ML20082B923

Forwards Commitments to Resolve Fire Protection Issues Raised at 831114 Meeting W/Region III Re 10CFR50,App R, Audit.Commitments Resolved Include Water Sys,Detector Locations,Air Supply & Fire Watch Training

ML20082B923
Person / Time
Site:	LaSalle
Issue date:	11/16/1983
From:	Schroeder C COMMONWEALTH EDISON CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
NUDOCS 8311210371
Download: ML20082B923 (18)

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Commonwealth Edison O One First N1tional Plus, Chicago. Ilknois v Address Reply to: Post Office Box 767 s Chicago. Illinois 60690 November 16, 1983 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Subject:

LaSalle County Station Unit 2 Fire Protection NRC Docket No. 50-374

Dear Mr. Denton:

On November 14, 1983, D. L. Farrar, et al. of Commonwealth Edison Company met with Dr. A. Bournia, et al. of your staff and Mr. R. L.

Spessard, et al. of Region III regarding fire protection. During that i meeting, several issues were discussed which had been identified as con-cerns during the recent Region III Appendix R audit at LaSalle County Station. Although no inspection report has been issued to date by Region III and no fonnal or infonnal written questions have been pro-vided by NRR, Commonwealth Edison believes that a majority of these issues are straightfomard. In order to expedite closure of these issues, Commonwealth Edison has prepared the ' attachments which sunnarize the issues and provide our commitments.

To the best of my knowledge and belief, the statements contained herein and in the attachments are true and correct. In some respects these statements are not based on my personal knowledge but upon infor-mation furnished by other Commonwealth Edison employees and contractor employees. Such information has been reviewed in accordance with Company practice and I believe it to be reliable.

If there are further questions in this matter, please contact this office.

Very truly yours i

nfr7[93 C. W. Schroeder Nuclear Licensing Administrator cc: NRC Resident - LSCS J. G. Keppler I I B311210371 B31116 PDR ADOCK 05000374 p PDR

1. Water Systems

2. SW Backup

! 3. Detector Locations

4. Emergency Lighting i

5. App. R Deviation i

j 6. AEER Roll-up Door

7. Supp. Pool Level & Temp.

8. Dampers & Doors s a) Manual Dampers i b) Surveillance i_

9. Fire Watch Training a

10. Air Supply

11. Fire Seal Test Data

12. RCIC/RHR Pressure Hi/Lo 4

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\.6 ISSUE 1. N

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Region III NRC personnel identified concerns regarding the l

fire protection water system adequacy as a result of the Appendix '

R audit which was conducted at LaSalle County Station.

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j COMMITMENTS / STATUS '

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1. The A diesel fire pump has been replaced-with a rebuilt diesel engine and an overhaul fire pump.

2. On November 5, 1983, a test of the A pump was performed.

4 The results of that test have been provided to Region III.

3. Commonwealth Edison fire protection engineer and M&M Protec-tion Consultants are reviewing the results of the A pump l test against the applicable section of NFPA 20.

4. A replacement diesel for the B diesel fire pump is expected j

to be delivered by December 1, 1983.

5. A test will be performed on the B diesel fire pump, prior to Unit 2 initial critical, and these results will also be reviewed against the applicable sections of NFPA 20.

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Commonwealth Edison Company has performed a " Preliminary Evaluation of the Service Water System as a Backup' to the

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Fire ' Protection System." That evaluation was provided to s

NRR and Region III by letter dated October 31, 1983.

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7. Commonwealth Edison Company has commissioned Marsh and "'

l McClennan Protection Consultants' to perform a full computer analysis of the fire protection water system. ,

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is scheduled for completion by' November 30, 1983. ,.

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8. Prior to exceeding ,5% power, Commonweath Edison will com-plete its review of the computer analysis and will provide a

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l proposed testing program,' for the, fire pump and the main loop l to assure adequate capacity. T'his testing program will be the basis for$ th'e surveillance program on the LaSalle fire pump and main loop.

9. Commonwealth Edison Company Project Engineering department is determining the appropriate setpoint for the fire pump relief valves, and those new setpoints will be incorporated' before criticality'of LaSalle' Unit 2.

10. The hose nozzles on the refueling floor will be evaluated andi replaced, if necessary, with nozzles '

appropriately rated prior to Unit 2 initial critical.

11. The application of the jockey booster pumps shall be reviewed. Any required changes will be implemented prior to-startup following the first refueling outage.-

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i ISSUE 2.

