ML20039B697
| ML20039B697 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 12/18/1981 |
| From: | Sargent C COMMONWEALTH EDISON CO. |
| To: | Schwencer A Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8112230434 | |
| Download: ML20039B697 (5) | |
Text
.
Commonwealth Edison
] )7 Address Reply to: Post Office Box 767 one First _Nationa Plaza, Ch ctgo, lltinc,tsi
'/
j-Chicago. Illinois 60690 l
December 18, 1981 1
Mr. A. Schwencer, Chief Licensing Branch #2 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Subject:
LaSalle County Station Units 1 and 2 Fire Protection Program l
NRC Docket Nos. 50-373 and 50-374 i
References (a):
L. O. De1 George letter to A.
1 Schwencer dated November 3, 1981.
l (b):
Draft - Fire Protection Supplemental Safety Evaluation Report - no date.
Dear Mr. Schwencer:
i j
The purpose of this letter is to update our position regarding deviations from 10 CFR 50, Appendix R (Reference (a))
based upon our review of Reference (b) and recent telephone a
i conversations with members of your staff.
The revised positions are j
aodressed in the same order as in Reference (a) and (b).
i i
1.
Appendix R,Section III.E - Hydrostatic Hose Tests LaSalle County Station will test interior standpipe hose at intervals according to 1981, NFPA 1962 (1979) volume 12.
This represents no change from our position in Reference j
(a) and was found to be an equivalent level o f protection as contained in Appendix R in your review of our position (Reference (b)).
a 2.
Appendix R,Section III.F - Automatic Fire Protection In our previous submittal Reference (a), we requested
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deviction from the requirements of Appendix R in the
}
following areas:
2C/3C, 2K/3K, 4A, 48, 4C3, SCll, 584 and 1
6E.
In the draft SER, Reference (b), fire areas 4A, 48,
}
and SCll were found to.have no deviaton from Appendix R requirements'because they contained fire detection systems previously approved by the staff.
The requested deviation was granted for area 2K/3K because there are essentially no 8112230434 811' 18" l
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A. Schwencer December 18, 1981 combustibles in the. area.
A deviation was also granted for area.584 because there is not safety-related equipment in the area.
You did not accept our request for deviation in areas 2C/3C, 4C3 and 6E.
Commonwealth Edison will provide fire detection systems for these areas ^in'accordance with the requirements of Appendix R.
This will be completed prior to startup following the first refueling outage as discussed in our telephone conce.sation of November 17, 1981.
3.
Appendix R, Section.III.G - Safe Shutdown Based upon the contents of the LaSalle FSAR Section H.4 and the discussion presented in' Reference (a), no devia-tions from the requirements of Appendix R were identified in your review.
Therefore, no further action is required in this area.
4.
Appendix R,Section III.H - Air Packs The previous submittal, Reference (a), indicated LaSalle County Station requested deviation from Appendix 'R with regard to the number of air packs and backup supply.
LaSalle County Station will meet the requirements of Appendix R; Ten (10) self contained breathing apparatus-available for use by the fire brigade with a six (6) hour supply of reserve air.
The additional equipment necessary to meet this requirement will be in place as soon as vendor delivery allows.
It is expected within six months of fuel load.
5.
Appendix R,Section III.I - Fire Brigade Training Our letter in Reference (a) identified five areas which were thought to deviate from Appendix R.
Based upon our discussions with your staff, the following resolutions were found mutually agreeable.
Specific identification of each individual's assigned a.
responsibility - paragraph 1.a(1).
This requirement l
will be addressed in the LaSalle County Station-training program.
4 b.
Regularly planned meetings --paragraph 1.d - LaSalle County Station will comply with this requirement.
See i
comments in Item d. below.
A. Schwencer December 18,-1981 1
c.
Refresher training sessions - paragraph 1.e - LaSalle County Station will comply with this requirement.
d.
Practice - paragraph 2 - LaSalle County Station will comply with this requirement with the understanding that the phrase "each Shif t Fire brigade", as described in the LaSalle training procedure is acceptable.
Additionally, a program for how to "make-up" training for fire brigade members who miss the regularly scheduled training sessions will be included in the Station training procedures.
e.
Drills - pa agraph 3.b.
The same comments apply as in j
(d) above.
6.
Appendix R,Section III.K - Administrative Controls i
Several items in paragraph III.K.12 were identified as
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not being specifically addressed in each of the fire fighting strategies as required.
Following discussions j~
with your staff, it was determined that LaSalle complied with the requirements but not necessarily in the fire plans themselves.
This was determined acceptable provided the fire protection procedure identified where each of the strategies is implemented.
This will be completed prior to l
fuel load on Unit 1.
I 7.
Appendix R,Section III.N - Fire Doors The requirements of the LaSalle County Station Technical Specifications will be complied with.
It is our understan-ding that this specification is consistant with Appendix R requirements.
It is judged that this position accurately reflects the i
agreements made during our telephone conversations with your Messrs. G. Harrison, R. Ferguson, A.
Bournia and J.
Grobe (Region III).
It is also our understanding that with the implementation of these commitments made in response to your concerns that LaSalle County Station is in compliance with Appendix R or has been found to provide an equivalent level of fire protection safety.
In this regard, we request you to document your concurrence in the SER, Inspection Report or equivalent document to preclude future enforcement problems.
-.-,--,_.---.r-.
A. Schwencer Decembe r 18, 1981 As a matter of information, the updated schedule for the installation and Testing of fire stops for non-segregated phase bus duct penetrations is provided in Enclosure 1.
If there are any questions regarding this matter, please contact this of fice.
Very truly yours, c eL ~Y y
C. E. Sa rgent Nuclear Licensing Administrator Enclosure cc:
NRC Resident Inspector - LSCS 1
I 1
3075N
J',
1 ENCLOSURE 1 Action Week of 1.
Tech Sil submits proposal 9/28/81*
2.
CECO issues order (CCA) 10/12/81*
3.
a)
Tech-Sil submits fire stop a) 11/16/81*
design and (b) fire test b) 12/14/81 procedure and approval 4.
CECO /S&L reviews and approves a) 12/07/81*
the (a) design and (b) test b) 12/28/81 procedure.
5.
CECO furnishes sections of bus 9/21/81*
duct to Tech-Sil for the test 6.
Tech-Sil installs fire steps &
1/04/82 starts test 7.
Tech-Sil completes tests 2/15/82 8.
Tech-Sil submits report 3/01/82
- Actual dates 3075N