ML20248F760
| ML20248F760 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 03/31/1989 |
| From: | Roche M GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8904130188 | |
| Download: ML20248F760 (48) | |
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l GPU Nuclear Corporation g gf Post Office Box 480 Route 441 South Middletown, Pennsylvania 17057 0191 717 944 7621 l TELEX 84 2386 Writer's Direct Dlai Number:
(717) 948-8400 )
e-March 31, 1989 4410-89-L-0019/0449P ;
1 l
US Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555
Dear Sirs:
Three Mile Island Nuclear Station, Unit 2 (TMI-2)
Operating License No. DPR-73 '
l Docket No. 50-320 Additional Information on the Post-Defueling Monitored Storage Safety Analysis Report t This letter completes the response to your reauest, dated January 3, 1989, for additional information on the Post-Defueling Monitored Storage (PDMS) Safety Analysis Report (SAR). Attached is Amendment 3 to the PDMS SAR which includes changed pages for the main SAR text and responses to Questions 2, 6 through 28, and 30 through 34.
Sincerely, M. B. Roche Director, TMI-2 EDS/ emf Attachment cc: T. A. Moslak - Acting Senior Resident Inspector, TMI W. T. Russell - Regional Administrator, Region I J. F. Stolz - Director, Plant Directorate I-4 L. H. Thonus - Project Manager, TMI Site f0Y f (
8904130188 890331 i PDR ADOCK 05000320 p PDC GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation l
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POST-DEFUEL!NGMONITOREDSTORAGESAFETYANALYSXSREPORT List of Effective Pages PAGE: AMEN 0 MENT. PAGE AMENOMENT Chapter 1- 1.2-19 0 1 1.2-20 0=
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POST-DEFUELING MONITORED STORAGE' SAFETY ANALYSIS CrPORT-List of Effective Pages
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POST-DEFUELING MONITORED STORACE SAFETY ANALYSIS REPORT 1 List of Effective Pages PAGE AMENDMENT PAGE AMENDMENT xiil 3.1-30 0 3.1-1 0 3.1-31 0 3.1-2 0 3.1-32 0 3.1-3 0 3.1-33 0 3.1 4 0 3.1-34 0 3.1-5 0 3.1-35 0 3.1-6 0 3.1-36 0 3.1-7 0 3.1-37 0 3.1-8 0 3.1-38 0 3 .1.- 9 0 3.1-39 0 3.1-10 0 3.1-40 0 3.1-11 0 3.1-41 0 3.1-12 0 3.1-42 0 3.1-13 0 3.2-1 0 3.1-14 0 3.2-2 0 3.1-15 0 3.2-3 0 3.1-16 0 3.2-4 0 <
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POST-DEFUELING MONITORED' STORAGE SAFETY ANALYSIS REPORT l List of Effective Pages-. ,
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POST-DEFUELING MONITORED STORAGE SAFETY ANALYSIS REPORT List of Effective Pages PAGE AMENDMENT PAGE AMENDMENT 6.2-4 0 6.3-6 0 6.2-5 0 6.3-7 0 6.2-6 0 6.3-8 0 6.2-7 0 6.3-9 0 6.2-8 0 6.3-10 0 6.2-9 0 6.3-11 0 6.2-10 0 6.3-12 0 6.2-11 0 6.3-13 0 6.2-12 0 6.3-14 0 .
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POST-DEFUELING MONITORED STORAGE SAFETY ANALYSIS REPORT List of Effective Pages PAGE AMENOMENT PAGE AMENDMENT 6.5-10 0 7.2-9 2 7.2-10 3 Chapter 7 7.2-11 0 1 7.2-12 0 11 7.2-13 0 111 7.2-14 0 iv 7.2-15 0 v 7.2-16 0 vi 7.2-17 0 vil 7.2-18 0 viii 7.2-19 0 ix 7.2-20 0 7.0-1 0 7.2-21 0 7.1-1 0 7.2-22 0 7.1-2 0 7.2-23 0 7.1-3 0 7.2-24 0 7.1-4 0 7.2-25 0 1 7.1-5 0 7.2-26 0 l 7.1-6 0 7.2-27 0 7.1-7 3 7.2-28 0 7.1-8 0 7.2-29 0 7.1-9 0 7.2-30 0
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POST-DEFUELING MONITORED STORAGE SAFETY ANALYSIS REPORT List of Effective Pages PAGE AMENDMENT PAGE AMENDMENT 7.2-39 0 7.2-66 0 7.2-39a 2 7.2-67 0 7.2-39b 2 7.2-68 0 7.2-69 I 7.2-39c 2 0 7.2-40 0 7.2-70 0 7.2-41 0 7.2-71 0 7 . 2->'2 0 7.2-72 0 7.2-43 0 7.2-73 0 7.2-44 0 7.2-74 0 7.2-45 0 7.2-75 0
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POST-DEFUELING MONITORED STORAGE SAFETY ANALYSIS REPORT List of Effective Pages PAGE AMENDMENT PAGE AMENDMENT 8.1-1 0 IV 8.1-2 0 v 8.1-3 0 1-1 0 8.1-4 0 1-2 0 8.1-5 0 1-3 0 8.1-6 0 2-1 0 8.1-7 0 3/4.0-1 0 8.1-8 0 3/4.0-2 0 8.1-9 0 3/4.1-1 0 8.1-10 0 3/4.1-2 0 8.1-11 0 3/4.2-1 0 8.1-12 0 3/4.2-2 0 8.1-13 0 3/4.2-3 0 8.2-1 0 3/4.2-4 0 8.2-2 0 3,4.2-5 0 8.2-3 0 3/4.2-6 0 8.2-4 0 3/4.2-7 0 8.2-5 0 3/4.2-8 0 8.2-6 0 3/4.2-9 0 l 8.2-7 0 3/4.2-10 0 8.2-8 0 5-1 0 8.2-9 0 6-1 0 8.2-10 0 6-2 0 8.2-11 0 6-3 0 8.2-12 0 6-4 0 l 6-5 0 chapter 9 6-6 0 1 6-7 0 11 6-8 0 111 6-9 0 AM. 3 - MARCH 1989 0424P i