During the NRC inspection at LaSalle County Station for conformance with 10 CFR 50 Appendix R, a concern was raised regarding the adequacy of the Service Water system as a "back-up" i for the fire protection system, i

4 l COMMITMENT As stated in response to the previous issue, Commonwealth Edison has performed a " Preliminary Evaluation of the Service Water System as a backup to the Fire Protection System." That evaluation was provided to NRR and Region III by letter dated

October 31, 1983. Commonwealth Edison Company has further com-missioned Marsh and McClennan Protection Consultants to perform a full computer analysis of the fire protection water system, including an analysis of the Service Water system to perform its function as a backup to the fire protection system. This computer analysis is scheduled to be completed by November 30,

. 1983, and we will complete our review of it prior to exceeding 5%

power on Unit 2.

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ISSUE 3.

During the Appendix R audit, Region III personnel questioned certain aspects of the fire detector design.

Specific questions were raised regarding:

a) Location and number of detectors with respect to NFPA72E.

b) Location of detectors in rooms with high air flow c) Areas (switchgear and auxiliary electrical equipment room) in which detector activation does not result in automatic trip of supply air fans.

COMMITMENT For areas containing safety related equipment or equipment required for safe shutdown (excepting the cable spreading room which has been accepted by NRR), a review of a, b, and c above will be completed prior to exceeding 5% power on Unit 2. Any required changes will be implemented no later than startup following the first refueling outage. 2.

ISSUE 4.

During an NRC Region III inspection at LaSalle County Station with respect to compliance with 10 CFR 50 Appendix R (Inspection Report 50-374/83-48 which has not yet been issued), a potential item of non-compliance was identified with regard to Appendix R, Section III.J. covering the adequacy of the installed emergency lighting system.

COMMITMENT In a meeting on November 14, 1983, with NRR and Region III, Commonwealth Edison committed to comply with the requirement to provide Emergency lighting units with at least an 8-hour battery power supply in the Control Room and in the Auxiliary Electric Equipment Room at the Remote Shutdown Panel, and on a dedicated access route from the Control Room to the Auxiliary Electrical Equipment Room which will include two egress doors from the Control Room. The dedicated route will be identified in the Control Room Evacuation Procedures. This commitment will be completed prior to first criticality of LaSalle Unit 2.

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, ISSUE 5.

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, It has been determined that control cables for the fuel oil transfer pumps for the "O" and "2 A" diesel generators are routed I through the same fire zone. This is in conflict with Appendix R,

Section III.G.l.a in that, if the fuel oil day tanks for both

! diesels were at minimum level, only a few hours of diesel opera- "

i tion could be assured if the control cables for the diesels were destroyed. (The LaSalle FSAR page H.4-ll takes credit for a i

repair procedure that is currently included in the fire plan for Unit 2.)

1 l COMMITMENT i

Prior to startup following the first refueling outage, I

Commonwealth Edison Company will either:

a) Reroute one set of fuel oil transfer pump control cables, or b) I.1 stall a local control switch on one of the fuel oil transfer pumps, or c) Provide physical protection for one set of the fuel oil

transfer pump control cables.

1 j In the interim, Commonwealth Edison Company will administra-J tively maintain the fuel oil level at nominal " f ull . " This will be accomplished procedurally by refilling the day tank for each respective "O" and "2A" diesel following operation and by a '

l weekly surveillance that the "O" and "2A" day tanks indicate '

l " full" of fuel oil.

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ISSUE 6 I 1

Due to parts delivery problems, a roll-up fire door in the Aux. Electric Equipment Room, Unit 2 has not yet been installed.

COMMITMENT Commonwealth Edison Company will install the missing roll-up door in the Unit 2 Auxiliary Electric Equipment Room prior to initial criticality on Unit 2.

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ISSUE 7. l 1 l Commonwealth Edison Company has installed all required instrumentation on the Remote Shutdown Panel in accordance with our FSAR and in accordance with the requirements of the Standardized Technical Specifications.

i During the Appendix R audit at LaSalle County Station, the NRC Region III staff told Commonwealth Edison Company that they were provided specific " acceptance criteria" by NRR. These

" acceptance criteria" have apparently never been published nor approved through Commissioner's action. The NRC staff (Region III and Auxiliary Systems Branch) maintain that even though the required safe shutdown instrumentation are clearly defined in the I

Standard Technical Specifications (which is a published, public document) and were specified and approved in the LaSalle County Station Unit 1 Technical Specifications in accordance with the commitments in the FSAR, the NRC's position is that the applicant shall provide instrumentation remote to the control room for i Suppression Pool Level and Temperature Indication. Although LSCS Unit 2 has Suppression Pool Level and Temperature Indication on the remote shutdown panel, it is not. electrically independent monitoring capability. Although there may be local suppression pool level and temperature indication which is electrically inde-pendent of the control room, there is no description of the communications between the various local work stations or panels, nor is emergency lighting provided at those instruments.

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COMMITMENT Commonwealth Edison believes that this issue is a generic issue applicable to all BWRs. As such, it should undergo the reviews appropriate to such generic issues. We would like addi-tional discussion with NRC senior management before considering a commitment for LaSalle County Station.

