ML20087D326
| ML20087D326 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 02/15/1984 |
| From: | Reed C COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20087D296 | List: |
| References | |
| 7949N, NUDOCS 8403130359 | |
| Download: ML20087D326 (20) | |
Text
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Commonwealth ECson
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Ons First N1tional Plats. Chicago, lihnois (C'
Address Riply to: Post Othcs Box 767 N
Chicago, liknois 60690 February 15, 1984 Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
LaSalle County Station Units 1 and 2 Response to Inspection Report Nos.
50-373/83-44 and 50-374/83-48 NRC Docket Nos. 50-373 and 50-374 Reference (a):
R. L. Spessard letter to Cordell Reed dated December 12, 1983.
(b):
Cordell Reed letter to H. R. Denton dated January 27, 1984.
(c):
LaSalle County Station Unit 2 License NPF-18.
Dear Mr. Keppler:
This letter is in response to the inspection conducted by Messrs. F. Maura, C. Ramsey, and J. Ulle on September 28-30, October 3-7, 11-14, 17-21, and November 3, 1983, of activities at LaSalle County Station.
Reference (a) indicated that certain activities appeared to be in noncompliance with NRC requirements.
The Commonwealth Edison Company response to the Notice of Violation is provided in the enclosure. 'The extended submittal date for this response was approved in discussions with Mr. W. Little of your, office.
Commonwealth Edison Company believes that certain'of the items categorized as examples of non-compliance are, in fact, not in violation of the regulations.
In Reference (b), Commonwealth Edison Company is requesting consideration of those positions of the NRC Region III and Nuclear Reactor Regulation (NRR) staff with which we take exception.
In the attached response, we have specified those positions with which we have disagreement.
Although we disagree with the fact that the NRC has categorized those items as being violations, we have initiated actions to address the NRC concerns.
In those cases where the issue is currently addressed in Reference (c), we are proceeding in accordance with the schedule specified in the Unit 2 License Conditions.
8403130359 840306 PDR ADOCK 05000373 G
PDR WB 23
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i J. G. Keppler February 15, 1984 To the best of my knowledge and belief the statements contained herein and in the attachment are true and correct.
In some respects these statements are not based upon my personal knowledge but upon information furnished by other Commonwealth Edison employees.
Such information has been reviewed in accordance with Company practice and I believe it to be reliable.
If you have any further questions on this matter, please direct them to this office.
Very truly yours, ppAL Cordell Reed Vice President CWS/lm Attachment cc:
NRC Resident Inspector - LSCS 7949N
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1 RESPONSE TO INSPECTION REPORT i
Nos. 50-373/83-44 and-50-374/83-48 j
Alleged Item of Noncompliance 1.
LaSalle County Station Unit 1,-Facility Operating License No. NPF-ll states in part, "the licensee shall maintain the fire protection program set forth in Appendix R to 10 CFR Part 50, except for the i
following deviatiores:
(1) hydrostatic hose test in accordance.with NFPA 1961-1979, and (2) no automatic fire detection systems in areas 2K/3K anj 584."
10 CFR 50, Appendix R, Section III.J requires that emergency lighting units with at least an 8-hour battery power supply'shall be provided in all areas needed for operation of safe shutdown equipment and in access and egress routes thereto.
Contrary to the above, adequate emergency lighting was not provided for access and egress routes to areas and equipment needed to accomplish safe shutdown.
In addition, four to five emergr.ncy lighting units tested failed the 8-hour discharge test.
j This is a Severity Level IV violation (Supplement I)(Unit-'1).
Response
Corrective Action Taken and Results Achieved 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.
These actions have-been completed.
In addition, the dedicated l
route has been -identified in the Control Room Evacuation procedures..
Corrective Action Taken to Avoid Further Non-Compliance Procedures LES-DC-106, "D.C. - Emergency L Light Check and Circuitry-Test" and LES-DC-107, "D.C. Emergency Light 8 Hour. Discharge Test"~
have been written to require. periodic surveillance of these. lights.
These procedures address periodic functional. testing, beam direction, and extended discharge. testing.
