ML19309H431
| ML19309H431 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 04/30/1980 |
| From: | Peoples D COMMONWEALTH EDISON CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19309H432 | List: |
| References | |
| NUDOCS 8005130251 | |
| Download: ML19309H431 (8) | |
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C. C:mmonw ith Edison
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p* one First National Plaza. Chicago. Ilknois l
Address Reply to: Post Ottice Box 767
,/ Chicago Ilknois 60690
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April 30, 1980 Mr. Harolo R. Denton, Director Of fice of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555
Subject:
Zion Station Units 1 and 2 Additional Fire Protection Information NRC Docket Nos. 50-295 and 50-304 Reference (a):
March 24, 1980 letter from A. Schwencer to D. L.
Peoples Dear Mr. Denton.
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In Reference (a), the NRC Staff requested Commonwealth Edison Company to provide additional information concerning the Zion Fire Protection Program.
The following information is provided in response to the NRC request.
The response format will follow that of the five enclosures of Reference (a). - Status of Resolution of Incomplete Items I
SER Item 3.1.1 - Test results verifying that fire detectors are correctly located physically will be provided after the tests are complete.
Currently, a test method has not been identified which will accomplish the verification.
When a satisfactory test is developed, it will be used to perform the required tests.
SER Item 3.1.3 - (1) The required information concerning the gas suppression system in the inner and outer spreading area was submitted in a letter to H. R. Denton from W. F. Naughton dated October 31, 1979.
(3) The required information concerning the automatic gas suppression system for the diesel driven containment spray pumps was submitted in a letter to H. R. Denton from W. F. Naughton dated October 31, 1979.
- I C:mm:nw;cith Edison a
Mr. Harold R. Denton, Director April 30, 1980 Page 2 SER Item 3.1.4 - (a) The required information concerning the automatic water curtain for the diesel generator air intakes was submitted in a letter to H. R. Denton from W.
F. Naughton dated October 31, 1979.
(b) The required information concerning the automatic directed water suppression on the diesel fire pump and its day tank was submitted in a letter to H. R. Denton from W. F. Naughton dated October 31, 1979.
j SER Item 3.2.1 - The reply to the NRC concerns in the area of Administrative Controls is provided in to this letter in response to of Reference (a).
SER Item 3.2.8 - A Safe Shutdown analysis for Zion Station is provided in Attachment 2 to this letter.
This
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analysis should also resolve SER Items 3.2.4, 3.2.5 and 3.2.7.
j - Evaluation Of Supplement Items That Are Complete This portion of Reference (a) provided a statement of Zion Fire Protection Supplement items that are complete and need no further response from Commonwealth Edison. - Evaluation Of Supplement Items That Require Additional Information 1
This portion of Reference (a) requested additional information for Zion Fire Protection SER Items 3.1.1, 3.1.3 and 3.1.4.
The response to these items has already been given above in " Enclosure 1 - Status of Resolution of Incomplete Items." - Evaluation Of Supplement Items For Which The Licensee's Proposal Is Unacceptable This portion of Reference (a) provided a statement of those responses to the Zion Station Fire Protection Evaluation of Supplement Items that the NRC Staff deemed unacceptable.
Commonwealth Edison's response to the NRC Staff's concerns are contained in Attachment I to this letter.
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C:mm:nwrith Edison Mr. Harold R. Denton, Director April 30, 1980 Page 3
. - Staff Position Safe Shutdown Capacility This portion of Reference (a) provided the "Staf f Position on Safe Shutdown Capability".
A safe shutdown analysis which takes the plant to a hot shutdown is provided in Attachment 2 to this letter.
A supplement to this analysis which will take the plant to a cold shutdown will be submitted by June 6, 1980.
Part 8 of Enclosure 5 is a list of information required by the NRC Staf f for their review of the safe shutdown analysis.
Part 8(a) is responded to in the Safe Shutdown Analysis submitted in Attachment 2 to this letter and in the report "Information Relevant to Fire Protection Systems and Programs, Zion Nuclear Power Station" dated April, 1977.
The modification designs proposed in the Safe Shutdown Analysis are not yet formalized, and therefore, complete descriptions and drawings are not available at this time.