- t ISSUE Ba.

During the NRC Region III inspection of the compliance of LaSalle County Station to 10 CFR 50 Appendix R, an open item was identified as to the status of the implementation of manual operators on certain LaSalle County dampers.

COMMITMENT Commonwealth Edison is proceeding with the installation of this backfit per LaSalle Unit 2 ECN-M-763-LA and LaSalle Unit one I Modification M-1-1-82-311. In the interim, the required dampers which do not currently have manual operators will be identified in normal system operating procedures and a statement will be added to acknowledge that in certain fires the respective Ventilation System may be restored to a satisfactory line up if l conditions warrant by use of craft capability overides. The l procedures will be in place prior to LaSalle Unit 2 first criti-cality. It should be understood that the backfit to be imple-mented merely provides an improvement to craft capability to operate these dampers which have been in use at the site for some time.

ISSUE 8b.

Commonwealth Edison Company meets all current requirements of Appendix R and the Standard Technical Specifications regarding the operability surveillances of fire doors and fire dampers.

The NRC has a concern, however, that the current requirements may not be suf ficient to assure operability of fire doors and fire dampers for the forty year life of the plant.

COMMITMENT Commonwealth Edison has no reason to believe that our current fire door and fire damper surveillances are inadequate.

The NRC apparently has historical information which indicates that there may be a long-term problem with fire door and fire dampers operability. It is our recommendation that this informa-1 l tion be disseminated to all licensees on a generic basis. Any l requirements in this area should be imposed on a generic basis af ter appropriate review by NRC senior management. We would like additional discuss 4.ons with NRC senior management before con-sidering a commitment for LaSalle County Station.

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ISSUE 9.

Commonwealth Edison Company has committed to meet the

! requirements of " Nuclear Plant Fire Protection Functional Respon-sibilities, Administrative Control and Quality Assurance," dated

June 14, 1977. That document requires that personnel performing fire watch duties must be trained. That document further references NFPA SlB which states that " hands on" training must be provided.

COMMITMENT Commonwealth Edison believes that this issue should be addressed by a corporate policy and should not be considered as a licensing concern for LaSalle Unit 2. Therefore, we commit to review and develop that corporate policy and to review it with 1

i NRC Region III prior to March 1, 1981.

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ISSUE 10. I During the NRC Region III inspection of LaSalle Unit 2 with respect to compliance with 10 CFR 50 Appendix R (Inspection Report 50-374/83-48 which has not yet been issued), a potential item of non-compliance was identified with regard to Appendix R Section III. H. concerning the availability of self-contained breathing apparatus air bottles for the protection of the fire brigade.

COMMITMENT C. E. Sargent letter to A. Schwencer dated 12/18/81 committed to maintain ten (10) self-contained breathing apparatus available for use by the fire brigade with a six (6) hour supply of reserve air. This commitment will be met by ten dedicated self-contained breathing appartus at all times and either an approved air compressor with appropriate administrative controls or suf ficient air bottles on site to comply with the with the 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> requirement. This commitment will be implemented prior to first criticality of LaSalle Unit 2.

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ISSUE 11.

NRC Region III believes that not all of the fire stop con-figuration which have been installed for LaSalle Unit 2 have been adequately tested by independent testing companies.

COMMITMENT Commonwealth Edison has submitted numerous test results to NRR for their review. A meeting was held on November 16, 1983 with NRR to further explain the data which we have provided.

The conclusions of this meeting are as follows:

1. It is agreed that, by engineering judgment, the "L" shaped control room penetrations are bounded by perviously submitted test results and, threfore, are acceptable.

2. Commonwealth Edison Company finds acceptable, by engineering judgment, the slight exceedences (5 2.6% and 51.4% cable fill for wall penetration versus the maximum 51.1% tested). In order to obtain closure of this item, however, Commonwealth Edison Company agrees to provide a second similar fire stop in series with the first existing fire stop for the two cases of exceedence, prior to initial criticality on Unit 2.

3. Commonwealth Edison will review the procedure associated with penetration seal surveillance to establish clearly defined acceptance criteria. The 3/8" separation criteria will be justified or a new criteria will be submitted for NRC review and approval. Personnel will receive adequate training to perform the surveillance.

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I Penetrations seals which are identified in the future as having abnormailities such as cracks and/or separations will be identified even when they satisfy acceptance criteria in the surveillance procedure.

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ISSUE 12.

There are three valves in series which constitute the high pressure / low pressure interfaces between RCIC and RIIR. The con-trol circuits routing for those three valves require review to assure that a fire in a single fire zone cannot result in opening l of all three valves.

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COMMITMENT Prior to exceeding 5% power on Unit 2, a review will be completed and appropriate actions, if any, shall be implemented i

i to assure that a fire in a single fire zone will not result in l opening of all three valves.

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