Date of Full Compliance g
- The listed.8-hour battery powered lights and dedicated-route are in place.
Full ~ compliance willLbe achieved-prior to exceeding five percent power on LaSalle Unit 2 per NPF-18 License Attachment /1,
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Condition E.2.
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, Alleged Item of Noncompliance 2.
LaSalle County Station, Unit 1, Facility Operating License No. NPF-ll states in part, "the licensee shcIl maintain the fire protection program set forth in Appendix R to 10 CFR Part 50, except for the following deviations:
(1) hydrostatic hose tests in accordance with NFPA 1962-1979, and (2) no automatic fire detection systems in areas 2K/3K and 584."
10 CFR 50, Appendix R, Section III.H requires that "self-contained breathing apparatus (SCBA) using full-face positive pressure masks approved by NIOSH (National Institute for Occupational Safety and Health) shall be provided for fire brigade, damage control, and control room personnel."
(NIOSH approval requires hydrostatic retesting every three years.)
"At least 10 masks shall be available for fire brigade personnel... At least a 1-hour supply of breathing air in extra bottles shall be located on the plant site for each unit of self-contained breathing apparatus.
In addition, an onsite 6-hour supply of reserve air shall be provided...."
Contrary to the above, an onsite 6-hour supply of reserve air was not provided in that neither the air compressor was operable to provide breathing quality air, nor was there suf ficient. numbers of. NIOSH approved charged air cylinders available.
Sixty self-contained breathing apparatus air-pak cylinders were identified as being past due regarding their required hydrostatic retest schedule; thus when they are attached to a self-contained breathing apperatus unit, this invalidates the unit's approval of NIOSH.
This is a Severity Level V violation (Supplement I)(Unit 1).
Response
Corrective Action Taken and Results Achieved LRP 1310-9, Revision 5, which has been approved, indicates the. method-of charging SCBA air cylinders with the air compressor when 'the C0 monitor is inoperable.
Therefore, the air compressor is operable to provide breathing quality' air and meet the six-hour reserve air supply requirement.
In addition the.SCBA air cylinders that were past due for their hydrostatic. test were taken out of service and were systematically sent to 's vendor. for the hydrostatic-test.- A six-hour reserve air supply for fire fighting / damage. control is available with adequate numbers of current hydrostatically tested SCBA and reserve SCBA air cylinders available for. service.
7.
. Corrective Action Taken to Avoid Further Noncompliance As the SCBA cylinders are returned from the vendor after their hydrostatic test, the surveillance program.y are being placed on the LSCS computer This program will provide assurance that each SCBA air cylinder will be hydrostatically tested every three years.
LRP 1310-9, Revision 5, and LRP 1310-5, Revision 4 now include a statement requiring that a six-hour reserve air supply be available onsite at all times.
Date When Full Compliance Will Be Achieved Full compliance has been achieved.
License NPF-18, Attachment-1, Item E.6 is therefore satisified.
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, Alleged Item of Noncompliance 4
3.
10 CFR 50.48 requires each operating plant to have a fire protection plan that satisfies Criterion 3 of Appendix A to 10 CFR 50.
Criterion 3 of Appendix A to 10 CFR 50 establishes that fire protection structures, systems and components including fire detection and fire _ fighting sytems be designed and provided to l
minimize the probability and effect of fires and explosions on structures, systems and components important to safety.
i Criterion 1 of Appendix A to 10 CFR 50 is applicable to fire protection systems, structures, and. components such as those required by 10 CFR 50.48, and requires quality standards and records-commensurate with the safety functions to be' performed.
Amendment 49 of the FSAR, dated May 1980, states, "LaSalle County Station follows the staff supplemental guidance contained in " Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls, and Quality Assurance", dated August 29, 1977.
