ML091110523
| ML091110523 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 04/21/2009 |
| From: | Hiland P NRC/NRR/ADES |
| To: | Pardee C Exelon Generation Co |
| References | |
| EA-09-033 IR-08-007 | |
| Download: ML091110523 (5) | |
See also: IR 05000373/2008007
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION III
2443 WARRENVILLE ROAD, SUITE 210
LISLE, IL 60532-4352
April 21, 2009
Mr. Charles G. Pardee
Chief Nuclear Officer and
Senior Vice President
Exelon Generation Company, LLC
4300 Winfield Road
Warrenville, IL 60555
SUBJECT:
RESPONSE TO DISPUTED NON-CITED VIOLATION
LASALLE COUNTY STATION UNITS 1 AND 2
INSPECTION REPORT 05000373/2008007; 05000374/2008007(DRS)
Dear Mr. Pardee:
On January 29, 2009, Mr. Daniel J. Enright, Exelon Generation Company, LLC (Exelon),
LaSalle County Station (LSCS) provided a response to NRC inspection report issued on
December 31, 2008, concerning activities conducted at your facility. Specifically, the Exelon
letter contested one of the Non-Cited Violations (NCVs) contained in the inspection report,
namely NCV 05000373(374)/2008007-02, associated with the Failure to Provide a Sprinkler
System for Fire Zone 4F3. By our letter dated February 5, 2009, the NRC acknowledged your
letter and advised you that we were evaluating your reply and would inform you of the results of
our evaluations. We have completed our review of your response.
In the January 29, 2009 letter, your staff stated that a pre-action sprinkler system was not
required by the LSCS licensing basis and that the installed pre-action spray system was
appropriate for the identified hazard in the area.
1.
Your staff provided information to support this position, including:
a)
replacing the existing pre-action spray system with a sprinkler system would decrease
the effectiveness of the fire protection features;
b)
given the way the cable trays are stacked and run, a sprinkler design would
compromise the response to the primary hazard in order to improve the response to a
less credible scenario;
c)
at present, the installed spray system remains fully capable of controlling a severe fire
in the overlab space, as well as assure that the fire area boundaries are not challenged
by a fire within the space;
d)
sprays have an enhanced tendency to detect and actuate;
e)
the actuating temperature for the sprays is far below the cable insulation temperature
ratings; and
C. Pardee
-2-
f)
sprinklers in the above-ceiling space are not and cannot be credited with fire
suppression in the Chemistry Laboratory itself, because the ceiling would interfere with
the sprinkler function.
2.
Your staff also raised the point that there are contradictory statements in the UFSAR, e.g.:
a)
Updated Final Safety Analysis Report (UFSAR) Appendix H, referred to the system as
a sprinkler system;
b)
Section 9.5.1.2.2 referred to the system as an automatic pre-action sprinkler system,
while; and
c)
Section 9.5.1.1.3 of the UFSAR described the system as an automatic water spray
system.
3.
Your staff stated, that in accordance with the National Fire Protection Association (NFPA)
Handbook 14th Edition, NFPA-15 gave guidance for special applications not covered in the
NFPA-13 Sprinkler Code, leading to the imprecise use of the term sprinkler to apply to
both types of systems.
4.
In addition to your letter, your staff provided additional evaluations documenting the issues
and impacts related to the as-found configurations in the laboratory area.
NRC Staffs Review:
The NRC staff reviewed the information you provided to determine whether the installed pre-
action spray system complies with the current licensing basis. These staff members were
independent of the initial inspection effort. The review focused on NRC licensing and regulatory
requirements (i.e., LSCS Fire Protection Program, Final Safety Analysis Report (FSAR), UFSAR,
and related Safety Evaluation Reports) rather than the technical adequacy of the presently
installed pre-action spray system. After careful consideration of the information you provided,
we have concluded that the violation occurred as stated in the inspection report.
The licensing basis for LSCS describes a sprinkler system, not a spray system. In Section
9.5.1.2.2, the UFSAR refers to the area above the suspended ceiling as having a pre-action
sprinkler system. In Appendix H, Section H.3.4.18, Auxiliary Building Ground Floor - Fire Zone
4F3, the UFSAR also refers to the suppression system as a sprinkler system. There is one
reference to a water spray system in UFSAR Section 9.5.1.1.3, Facility Features, however,
that description appears in a short overview and was not considered definitive.
The license-amendment history also reflects that LSCS was to have installed a sprinkler
system, not a spray system. In May 1980, LSCS submitted FSAR Amendment 49 in response
to NRC concerns and clearly communicated that an automatic sprinkler system was to be
provided for the cable concentration located above the suspended ceiling in Fire Zone 4F3. In
March 1981 the NRC issued its Safety Evaluation Report (NUREG-0519), which concluded that
the sprinkler system described in the amendment met the guidelines of Appendix A to Branch
Technical Position ASB 9.5-1.