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PAGE AMENDMENT PAGE AMENOMENT Chapter 10 S1-16 3 i 51-17 3 11 S1-18 3 10.0-1 0 51-11 3 10.1-1 0 S1-20 3 10.2-1 0 S1-21 3 10.3-1 0 S1-22 3 10.4-1 0 SI-23 3 10.5-1 0 51-24 3 10.5-2 0 51-25 3 10.5-3 0 51-26 3 10.5-4 0 51-27 3 10.5-5 0 S1-28 3 51-29 3 Supplement 1 51-30 3 S1-1 2 51-31 3 S1-2 3 SI-32 3 S1-3 3 51-33 3 SI-4 3 S1-34 3 51-5 3 51-35 3 SI-6 3 31-7 3 SI-8 3 SI-9 3 S1-10 3 S1-11 3 S1-12 3 S1-13 3 ,
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6.3.51 REACTOR COOLANT PUMPS HOTOR OIL DRAIN SYSTEM 1 This system was used to drain oil leakage from the Reactor Coolant Pump Motors. Oil was diverted from the upper bearing oil splash shielding and lower bearing oil splash shielding to oil shleid drain tanks located in the-Reactor Building basement. Not all of this oil has been removed since the dose rates severely limit access to the area of the pumns and oil collection / drain systems.
6.3.52 DEFUELING TEST ASSEMBLY The Defueling Test Assembly (DTA) was designed and installed during the TMI-2 cleanup period to f acilitate mock-up training, defueling tool design, and proof-of-principle demonstrations. The DTA tank filtration system was a temporary system located in the Turbine Building. The system filtered the water in the DTA tank to maintain acceptable water clarity. This system did not handle radioactively contaminated water.
6.3.53 GRAY AND WHITE DIESELS SYSTEM The Gray and White Diesel Generators were installed during the TMI-2 cleanup period. They were designed to power the steam generator cooling systems including the Secondary Services Closed Cooling Water System and the secondary services river water pumps. The objective of these units was to maintain the integrity of existing two bus balance of plant electrical distribution. The diesel generators have been removed from the site.
l 6.3.54 DIESEL GENERATORS The Diesel Generators were used during normal reactor operation and during the cleanup period. Upon loss of off-site power, power was supplied to the unit from the two autornatic, fast startup diesel generators. The diesel generators were sized so that either one could carry the required safety related loads.
Each Diesel Generator fed one of the engineered safety feature 4160 buses, 2-lE and 2-2E, and their associated buses. Each generator was capable of feeding the entire connected safety feature load of one 4160 volt bus plus other selected unit loads continuously, following a LOCA. Each of the Diesel Generators was designed for local manual control, remote manual control, or fully automatic start. The diesel engines were to be automatically started by their respective SFAS signal. Upon loss of voltage on either 4160 volt engineered safety feature bus and after both circuit breakers of the incoming feeders had been tripped, the associated Diesel Generator unit was automatically connected to its bus.
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L intake shaf t which branches out into the individual supply ducts for the plant ventilating systems. The sump contains two 100 gpm pumps and a sump heater.
7.1.5.3 Evaluation The Air Intake Tunnel is maintained during PDMS to provide an air supply pathway for operational plant ventilating systems. The structure is designed to protect the Air Intake System against projectiles and flooding. The openings in the tower are above the probable maximum flood level, and the l baffled intake and screen prevent projectiles from entering the intake.
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-The Air Intake Tunnel also prevents the spread of. fire into plant ventilating systems. During extended periods of time when the ventilating systems are not y operating, the six fire dampers are shut, preventing air from passing through
, the Air Intake Tunnel. During plant ventilating systems operations, a sufficient number of fire dampers are in the open position to provide supply air. In the event of a fire in the air intake pathway, the fire dampers will be closed by operator action from a remote location. As a backup, each damper is provided with 165'F fusible links which melt to shut the dampers in the
. event of automatic releasing mechanism malfunction.
7.1.6 UNIT 1/ UNIT 2 CORRIDOR 7.1.6.1 PDMS Function During PDMS, the Unit 1/ Unit 2 corridor serves as an operational facility to provide:
- a. Heated weather enclosure for various operational system piping such as domestic water and Unit 1 discharge to IHTS.