The NRC staff supplemental guidance, " Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls, and Quality Assurance", Attachment No. 6 contains the following: _(a) Section 2.0(b) requires that tests be prescribed and accomplished in accordance with documented instructions, procedures,'and drawings; (b) Section 4.0 requires that a program be established and executed by, or for, the organization performing the activity to verify conformance to documented installation drawings and test procedures for accomplishing activities;-(c) Section 5.0 requires that tests be performed in accordance with' written. test procedures;-test results should be properly evaluated and acted on; (d) Section 5.0(b) requires periodic testing for fire protection equipment, emergency-lighting, and communication equipment to assure that the equipment will properly function'and continue to meet the design. criteria.
Contrary to the above:
b (a)- The licensee failed.to establish-and' implement a procedure that would verify the quality of the breathing air while the carbon monoxide monitor is inoperable as required by 10 CFR 50, Appendix R,-Section III.H (Unit 1).1 (b)- Procedure LRP-1310-5 (Monthly Inspection - Self Contained Breathing Apparatus (SCBA) failed'to provide verification that-l the air-pack cylinders are-within the hydrostatic retest schedule as required by the Department of Transportation (DOT) exemption identifier-DOT-E7235-4500Lin that'NIOSH approval of the SCBA is based on-conformance to the hydrostatic-retest schedule. NIOSH: approval is required by 10 CFR-50,' Appendix R,Section III.H.(Unit 1).
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(c)
The.11censee' failed to establish and implement a procedure to inventory personal protective equipment (turnout coats, bunker boots, gloves, helmets) and verify operability of the portable ventilation equipment and portable lights as required by 10 CFR 50, Appendix R, Section III.H (Unit 1)
(d)
Emergency lighting unit surveillance procedures identified a3 Station Code E-M01-000/ Maintenance Departent Code EMD (monthly lighting unit test) did-not.specify an 8-hour discharge test, level of illumination, or verify lighting unit lamp direction as required in 10 CFR 50, Appendix R, Section III.J.
(e)
Procedure LMP-FP-10 (Monthly Fire Inspection of Portable Fire i
Extinguisher and Fire Hose Stations) failed to:
(1) require a check os the tightness of the fire hose coupling to the nozzle, (2) checking the exposed female coupling'end for' obstructions, and (3) verify the nozzle is in the closed position!as required in NFPA 14.
( f)
The licensee failed to establish-and implement a ' procedure for-periodic surveillance testing of fire p6mps and did not conduct a field acceptance test of the fire' pump installations in accordance-with NFPA-:20.
(g)
The licensee failed-to adequately test fire protection 1 water' supplies for fire protection in.-that surveillance procedure LTP-100-2 did not require flowing of fire t hydrants as.specified in Chapter 5, Section 11 of-the 14th Edition of the National Fire Protection Association Handbook.
(h)
The licensee failed to adhere to surveillance testing acceptance criteria for fire protection. systems in_that six-surveillance testing procedures did not incorporate NFPA requirements.
This is a Severity Level IV violation (Supplement.I) (Unit 1).
Response
Commonwealth Edison Company takes exception.with the referencing of; GDC-lias_the basis for'.this violation.
Reference'.(b).and its Enclosure _'l provide aniin-depth. discussion of.our position in-this matter.
Notwithstanding our disagreement with the NRC1 Region III staf f on this issue,.each' of the examples of non-compliance have been. addressed.
3a.,. Corrective Action Taken'and Results Achieved StationLprocedure LRPfl310-9,iRevision 5, " Charging o ff Air. Cylinders -
for Respiratory Equipment", has been revised to_ incorporate?e means 3
l to Lverify.the quality / of1 breathing air 'while. the carbon Emonoxide-
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monitor is inoperable.-
.. - Corrective Action Taken to Avoid Further Noncompliance See above.
Date of Full Compliance Full compliance has been achieved.
3b.
Corrective Action Taken and Results Achieved The SCBA air cylinders that were past due for their hydrostatic test were taken out of service and were systematically sent to a vendor for the hydrostatic test.
L RP 1310-5, Revision 3 was approved on December 14, 1983.
This revision required the hydro date of the SCBA bottles to be documented as part of the monthly SCBA inspection.
Corrective Action Takr:n to Avoid Further Noncompliance The SCBA air cylinders are being placed on the LSCS computer surveillance program.
