ML19211A824

Submits Addl Response to NRC Ltr Re Fire Protection & Safe Shutdown Capability.Requests Clarification of Requests & Previous Negotiated Agreements

ML19211A824
Person / Time
Site:	Millstone
Issue date:	12/12/1979
From:	Counsil W NORTHEAST UTILITIES
To:	Reid R Office of Nuclear Reactor Regulation
References
NUDOCS 7912210148
Download: ML19211A824 (2)

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'!l,",:ZlO?" ~ am) 666-6911 k t J T: ' '.L Z" ' :l Dec ember 12, 1979 Docket No. 50-336 Director of Nuclear Reactor Regulation Attn: Mr. R. Reid, Chief Operating Reactors Branch (14 U. S. Nuclear Regulatory Commission Washington, D. C. 20555

References:

(1) R. Reid letter to W. G. Counsil dated September 21, 1979.

(2) R. Reid letter to W. G. Counsil dated September 19, 1978.

(3) W. G. Counsil letter to D. L. Ziemann and R. Reid dated July 31, 1979.

(4) W. G. Counsil letter to D. L. Ziemann and R. Reid dated October 9, 1979.

(5) W. G. Counsil letter to R. Reid dated November 21, 1979.

Gentlemen:

Millstone Nuclear Power Station, Unit No. 2 Fire Protection - Safe Shutdown Capability In Ref erence (1), Northeast Nuclear Energy Company (NNECO) was requested to provide additional detailed information with respect to Staf f concerns on the topic of Fire Protection and its affects on safe shutdown capability.

Reference (1) states that Alternate Safe Shutdown Capability was identified as an incomplete item of review in Section 3.2 of the Safety Evaluation.

NNECO finds it very curious that while Reference (1) emphasizes that Alternate Safe Shutdown Capability was identified as an incomplete item in Ref erence (2),

Reference (1) did not reiterate what the Staf f identified as items to be resolved to disposition the safe shutdown issue. Specifically, Reference (2) identified the need for five issues /submittals involving:

(1) Cable Spreading Area (2) Protectior. of Redundant Cable Trays (3) Smoke Detection System Tests (4) Cable Fire Barrier Penetrations Test Data (5) Primary Coolant Pump Lube Oil Fire Hazard NNECO responded to each of the above concerns in Reference (3). A subsequent site inspection and numerous telephone conversations resulted in the need for additional clarification, which was provided in References (4) and (5) . As indicated in References (3), (4), and (5), it was NNECO's understanding that this documentation served to formalize an agreement reached between our respective Staffs. Therefore, NNECO has been led to believe that the 1635 351 N2sen

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open items identified in Reference (2) have been completed / resolved to the satisf action of the Staf f. This understanding is reinforced by numerous statements in Ref erence (2), such as the following excerpt from Section 4.1:

"We have evaluated the separation between redundant safe shutdown systems and components to determine that they are either separated f rom each other or protected by suppression systems such that a fire will not af fect redundant equipment, and therefore a sufficient number of systems and components will be available to perform their shutdown function following a fire."

Af ter each section of Reference (2), which discusses implementation of the modi-fications, language typified by the following is included:

We find that , subject to the implementation of the above described modifications, the objectives identified in Section 2.2 of this report are satisfied and is, therefore, acceptable.

Thus, af ter years of ef fort involving intensive study of the Browns Ferry Fire, development of a plant-specific Fire Hazards analysis, review of numerous Staf f fire protection criteria documents, issuance of safety technical specifications, publication of the Staf f's Safety Evaluation Report, and implementation of customized saf e shutdown related fire protection modifications, the Staff is requesting additional information to assess the adequacy of the Alternate Safe Shutdown Systems of Millstone Unit No. 2. Based upon the above historical synopsis of this topic, it would appear that the completeness of the previously agreed upon modifications is suspect in the judgment of the Staff. These developments are viewed as enigmatic and perplexing by NNECO. If it is the Staff's opinion that the adequacy of the modifications must be reassessed, it should be so stated. This point is most relevant in light of the infrequently employed method used to document NNECO's commitment to these modifications, that of a license condition.

To that end, NNECO respectfully requests clarification from the Staff regarding the relationship between the Ref erence (1) requests and the previously negotiated agreements. NNECO had previously concluded , as did the Staf f in Reference (2),

that upon completion of the modifications identified, the issue of safe shutdown would be satisfactorily dispositioned. In the interest of ef ficient utilization of resources required to resolve the fire protection issue, a timely reply to the above concerns would be most appreciated.

4 We trust you find the above information adequate to understand our position.

Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY t l WA W.' G. Counsil Vice President .