- b. Access to the Auxiliary Building from the east outside yard through rollup security door 10.
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- c. Interconnecting corridor between Unit 1 and Unit 2.
7.1.6.2 Facility Description The Unit 1/ Unit 2 corridor is a heated passageway running north to south adjacent to the east side of the Turbine, Service and Control, and Auxiliary Buildings. It is a steel frame structure with tretal siding over a concrete base floor, with a partial block wall up to the windows to the outside east yard. The roof consists of built up layers of felt and asphalt.
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isolated. To prevent. the pipe from repressurizing due to valve
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leakage, additional 1 in, drain valves have been installed and are piped to clean buildin? sumps and will remain open while the system is isolated. The loop can be placed into . service quickly by opening isc21ation valves in the yard, and closing the drain valves; closing the 1 in drain valves is not essential.
- 1. All portions of the Fire Protection System located inside buildings in areas where the fire hazard risk is small have been deactivated. The system' has been placed in a configuration which allows reactivation of the deactivated portions by the realignment of valves if necessary.
- m. The station fire brigade has been fully trained to assure that the l personnel are familiar with system configurations, plant layout, and the procedures in Unit 2. l
- n. The deluge systems for the auxiliary transformers and east wall l curtain are maintained in the Turbine Building.
7.2.2.3 Evaluation
'The scope of fire protection has been reduced for areas in which systems have been deactivated and combustibles removed, so that the corresponding fire hazards have.been eliminated.
. Deluge systems for the auxiliary transformers and east wall curtain are maintainea in the Turbine Building. Actuation of these systems will not cause damage to any equipment required to support PDMS. Deluge systems in the Auxiliary and Control Buildings have been deactivned for PDMS. There are no deluge systems in the Containment.
Detection devices provide contacts for supervisory indication that each device is operational and, in the event of detector actuation, indicates which j detector actuated the alarm or trip function until reset.
I The station fire brigade is under the supervisory control of Unit 1. Upon detection of a fire in Unit 2, the station fire brigade will respond to the specific location in-Unit 2. This response in accordance with ongoing station fire brigade training and procedures will ensure mitigation of a fire in Unit 2 during PDMS.. The fire protection and suppression systems are configured to provide adequate capability to extinnuish any potential fire during PDMS.
l 7.2.3 RADI0 ACTIVE WASTE MANAGEMENT Liquid radwaste management systems that are operational during PDMS are the Radioactive Haste - Miscellaneous Liquids System and the Sump Pump Discharge 7.2-10 AM. 3 - MARCH 1989 0235P
l SUPPLEMENT 1
- 2. Section 3.7.1.2. Please provide a complete listing of all containment penetrations (both current and intended), any modifications made to the i penetrations since the accident, and the status of the penetrations during PDMS.
RESPONSE: A complete listing of all containment penetrations is provided.in PDMS SAR Table 7.2-2 which includes the status of each for PDMS.
The containment penetrations that will be in a modified i configuration for PDMS are listed in Table 2-1 which also provides details of the modifications. For this review, a modification.to a containment penetration was included if the modification t<as made to the area from the inboard isolation valve through the penetration to and including the outboard isolation valve.
Modifications to containment penetrations during the recovery period have been accomplished such that the combined modified cross sectional area does not exceed the NRC safety evaluation requirements of 40 square feet.
The Containment Atmospheric Breather has been added to the Containment to provide passive cressure control of the Containment relative to ambient atmospheric pressure and to establish a "most probable pathway" through which the Containment will " breathe."
This addition ensures that the Containment structure will not i experience significant pressure differential to threaten the structural capability of the contamination boundaries provided by ,
the Containment. Further discussion of the Breather 1s provided in PDMS SAR Section 7.2.1.2.
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- 1. NRC Letter from H. D. Travers, Director, TMI-2 Cleanup Project Directorate, Office of Nuclear Reactor Regulation, to F. R. Standerfer, Director, TMI-2, GPU Nuclear Corporation, dated April 3, 1987.
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SUPPLEMENT 1 TABLE 2-1 MODIFIED CONTAINMENT PENETRATIONS PENETRATION NUMBER MODIFICATION R-401 This penetration was modified in late summer 1979 to allow access to obtain samples of the Reactor Building (RB) sump water. Following successful completion of the sampling program, further changes were made to use the penetration for .
RB water level measurement by addition of a manometer system !
to the sampling tube. A further modification was made to provide a more permanent closure in consideration of future potential increase of RB water level to the extent of flooding the penetration. This final modification removed the 12 inch ;
gate valve and the special cover assembly outboard of the I valve and welded a closure assembly to the penetration.
R-537 The penetration was modified to p ovide a flow path into and out of the RB for the Defueling Hater Cleanup. System (DHCS).
This penetration modification consisted of adding a pipe for hose connections to the isolation test connections inside and outside containment and adding a blind flange on the outboard side to isolate the system from the plant nitrogen.
R-539 The penetration was modified to provide a flow path into and out of the RB for the DHCS. This penetration modification consisted of tying-in with pipe
- and adding a second containment isolation valve on the outboard side and providing piping for a hose connection on the inboard side.