This program will provide assurance that each SCBA air cylinder will be hydrostatically tested every three years.
L RP 1310-5, Revision 4 was completed to further document all SCBA air cylinder hydrostatic test dates on a monthly basis.
Date of Full Compliance Full compliance has been achieved.
3c.
Corrective Action Taken and Results Achieved Although no written procedure existed, an inspection of personal protective equipment including boots, coats, gloves, helmets, flashlights, ventilation equipment.and other equipment utilized by the Fire Brigade was being performed by the Fire Marshal.
A surveillance procedure to inventory this equipment has been developed and approved.
This procedure includes all equipment located in the fire protection cages and also includes the 10 required SCBA.
Corrective Action Taken to Avoid Further Noncompliance The procedure has been added to the computerized surveillance program in order to ensureLit is regularly performed.
Date of Full Compliance Full compliance has been achieved.
7949N
- 3d.
Commonwealth Edison Company notes that, contrary to the wording of this example of non-compliance, 10 CFR 59, Appendix R, Section III.J does not require "an 8-hour discharge test, level of illumination, or verify lighting unit lamp direction."
10 CFR 50, Appendix R, Section III.J. states:
"J.
Emergency lighting units with at least an 8-hour battery power supply shall be provided in all areas needed for operation of safe shutdown equipment and in access and egress routes thereto."
To our knowledge, there is no Regulatory Guide or other official document which has been provided for public comment or which has received CRGR review and approval that specifies requirements for level of illumination or verification of lighting unit lamp direction.
We must protest this circumvention of the rulemaking procedures and of even the NRC policies for promulgating regulatory guidance.
Notwithstanding our protest of this circumvention of the legal methods for imposition of regulations, we recognize that certain battery powered lights did not last for an 8-hour discharge test.
Our response to that non-compliance has been addressed in our response to Item of Noncompliance No. 1 in this letter.
Corrective Action Taken and Results Achieved Procedures LES-DC-106, "D.C.
Emergency Light Check and Circuitry Test" and LES-DC-107, "D.C Emergency Light 8 Hour Discharge Test" have been written to require periodic surveillance of these lights.
These procedures address periodic functional testing, beam direction and extended discharge testing.
Corrective Action Taken to Avoid Further Noncompliance These procedures will be placed in the LaSalle County Station computerized surveillance program to assure ongoing compliance.
Date of Full Compliance These procedures will be in place and be implemented prior to Unit 2 initial criticality.
3e.
Corrective Action Taken and Results Achieved All fire hoses have been connected to the hose station valves.
Before being connectea, the hose and hose station valve were checked for obstructions that could reduce or obstruct water flow".
No l
obstructions were found.
In addition, the-position and tightness ~of j
the nozzle were checked.
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Corrective Action Taken to Avoid Further Noncompliance Procedure'LMP-FP-10,'(Monthly Inspection of. Fire Extinguishers and Fire Hose Stations) -has been. revised to check the tightness of the fire hose coupling to the nozzle and to verify the nozzle is in the closed position.
This revision includes requirements to check that the hose is connected to the hose station valve tightly and that the valve itself is closed tightly.
Date of Full Compliance 4
Full compliance has been achieved.
3f.
Commonwealth Edison Company does not agree with the categorization of this item as an example of noncompliance.
Commonwealth Edison Company did commit to install the Fire Pumps in accordance with NFPA-20.
This was accomplished.
As addressed in Reference (b),, Commonwealth Edison Company takes exception with the apparent policy of Region III-staf f to : require compliance with all portions of all NFPA codes.
Our commitment for testing and inspection of fire protection systems is clearly stated ~1n the FSAR:
"9.5.1.4 Inspection and Testing Requirements 4
Initial construction and preoperational testing of the fire protection system is to be conducted.in accordance with the.
-preoperational test program defined.in Chapter'14.0.-
j Periodic inspections and operational checks to demonstrate integrity are routinely performed on' fire protection
'j systems.
These tests and inspections are identified in Subsection '4.7.5 ~of Chapter 16.0, Technical Specifications."