The information required by Part 8(b) th ough 8(1) will be provided by September 30, 1980.
Please address any questions that you might have concerning this matter to this office.
One (1) signed original and thirty-nine (39) copies of this transmittal are provided for your use.
Very truly yours, l QW D. L. Peopl'es Director of Nuclear Licensing DLP:WFN: rap I
attachments (2) l l
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ATTACHMENT 1 Response to Items in Enclosure 4 of the Letter from A.Schwencer to D.
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Peoples dated March 24, 1980 4
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i Response to Items in Enclosure 4 Item 3.2.1 - Administrative Control Request from Page 1 Enclosure 4' Identify the offsite management position responsible for developing the Request:
fire protection program using NFPA publications.
At the present time, the Division Manager, Nuclear Stations Division has
Response
delegated the responsibility for developing the fire protection program for the nuclear generating stations to a full-time Fire Protection En-The Fire Protection Engi-qineer, who was recently added to his staff.
neer received his B.S. degree in Fire Protection Engineering in December, In order to meet the requirements of having access to a qualified 1979.
Fire Protection Engineer, the Company has. retained M&M Protection Con-M&M Protection Con-sultants, a Technical Service of Mprsh & McLennan.
sultants assist the Fire Protection Engineer on matters requiring a qualified Fire Protection Engineer.
" Provide assurance that at 3 year intervals, drills are audited by quali-Request:
fied individuals independent of the utility's staff."
Fire Protection audits are performed at 3 year intervals by qualified
Response
individuals independent of Commonwealth Edison's staff. During the audit, a fire brigade drill is witnessed and critiqued by the independent The auditors also review drills which were conducted in the auditors.
3 year period previous to the audit. The most recent audit was performed in 1979 by M&M Protection Consultants.
"We will require that, annually, fire brigade members be given a physical examination to determine their capacity to undergo streneous physical ac-Request:
tivity as experienced in firefighting."
Each member of the fire brigade is screened annually by Commonwealth
Response
Edison's Health Evaluation Program or by letter from his personal physician. An E.K.G., blood tests, spirometer test, blood pressure are included in the Health Evalu-reading, chest X-ray, and urinalysis This screening is given in order to meet the require-ation Program.
ments of Regulatory Guide 8.15 which fulfills the intent of this staff position.
Requests from Pages 2, 3 and 4 of Enclosure 4 Govern the handling and limitation of the use of ordinary combustible materials, combustible and flammable gases and liquids, high efficiency particulate air and 1.
charcoal filters, dry ion exchangt resins, or other combustible supplies in safety-related areas.
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.e 2-l This item is implemented by present administrative controls at the station and is being reinforced by a procedure change to ZAP 02A.
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Prohibit the storage of combustibles in safety-related areas or establish designated storage areas and fire protection therefor.
2.
This item is implemented by present administrative controls at the station and is being reinforced by a procedure change to ZAP 02A.
Response
Govern the handling of and limit transient fire loads such as combustible flammable liquids, wood and plastic products, or ot 3.
modification, or refueling operations.
This item is implemented by present administrative controls at the station and is being reinforced by a procedure change to ZAP 02A.
Response
Designate the onsite staff member responsiale for the in-plant fire p review of proposed work activities to identify potential transient fire haz 4.
and specify required additional fire protection in the work activity proce This item is being implemented by a procedure Response _:
the Fire Marshall or his assistant for review and implementation.
Govern the use of ignition sources by means of a flame permit system tha A separate trols welding, flame cutting, brazing, or soldering operations.
5.
permit shall be issued for each area where work is to be done, and continues over more than one shift, the permit shall be valid for not more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
This item is already in effect in a Maintenance Department Instruc Response _:
Govern the removal from the area of all waste, debris, scrap, oil spills, or other combustibles resulting from the work activity, or at the end of eac 6.
work shift, whichever comes first.
This item is implemented by present administrative controls at the station and is being reinforced by a procedure change to ZAP 02A
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Govern the periodic housekeeping inspections to ensure continued com 7.
with these administrative controls.
This item is implemented by present administrative controls at th station and is being reinforced by a procedure change to ZAP 02 I
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All wood used Govern the use of. specific combustibles in safety-related areas.
in safety-related areas during maintenance, modification, or refue 8.
