ML19351A634
| ML19351A634 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 12/07/1989 |
| From: | Zwolinski J Office of Nuclear Reactor Regulation |
| To: | Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| TAC-66104, TAC-66105, NUDOCS 8912200080 | |
| Download: ML19351A634 (4) | |
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December 7, 1989 Docirt Nos. 50-373 and 50-374 MEMORANDllM FOR: Hubert J. Miller, Director Division of Reactor Safety Region 111 FROM:
John A. Zwolinski Assistant Director for Region 111 Division of Reactor Projects 111, lV, V and Special Projects Office of Nuclear Reactor Regulation SLTJECT:
LASALLE FIRE DETECTION SYSTEti (TAC NOS. 66104 AND C6105, TIA NO. 111 87-7, AITS F03016887)
This $mo is in response to the request f rom ti. J. Chrissotimos to Gary Holahan, subject concerning violations of fire protection requiremtns at LaSalle, dated May 2?, 1987. We have reviewed those portions of the Region 111's inspection Report and Notice of Violation, transmitted to the licensee on February 28, 1986.
We have also reviewed the licensee's response contained in letters dated April 11, 1980 and April 15,1987. We agree with and support the Region Ill's staft liiterpretation of the first L
issue. However, we agree with the licensee on the second. Our technical raticnale in support of our positions is as follows.
The first issue had to do with lack of electrical supervision on locel tire alarm circuits. The licensee's position is that supervision of-these circuits is not required by the 1975 edition of NFPA 720 because the local audible or visual alarm circuits are in the category of " supplementary alarms," and NFPA No. 72D-1975 provides an exception from the requirement for installing electrical supervision for supplemental alarms (% 2441.a). We reject this position on two counts.
1 First, Section E.1.(b) of Appendix A to Branch Technical Position (BTP) APCSD 9.5-1 (August 23,1976) states:
"(b) Fire detection system should give audible and visual alarm and annunciation in the control room. Local audible alarms should also sound at the location of the fire."
This section of the BTP indicates that the staff did not consider the local alarms to be " supplemental" in the sense that they were simply in addition to l
the control room alarm but basically not essential. Specificially, the staff considered the local alarm to be an integral part of the alarm / annunciation system which served to warn regular employees and assist the fire brigade in their response notification.
it seems the licensee understood this requirement CONTACT:
Paul Shemanski, NRR/PD32 OIPl i
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December 7, 1980 since, in certain locations, they also installed visual alarms; a practice usually followed only in locations where the ambiE0t noise levels are sufiiciently high that audit,le alarn,s elone cannot be reliec upon.
Second, Section 2441.8 of NFpA 72D-1975, a paragraph that the licensee quotes to justify their positior., states:
"2441.
The electrical supervision shall include all circuits for operating alarni sounding devices and appliances except:
a.
A circuit employed to produce a supplementary local alarm tignal to it.dicate the operation of an automatically operated alarm transmitter or a manual fire alarm box provided that an op %' H e en or around fault of the sicnal circuit conducoF M suYtson I Es of the s g lement dp[s~jgna % Ep E s*Iid8 W ') ~ ~ '
t Even if tFe staff accepted the licensee's interpretatien of this section of NFPA 720-1975 that the local alarms are " supplementary" alarrs, the staff would not permit those circuits to remain unsupervised since the electrical faults did not result "only in the loss of the supplementary signal." As described in the inspection report, "... local alarms in the Unit I reactor building were giving audible fire alarms simultaneously as a result of a wire to wire short." In addition, "...according to interviews with cognizant licenste personnel, this was a recurrirg event that confused and diministed employees and fire brigade niember confidence in the fire alarm system to the extent that it is difficult to distinguish an actual fire alarm from a false one."
For these two reasons, we reject the licensee's position that installation of electrical supervision of local fire alarm circuits is not required.
