ML19340D833
| ML19340D833 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 12/29/1980 |
| From: | Lundvall A BALTIMORE GAS & ELECTRIC CO. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8101050437 | |
| Download: ML19340D833 (3) | |
Text
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e BALTIMORE GAS AND ELECTRIC COMPANY P. O. BOX 1475 B ALTIMORE, M ARYLAN D 21203 December 29, 1980 Antwva E. LUNOVALL,d R.
v.cc mess.oce s o.o Mr. D. G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Vashington, D. C.
20555
Subject:
Calvert Cliffs Nuclear Power Plant Units Nos.1 & 2, Dockets Nos. 50-317 & 50-318 Fire Protection Modifications
Dear Mr. Eisenhut:
Your letter of November 2h identified eight open fire protection items and stated the staff's position on requirements for resolution of these items. In response to that letter and to avoid misunderstanding, we offer the following discussion of our approach to resolving the open issues.
In general, the remainder of our fire protection work vill be largely dictated by the results of our Safe Shutdown Study, which is being done in accordance with Anpendix R paragraph III.G and SER Section 3.2.1.
Thouah we do not expect to complete all final design decisions by the submittal date required by Appendix R (" arch 19), the substance of the Safe Shutdown Study and definite design criteria vill be submitted for URC review by the required date.
The Safe Shutdown Study vill result in specific criteria for the following:
3.1.20 Unnrotected Doorways - The designation of fire areas will be refined and locations where fire doors are required vill be finalized based on safe shutdown criteria. The list of specific doorways to be protected may, therefore, be slichtly different than previously de-ignated. Doors protecting such areas vill be appropriately rated and vill meet the requirements of Appendix R paragraph III.N.
3.2.2(3) Adecuacy of Detector Installation - Cable chases 1C and 2C, as well as all other areas, vill be evaluated for redundant safe shutdown functions and vill meet applicable requirements of Aupendix R paragraph III.G.
Obviously, if the evaluation i
determines that all safe shutdown functions performed by equip-ment in that room can be performed by equipment in other rooms, the requirements of Appendix R paragraph III.G do not apply, since no redundant safe shutdown functions would be jeopardized.
l 1
ht I
l 01 M E 81
Mr. D. G. Eisenhut Page 2 December 29, 1980 3.2.h Ventilation Duet Penetrations - As in the discussion above on 31.20, fire dampers in barriers separating fire areas vill be rated consistent with requirements for the barriers, and will be installed per the conditions of the testing laboratory.
The remainder of the items in your letter do not directly relate to the Safe Shutdovr Study. Comments on these are as follows:
3.1.1.9 Fire Detection in Safety Felsted Areas - We are beginning expansion of the detection system to meet Appendix R paragraph III.F.
3.1.21 Manual Hose Coverage - We are extending the hose system outside containment to include additional coverage.
In one instance, coverage of a room vill be provided by host stream from the elevation below through floor grating.
3.2.5 Drain system Baekflow Protection - We are planning to install check valves or suitable alternate backflow protection in diesel generator room floor drains.
3.3.7 Quality Assurance Program - Our QA program for fire protection is governed by Quality Assurance Procedure (QAP) 9, which was discussed and compared to the requirements of Section C of the BTP Appendix in our letters of March 22, 1979, and December 31, 1979 This CAP is under the management control of the QA Department and is coordinated through (and therefore acceptable to) the departments responsible for fire protection.
It specifies requirements for review, surveillance and audits, and is part of the overall plant QA program. We vould appreciate being informed of specific unacceptable aspects of our program so that perceived shortcomings can be addressed.
Our interpretation of schedule requirements for these open items is shown in the attachment. We currently believe all of these are attain-able with the exception of mechanical changes to plant systems required to meet certain specific aspects of the Safe Shutdown Study. These may be limited by delivery of mechanical equipment, such as valves. In addition, the NRC review schedule and any substantiative changes resulting from that reviev vill obviously impact our ability to co=plete the modifications on time.
Concerning co=oletion of our fire protection modifications currently underway, we are prcgressing satisfactorily and plan to be compl?te at least by the extended implementation date of February 19, 1981.
Very truly yours, 11; p.
,/,
Vice President-Supply ec:
J. A. Biddison, Esquire G. F. Trewbridge, Esquire Mr. E. L. Conner, Jr.
Attachment to A. E. Lundvall Letter or Schedule Requirements for Open Fire Protection Items 50.h8 REQUIRED SER ITFN DESCRIPTION PARAGRAFli COffPLETION DATE 3.1.19 Detection (c) (2) 11/19/81 (partial)
(c) (3) 1982 refueling outages (partial) 3.1.20 Doorways (c) (2) 11/19/81 (partial)
(e) (3) 1982 refueling outages (partial) 3.1.21 Hose Coverage (c) (2) 11/19/81 3.2.1 Alt SD Description (c) (5) 3/19/81 Alt SD Installation (c) (4)
Outage 6 or 30 months arter NRC approval 3.2.2(3)
Chase Detection (c) (h) 6 months arter approval, or outage 6 months arter approval 3.2.h Duct Penetrations (c) (2) 11/19/81 (partial)
(c) (3) 1982 refueling outages (partial) 3.2.5 Drain Backflev (c) (2) 11/19/81 3.3.7 QA (c) (1) 3/19/81 5 9 a
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