ML19351F406
| ML19351F406 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 11/24/1980 |
| From: | Eisenhut D Office of Nuclear Reactor Regulation |
| To: | COMMONWEALTH EDISON CO. |
| Shared Package | |
| ML111960120 | List: |
| References | |
| NUDOCS 8101120535 | |
| Download: ML19351F406 (6) | |
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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50-295/304
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TO ALL POWER REACTOR LICENSEES WITH PLANTS 9
LICENSED PRIOR TO JANUARY 1, 1979 The Commission published on November 19,1980 (45 FR 76602), a revised Section 10 CFR 50.48 and a new Appendix R to 10 CFR 50 regarding fire pr:tection 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 copy of the Federal Register Notice is enclosed (Enclosure 1).
The provisions of Appendix R that are applicable to the fire protection features of your facility can be divided 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 net 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 Thutdown Capability; III-J, Emergency Lighting; and III-0, Oil Collectit.. systems for Reactor Coolant Pu J.
The fire protection features of your facility must satisfy the specific requirements of these three Sections by the dates established by Paragraph 50.48(c), unless an exemption from the Appendix R requirements is approved by the Commission. You should note the provisions for tolling the time for conpleting the modifications required by these three Sections of Appendix R set forth in Paragraph 50.48(c)(6).
The second category of Appendix R provisions applicable to the fire protection features of your facility 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
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aporoved by the NRC staff as satisfying the provisions of Appendix A to
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Branch Technical Position BTP PCSB 9.5-1, as reflected in a staff fire protection sdety evaluation report. The fire protection features of your facility that are in this category must satisfy tne specific requirements of i'
Appendix R by the dates established by Paragraph 50.48(c), unless an exemp-tion from the Appendix R requirements on those features is approved by the Comission. is a summary listing of the, open items concerning the fire protection features of your facility based on a review of our records. Also included is our position on the specific requirements that nust be satisfied in order to resolve these open items.
If you have any questions or disagree-cer.ts with this enclosure, please advise us within 30 days of your receipt of l
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. Witn regarc to the fire protection modifications that have Deen previously approved by the NRC staff, Paragraph 50.48(d) s::ecifies a new schedule for their cc:=letion.
This paragraph, when it becomes effective, will supersede the currently affective section of the regulations that temporarily suspends co::aletion dates for previously approved fire protection mocifications that are given in f acility license conditions (45 FR 71569, October 29,1980).
The Comission expects that all such modifications will be cocoleted 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 Paragraph 50.48(d)], or an exemotion has been requested and granted by the Co:miission pursuant to Section 50.12 of the Comission's regulations.
If you' have previously requested extensions of dates for completion of modifications that are required by license conditions for your facility which were not aporoved, and you have determined that these extensions are still necessary and justifiable, it will be necessary for you to reapply for any such extensions in accordance with the provisions of Paragraph 50.48(d).
All requests for Comission action resulting from this rule are subject to the schedule of fees specified in 10 CFR 170.21.
If you have any questions concerning the subject matters of this letter, please contact the NRC Project Manager for your facility.
Sincerely, u.3W Q<L -
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Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation
Enclosures:
1.
Notice - Fire Protection Rule 2.
Sur.:ary of Staff Require-ments to Resolve Open Items cc w/ enclosures:
See next page
SUMMARY
OF STAFF REQUIREMENTS TO RESOLVE OPEN ITEMS ZION UNITS 1 AND 2 50-295 AND 50-304 3.2.4 Physical Separation Tests 3.2.5 Control Room Analysis 3.2.6 Containment Penetration Vault Analysis 3.2.7 Auxiliary Electrical Equipment Room In the Fire Protection Safety Evaluation Report, it was our concern that the physical separation of electrical cable trays is not adequate to pre-vent fire damage to redundant safety related systems due to electrical cable insulation fires or exposure fires.
By letter dated September 8,1978, the licensee claimed that the results of the Sandia Laboratories tests demonstrated the effectiveness of the cable separation.
The licensee's arguments center on the results of testes performed on solid bottom cable trays with IEEE and non IEEE-383 qualified cables; and with covered and ventilated trays. The licensee refers to the fact that IEEE-383 qualified cable when subjected to an external fire source did not catch fire, and that solid bottom trays provide an effective fire barrier. We do not agree with the licensee, because:
a.
The cable configurations Sandia tested were different from the physical separation conditions existing at Zion Station, b.
The cable concentrations and geometries of the cables were different from those at Zion Stations; c.
There are a number of areas at Zion Station where tray covers are not l
installed, and d.
There is no assurance that expsoure fires would not cause the loss of redundant safe shutdown related cables conduct or equipment.
