ML20055A821
| ML20055A821 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 07/02/1982 |
| From: | Clark R Office of Nuclear Reactor Regulation |
| To: | Counsil W NORTHEAST NUCLEAR ENERGY CO. |
| References | |
| NUDOCS 8207200009 | |
| Download: ML20055A821 (4) | |
Text
..--
\\
( *.
3 nas v's-oI6 DISTRIBUTION:
d
'JM. 7N v0bcket File ORB #3 Rdg L PDR NRC PDR Docket No. 50-336 NSIC DEisenhut JHeltemes OELD Mr. W. G. Counsil I&E Nuclear Engineering and Operations ACRS-10 Northeast Nuclear Energy Company RAClark Post Office Box 270 PMKreutzer-3 Hartford, Connecticut 06101 Econner Gray File
Dear Mr. Counsil:
SUBJECT:
MILLSTONE STATION UNIT 2 - 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 specific. provisions of Section III.G of Appendix R to 10 CFR Part 50, the objective of assuring safe shutdown capability in the event of a fire is met.
Our concerns about the Millstone submittal are of such a significant nature that the exemption request may be denied if further clarifica-tions cannot be provided within a reasonable time.
Enclosed is a delineation of our concerns.
Sincerely, Orig'na! *.,~f by Robert A. Clark Robert A. Clark, Chief Operating Reactors Branch #3 Division of Licensing
Enclosure:
As stated cc: See next page 8207200009 820702 PDR ADOCK 05000336 F
.h ORB #3:DL ORB #3:DL ORB o,,,c, b........zei M @,%,g,, ',jg{,'%b
,1 suan*= >
7/.. /.82 7
../.Z../.82 7/.7 /82 oars >
Nec ronu ais oo-ec> Nncu oua OFFICIAL RECORD COPY use.m m_m E
[4 Northeast Nuclear Energy Company cc:
William H. Cuddy, Esquire Mr. John Shedlosky Day, Berry & Howard Resident In_spector/ Millstone Counselors at Law c/o U.S.N.R.C.
One Constitution Plaza P. O. Drawer KK Hartford, Connecticut 06103 Niantic, CT 06357 Mr. Charles Brinkman Regional Administrator Manager - Washington Nuclear Nuclear Regulatory Commission, Region I Operations Office of Executive Director for Operatior C-E Power Systems 631 Park Avenue Combustion Engineering, Inc.
King of Prussia, Pennsylvania 19406 4853 Cordell Aven., Suite A-1 Bethesda, MD 20014 Mr. Lawrence Bettencourt, First Selectman Town of Waterford Hall of Records - 200 Boston Post Road Waterford, Connecticut 06385 Northeast Nuc_ lear Energy Company ATTN: Superintendent Millstone Plant Office of Policy & Management Post Office Box 128 ATTN: Under Secretary Energy Waterford, Connecticut 06385 Division 80 Washington Street Waterford Public Library Hartford, Connecticut 06115 Rope Ferry Road, Route 156 Waterford, Connecticut 06385 U. S. Environmental Protection Agnecy Region I Office ATTN:
Regional Radiation Representative John F. Kennedy Federal Building Boston, Massachusetts 02203 Northeast Utilities Service Company ATTN: Mr. Richard T. Laudenat, Manager Generation Facilities Licensing P. O. Box 270 Hartford, Connecticut 06101
-n
c Enclosure Fire Protection Review Millstone 2 Nuclear Power Station j
Docket No. 50-336 l
By letter dated March 1, 1982, the licensee submitted plans and schedules intended to demonstrate that by a combination of compl9nce with and exemptions from the specific provisions of Section III.b of Appendix R to 10 CFR Part 50, the objective of assuring safe shutdown capability in the event of a fire is met.
i In a meeting with the licensee on May 13, 1982, we expressed our concerns about the incompleteness of the submittal.
The following identifies our concerns:
j 1.
Fire Zones h
Section III G of Appendix R identifies acceptable methods to provide fire protection for shutdown systems, when redundant trains are j
' 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 r.es'istance or ~a water curtain.
Fire hazards analyses conducted prior to Appendix R, to sati'sfy HRC Supplimentary Guidance for Fire Protection Program Evaluation (September 1976), evaluated plant conditions frem 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 protection for safe shutdown capability on the basis of fire areas.
The licensee has relied upon a concept of fire zones to assess compliance with Appendix R.
This approach may have resulted in incorrect conclusions with regard to the adequacy of separation of redundant trains.
To assure ccmpliance 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 1
Information contained in our Safety Evaluation Report, dated September 19, 1978, and in the licensee's submittal, indicates that the licensee's interpretation of the requirements of_S_ectio'n III.G pertaining to the nee:
for area fire detectors and fire suppression systems is not correct.
As a result, the licensee's conclusions with regard to compliance with i
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 specifi.c, isolated hazards.
This protection,.is not sufficient to comply with the 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 adequat.e fire protection in some instances.
Such configurations could be the subject of exemption requests.
n n
(-
r 3.
,h34uested Exemption Tne licensee's subnittal ir, pert, is not specific as to what requirement is not being met and what alternative is proposed.
It state 5, for example, that an indiviual area "does not comply with Section III G.2 of Appendix R",
3 but does not directly identify the nature of the noncompliance.
The information supplied (highlighted drawings and text) regarding divisional separation is insufficient to identify the degree of separation between i
redundant trains or the consequences of a fire on safe shutdown captbility, i
4.
Proposed Modifications The licensee has not adequatoly described alternatives that are proposed to be implemented in conjunction with the exemptions to permit our evaluation.
For instance, the licensee has not described the design of the one hour fire i
rated barrier that is to be used to enclose select cables.
5.
Fire Zone A-14 The following specific information is needed to complete our analysis,0f i
the proposed alternate protection:
}
- b. The distance from the top of the duct to the floor / ceiling above 1.
l 6.
Conclusion
~!
Based on our inital review, we conclude that the exemption requests
'I.
should be denied if further clarification cannot be provided by the.
licensee within a reasonable time.
- ?
h s
}'
J i
s-.
. -. -