ML20054K316
| ML20054K316 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 06/25/1982 |
| From: | Crutchfield D Office of Nuclear Reactor Regulation |
| To: | Counsil W NORTHEAST NUCLEAR ENERGY CO. |
| References | |
| LSO5-82-06-102, LSO5-82-6-102, NUDOCS 8207010420 | |
| Download: ML20054K316 (4) | |
Text
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Distribution 2
Docket File NRC PDR June 25, 1982 Local PDR 4
ORB Reading NSIC D. Crutchfield Docket No. 50-245 H. Smith LS05-82-06-102 J. Shea OELD Mr. W. G. Counsil OI&E Nuclear Engineering and Operations ACRS(10)
Northeast Nuclear Energy Company AWPB Post Office Box 270 Hartford, Connecticut 06101
Dear Mr. Counsil:
1
SUBJECT:
MILLSTONE STATION UNIT 1 - FIRE PROTECTION RULE By letter dated March 1, 1982, you submitted plans and schedules intended to demonstrate that by a combination of compliance with and exemptions from the specifice provisions of Section III.G of appendix R to 10 CFR Part 5, the objective of assuring safe shutdown capability in the event of a fire is met.
!I Our concerns about the Millstone submittal are of such a significant nature that the exemption request may be denied if further clarifi-cations cannot be provided within a reasonable time.
Enclosed is a delineation of our concerns.
Original signed by Dennis M. Crutchfield, Chief Operating Reactors Branch #5 Division of Licensing
Enclosure:
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Mr. W. G. Counsil June 25, 1982
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cc William H. Cuddy, Esquire State of Connecticut Day, Berry & Howard Office of Policy & Management Counselors at Law ATTN:
Under Secretary Energy One Constitution Plaza Divjsion Hartford, Connecticut 06103 80 Washington Street Hartford, Connecticut 06115 Ronal d' C. Haynes, Regional Administrator Nuclear. Regulatory Commission Region 1 Office 631 Park Avenue King of Prussia, Pennsylvania 19406 Northeast Nuclear Energy Company ATTN:
Superintendent Millstone Plant P. O. Box 128 Waterford, Connecticut 06385 Mr. Richard T. Laudenat Manager, Generation Facilities Licensing Northeast Utilities Service Company P. O. Box 270 Hartford, Connecticut 06101 Resident Inspector c/o U. S. NRC P. O. Box Drawer KK Niantic, Connecticut 06357 First-Selectman of the Town of Waterford Hall of Records 200 Boston Post Road Waterford, Connecticut 06385 John F. Opeka Systems Superintendent Northeast Utilities Service Company P. O. Box 270 Hartford, Connecticut 06101' O. S. Environmental Protection Agency Region I Office ATTN:
Regional Radiation Representative JFK Federal Building Boston, Mass'achusetts 02203
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Enclosure Chemical Engineering Branch Fire Protection Section Exemption Request Millstone 1 Nuclear Power Station Docket No. 50-245 By letter dated March 1, 1982, the licensee submitted plang and schedules inteaded to demonstrate that by a combination of compliance with.and exemptions from the specific provisions of Section III.G of Appendix R to 10 CFR Part 50, she objective of assuring safe shutdown capability in the event of a fire is met.
In meeting with the licensee.on May 13, 1982, we expressed our concerns about the incompletness of the submittal. The following is a delineation of our concerns..
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Fire ZonesSection III.G of Appendix R identifies acceptable methods-to provide fire protection for shutdown systems, when redundant trains are located "within the same fire area."
A fire area is generally bounded by construction having a fire resistance of at least.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> or by equivalent protection such as a justified fire barrier of less fire resistance or a water curtain. Fire hazards analyses conducted prior to Appendix R to satisfy NRC Supplementary guidance for fire protec-tion program evaluation (September 1976), evaluated plant-conditions from the perspective of both fire areas and fire zones (locations within a fire area that are not bounded by fire barriers). However,Section III.G of Appendix R only permits the evaluation of fire pro-tection for safe shutdown capability on the basis df fire areas.
The licensee has relied upon a concept of fire zones to assess compli-ance with Appendix R.
The approach may have resulted in incorrect conclusions with regard to the adequacy of separation of redundant-trains. To assure compliance with Section III.G, the licensee is required to comprehensively reassess the fire protection in each fire area containing redundant shutdown systems.
2.
Area Fire Detectors and Fire Suppression System i
Information contained in our Safety Evaluation Report, dated September 26, 1978, and in the licensee's submittal, indicates that the licensee's interpretation of the requirements of Section III.G pertaining to the need for area fire detectors and fire suppression systems is not correct. As a result, the licensee's conclusions with regard to compliance Appendix R are in error.
Specifically, in select areas of the plant, the extent of fire detection and fire suppression, consists of partial (spot) coverage, intended to provide protection from specific, isolated hazards. This protec-tion, is not sufficient to comply withithe requirements of Section III.G which requires that fire detectors and a fixed-fire suppression system be installed throughout the fire area. However, this partial coverage may provide adequate fire protection in some instances.
Such cdnfigurations could be the subject of exemption _ requests.
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. 3. Requested Exemption The licensee's submittal is not specific as to what requirement is not being met and what alternative is proposed. It states, for example, that an individual area "does not comply with Section III G.2 of Appendix R", but does not directly identify the nature of the noncompliance.
The information supplied (highlighted drawings and text) regarding divisional sep' ara' tion is insufficient to identify the degree of separation between redundant trains or the con, sequences of a fire on safe shutdown capability.
- 4. Proposed Modifications Thelicenseehasnotadeku'~tely"describedalternativesthatare
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a proposed to be implemented in co.njunction with the_,exemptiops to,
permit our evaluation. For instance, the licensee has not de-scribed the design of:
a.
The one hour fire rated barrier that is to be used to enclose select cables.
b.
The fire suppression system that is proposed to be installed in the cable vault (T416).
- 5. Open SER Item The licensee contends that the submittal resolves all outstanding SER open items. However, as of January. 28, 1982,. SER item 3.1.~14, Auxiliary Boiler Blast Wall, has not been adequately addressed
- 6. Conclusion Based on our initial review, we conclude that the exemption requests should be denied if further clarification cannot be provided.j the licensee within a reasonable time.
In addition, the licensee should address our position regarding SER item 3.1.14 Auxillary Boiler Blast Wall as stated in our SER dated Sept. 30, 1980 l
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