ML19341C870
| ML19341C870 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 11/24/1980 |
| From: | Eisenhut D Office of Nuclear Reactor Regulation |
| To: | COMMONWEALTH EDISON CO. |
| References | |
| LSO5-80-11032, NUDOCS 8103040336 | |
| Download: ML19341C870 (7) | |
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5 UNITED STATES
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'i NUCLEAR REGULATORY COMMISSION usmNorom. o c. osss November 24, 1990
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TO ALL POWER REACTOR LICENSEES WITH PLANTS S
LICENSED PRIOR TO JANUARY 1,1979 g
N The Comist inn published on November 19,1980 (45 FR 76602), a revised Section 10 CFR 50.48 and a new Aapendix R to 10 CFR 50 regarding fire protection features of nuclear power plants.
The revised Section 50.48 and Appendix R will become effective February 17, 1981, which is 90 days after publication. A ccpy of the Feceral Register Notice is enclosed (Enclosure 1).
The provisiens of Appendix R that are apolicable to the fire protection features of your f acility can be civided into two categories. The first category consists of those provisions of the Appendix that are required to be backfit in their entirety by the new rule, regardless of whether or not alternatives to the specific requirements of these Sections have been previously approved by the NRC staff. These requirements are set forth in Sections III.G, Fire Protection of Safe Shutdown Capability; III-J, Emergency Lighting; and III-0, Oil Collection Systems for Reactor Coolant Pump. The fire protection features of your facility must satisfy the specific requirements of these three Sections by the dates establishe by Paragraph 50.48(c), unless an exemption from the Appendix R requir ants is approved by the Comission. You should note the provisions for tolling the time for comoleting the modifications required by these three Sections of Appendix R set forth in Paragraph 50.48(c)(6).
The second categcry of Appendix R provisions applicable to the fire protection features of your f acility consists of requirements concerning the "open" items of previous NRC staff fire protection reviews of your facility. An open item is defined as a fire protection feature that has not been previously approved by the NRC staff as satisfying the provisions of Appendix A to Branch Technical Position BTP PCSB 9.5-1, as reflected in a staff fire protection safety evaluation report. The fire protection features of your facility that are in this category must satisfy the srnific requirements of Accendix R oy :ne dates established by Paragraph 50.48(c), unless an exe::p-tion from the A:pendix R requirements on those features is approved by the Ccani s sion. is a summary listing of the caen items concerning the fire protection features of your f acility based on a review of our records. Also included is our cost:icn on the scecific recuirements that mst te satisfied i
in order to resolve these 0;en items.
!f you have any questions or disagree-l ments witn this enclosure, clease aovise us within 30 days of your receipt of nis lettar.
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. Witn regard to the fire protection mocifications that nave seen previcusly approved by the NRC staff, Paragraoh 50.48(c) s::ecifies a new senedule for their cc:mletion.
This paragraph, when it ::ecomes effective, will supersede the currently affective section of the regulations that temcorarily suspencs cormletion dates for previously approved fire protection modifications tnat are given in f acility license conditions (45 FR 715o9, October 29,1980).
The Comission excects that all such modifications will be comoleted in accordance with this new schedule, unless an extension has been requested and granted by the Director of the Office of Nuclear Reactor Regulation
[see Paragraoh 50.48(d)], or an exemotion nas been reouested and granted by the Comission oursuant to Section 50.12 of the Comission's regulations.
If you have previously requested extensions of cates for comoletion of
- nodifications that are required by license conditions for your facility wnicn were not accrosed, and you have determined tnat these extensions are still necessary and justifiable, it will be necessary for you to reapply for any such extensions in accordance with the provisiens of Paragrapn 50.48(d).
All requests for Comission action resulting from tnis rule are subject to the schedule of fees s]ecified in 10 CFR 170.21.
If you have any questions concerning the subject matters of this letter, please contact 3
the NRC Project Manager for your facility.
Sincerely,
'Omuacmcw
[ Division of Licensing Oarrell G. Eisenhut, Director Office of Nuclear Reactor Regulation
Enclosures:
1.
Notice - Fire Dectaccion Rule 2.
