ML17174A545
| ML17174A545 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 10/27/1980 |
| From: | Ippolito T Office of Nuclear Reactor Regulation |
| To: | Abel J COMMONWEALTH EDISON CO. |
| References | |
| NUDOCS 8011170573 | |
| Download: ML17174A545 (6) | |
Text
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. OCT : 2 7 1900 I
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Vo{ket'
- _ TI ppo l ito
-*NRC PDR.
. SNorrts
~Local PDR-RBevan
.'.i Docket No. 50-249 *
-and 50-237 r *;
- ORB :Readfng-OELD -
. NRR ~eading I&E'. (3)
DEisenhut.
- NSIC Mr. J. S
- Abel
'.Dfrectof of Nuclear. L iC:ensing Commoowea 1th Edi son Compa riy:
P; 0. Box 767 Ch1cago,.-I1l1nofs 60690
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Dear Mr. Abel:
RPurple TERA TNovak
- ACRS (16)
RTedesco
- GLa*i nas *
- JRbe JHe.l temes, AEOD -
I On May 29, 1980, the Corrmfssfon published a proposed rule, a*- new*
paragraph 50.48 a*nd Appendix. *R* to 10 CF~ Part _so, concerning fire protection,
-.. which s"ets forth the minimum' acceptable fire protection requirements nec*essary to resolve contested areas of concern for nuelE!ar. power plants operating prior.to January l, 1979.
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We have reviewed all the information "you have provided t~ date reg.ardfng
- your fire protection program. Several of the open itens fndfcated in-our Safety Eval uat1on Report issued March 22, 19.79 remain unresolved.
EnclOsure 1 presents our posJticin o.n modf.ficatfons that would have -to be made at your facility to resQ)ve these open items, in a manner that would meet -the requirem.ent!) of ~he* proposed AppE!ndix R.
Enclosure:
As* Stated * :.
- c~ w/enclosure:
See next page s~ ncerely;*
Original Signed by_
.. T. A. lppoHto Thomas A. Ippolito, Chief
, Operating Reactors Branch #2
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- Division of Licensing t*:r*
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- -r OFFICE
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NRC'FORM 318 (9-76) NRCM 0240
.. ;._. *u.s: GOVERNMENT-PR.INTING OFFiCE:-19l9*2*89*369 I
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Mr. J. cc:
Mr. John W. Rowe Isham, Lincoln & Beale Counselors at Law One First National Plaza, 42nd Floor*
Chicago, Illinois 60603 Mr. B. B. Stephenson Plant Suoerintendent Dresden Nuclear Power Station Rural Route #1 Morris, Illinois 60450 Morris Public Library 604 Liberty Street Morris, Illinois 60451 U. S. Nuclear Regu.latory Commission Resident Inspector's Office Dresden Station
.. RR.#1 Morris, Illinois 60450 Susan N. Sekuler Assistant Attorney General Environmental Control Division 188 W. Randolph Street Suite 2315 Chicag~, Illinois 60601 John F. Wolf, Esq.
3409 Shepherd Street Chevy Chase, Maryland 20015 Dr. Linda W. Little 500 Hermitage Drive Raleigh, North Carolina 27612 Dr. Forrest J. Remick 305 East Hamilton Avenue State Co 11 ege, Pennsylvania, 16$01 October 27, 1980
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SUMMARY
OF STAFF REQUIREMENTS TO RESOLVE OPEN ITEMS DRESDEN UNIT NOS. 2 ANO 3 DOCKET NOS. 50-237 ANO 249 3.1.2 Smoke Detection System Tests In the SER, it \\*1as our concern that the smoke detectC""s mf ght not respond to the products of combustion for the combustibles in t.~e areas where smoke detectors are installed.
We were also concerne:1 ".h:t ventilation air flow patterns in the area might reduce or prevent de-:e:tor response and we recommended that the licensee conduct bench te5tincr of smoke detectors and an in-situ test. The licensee has not resp;nded with information regarding this. item for our evaluation.
The required methodology for an in-situ smoke detecto:- test is beyond the current state-of-th2-art and, therefore, cannot be pe:-fm-:-:ed at this time.
To adequately address the. concerns of the staff and a£s:.. Jr: that the detection system will provi~e timely detection of any fir!s, the licensee should conduct bench tests *of the. detectors to verify tr.a: they wi 11 be responsive to the products of combustion of combustib~es, including trans-ient ca~bustibles, in each area where the detectors a~e irsta1led.
3.1.5 Water Suppression Systems In the *sER, it was our concern.that the pre-action sp:-ink:er system which protects the redundant divisions of cables on the 1mez:anire may not be adequate to preserve safe shutdown capability.
By letter dated December 4, 1979,. the licensee provid:d de:sign information regarding the pre-action system.
Based on our review, we find that the pre-action syst:m dces not provide adequate protection to pres~rve safe shutdown capabilfty.
~e requested the 1 i censee to:
- 1.
Provide alternate shutdown capability independent of :~e t~rbine mezzanine area.
- 2.
Provide 1 ine detectors i.n. the cab le trays or spot type heat detectors between the horizonta 1 trays for actuation of the pre-~ct ion system.
- 3.
Verify that the pressure: sensing switch for the t~rbir: mezzanine water system is located on the., system side of any regulators or check valves.