Notwithstanding our position that there.is'no regulatory basis for l
requiring procedure (s)-in accordance with NFPA-20Efor periodic-surveillance testing and field acceptance tests, in C. it. Schroeder-letter to H. R..Denton dated-November 23, 1983,-Issue 1, Item 2 we explained:'
j-
"On November 5, ~1983, a test of the " A" pump wascperformed.
The results of that test have been 'provided to Region-III."
That letter continued with Issue 1, Item:5 which stated:
~
i "A test will be performed on the "B" diesel fireipump, prior to Unit 2 initial criticality.":
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The NRC confirmed this commitment with Reference (c), Unit 2 License Condition 2.C.(15).(b):
" Prior to initial criticality, the licensee shall-replace the "B" diesel fire pump engine aied perform a test in accordance i
with Sections 11-2.3, ll-2.4. and 11-2.5 o f NFPA-20/1983. "
Furthermore, Unit 2 License Condition 2.C.(15).(c) states:
" Prior to initial criticality, the-licensee shall revise the periodic fire pump surveillance tests to:be in accordance with 4
Section 11.3 of NFPA-20/1983 to be conducted on 18-month intervals."
We are proceeding to complete these license conditions on the schedule specified.
r 3g.
Commonwealth Edison Company'does not agree with the categorization of this item as an example of noncompliance.
At our request, M&M Protection-Consultants'have conducted a review of the LaSalle Fire Suppression Water Systems Flow-Procedure LTS-1000-15, Revision C2, dated October 5, 1983 in relation to the:
14th Edition of-the NFPA Handbook,:Section 11, Chapter 5.
They_
concluded that the procedure described accomplishes'the-intent of-the water supply testing by NFPA.
With respect to the specific;1 tem stated in the notice of violation, "The liccqsee failed.to adequately test fire-protection water.
supplies for fire protection in that surveillance-procedure LTP 100-2 did not require flowing of fire hydrants as specified.in Chapter 5, Section 11 of the 14th Edition of the National Fire -
Protection Association Handbook."
i i
we note that all of. the hydrants are: regularly flushed (semi-annually) in accordance with LMS-FP-4, Fire' Hydrant; Flush."
In accordance with Reference.(c), Condition 2.C.(15).(d):.
4 i
" Prior to initial criticality, the-licensee:shall revise the fire protection loop flow test in accordance with Chapter:5, l-Section :ll. of the Fire Protection Handbook, Ll4th L Edision i
published by the National Fire: Protection Association."
l Commonwealth Edison Company Is proceeding to revise procedure LTS-1000-30 to provide procedure clarification and'more: definitive' ~
4 acceptance criterie.
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Commonwealth Edison Company does not agree with the categorization of this item as an example of noncompliance.
Reference (b) and its provide our position on this subject.
It should be noted that the six surveillances are identified in the body of the Inspection Report but only one specific example (Item 3) of improper testing acceptance criteria was identified.
The following actions have been implemented to address areas where Commonwealth Edison considers the procedures neeo revision or clarification:
1.
LOS FPA2
" Fire Protection System Functional Test" has been revised to reflect the issued Unit 2 Technical Specifications flow requirements.
2.
LMS FP09
" Yearly Maintenance of AFFF Fire Extinguisher" has been revised to include a check of the hydrostatic test date.
The following procedures have been submitted to the Commonwealth 4
Edison corporate fire protection engineer for review to assure that the procedures adequately address testing and inspection.
1.
LES FP03
" Hydrogen Seal Oil Deluge Initiation Circuit Functional Test."
It should be noted that other procedures currently address periodic alarm test and drain flow test.
2.
LOS FPAl
" Fire Prctection Flow Path Valve Cycling Test."
It should be noted that other procedures currently address periodic outside yard hydrant flush and maintenance.
3.
LMS FP06
" Fire Protection Hose Station Valve Operability and Flow Verification."
4.
LOS FPA3
" Fire Protection Sprinkler and Deluge System Drain Flow and Cycling Test."
7949N
, Alleged Item of Noncompliance 4.