Sumary of Staff Recuire-ments to Resolve Ocen Items cc w/ enclosures:
See next page
Mr. J. S. Abel November 24, 1980 cc w/ enclosures:
Isham, Lincoln & Beale Director, Criteria and Standads Counselors at Law Division One First National Plat a, 42nd Floor Office of Radiation Programs Chicago, Illinois 60603 (ANR-460)
U. S. Environmental Protection Mr. B. B. Stephenson Agency Plant Superintendent Washingtc,, D.C.
20460 Dresden Nuclear Power Station Rural Route #1 U. S. Environmental Protection Morris, Illinois 60450 Agency Federal Activities Branch U. S. Nuclear Regulatory Commission Region V Office Resident Inspectors Office ATTN: EIS COORDINATOR Dresden Station 230 South Dearcorn Street RR #1 Chicago, Illinois 60604 4
Morris, Illinois 60450 Resident Inspector Susan N. Sexuler Dresden Nuclear Pcwer Station Assistant Attorney General c.o V. S. NRC Environmental Control Division Rural Route il 188 W. Randolph Street Morris, Illinois 60450 Suite 2315 Chicago, Illinois 60601 Morris Public Library 604 Liberty Street Morris, Illinois 60451 Chai rman Board of Supervisors of Grundy County Grundy County Courthouse Morris, Illinois 60450 Department of Public Health ATTN: Chief, Division of Nuclear Safety 535 West Jefferson Springfield, Illinois 62761
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l TO ALL F3WER REACTOR LICENSEES WITH PLANTS LICENSED PRIOR TO JANUARY l,1979 The Fperal Register Notice enclosed with my letter dated November 24, 1980 has a typographical error in the effective date. The effective date should be February 17, 1981. A correction will be published in the Federal Recister in the near future.
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Darrell G. Eisenhut. Director D
Oivision of Licansing go D
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ENCLOSURE 2
SUMMARY
OF STAFF REQUIREMENTS TO RESOLVE OPEN ITEMS Dresden 1 50-010 3.1.3 Fire Water Pumo In the SER, it was our concern that the existing fire pump was not sufficient to meet the largest site fire water demand.
By letter dated December 4,1979, the licensee provided design details for the new diesel driven fire pump to replace the existing pump. The licensee verbally proposed to provide a 10-inch discharge pipe and provide a two inch bypass valve around the normally closed motor operated valves that control the flow of water from the Unit 2 and 3 screen wash pumos and the fire water system.
The licensee has not documented that the above proposed t anges have been impl emen ted.
To meet NFPA 20 the licensee should document that a 10-inch discharge pipe for the 2500 gpm pump has been provided. In addition, to maintain supervisory pressure in the fire loop, the licensee should provite a 2-inch bypass line around the normally closed motor operated valves that control the flow of water from the Unit 2 and 3 screen wash sumps and the fire water system.
3.1.5 Water Suoeression Systems In the SER, it was our concern that the licensee's fire suopression systems for the cable penetration area and tre cable tunnel may not be adequate.
By letters dated December 4,1973 and April 8,1980, the licensee provided additicnal design details regarding the sprinkler systems installed in these areas. By our letter dated July 9, 1980, we informed the licensee that the following modifications should be made:
1 The feed to the preaction system for the cable penetration area should be an independent feed.
2.
Low air suoervision should be provided on the closed head spray piping of the automatic preaction deluge systems in the cable tunnels.
To meet the guidelines of Section E.3.(a) of Apoendix A to STP APCSB 9.5-1, the licensee shou.
'a required to provice an independent feed for the preaction system in the cable netration area. Addit.*onally, to meet the recocmendations of NFPA 13, the licensee should provide low air supervision an the closed head portion of the lutomatic preaction deluge systems in tne cable tunnels.
3.2.1 Smoke Detection System Tests In the SER, it was our concern that the smoke detectors might not' respond to the products of combustion for the combustibles in the areas where smoke detectors are installed. We were also concerned that ventilation air flow patterns in the area might reduce or prevent detector response and we recom-mended that the licensee conduct bench testing of smoke detectors and an in-situ test. The licensee has not responded with information regarding this item for our evaluation.