C. Pardee
-3-
Finally, NRC staff reviewed the guidance in NFPA-13 and NFPA-15, as well as the NFPA
Handbook, and determined that the primary distinction between whether a water spray or
sprinkler system should be used is whether a specific area coverage is needed (spray) versus
general area coverage (sprinkler). As indicated above, and based upon the LCSC previous
response to the NRC concern in May 1980, a general area coverage water suppression system
was approved by the NRC for this area.
The LaSalle County Station provided several justifications why the installed pre-action spray
system was appropriate for the identified hazard in the area. The licensee is permitted to make
changes to their Fire Protection Plan without prior NRC approval, provided that those changes
would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.
However, at the time of the inspection, LSCS had not evaluated why the change to a spray versus
sprinkler system above the laboratory ceiling did not adversely affect the ability to achieve and
maintain safe shutdown.
In accordance with 10 CFR 2.390 of the NRC's ARules of Practice,@ a copy of this letter and your
January 29, 2009, response will be available electronically for public inspection in the NRC Public
Document Room or from the NRC's document system (ADAMS), accessible from the NRC Web
site at http://www.nrc.gov/reading-rm/adams.html.
Sincerely,
/RA/
Patrick L. Hiland
Acting Deputy Regional Administrator
Docket Nos. 50-373; 50-374
cc:
Site Vice President - LaSalle County Station
Plant Manager - LaSalle County Station
Manager Regulatory Assurance - LaSalle County Station
Senior Vice President - Midwest Operations
Senior Vice President - Operations Support
Vice President - Licensing and Regulatory Affairs
Director - Licensing and Regulatory Affairs
Manager Licensing - Braidwood, Byron and LaSalle
Associate General Counsel
Document Control Desk - Licensing
Assistant Attorney General
J. Klinger, State Liaison Officer,
Illinois Emergency Management Agency
Chairman, Illinois Commerce Commission
C. Pardee
-3-
Finally, NRC staff reviewed the guidance in NFPA-13 and NFPA-15, as well as the NFPA Handbook,
and determined that the primary distinction between whether a water spray or sprinkler system should be
used is whether a specific area coverage is needed (spray) versus general area coverage (sprinkler).
As indicated above, and based upon the LCSC previous response to the NRC concern in May 1980,
a general area coverage water suppression system was approved by the NRC for this area.
The LaSalle County Station provided several justifications why the installed pre-action spray system was
appropriate for the identified hazard in the area. The licensee is permitted to make changes to their Fire
Protection Plan without prior NRC approval, provided that those changes would not adversely affect the
ability to achieve and maintain safe shutdown in the event of a fire. However, at the time of the inspection,
LSCS had not evaluated why the change to a spray versus sprinkler system above the laboratory ceiling
did not adversely affect the ability to achieve and maintain safe shutdown.
In accordance with 10 CFR 2.390 of the NRC's ARules of Practice,@ a copy of this letter and your
January 29, 2009, response will be available electronically for public inspection in the NRC Public
Document Room or from the NRC's document system (ADAMS), accessible from the NRC Web site at
http://www.nrc.gov/reading-rm/adams.html.
Sincerely,
/RA/
Patrick L. Hiland
Acting Deputy Regional Administrator
Docket Nos. 50-373; 50-374
cc:
Site Vice President - LaSalle County Station
Plant Manager - LaSalle County Station
Manager Regulatory Assurance - LaSalle County Station
Senior Vice President - Midwest Operations
Senior Vice President - Operations Support
Vice President - Licensing and Regulatory Affairs
Director - Licensing and Regulatory Affairs
Manager Licensing - Braidwood, Byron and LaSalle
Associate General Counsel
Document Control Desk - Licensing
Assistant Attorney General
J. Klinger, State Liaison Officer,
Illinois Emergency Management Agency
Chairman, Illinois Commerce Commission
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DOCUMENT NAME: G:\\EICS\\ENFORCEMENT\\Enforcement Cases 2009\\EA-09-033 LaSalle Disputed\\EA-09-
033 LaSalle Final Response to Disputed NCV 2008-007.doc
- Publicly Available Non-Publicly Available Sensitive ; Non-Sensitive
OFFICE
RIII
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RIII
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NAME
ADahbur:ls
RDaley
SWest
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PHiland
DATE
04/15/09
04/15/09
04/17/09
04/15/09
04/20/09
04/21/09
OFFICIAL RECORD COPY
1 OE concurrence provided in E-mail from G. Gulla on 04/15/09
Letter to Mr. Charles Pardee from Mr. Patrick L Hiland dated April 21, 2009.
SUBJECT:
RESPONSE TO DISPUTED NON-CITED VIOLATION
LASALLE COUNTY STATION UNITS 1 AND 2 INSPECTION REPORT
05000373/2008007; 05000374/2008007(DRS)
EA 09-033
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