ML19256A658

Corrects & Clarifies Positions Re Cable Fire Barrier Penetrations Test Data,Communications Sys,Cable Spreading Area Fire Protection & Containment & Auxiliary Bldg Mods, for Amend 43 to Operating License

ML19256A658
Person / Time
Site:	Millstone
Issue date:	01/02/1979
From:	Counsil W NORTHEAST UTILITIES
To:	Reid R Office of Nuclear Reactor Regulation
References
NUDOCS 7901090154
Download: ML19256A658 (3)

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l(Hrl'HI!A!iT UTIX.ITII!!i

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P o Box 270 34- ,' l ,( ', ^ ' ' '

, HMITFoRD. CONNECTICUT 06101

. , ,,1 ,. s 2 (203) 666-6911 k L J 4 , .

January 2,1979 Docket No. 50-336 Director of Nuclear Reactor Regulation Attn: Mr . R. Reid , Chief Operating Reactors Branch #4 U. S. Nuclear Regulatory Commission Washington, D. C. 20555

References:

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

(2) W. G. Counsil letter to D. L. Ziemann and R. Reid dated Augus t 17, 1978.

Centlemen:

Millstone Nuclear Power Station, Unit No. 2 Fire Protection In Reference (1), Nor theast Nuclear Energy Company (NNECO) was issued Amendment No. 43 to the Millstone Unit No. 2 operating license which consisted of Technical Specification changes and license condir. ions related to fire pro-tection. The Safety Evaluation for this amendment summarized the Staff evalua-tion of the fire protection prcgram at Millstone Unit No. 2. The evolution of Reference (1) involved numerous iterations and negotiations ranging from verbal commitments to docketed responses and every effort was made to eliminate mis-understandings in all phases of the process. However, our review of Reference (1) has identified several items which require correction and/or clarification of the NNECO position. Each item in question from the SER has been listed below, followed by the NNECO position aad justification. In most instances the clarification references a different section within the SER.

Section 3.2.4 Cable Fire Barrier Penetrations Test Data SER: " Test data will be provided to demonstrate the adequacy of electrical cable fira barrier penetrations."

NNECO Position:

Test data on all new penetrations will be provided to demonstrate the adequacy of electrical cable fire barrier penetrations. As stated in Section 4.9, tests have been conducted to d6monstrate that. the existing cable penetration seals have an adequate fire rating. Therefore. itat data on new penetrations wl'l be suf ficient to ensure that the fire barrier penetrations vill adequately prevent the spread of fires.

7901090159

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Section 4.7 Communication Systems SER: "A second system consists of telephone stations located throughout the plant."

NNECO Position:

The system is more accurately described by the statement: "A second system consists of telephone jack stations located throughout the plant."

Section 4.7 Communication Systems SER: "We find that , subject to the provision of portable radio communications, the communications are adequate to coordinate fire fighting and safe shutdown activity."

NNECO Position:

The words " subject to the provision of portable radio communications" should be d ele ted . As stated at the bottom of Page 4-6, " Portable communications radios are provided for emergency use", and are currently in use.

Section 5.2.5 Cable Spreading Area - Adequacy of Fire Protection SER: "Duu to the limited separation between redundant electrical cables f or shutdown systems, the limited access which prevents effective manual fire fighting, and a concern for ti.e effectiveness of the ceiling mounted manually actuated deluge sy ; tem, the present fire protection for this area does not provide adequ; te assurance that fire damage could not result in a loss of shutdown capability."

NNECO Position:

NNECO disagrees with this statement. As stated in Reference (2), an eve 1ua tion will be performed for the casle spreading area to determine if redundant cable systems are routed in close proximity and determine the best possible method of providing either isolation, separation, or additional protection, if necessary.

Concerning access to this area, the three points of access permit sufficient manual fire fighting capability. Also, tha Staff's concern for the effectiveness of the ceiling mounted deluge system is not substant1nted. Therefore, any con ~

clusions as to the inadequacy of the fire protection in this area are premature.

An evaluation is in progress.

Section 5.8.6 Auxiliary Building - Modifications SER: " Automatic sprinklers or suitable fire barriers will b<, provided to assure that fire damage does not result in a loss of shutd9wn capability where prompt action is not taken to suppress fires in these areas."

NNECO Position:

Protective measures, consisting of either automatic sprinklers, fire barriers, fire retardent coatings, or detection, will be provided to assure that fire damage does not result in a loss of shutdown capability. Reference to a lack of prompt action is also inappropriate.

a "Section 5.10.6 Containment - Modifications SER: " Detection systems will be provided at the elevation above the cable trays and in the reactor coolant , p areas."

NNECO Position:

Existing detection systems will be expanded to provide coverage for cable tray concentrations. Detection will also be provided for the reactor coolant pump area.

We trust that. due consideration . rill be given to these concerns in subsequent correspondence on this subject.

Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY

/ L - ?ix,e W.'G. Counsil Vice President

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