1988.
5.
Badging the three chief officers will improve access to the site and permit follow-up. inspections on fire occurrences. ' Plant procedures '
I will be reevaluated to ensure rapid offsite fire department perso.,.nel (badged and unbadged) and equipment access during scheduled fire..
t drills within security constraints. Any' revisions deemed appropriate will be implemented by March 31, 1988.-
6.
The prefire plans will become controlled documents, thereby requiring-review,' approval and distribution-of updates to be specified. This will be completed by' March 31, 1988.
^
7.
PGE will revise the formal service contract to clearly specify the.
I responsibilities and expectations of PGE and the offsite fire departi ment'.
Inasmuch as the service contract should reflect all other cor-l rective actions occurring beforehand, a completion date of August 30,
~
1988 is specified.
l l
2092P.1287
.j j
i
\\
t Trojan Nuclear Plant Document Control Desk Docket 50-344 December 28, 1987 License NPF-1 Attachment B Page 1 of 5
.)
RESPONSE TO ADDITIONAL ITEMS DISCUSSED IN INSPECTION REPORT 50-344/87-34 1
I Issue No. 1 (Open Item 344/87-34-04)
Fire Pump Operability Test Every 18 Months 1
The licensee's response to NRC guideline position statement No. 1.3.1 of Appendix A to Branch Technical Position (BTP) 9.5-1 reads in part, "a test program will be established and implemented to assure that testing is per-formed to demonstrate conformance with design and system readiness require-ments".
The licensee's procedure, Periodic Operating Test (POT) No. POT-10-2, does not contain instructions for testing the station fire pumps in accordance I
with the design criteria of National Fire Protection Association (NFPA) 20,
" Centrifugal Fire Pumps".
Regarding the fire pump installation, the
{
licensee's response to NRC guideline position statement No. 5.2.3.2 of Appendix A to BTP 9.5-1 reads in part, "the fire pump installation was designed in accordance with NFPA 20".
NFPA 20 parameters of fire pump assemblies required to be tested annually include the following:
1.
Measurement of 3 points on the pump performance curve (shutoff churn test with no flow; approximate rated capacity and 150 percent of rated capacity or peak load).
2.
Measurement of suction and net discharge pressures at minimura, rated and peak loads.
3.
Measurement of electric current for electric motor driven pumps at minimum, rated and peak loads.
4.
measurement of pump speed at minimum, rated and peak loads.
5.
Measurement of pump vibration at minimum, rated and peak loads.
6.
Comparison of test results to pump characteristic curves to determine performance is maintained between 5 and 10 percent of original design.
Technical Specification No. 4.7.8.1.1. only requires that the station fire pumps be demonstrated operable every 18 months by demonstrating their ability to achieve 2000 gpm at 125 psi (rated capacity). An example of Why the licensee would be prudent to perform more extensive testing is that for the fire pumps to provide a backup water supply to the Service Water System, in accordance with the licensee's emergency procedure for a loss of the Service Water System, the licensee's calculation No. TNP-83-59, which supports the adequacy of the emergency procedure, is based on each pump operating above
Trojan Nuclear Plant Document Control Desk Docket 50-344 December 28, 1987 License NPF-1 Attachment B Page 2 of 5 rated capacity and delivering 2500 gpm at approximately 95 psi.
By not testing the pumps in accordance with NFPA 20 test criteria, the licensee is not periodically demonstrating the pump's ability to achieve this flow.
Licensee Position During the inspection, the licensee's representative stated that the purpose of performing test procedure No. POT-10-2 was to demonstrate that Technical Specification requirements (2000 gpm at 125 psi or above) were met and that no other testing was required. Although the inspector concluded that the licensee'was in compliance with the minimum surveillance requirements, the inspector observed that this philosophy in system testing is contrary to the licensee's stated intention of performing surveillance at more than the minimum level.
PGE Rasponso PGE maintains a test program to ensure "...that testing is performed to demonstrate conformance with design and system readiness requirements". This test program consists of Periodic Operating Tests (POTS), Periodic Engineering Tests (PETS), and Maintenance Procedures (MPs). These procedures ensure the fire system is operable and capable of performing its intended function.
Please note that additional testing beyond that required by the Technical Specifications has been performed. Examples are:
1.
TPT-121 (conducted October 1985) which established a new pump curve for both fire pumps.
2.
Fire pump flow tests conducted yearly by American Nuclear Insurers (ANI) and evaluated by onsite engineering. These tests record suction and discharge pressure, shaft rpm, and pump gpm at 5 points.
PGE will evaluate the maintenance and testing criteria of NFPA 20 to determine the additional testing required.
POT-10-2 will be revised subject to the findings of the evaluation.
Any deviations taken to NFPA 20 criteria will be documented in Topical Report PGE-1012. Trojan Nuclear Plant Fire Protection Plan Program Description.
These efforts will be completed by July 1, 1988.