10 CFR 50.48 requires each operating plant to have a fire protection plan that satisfies Criterion 3 of Appendix A to 10 CFR 50.
Criterion 3 of Appendix A to 10 CFR 50 establishes that fire protection structures, systems and components including fire detection and fire fighting systems be designed and provided to minimize the probability and effect of fires and explosions on structures, systems and components important to safety.
Criterion 1 of Appendix A to 10 CFR 50 is applicable to fire protection systems, and components such as those required by 10 CFR 50.48 and requires quality standards and records commensurate with the safety functions to be performed.
Amendment 49 o f the FSAR, dated May 1980, states, "LaSalle County Station follows the staff supplemental guidance contained in Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls, and Quality Assurance", dated August 29, 1977 "
The NRC staff supplmental guidance
- Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls, and Quality Assurance", Attachment No.
6, Section 8.0 states, in part, " measures shall be established to ensure that conditions adverse to fire protection such as failures, malfunctions, deficiencies, deviations, defective components... are promptly identified, reported, and corrected".
Contrary to the above, the licensee failed to take prompt corrective action after an air flow problem with carbon monoxide monitor was identified on March 15, 1982.
The monitor is required to assure air quality when refilling the self-contained breathing apparatus used by the Fire Brigade.
This is a Severity Level V violation (supplement I) (Unit 1).
Response
Commonwealth Edison Company does not disagree with the categorization of this item as an item of non-compliance.
We do, however, take exception with the reference of GDC-1 as the basis for this violation.
Reference (b) and its Enclosure 1 provide an in-depth discussion of our position in this matter.-
o
. Corrective Action Taken end Results Achieved The compressor was made operable by jumpering the CO monitor shutdown function.
A means was developed to verify the quality of tha breathing air while the carbon monoxide monitor is inoperable.
In addition, a sign was placed on the compressor stating:
"In the event the SCBA compressor is inoperable, immediately notify the Station Fire Marshal in order to expedite corrective action.
If the Fire Marshal is not available, notify the Shift Engineer.
The compressor is required to be operable at all times by 10 CFR 50, Appendix R.
If the compressor is not readily repairable, an inventory of SCBA cylinders must be performed to verify that 120 cylinders are available."
Corrective Action Taken to Avoid Further Noncompliance Revision 5 to Station Procedure LRP 1310-9 " Charging of Air Cylinders for Respiratory Equipment", was processed to incorporate the above mentioned corrective actions.
This revision was approved by onsite review on January 6, 1984.
Date Of Full Compliance Full compliance has been achieved.
7949N
. Alleged Item of Noncompliance 5.
10 CFR 50.48 requires each operating plant to have a fire protection plan that satisfies Criterion 3 of Appendix A to 10 CFR 50.
Criterion 3 of Appendix A to 10 CFR 50 establishes that fire protection structures, systems and components including fire detection and fire fighting systems be designed and provided to minimize the probability and effect of fires and explosions on structures, systems and components important to safety.
Criterion 1 of Appendix A to 10 CFR 50 is applicable to fire protection systems, and components such as those required by 10 CFR 50.48 and requires quality standards and records commensurate with the safety functions to be performed.
Amendment 61 of the FSAR dated December, 1982, states that, "the configuration of each erea determines the number and actual location of fire detectors.
The actual number and spacing of detectors is per NFPA 72E."
Paragraph 4-3.7-3 of NFPA 72E 1981 states that, "If the beams exceed 18 inches in depth and are more than 8 feet on centers, each bay shall be treated as a separate area requiring at least one spot-type or line-type detector."
Paragraph 4-3.2 of NFPA 72E covering the location of automatic fire detectors states in part that, " Spot-type smoke detectors shall be locate on the ceiling not less than 4 inches from a sidewall."
The NRC staff supplemental guidance " Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls, and Quality Assurance", Attachment No.
6, Section 1.0(b) requires that measures should assure that quality standards are specified in.the design documents such as appropriate fire protection codes and standards, and deviations and changes from these quality standards are.
controlled.