R-542 The penetration was modified to provide a flow path into and out of the RB for the DHCS. This penetration modification consisted of tying-in with pipe
- and adding a second containment isolation valve on the outboard side and providing piping for a hose connection on the inboard side.
R-544 The penetration was modified to provide a flow path into the RB for a high pressure decontamination water supply. This penetration modification consisted of replacing an existing 1 inch line with a 1 inch XXS carbon steel pipe.
R-545 This spare penetration was modified to provide a flow path into and out of the RB for the DHCS. This penetration modification ccasisted of adding a double valve pressure boundary on the cutboard side and providing piping for a hose connection on the inboard side.
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SUPPLEMENT 1 TABLE 2-1 (Cont'd) 40DIFIE0 CONTAINMENT PENETRATIONS PENETRATION NUMBER MODIFICATION R-546 The penetration was modified to provide a flow path into and out of the RB for the DHCS. This penetration modification consisted of providing piping for a hose connection on the inboard side and tying-in with pipe
- on the outboard side.
R-553 The penetration was modified to provide a flow path into and out of the RB for the D4CS. This penetration modification consisted of providing piping for a hose connection on the inboard side and tying-in with pipe
- on the outboard side.
R-554 The penetration was modified to provide a source of clean compressed air for use with pneumatic controls and operators.
This penetration modification consisted of replactrg two (2) outboard containment isolation valves with three (3) valves and adding a flow limiter and quick disconnect on the inboard side.
R-562 The penetration was modified to provide a flow path for sludge transfer from the RB .o the spent resin storage tank in the i~ Auxiliary Building. This penetration modification consisted of adding a double valve pressure boundary on the outboard side and piping for a hose connection on the inboard side.
R-565 The penetration was modified to provide a means of transferring shield water to the containment sump. This penetration modification consisted of adding a piping spool assembly to the outboard side of the penetration.
R-626 The penetration was initially modified to insert an antenna and camera arrangement into Containment. These were subsequently removed and the penetration was modified to allow pumping out of the RB basement. This penetration modification j consisted of installing a new spool piece and piping.
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- " Tying-in with pipe" can be effected in one of two ways:
, 1. Cutting the existing pipe completely and adding a "T" fitting; or l
- 2. Cutting a circular hole in the existing pipe and welding a new pipe to it. I I
In either case, the end result is two parallel flow paths where one previously l
,- existed. !
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i SUPPLEMENT 1
- 3. Do all containment and auxiliary building vents discharge to the station vent? Wili all vents be closed during those times that the ventilation system is not operating? If not, will they be monitored?
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RESPONSE: All Containment and Auxiliary Building vents discharge to the station vent. The vents for the Auxiliary and Fuel Handling Buildings (AFHB) will not be closed during periods that the ventilation is not operating. This will allow pressure equalization with the environment through a filtered pathway. The Reactor Building (RB) is planned to be vented through a filtered breather while the RB purge is secured.
The station vent will not be monitored by real time sampling during periods when the ventilation is not operating. First of all, sampling would not be representative during periods of very low flow and secondi f the potential for a significant release to the environment is very small.
The RB has larger quantities of residual contamination available to release than the AFHB. The RB breather filter will be removed and assayed at least semi-annually to estimate the release to the environment during periods of inactivity. If the RB releases are very small, which they are expected to be, then the Auxiliary Building releases would be even smaller. In any event, the releases to the environment during periods of inactivity are expected to be insignificant because there is no motive force for forcing the radioactivity through the ventilation system to the environment.
Off-normal events which could provide a motive force, such as a fire, have previously been studied to determine the potential releases to the environment from the AFHB. These studies have shown that the off-site doses resulting from off-normal events would result in a dose of less than 1 millirem to the maximum exposed individual.
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SUPPLEMENT 1
- 4. Section 7.1.2.2. The auxiliary building ventilation systein will be operational and used part of the time during PDMS. What will prevent air back-flow from becoming a pathway for unfi!tered and unmonitored release, during the time the ventilation system is not operating?
RESPONSE: There are six (6) fire dampers located in the station air intake tunnel. During those times when the ventilation system is shutdown, the fire dampers will be closed and back-flow will be prevented thereby causing the buildings to preferentially breathe via the HEPA filters exhaust pathways, t
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i SUPPLEMENT I
- 5. Section 7.2.2.1. The SAR states that the zone detection system will be operational throughout operational areas. Please specifically list the operational areas in which'the zone detection system will operate.
RESPONSE: Table'7.2-4 was added to the PDMS SAR; this table-lists those areas where zone detection is operational (PDMS status "05") or deactivated (PDMS status "0S"). The detectors which have been deactivated have been selected on the basis that they are located in ventilatica ductwork and are ineffective when ventilation is not in operation.
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SUPPLEMENT 1
- 6. Section 7.2.2.1. The SAR references a POM3 Alarm and Monitoring Station. Please provide further description including location. s RESPONX The final design and location for the PDMS Alarm and Monitoring System has not been completed. See the response to Question No. 20.
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- 7. Section 7.2.2.1. What sections of the ionization detection system will remain operational?