The licensee has not demonstrated that adequate prote~tf or features have been-provided for cables and! equipment of redundant s~*ste;-:-s irqort~nt to achieving safe shutdown conditions to ensure that ~t 1:=.st ~me i.leans bf achieving such conditions survives postulated fires.
To meet our fire protection guidelines, alternate shutdown capability should be provided when safe shutdown cannot be ensured by barriers and detection and suppression systems because of the exposure of redundant safe shutdown equipment, cabling, or components in a single fire area, to an exposure fire, or fire suppression activities, or rupture or inadequate operation of fire suppression systems.
To meet Section III, Paragraph G_of the proposed Appendix R to 10 CFR Part 50, the licensee should provide an alternate sh~tdown capability independent of this area. The alternate shutdown system should meet the requirements of Section L, Paragraph III of pro~osed Appendix R to 10 CFR Part 50.
In addition, the licensee ihould provide a line-type detection system in the cable trays for actuation of the pre-action system. Also, the air pressure sensing switch for the turbine mezzanine water system should be located on the system side of any regulation or check valves.
- 3. 1.6 Gas -Suppression Systems - Auxiliary Electrical Equipment Room In the SER, it was our concern that the fire suppression systems for the auxiliary electrical equipment and computer rooms may be inadequate to suppress a fire.
By letter dated September 28, 1978, the licensee provided design details regarding the automatic Halon fire suppression system and the manual C02 fire suppression system.
As a result of our review, we requested the licensee to provide Halon and C02 discharge nozzles in the underfloor area of the computer room and the small area of the tunnel.
To meet accepted fire protection engineering practice the licensee should provide Halon and C02 discharge nozzles in the underfloor area of the computer room and the small area of the tunnel.
3.1.12 Portable Veritilation Equipment In the SER, the concern was that installed ventilation systems would not be adequate to remove the smoke and heat from a fire in most areas of the plant.
By letter dated November 30, 1978, the licensee committed to provide the following portable smoke ejector units and accessories:
- l. Two electric motor driven smoke ejector fans with air flow capacities of 5,200 cfm each.
- 2.
One hundred fifty feet of 16 incp diameter flexible duct *
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e We are of the opinion that three portable smoke ejector units with a combined capacity of 17,500 cfm be provided to adequately remove heat and smoke from the fire areas, ~nd therefore the two smoke ejector units proposed by the licensee are not sufficient.
To meet the guidelines of Section D-4 of Appendix A to BTP 9.5~1 and pro-vide adequate smoke removal capability the licensee should provide at least three portable smoke ejectors-with a combined capacity of at least 17,500 cfm.
The smoke ejectors provided should be capable of being operated in case of loss of offsite power.
3.2.4 Shutdown Capability In the Fire Protection Safety Evaluation Report, it was our concern that in several areas of the plant, the physical separation of redundant safe shutdown systems is inadequate so that redundant systems could be damaged by a single fire, thus the possibility of affecting safe shutdown *. By letters dated June 5, 1978, and January 24, 1980, the ljcensee provided the results of an evaluation of the capability to achieve and maintain safe shutd01-m for postulated fires in various plant areas.
The information is not enough for us to make an independent evaluation.
The licensee has not ~emonstrated that adequate protection features have been provided for cables and equipment of redundant systems important to achieving safe shutdown conditions to ensure that at least one means of achieving such conditions survives postulated fires.
To meet our fire protection guidelines, alternate shutdown capability should be provided when safe shutdown cannot be ensured by barriers and detection and suppression systems because of the exposure of redundant safe shutdown equipment, cabling, or components in a single fire area, to an exposure fire, or fire suppression activities, or rupture or inadequate operation of fire suppression systems~
To meet Section III; Paragraph G_of the proposed Appendix R to 10 CFR Part 50, the licensee should~provi~e an alternate shutdown capability for the following areas of the plant:
- 1.
Control Room (Fire Area 2.0).
- 2.
Cable spreading area (Fir.e Zone 6.2) - auxiliary electrical equipment room.
- 3. Turbine Building, (Fire Zbnes 8.2.6.A and 8.2.5A) - 4kv switchgear groups 23 and 24.
Area at elevation 534 feet bounded by column rows D-E and 31-33 and elevation 517 feet bounded by column rows D-E and 31-36.
- 4.
Turbine Building, (Fire.Z6ne 8.2.68 and 8.2.58) - 4kv switchgear groups 33 and 34.
Area at elevation 517.feet bounded by column rows D-E and 52-56.
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- 5.
Reactor Building, (Fire Zone l.1.2.3A) - 4kv switchgear 23-1 and 24-1. Area at elevation 545 feet bounded by cobmn rows M-:N and 39-42.
- 6.
Reactor Building, Area at elevation
- 7.
Reactor BuiJding, Area at elev:tion
- 8. Reactor Building, Area at elevation (Fir~ Zone 1. 1. l.3A) - 4kv switchgear 33-1 and 34-l.
545 feet bounded by column rows M-N and 46-49.
(Fire Zone 1. l.2.4A) - 480V swtichgear 28 and 29.
570 feet bounded by column rows M-N and 40-42.
(Fire Zone l.l.l.4A) - 480V switchgear 38 and 39.
570 feet bounded by*column rows M-N and 46-48.*
- 9.
Unit 3 cable tunnel, (fire Zone 8.2.4).
The alternate shutdown system should meet the requirements of Section L, Paragraph III of proposed Appendix R to 10 CFR Part 50.