(such as lay-down blocks or scaffolding) shall be flame-retardant Equipment or supplies (such as new fuel) ship I
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e However, all combustible materials shall be removed from the area reasons.
imediately following the unpacking.
Combustible material shall not be left unattended during lunch breaks, shift changes, or other similar periods.
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combustible packing material such as wood or paper excelsior shall be placed in metal containers with tight-fitting self-closing metal covers.
This item is implemented by present adminstrative controls at the
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station and is being reinforced by a procedure change to ZAP 02A.
Staff Position - Control of Ionition Sources, Page 3, Enclosure 4 Where welding, grinding, open flame work and cutting is being performed, all immovable combustible material below and within a 35-foot radius should be pro-tected by asbestos curtains, metal guards, or flame proof covers.
The requirement for Fire Blankets on any flammable components within a
Response
35-foot radius of any welding operation will be implemented by a pro-cedure change.
Staff Position - Firefighting Strategies, Page 4, Enclosure 4 Firefighting strategies shall designate:
Fire hazards in each area covered by the specific firefighting procedures.
a.
Fire extinguishants best suited for controlling the fires associated with the b.
fire hazards in that area and the riearest location of these extinguishants.
Most favorable direction from which to attack a fire in each area, in view of c.
the ventilation direction, access hallways, stairs, and doors that are most likely to be fire free, and the best station or elevation for fighting the fire.
All access and egress routes that involve locked doors should be specifically identified in the procedure with the appropriate precautions and methods for ~
access specified.
Plant systems that should be managed to reduce the damage potential during a d.
local fire; location of local and remote controls for such management (e.g.,
any hydraulic or electrical systems in the zone covered by the specific fire-fighting procedure that could increase the hazards in the area because of over-pressurization or electrical hazards).
Vital heat-sensitive system components that need to be kept cool while fighting e.
a local fire. Particularly hazardous combustibles should be designated to re-ceive cooling.
The Training Department will include specific safety-related area strate-
Response
gies in the firefighting training and retraining which will resolve the concerns of items a through e above.
Organization of firefighting brigades and the assignment of special duties ac-f.
cording to job title so that all firefighting functions are covered by any com-plete shift personnel complement. These duties include command control of the
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brigade, transporting fire suppression and support equipment to the fire scenes, applying the extinguishant to the fire, comunication with the control room, and coordination with outside fire departments.
Response: Organization of firefighting brigades, etc., as described in item f, are already implemented in procedure ZAP 02 which is also reviewed in training for fire brigade members.
g.
Radiological and toxic hazards in fire zones.
h.
Ventilation system operation that ensures desired plant pressure distribution when the ventilation flow is modified for fire containment or smoke clearing operations.
- i. Operations requiring control room and shift engineer coordination or authorization.
Response: The Training Department will include specific safety-related area strategies in the firefighting training and retraining which will resolve the concerns of item i above.
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Instructions for plant operators and general plant personnel during fire.
Response
Instructions for plant operators snd general plant personnel during fire are already implemented in procedure ZAP 02.
Item 3.2.4 - Physical Separation Tests An analysis of alternate shutdown capability showing shutdown capability independent from the cable spreading room, containment penetration vaults, auxiliary electrical equipment room, auxiliary building elevations 642, 617, 592, 560 and 542, reactor containment and the Crib House is prcvided as Attachment 2 to this letter.
Item 3.2.5 - Control Room Analysis The attached Safe Shutdown Analysis indicates that required instrumentation will;be provided at the Remote Shutdown Panel which can be isolated from the Control Room.
The Diesel Generator circuitry will bt designed such that a local-remote transfer switch will isolate the governor contri'. from the Control Room.
Item 3.2.7 - Auxiliary Electrical Equipment Room Analysis The attached Safe Shutdown Analysis indicates that required instrumentation will be provided at the Remote Shutdown Panel which can be isolated from the Auxiliary Elec-trical Equipment Room.
Item 3.2.8 - Alternate Shutdown Capability An Alternate Safe Shutdown Analysis is attached which will take the plant to hot I
shutdown. A supplement to this analysis to take the plant to cold shutdown will
,be submitted before June 6,1980.
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