RESPONSE: Those portions of the ionization detection system which will rrmain operable are listed in PDMS SAR Table 7.2-4. ,
S1-9 AM. 3 - MARCH 1989 0430P
SUPPLEMENT 1
- 8. Please identify the cubicles (if any) in the AFHB that will be sealed prior to PDMS, describe the methods used to seal the cubicles and provide an estimate of the air exchange rate between these cubicles and the remainder of the building.
RESPONSE: To date, no cubicles have been identified which will require secling/ encapsulation, i
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l 51-10 AM. 3 - MARCH 1989 0430P i
SUPPLEMENT 1 ,
- 9. Section 7.2.4.3 - Effluent Monitoring - indicates that " Areas and systems within the AFHB containing contamination sufficient to pose a potential
- for a release will be sealed". In the previous question we asked about the cubicles that will be sealed. Provide the following information for j those areas and systems not discussed in your answer to our previous question:
- 1. What additional areas and systems will be sealed,
- 2. The guidelines used to determine if an area should be sealed,
- 3. The estimated level of contamination in each of the areas or systems that will be sealed (fixed and removable),
- 4. Where each area and system will be sealed and the method that will be used for sealing to ensure that there will be no release of contamination.
RESPONSE
- 1. To date, no area has been identified which will require sealing, l since there are no areas expected to contain sufficient loose contamination to pose a contamination spreading concern. Piping systems which are found to be internally contaminated upon draining are sealed by closing vent and drain valves or valves which form a boundary with interfacing systems. Unisolable vent paths (e.g.,
the steam exhaust stack from the turbine driven emergency feedwater pump) will be sealed by capping, : lugging, etc.
- 2. An area will be considered a cand4date for sealing if surface contamination levels and area air flow characteristics create a contamination spreading concern.
- 3. To date, no area has been identified which will require sealing.
Piping systems are sealed when sample results indicate levels of contamination greater than LLD.
- 4. Since, to date, no areas have been identified as requiring sealing, the method of sealing cannot be provided. Systems are sealed by closing vent and drain valves and valves which form a boundary with interfacing systems.
$1-11 AM. 3 - MARCH 1989 0430P
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- 10. Are the station vent and the plant vent the same?
RESPONSE: Yes. Station vent and plant vent are names for the same piece of plant equipment.
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$1-12 AM. 3 - MARCH 1989 0430P 1
SUPPLEMENT 1
- 11. Section 1.2.7 - PDMS Support Systems - Is "domestie water" synonymous with fire protection water?
RESPONSE: No. Section 1.2.3 discusses the fire service systems. The only connections between domestic water and the fire service systems are in TMI-1; these are described in THI-l FSAR 3ection 9.9.
J S1-13 AM. 3 - MARCH 1989 0430P
i SUPPLEMENT 1
- 12. Section 6.17 - Mechanical Draft Cooling Tower. " Fire Protection for the wood portion of cooling towers will remain operational to mitigate consequences of a fire."
- 13. What type of fire protection system is in place? What methods are used to avoid pipe damage as a result of freezing temperatures?
RESPONSE: (The correct reference is to Section 6.1.7.)
i This non-saiety related structure is protected by an existing dry-pipe, 911ot-actuated (Ng) fire suppression system which will be maintained operational since the tower construction utilizes redwood framing. The purpose of this fire suppression system is to prevent a fire from crossing to the non-safety related THI-l mechanical draft cooling tower. The only section of the system containing water is the fire piping between the cement floor and the automatic' valves. This will require either room heat or heat tracing to prevent freezing. GPU Nuclear is considering dismantling the tower to eliminate the combustible redwood framing, thus negating the need for the fire suppression system.
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l-51-14 AM. 3 - MARCH 1989 0430P o--
SUPPLEMENT 1
'14. Section 6.3.45 - Fire Pump House Heating and Ventilation System - The pump house HVAC system is deactivated and the fire pump is put on
-standby. How will heating be provided to prevent the freezing of the I pump and associated piping?
RESPONSE: The Unit 2 diesel fire pump FS 3-1 has been turned over to Unit I and will serve only'as an emergency backup fire supply source.
This reserve pump will be placed in service, if necessary, to maintain system operability requirements (there are three other fire pumps; only two are needed for system operability). During periods of freezing weather (October 1 through April 1), the pump will either be in layup or heat will be available by heat trace or building HVAC; piping' protection requirements are minimal. No protection is required for the pump section which is submerged in the intakes (which does not encounter freezing temperatures).
Procedures for putting FS-P-1 in/out of layup or standby have not yet been developed.
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$1-15 AM 3 - MARCH 1989 0430P
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SUPPLEMENT 1
~15. Section 7.1'5.3 - Air Intake Tunnel - indicates that "In the event'of a fire in the air intake pathway, the fire dampers will be closed by.
operator action from a remote location." What mechanism will be used to
. indicate a fire? Oces " operator" refer to a person, is it considered the l automatic operation or is there another device such as a smoke. detector-or fire alarm trip that automatically shuts the damper?
