ML18353A519
| ML18353A519 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Quad Cities, Zion  |
| Issue date: | 04/25/1975 |
| From: | Bolger R Commonwealth Edison Co |
| To: | James Keppler Office of Nuclear Reactor Regulation |
| References | |
| IEB-75-004, IEB-75-004A | |
| Download: ML18353A519 (4) | |
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Corrimonv~ealih Edison One First National Plaza.'Chicago. Illinois Address Reply to: Post Deice Box 767 Chicago, illinois 60690 April 25, 1975 Mr. J.
G. Keppler NRC Dkts. 50-10~ 50-237, 50-249~
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50-295,, and 50-304 Directorate of Regulatory Operations U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137 I ~
Dear Mr. Keppler:
1 This letter is responsive to IE Bulletin No. 75-04 and No.75-04A requiring action by Commontrealth Edison.
Mr. Elfrink of'. my office called Mr. Gaston Fiorelli on April 23, 1975 and asked for and received an extension of the due date of this response from April 24, 1975 to April 28, 1975.
No. 75-04 Although Commonwealth Edison does not have any major construction activities at its operating power reactor sites, we have conducted the reviews and evalu'ations requested in this Bulletin. It is important to note that at all operating plants in the Commonwealth Edison system, the Station Superintendent acts as
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- 4. and f'inal auti ority and control over all operations at the plant site, including maintenance and construction.
ITEM 1.
Review your overall procedures and system for control-1
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. ling construction activities that" interface with reactor operating activities, with particular attention to the installation and tesi,ing of seals for electrical cables between compartments of the reactor building, e.g.,
control room to cable spreading room.
Dresden Quad Cities and Zion All the areas, in each station, which contain electrical
'enetrations or concentrations of safety related cables are within the.,vital area boundary described in the site security plan.
Admittance to such areas is restricted.to authorized personnel, thereby maintaining control over any contained activities.
All work done in these areas is done in accordance with the Quality Assurance Program.
The Operating Engineer reviews each job to determine if safety related.
The i~laintenance Engineer revie:rs each safety related work request or modification package t'o deter-mine the procedural requirements for that activity.
The Quality Control group reviews the findings of the Maintenance Engineer to assure that these requirements have been properly specified.
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Prior to initiating the work, the shift supervisor must
( pprove the work request end authorl.ze commencement of work.
Zn addition, the shift supervisor will determine the need for any specialtprecautionary measures required and see that they are carried out..
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When the Commonwealth Edison Company Construction Depart-ment engages contractor personnel to perform work at an operating
.station, the work procedure control a'nd approval is provided for l
by the Quality Assurance Program.
Whenever such work interfaces with station operating activitie's, the Construction Department supervisors coordinate the scheduling and performance of the work with the Station Operating Department.
Because of a larger number of contracted activities, Dresden Station also uses a work permit system to provide additional control.of such activities.
ITEM 2.
Review the design of floor and wall penetration
- seals, with particular attention to the flammability of materials.
Dresden 0
Secondary Containment Tcro different designs have been used for cable penetra-tions and seals.
The most predominant design uti izes short conduit sleeves cast into the walls with cable trays on either side of the wall.
The sleeves are sealed with Oakum and Duc-Seal on the turbine room side of the penetration and are filled with General Electric Company =-type RTV-108 Si'licone Rubber from the reactor building side.
Duc-Seal is non-flammable, Oakum and RTV-108 are moderately flammable.
A lesser used design utilizes continuous runs of conduit through walls or floors.
Sealing is accomplished with Crouse-Hinds type EYS condulets filled with a non-flammable water base sealing compound.
Control Room Two similar designs are used here.
The cable slots through the floor are sealed with Flamemastic 71A brand of fire-proofing mastic over fiberglass Thermal Insulating Wool (T.I.W.)
which is supported by Ebony Asbestos board.
Cable tray wall pene-trations are packed with fiberglass T.I.W. and covered on both sides with Flamemastic 71A.
The material used in these designs is non-flammable.
Balance of Plant
'When required, cable tray and cable riser penetrations
'are sealed by one of two methods.
Fiberglass T.I.N. packed into the penetration covered with Flamemastic 71A on both sides, or cellular concrete.
Both designs utilize non-flammable materials.
Quad Cities Secondary Containment Cable penetrations and seals are similar to Dresden,
(.xcept, that s1eeve type penetraticns are stuffed with Oakum and Duc-Sea1 from the turbine building side, filled rrith foamed cement from the reactor building side, and then sealed with HTV-108 Silicone Rubber.
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Floor slot seals utilize the same design as Dresden; wall penetrations are not used.
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Balance of'lant Mhen required, cable t'ray and cable riser penetrations are sealed utilizing the same designs as Dresden.
A few isolated conduits may be sealed with polyurethane; this material is flammable.
Zion Station Designs utilizing cellular concrete are used throughout the plant.
Cellular concrete is non-flammable.
ITEM 3.
Evaluate your procedures f'r the control of ignition sources which may be used for leak testing or other purposes in areas containing flammable materials.
Dresden Quad Cities and Zion
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The procedures used for leak testing of'eals and pene-trations normally requires the use of le'ak testing methods which do not requi,re an ignition source, such as pressure decay or flow meter methods.
However, to ensure that ignition sources are not used without authorization, the procedures covering leak tests V ~
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Mith regard to other work activities, such as welding,'utting or burning in areas containing flammable.materials, Station Maintenance procedures related to fire prevention measures are presently in effect.
These procedures specify the use of a "welding and cutting" permit.
Such permits are authorized by the Maintenance Department.
The related procedures include the follow-ing provisions:
(i)
Inspection of work areas for combustibles prior to beginning any operations (ii)
Posting of a fire watch during operations (iii) 'einspection of'he work area by a supervisor following completion of the work, to verify that no accidental fires may have been started.
The permits are retained at the station for review by fire insurance inspectors.
The subject procedures for Dresden, Quad Cities and Zion been evaluated and adequately cover the areas of concern.
C' No.
75-OQA
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I Xn accordance with the request to report our schedule for completion of the. reviews requested in Bulletin No. 75-0LIA, we expect to complete the reviews and report on such reviews the week of June 2, 1975.
Xf you have any questions regarding these reviews and evaluations, please contact Mr. J.
S. Abel of'y office.
'I Very truly yours,
//~~Mm R. L. Bolger Assistant Vice President