To meet accepted fire protection engineering practices, the licensee should verify that the fire detection systems meet aporopriate NFPA codes and are designed by experienced personnel. Also, the licensee should conduct bench testing or verify that the bench testing of smoke detectors was done by the manu fa cturer. The required methodology for an in-situ smoke detector test is beyond the current state-of-the-art and, therefore, cannot be performed at this time.
3.2.2 Technical Saecifications For Existine Fire protection Systems and Mose stacions In the Fire protection Safety Evaluation Report it was our concern that hose stations and automatic systems were not incorporated into the plant Technical Specifications for safety-related areas. The licensee has not provided a list of hose stations and automatic systems which should be part of the Technical Speci fica tions.
The licensee has not provided any additional information for us to complete our review.
Based on our review, we conclude that, the licensee should include hose stations and automatic systems in the plant's Technical Specifications for safety-related areas.
3.2.4 Excosed Structural Steel In the SER, it was our concern that the exposed structural steel in thr; north auxiliary bay above the large concentration of cables may not be provided with adecuate fire protection.
By letter datad August 2,1979, the licensee provided information on the nortn auxiliary bay stating the combustible content, indicating that the diet:1 fuel and lubricants were being removed, and concluding that since the fuel loading was low and sprinklers were to be provided, no structural protection was necessary.
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, Although the transient combustibles will be removed from the area to minimize the amount of combustibles in the area, there continues to exist a need for changeout of the lube oil for the reactor feedwater pumps. This could mean that the area sees as much as 120 gallons of oil during the changeout process. The reactor feed pump area is not separated from the north auxiliary bay (wire glass double doors which are normally open separate the two areas) by by fire rated barriers.
To meet Section III, Paragraph G.2(a) of Appendix R to 10 CFR Part 50, the licensee should protect the structural steel forming a part of or supporting fire barriers to provide a 3-hour f. ire resistance.
3.2.5 Emergency Condenser Valves We require the emergency condenser return valves shall be placed on independent power sources and their co' trol and power cables physically separated from each other.
3.2.6 Emergency Condenser Makeuo We require that the licensee provide additional means to permit makeup to the emergency condenser independent of the existing makeup valve.
3.2.7 Emergency Condenser Level Indication We require that redundant level indication for makeup control be provided for the emergency condenser which is physically separated by separate fire areas or an additional means be provided to indicate level which is independent of fire damage to the existing level indication.
Fire Hazards Analysis In the SER, it was our concern that the licensee had not provided an analysis for each fire area containing safety related cable raceways or components to verify that the protection provided is adequate to prevent simultaneous damage to redundant safety systems from a possible exposure fire.
By letter dated March 20, 1979, the licensee claimed that the plant was reviewed to detemine where fires within single fire areas could jeopardi:e the ability to safely shut down the plant, but did not provide adequate information for our evaluation, and therefore, found the licensee's fire hazard analysis was not complete.
The licensee has not demonstrated that adequate protection features have been provided for cables and equipment of redundant systems important to achieving safe shutdown conditions to ensure that at least one seans o f achieving such conditions survives postulated fires.
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To meet our fire protection guidelines, alternate shutdown capability should be provided when safe shutd:wn cannet be ensured by barriers and detection and suppression systems because of the exposure of redundant safe shutdown equipment, cabling, or components in a single fire area, to an exposure fire, or fire suppression activities, or rupture or inadequate operation of fire suppression systems.
l To meet Section III, Paragraoh G of the Appendix R to 10 CFR Part 50, i
the licensee should provide an alternate shutdown capability independent of those areas. The alternate shutdown system should meet the requirements of Section III, Paragraph L of Aopendix R to 10 CFR Part 50.
In our letter dated July 9, 1C0, we indicated that Items 3.2.5 and 3.2.6 and 3.2.7 would be resolved within the Systematic Evaluation f rogram.
You will note that 50.48.C(4) specifies the new required completion date and 50.48.C(5) requires you to submit your design description of the modifications needed to provide alternative or dedicated shutdown capability eithin 30 days after the effective date of the rule.
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