RESPONSE:. During~the extended periods of time when the ventilation systems will not be operating, the dampers at the plant end of the tunnel. )
will be closed. However, when the dampers are open, the only fire- l that could occur in the Air Intake Tunnel is as a result of a hypothetical airplaae crash and subsequent fuel fire. An ;
evaluation of this issue is ongoing; two (2) potential solutions are:
- 1. The determination that no protection is required due to the low probability of an airplane crash and the immediate plant i
. response to this catastrophic occurrence; and. 1
- 2. The installation of fusible links on the dampers as well as 1 the remote ability (from a manned station).to trip the dampers (
if there is a fire or toxic / combustible vapor' accident in the yard area near the intake.
GPU Nuclear will. complete the review and implement the results ,
prior to entry into PDMS. i
.l SI-16 AM. 3 - MARCH 1989 0430P
SUPPLEMENT 1 l
l 16. Section 7.1.6 - Unit 1/ Unit 2 Corridor - The waste shredder, packaging, l and other similar items constitute a possible combustible loading that should be addressed for POMS. Are there fire barriers in place and/or extinguishing systems that protect the area? Are combustibles stored in a manner that reduces fire potential, such as minimal amounts in closed metal cabinets?
RESPONSE: This entire process (i.e., waste shredder, packaging, and other similar items) will be removed prior to entry into PDMS. Section 7.1.6 of the PDks SAR has been changed to reflect this.
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i SI-17 AM. 3 - MARCH 1989 l 0430P l 1
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- 17. Section 7.2.2 - F?re Protection Service and Suppression - This section discussed "potenticl" fires and " credible" fires, however, only three-cases are given in 3ection 8.2.5. Identify credible fires, by addressing combustible loading in the facility. Discuss the effects of such fires on PDMS-related systems (for example HVAC).
RESPONSE: The maximum credible fire as defined by the PDMS Environmental Evaluations assumed a fire in the vicinity of the blockwall in the Reactor Building and '.s the basis for the conclusions in Section 8.2.5. This ace.1 dent bounds any credible fire accident in the Auxiliary and Fuel Handling Buildings for PDMS. Combustible loading in contain.w nt and adjacent areas is outlined in the TMI-2 Fire Protection Program Evaluation (FPPE), which is the THI-2 fire hazards analysis. This evaluation was submitted to the NRC via GPU Nuclear letter 4410-87-L-0146, dated November 17, 1987. For the remainder of the plant, the fire loadings were discussed in the previous revision of the fire hazards analysis (submitted November 1, 1984). Those fire loadings have not changed significantly and are typically low (less than I hour loading of 80,000 STU/ft4 and in most cases less than a 1/2 hour loading of 40,000 BTV/ft2 ),
The combustibles consist of typical power plant materials, which are primarily electrical cable designed to IEEE-383. With the plant in PDMS, most electrical systems are de-energized, thus removing the principal ignition source. Therefore, many of the postulated fires in the FPPE are not considered credible; Section 8.2.5 discusses the worst-case credible fire with three (5) ventilation scenarios.
The effects of fire on systems used in PDMS is either insignificant -
or addressed in Section 8.2.5. Interlocks with ventilation are listed in Table 7.2-4 of the PDMS SAR.
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- 1. GPU Nuclear letter 4410-87-L-0025, F. R. Standerfer to U.S. NRC Document Control Desk, " Environmental Evaluation for THI-2 Post-Defueling Monitored Storage," dated March 11, 1987.
51-18 AM. 3 - MARCH 1989 0430P
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SUPPLEMENT 1
- 18. Section 7.2.2.1 - POMS Function - Paragraph (b) indicates that " automatic fire suppression shall be provided to areas of the facility and systems which contain significant amounts of combustibles and possible ignition sources." Define "significant quantitles" (for instance as BTU /sq ft in any one area). List the areas that you anticipate will contain these quantities.
RESPONSE: Presently, automatic suppression systems are required to be operable in PDMS in the following areas:
- a. The deluge systems for the auxiliary transformers and V e east turbine building wall;
- b. The deluge and sprinkler systems associated with the TMI-2 diesel generators and their fuel oil systems. For PDMS, this hazard may be eliminated by the removal of the fuel oil; in which case, the suppression systems would be de-activated.
However, TMI-l may utilize one of the diesel generators; this use would address the continued operability of the suppression systems.
- c. The dry pilot deluge systems associated with the Natural Draft and Mechanical Draft Cooling Towers will be maintained due to the fire risk. GPU Nuclea.r is considering dismantling the towers to eliminate the combustible redwood framing, thus negating the need for the fire suppression system.
- d. Fire Service Systems in miscellaneous facilities as shown in Figure 7.2-4 will be maintained operable as required to support ooerations in those facilities (e.g., WHPF, Respirator Cleaning Facility, Administration Building).
For TMI-2, 80,000 BTU /ft2 is the value used for "significant quantities" of combustibles. This value has been used in the plant's Fire Protection Program as a guideline limit requiring a review of the characterization and configuration of combustibles as well as the quantity to determine the need for automatic suppression. Presently, the need for automatic suppression with respect to this limit applies to the diesel generator fuel storage areas (no longer nuclear safety related), the cooling towers (out of service since 1979), and the auxiliary transformers (not safety related). Other areas of the plant with fire suppression systems will have the automatic systems de-activated based on the removal of combustibles, the de-activation of systems and the de-energization of most electrical power which significantly reduces the fire risk.
l S1-19 AM. 3 - MARCH 1989 0430P l
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SUPPLEMENT 1 ;
- 19. Section 7.2.2.1 - PDMS Function - Paragraph (e) states that the " presence of flammable and/or combustible liquids and materials shall be minimized to the maximum extent practical." How will the minimization of flammable 11gulds and combustibles be carried out and enforced. What procedures will be used to control these items? Will periodic fire inspections be conducted?
l RESPONSE: Section 7.2.2.2 items g, h, and i define the actions. planned to
. reduce combustible material inventories _in the plant, which are to remove most non-original plant' items installed post-accident, remove most lube oil and fuel oil.from tanks and reservoirs, and remove charcoal filters.