I l
i
Trojan Nuclear Plant Document Control Desk l
Docket 50-344 December 28, 1987 License NPF-1 Attachment B Page 3 of 5 Issue No. 2 (Open Item 344/87-34-10)
Use of Offsite Fire Department to Provide Backup Water Supply to the Service Water System Potential loss of the Service Water System is described in Section 9.2.1 of l
the Final Safety Analysis Report (FSAR) by the licensee. The results of the l
inspector's review of the licensee's mitigating actions for this condition are as follows:
1.
Complete Loss of Service Water Pumps Coincident With a Loss of Offsite Power For the case where the Service Water System pumps could be lost coincident with a loss of offsite power due to fire, instructions provided to opera-tors in the licensee's Emergency Procedure No. ONI-15 direct operators to implement the operator actions for alternative post-fire safe shutdown required by Emergency Fire Procedure (EFP) No. EFP-2.
To provide assur-ance that this capability is available, the licensee has provided fire barrier protection for electrical circuits to.the electric fire pump located in the Intake Structure.
The electric fire pump circuitry has also been modified to enable the pump motor to be driven by onsite power supplied from the emergency diesel generators; thereby, ensuring that both the electric-and diesel-driven fira pumps are available to provide a backup water supply to the Service Water System in this event.
To support implementation of this capability, the licensee provided the inspector with Engineering Calculation DJP-83-59 (SIC), which indicates
.{
that with both fire pumps operating in parallel, a balanced flow of 1
4500 gpm would be available from the pumps. This method provides for supplying the Service Water System via five outside pump discharge headers q
and the Number 1 fire hydrant using 6 lengths of 2-1/2-inch fire hoses (50 feet maximum) to feed 6 1/2-inch emergency Siamese connections to l
the Service Water System Train "A" supply piping. With each fire pump operating in accordance with the original manufacturer's pump curves, the l
pumps would deliver 2500 gpm at approximately 95 psi.
Based on these
)
values, it appears that operating in parallel, the pumps could deliver 4500 gpm to the branch tee at the Train "A" Service Water System 30-inch supply line.
The licensee indicated that there was no supporting test data available to demonstrate the adequacy of this backup capability.
The inspector con-cluded, that due to the unusual configuration of the system in this situa-tion, a test of the capability of the system to be properly aligned and to provide the required flow would be a prudent action.
l
4 Trojan Nuclear Plant Document Control Desk Docket 50-344 December 28, 1987 License NPF-1 Attachment B Page 4 of 5 2.
Use of Cooling Tower Basin as a Backup to the Service Water System In the event of a loss of all service water pumps or a loss of the Intake Structure, the licensee's emergency procedures direct the use of the cooling tower basin as an alternate cooling water supply for the service water system. Depending on the circumstances, the cooling tower basin may i
require a make-up water supply. Steps 3.5.19 and 4.5.11.1 of the licen-J see's Emergency Operating Procedure No. ONI-15 instructs operators to call the local fire department and initiate fire department pumper truck draf t-ing from the river.
I Upon the inspector's request, the licensee wa unable to provide a proce-dure for accomplishing this fire department evolution.
According to the j
offsite fire department personnel interviewed, offsite fire department
{
personnel have informed the licensee that this evolution was not possible q
with existing fire department pumper capability. Therefore, the licensee j
and the offsite fire department have been engaged in discussion about this 1
capability for the past two years.
I The offsite fire department indicated that using the licensee designated draf t site, fire department pumpers would not be capable of supplying i
water from the Columbia River in this situation due to design limitations for drafting. The fire department pumpers are Underwriters Laboratory (UL) certified for drafting water a maximum lift of 10 feet. From the licensee's designated desft site, the required drafting lift appears to exceed 25 feet.
In response to the inspector's concern over this capability, the licensee indicated that supporting engineering calculations or actual test data demonstrating the adequacy of this backup capability were unavailable.
This [ Items B.(1) and B.(2)] is considered an unresolved item pending further NRC verification of this backup capability.
PGE Response The situation described in (1) above refers to an alternative shutdown 3
capability necessary to comply with Section III.C of Appendix R to 10 CFR 50 in the event of fire in the service water pump room, Manhole No. 3 or Manhole No. 4.
PGE has previously walked through EFP-2 to demonstrate the ability to align the system in the proper configuration.
An actual flow test has not been performed. pGE agrees that such a test would be prudent and will perform such prior to startup from the 1988 refueling outage.
t
4 Trojan Nuclear Plant Document Control Desk Docket 50-344 December 28, 1987 License NPF-1 Attachment B Page 5 of 5 The situation outlined in (2) above, as described in FSAR Section 9.2.1.3, refers to a backup water supply to the Service Water System following exhaust-ing the first backup supply (Circulating Water System). The development of an alternative service water supply from the river via the installed fire pumps to meet the 10 CFR 50 Appendix R Rule, as outlined in EFP-2, eliminates the need to use a pumper truck to draf t from the river. Thus, PGE will revise ONI-15 to reflect the backup provision of the fire pumps in lieu of drafting from the river with a pumper truck. The FSAR will be amended to reflect this position in the next update scheduled for July 1, 1988.
DJM/mi 2133P.1287 i
I l
1 l
I L
- - - _ _