The second issue had to do with lack of electrical supervision on the visual alarm annunciator circuits for the Unit I and Unit 2 control room fire detection system. The ionization fire detection circuits at the LaSalle l
County Nuclear Station are electrically supervised from the individual cetectors to a par.el in the Auxiliary Electric Equipment Room (AEER).
In l
order to satisfy the requirements for a central supervised station of NFPA 72D-1975, the location where alarms are received must be continuously l
attended _ The AEER is not continuously attended. Therefore, the alarm l
circuits have been extended from the panel in the AEER to two parels in the control room which is continuously attended. These extended circuits are not electrically supervised. This lack of electrical supervision is not in accordance with the requirements of NFpA 72D-1975. The licensee's position is that this is a deviation only of the standard and that the deviation is acceptable at LaSalle County Nuclear Station. The licensee supports this position by stating that:
high quality cable is used throughout the installation, i
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o Hubert J. Miller
-3 December 7, 1989 modifications and maintenance on these cables / circuits are infrequent resulting in a low probability of removal of, or damage to the circuits, and surveillance of the circuits perf ormed on a once-per-shif t frequency would discover on a sufficiently timely basis any disruption to these circuits.
We find the lack of electrical supervision of these alarm circuits from the cabinets in the AEER to the control room acceptable primarily on the basis of the once-per-shift surveillance of the unsupervised circuits. This surveillance, in conjunction with the use of high quality cable and general absence of modifications or maintenance activities involving the circuits, renders the lack of supervision a minor deviation f rom the requirenents of NFPA 72D-1975. We, therefore, consider the level of protection provided by this arrangement to be essentially equivalent to the level that would be provided if all of these alarm circuits were electrically supervised.
(The licensee also stated that, "To supervise these circuits would be very expensive and result in routing hundreds of additional cables through the AEER, the Cable Spreading Room and the Control Room." While this statement did not weigh heavily in our consideration of this deviation, we question the accuracy of the assertion that hundreds of cables would be involved.)
We, therefore, recommend acceptance of the alarm circuits as installed from the AEER to the control room without electrical supervision.
Should future surveillances discover problems with these circuits, the issue should be reevaluated to assess the continued acceptability of this installation.
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John A. Zwo11nski, Assistant Director for Region 111 Division of Reactor Projects III, IV, V and Special Projects l
Office of Nuclear Reactor Regulation DISTRIBUTION (poetetFileJT PD32 Reading File NRC & Local PDRs JWermiel JKudrick RArchitzel THadani JRichardson l
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Hubert ). Filler 3-Decerter 7,1989 modifications and maintenance on these cables / circuits are infrequent resultino in a low probability cf removal of, or damage to the circuits, and surveillance of the circuits performeo on a once-per-shift frequency would_ discover on a sufficiently timely basis any tiisruption to these circuits.
Wa fir.J the lack of electrical supervision of these alarrr circuits f rora the cabinets-in the AEER to the control room acceptable primarily on the basis of the once-per-shift surveillance of the unsupervised circuits. This surveillance, in conjunctive <ith the use of_high quality cable and gersral absence of modifications or r.cintenance activities involving the circuits, renders the lack of supervision a niinor deviation from t.he requ%ments of NFPA 720-1975. We, therefore, consider the level of protection provioed by this arrangement to be essentially touivalent to the level that would be provided if 511 of these alarm circuits were electrically supervised.
(The licensee also stated that, "To supervise these circuits would be very expensive and rest'lt in routing hundreds of additional cables through the AEER, the Cable Spreading Room and the Control Room." While this statement did not weigh heavily in our consideration of this deviation, we question the accuracy of the assertion that hundreds of cables would be involved.)
We, therefore, ratonsnend acceptance of the alarm circuits as installed from the AEER to the control room without electrical supervisinr:
Should future surveillances discover problems with these circuits, the b ue should be reeveluated to assess the continued acceptability of tt4 installation.
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John A. Zwolinski, Assistant Director for Region 111 Division ot Reactor Projects III, IV, V and Special Projects Office of Nuclear Reactor Regulation 1
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