A Fire Protection Program similar to that.which is presently in-place will maintain these reductions and control the introduction of otler materials. This Fire Protection Program will also address plant fire protection and housekeeping' inspections. The frequency of these inspections will be at least quarterly.
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l S1-20 AM. 3 - MARCH 1989 '
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SUPPLEMENT 1
- 20. Section 7.2.2.2 - System Description - In Paragraph-(b) it-is not clear how the " zone detection" system functions. Is there only one (common) visual / audible signal sent to a constantly manned location in Unit I?
What signals does the operator see at the FDMS Alarm and Monitoring Station? Why would it be'necessary for the operator to go to the Unit 2 control room? Is the fire alarm portion of the PDMS Alarm and Monitoring Station a fire system designed to NFPA standards?
RESPONSE: The final design and location for the PDMS Alarm and Monitoring System has not been completed. The fire detection system.
operability status has been further described in Table 7.2-4 of the PDMS SAR.
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l S1-21 AM. 3 - MARCH 1989 0430P
SUPPLEMENT 1
- 21. Section 7.2.2.2 - System Description - Paragraph (c) - Provide a listing ;
of the deactivated, equipment-related detectors (indicating the ;
components on which they we*e installed), and the justification for their deactivation.
RESPONSE: Table 7.2-4 of the PDMS SAR provides a list of the plant fire detection systems and their planned status. The basis of de-activation is either removal of the risk (e.g., oil reservoir drained, tank inerted; or pumps de-energized out of service) or that the system associated with the detection system is no longer in service.
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51-22 AM. 3 - MARCH 1989 0430P l
SUPPLEMENT 1
- 22. Section 7.2.2.2 - System Description - Paragraph (d) - What is the justification for removal of the halon systems in the air intake tunnel? ,
RESPONSE: The justification for remeval of the halon systems in the air intake tunnel is based on the following:
- 1. The fire dampers will be closed when air intake is not in use. The ventilation system will not be operated often.
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- 2. There is a low probability of an airplane Leash combined with the infrequent use of the air intake. See response to Question No. 15.
$1-23 AM. 3 - MARCH 1989 0430P
j SUPPLEMENT 1
- 23. Section 7.2.2.2 - System Description - Paragraph (j) indicates that freeze protection has been added to applicable portions of the fire main. What is the method of freeze protection? How is it maintained?
2 RESPONSE: The principal means of freeze protection during PDMS will be the use of electrical heat tracing which will be maintained by approved maintenance procedures. Large fire protection system piping manifolds may be enclosed in a small room and provided with a small space heater.
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51-24 AM. 3 - MARCH 1989 ,
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SUPPLEMENT 1
- 24. Section 7.2.2.2 - System Description , Paragraph (k) indicates that the 12 in, fire service loop has been isolated. What is the justification for shutting down this loop? Will it affect secondary feed to systems if an outage should occur? How accessible are drain valves if need arises to turn on the fire service valves ir. an emergency?
, RESPONSE: The 12 in. fire service loop has been isolated since this feeds areas wherein the fire systr:ms are no longer required to be l operable. Sufficient redundancy exists with other multiple fire I service loops and sectional controls such that only multiple-serious impairments would require placing this fire loop in service to provide a normal flow path.
The new 1 in drain valves installed to accommodate valve leakage present no significant loss of fire system flow and pressure capabilities during system operations. Thus, during an emergency, although shutting these drain valves will be attempted as quickly as possible, if they are inaccessible due to fire or smoke condit' ions, they can remain open without rendering the system inoperable.
Section 7.2.2.2.k has been revised to reflect the above. PDMS SAR Figure 7.2-3 will be revised to more clearly reflect actual ,
operation.
51-25 AM. 3 - MARCH 1989 1 0430P
SUPPLEMENT 1 l
- 25. Section 7.2.2.2 ~ System Description - Paragraph (1) - It is unclear what drain valves ire referred to in this paragraph. Are these drain valves related to the drain valves discussed in the preceding paragraph (k)?
RESPONSE: Yes. This reference is to the 1 in. drain valves discussed in r Section 7.2.2.2.k. Section 7.2.2.2.) has been deleted since it is redundant.
I S1-26 AM. 3 - MARCH 1989 0430P
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- 26. Section 7.2.2.2 - System Description - Paragraph (m) - How was it determined that the fire hazard risk in certain areas was small? Has a fire hazard analysis conducted? If so, provide a copy of the analysis.
RESPONSE: Fire loadings less than 40,000 BTU /ft2 are considered small. The basis for this consideration is that the plant is in a stored condition with transient combustibles removed and most electrical systems de-energized.