We requested that the licensee to provide an alternate shutdown capability independent of the following areas:
1.
cable spreading room 2.
containment penetration vaults 3.
auxiliary electrical equipment room 4.
auxiliary building elevations 642, 617, 592, 579, 560, and 542 p
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reactor containment l
6.
crib house l
7.
contml room I
l 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 means of achieving such conditions survives postulated fires.
1 To meet our fire protection guidelines, alternate shutdown capability should be provided when safe shutdown cannot be ensured by barriers and detection and suppression systems because of the exposure of redundant safe shut-down 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.
To meet Section III, Paragraph G of Appendix R to 10 CFR Part 50, the licensee has proposed an alternate shutdown capability. This alternate capability is contained in the April 30,1980, May 28,1980 and September 30, 1980 letters with the exception of items 8(c) and 8(e) of Enclosure 5 to the March 24, 1980 NRC letter to the licensee. These items are to be addressed by the licensee and are restated here as follows:
(c) Demonstrate that changes to safety systems will not degrade safety systems (e.g., new isolation switches and control switches should meet desiga criteria and standards in FSAR for electrical equipment in the system that the switch is to te installed; cabinets that the switches are to be mounted in should also meet the same criteria (FSAR) as other safety related cabinets and panels; to avoid inadvertent isolation from the control room, the isolation switches should be keylocked, or alarmed in the control room if in the " local" or " isolated" position; periodic checks should be made to verify switch is in the proper position for normal operation; and a single transfer switch or other new device should not be a source for a i
single failure to cause loss of redundant safety systems).
(e)
Demcnstrate that alternate shutdown power sources, including all breakers, have isolation devices on control circuits that are routed through the area to be avoided, even if the breaker is to be operated manually.
The alternate shutdown systems are under staff review against the requirements of Section III, Paragraph L of Appendix R to 10 CFR Part 50.
ADMINISTRATIVE CONTROLS, SECTION 6.0 In our evaluation dated March 24, 1980, we informed the licensee that their ad.ninistrative controls did not meet our guidelines regarding:
(1) fire protection organization (2) fire brigade physical examination (3) control of combustibles (4) control of ignition sources (5) prefire plans
By letter dated April 30, 1980, the licensee provided additional infor-mation in regard to our concerns about the fire protection organization, the licensee identified the offsite management position responsible for developing the fire protection program and verified that fire protection audits will be performed at 3-year intervals by independent qualified individuals.
In regard to our concerns reoarding the fire brigade physical examination, the licensee verified that each member of the fire brigade is screened annually by the site Health Evaluation Program or by letter from his personal physican. Further, the licensee commited to meet our positions regarding the control of combustibles.
Based on our review, we conclude the licensee's modifications regarding their fire protection organization and fire brigade physicals adequately address our concerns and, therefore, are acceptable. The licensee's response to centrol of combustibles implements paragraphs 1 through 8 of Section III(K) of Appendix R and, therefore, is acceptable.
In response to our position regarding control of ignition sources, the licensee proposed to implement a requirement for fire blankets on any flamable compon-ents within a 35-foot radius of any welding operation. The licensee has substituted the term "flamable" for " combustible". These terms do not have the same meaning and, therefore, are not interchangeable. To meet our guidelines, the licensee should impicment a control so that where welding, grinding, open flame work and cutting is being performed, all immovable ccmbustible material below and'within a 35-foot radius will be protected by asbestos curtains, metal curtains, or flame proof covers.
In response to our position on prefire strategies, the licensee took excep-tion to the following:
Potential radiological and toxic hazards in fire zones; and ventilation system operation that ensures desired plant air distribution when the ventilation flow is modified for fire containment or smoke clearing.
To meet Paragraphs 12(g) and 13(h) of Appendix R, the licensee should modify their prefire strategies to include these items.
In addition, to meet Paragraphs 9,10,11 of Section III(K) of Appendix R, the licensee should modify their administrative controls to establish procedures to:
Control actions to be taken by an individual discovering a fire, such as notification of control room, attempt to extinguish fire, and actuation of local fire suppression systems;
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- Control actions to be taken by the control room operator to determine the need for brigade assistance upon report of a fire or receipt of alarm on control room annunciator panel, such as announcing location of fire over PA system, sounding fire alarms, and notifying the shift supervisor and the fire brigade leader of the type, size and location of the fire; and Control actions to be taken by the fire brigade after notification by the control room operator of a fire, such as assembling in a designated location, receiving direc-tions from the fire brigade leader, and, discharging specific fire fighting responsibilities including selection and transportation of fire fighting equipment to fire location, selection of protective equipment, use of fire suppression systems operating instructions, and use of preplanned strategies for fighting fires in specific areas.
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