The THI-2 FPPE was submitted to the NRC via GPU Nuclear letter 4410-87-L-0146, dated Novembrr l', 1987. See response to Question No, 17.
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J Sl-27 AM. 3 - MARCH 1989 0430P
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- 27. Section 7.2.2.3 - Evaluation - Is documentation available to show that combustibles have been removed (or procedures to indicate that combustibles will be removed) from areas in which the scope of fire ,
protection has been reduced? !
l l RESPONSE: Section 7.2.2.2 discusfies some of the removals. An internal PDMS Operational System Pitio punchlist tracks the removal of these materials. Essentially, as much as possible will be removed from the plant with limitations based on cost of removal vs. fire risk and continued need for the post-accident component or supply.
There is no intention to remove original plant or structural items other than significant hazards, such as fuel and lube olls (to the extent practical under ALARA considerations) and hydrogen gas.
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e 51-28 AM. 3 - MARCH 1989 0430P
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- 28. Paragraph 3 - Hill periodic function testing and maintenance occur to determine that each device is operational? If so, describe the testing "
program.
l RESPONSE: The testing and maintenance program currently in place will continue on subsystems and components required to be operational for PDMS. Any deletions or reductions in scope (e.g., NFPA compliance) or frequency will be evaluated under the provisions of 10 CFR 50.59. Specific testing requirements will be addressed in to-be-revised PDMS operating procedures.
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l 51-29 1. 3 - MARCH 1989 430P
SUPPLEMENT 1
- 29. Section 7.2.1.4. Are any of the reactor containment closure devices, air-locks, dcor seal:, etc., electrically operated or can they all.be closed manually?
RESPONSE: The Reactor Building has two means of ingress / egress: the equipment hatch and the personnel hatch. Both are operated manually.
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S1-30 AM. 3 - MARCH 1989 0430P
. SUPPLEMENT 1 r, i 30, figure 7,2 The left hand portion of the drawing indicates the
. instrumentation that has been disabled or de-energized. How will this' affect the fire' damper action?
i RESPONSE: The fire dampers will be manually closed when the air intake is tiot in ust. See response to Question No. 15 for possible modification to the trip mechanisms,
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t SI-31 AM. 3 - MARCH 1989 0430P
SUPPLEMElli 1
- 31. Figure 7.2 Blankoffs are indicated for the Auxiliary Building heating ard ventilation, that apparently were not blanked orior to the THI-2 accident. How will these blanked, deactivated items affect the facility air balance flows? Will there be an effort to rebalance this system?
RESPONSE: Changes to air flow within the Auxiliary Building Heating and Ventilation (H&V) due to the installation of blanks are insignificant to the overall facility air balance flows.
Rebalancing of the Auxiliary Building H&V System is not necessary. ,
51-32 AM. 3 - MARCH 1989 0430P
l SUPPLEMENT 1
- 32. Figure 7.2 Note 11 Indicates that the penthouse gravity dampers (upper left-hand corner) are Ircked open. These are the units downstream '
of the exhaust fans. What is the purpose for blocking these dampers in the open mode?
RESPONSE: Supply dampers are closed and exhaust dampers are left in the open position to allow a free flow of air through the HEPA filters and rtation vent to the atmosphere. No special provisions are made to ensure that air flos 1 primarily through the station vent.
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51-33 Ati. 3 - MARCH 1989 0430P l
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'33. Section 8.2.5 - Fire Inside Containment - This sectica postulates a fire j from oil in the reactor coolant pumps, yet paragraph 6.3.51 states that 1 the oil has been removed from the pumps. In addition, Section 7.0.2.2, j paragraph-(e) does not mention the removal of the oil from the reactor coolant pumps. Will the oil be present in the reactor coolant pumps during PDMS. How much will be present?
i RESPONSE: The entire reactor coolant pump lube oil inventory will not be j removed since the dose rates severely limit access to the areas of j the pumps and oi1 collection / drain systems. Section 6.3.51 has i been revised to reflect this. Each of the four reactor coolant pumps has two sumps containing 120 gallons of oil in the upper reservoir and 18 gallons in the lower for a total of 138 gallons of oil per pump. It is expected that 50% of this oil will be removed prior to entry into PDHS.
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l S1-34 AM. 3 - MARCH 1989 Oc30P 1
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f-T SUPPLEMENT 1 l 34. Pleate address the surveillance t 'ing of the protection systems, l- equipment, and fire walls. Will: retilance testing of fire protection equipment, valve posittoi.s, fire s_,1 integrity, etc. occur during POMS? -
Will the equipment be maintained and checked in accordance with recognized standards such as those of the NFPA! -
RESPONSE: Testing.. preventive, and corrective maintenarece currently in place {
will continee for those systems and components required.to be 1 functional during PDMS. 'Any changes to the Fire Protection Program j will be evaluated under the provisions of 10 CFR 50.59; deficiencies in the program, systems, or. components will be reported in accordance with Technical Specifications Section 6.7.1.
On the subjact of fire walls, the FPPE, discussed in response to Question No. 17, supported the deletion of all barriers with the exception of containment.
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.i S1-35 AM 3 - MARCH 1989 0430P i
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