Contrary to the above, the design and installation of the fire.
detection system throughout all areas of the plant, including the auxiliary electric equipment room in Unit 1, do not meet the provisions of the' National' Fire Protection Association Standard 72E (NFPA 72E) in that the number of detectors installed are inadequate and those detectors installed are improperly positioned on suspended conduit 4 feet beneath the ceiling and approximately 18 inches beneath the beams instead of being located at the ceiling as required by NFPA 72E.
This is a Severity-Level IV violation (Supplement I) (Units 1 and 2)'.
. Response Commonwealth Edison Company does not disagree with the categorization of this item as an item of non-compliance.
However, we take exception with the referencing of GDC-1 as the basis for this violation.
Reference (a) and its Enclosure 1 provide an in-depth discussion of our position in this matter.
Furthermore, we take exception with Region III staff position that the number of detectors installed are inadequate and that suspended detactors installed are improperly positioned.
Specifically, we note that NFPA 72E, 1982, Section 4-3 Location and Spacing states:
"4-3.1 General.
The location and spacing of smoke detectors shall result from an evaluation based on engineering judgment supplemented by the guidelines detailed in this Standard.
Celling shape and surfaces, ceiling height, configuration of contents, burning characteristics of combustible material present, and ventilation are some of the conditions that shall be considered.
4-3.1.1 Where the intent is to protect from a specific hazard, the detector (s) may be installed closer to the hazard in a position where the detector will readily intercept the smoke."
By C.
W.
Schroeder letter to H.
R.
Denton dated November 23, 1983, in the attached Issue 3,
" Detector Locations", we stated:
"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 NFPA 72E.
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.
If the review indicates that compensatory measures are required, they will be specified in that report.
Any required changes will be implemented no later than startup following the first refueling outage."
This commitment was documented b, License Condition E.1.y the NRC in Reference (c),
. The issue at hand, in our judgment, is the lack of documentation of an evaluation of the deviations and changes from the criteria listed in NFPA 72E.
Corrective Action Taken and Results Achieved to the license for LaSalle Unit 2 has the following two conditions regarding this matter:
Prior to exceeding 5% power on Unit 2:
"E.1 The licensee shall conduct a review of the adequacy of its fire detector system installation.
This evaluation shall specifically address the number and location of fire detectors to sense a fire.
The licensee shall initiate compensatory measures in areas found deficient to assure adequate fire detection capability.
These compensatory measures will remain in place until permanent modifications to correct any deficiencies are made to the fire detection system."
Prior to startup following the first refueling outage:-
"F.1 The licensee shall complete all modifications to the fire detection system identified as being required."
The licensee is proceeding with this review and will complete modifications, if required, on the schedule specified in the license.
In the interim, as committed to by C. W. Schroeder letter to J. G. Keppler dated December 13, 1983, "In order to address the concern of Fire Detector loctions, an additional commitment was made as follows:
C.
A roving Fire Watch will be established in the. safety-related unmanned portions of the Unit 1 and Unit 2 Auxiliary Buildings.
The post orders will include:
1.
Areas to patrol 2.
Notification."
This roving fire watch has been established.
The NRC requested that Region III be notified prior to reduction of this roving fire watch.
As the re-evaluation is satisfactorily completed for specific-areas of the plant,' we will request reduction in the extent of the roving Fire Watch.
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Corrective Action Taken to Avoid Further Ncncompliance j
Based on the results of the review of the ' adequacy of the fire detector system installation, an evaluation will be made to determine if the current modification procedure is adequate.
Date of Full Compliance 1
CECO intends to justify the detector installation and recommend and i
implement modifications:1f required, according to the. Unit 2 License'
+
Condition schedule.- If the review determines the~ current' modification
-procedure needs revisions, these revisions:will be in place 1four l
months following this determination.
In accordance with C. W. Schroeder letter to J. G. Keppler dated i
December 13, 1983 a Roving Fire Watch has been established in the safety-related unmanned portions of the Unit 1 and Unit 2 Auxiliary i
Buildings as an interim compensatory action.
Based'upon the results of the. above reviews, compensatory measures may be increased or decreased as determined appropriate.
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- Alleged Item of Noncompliance 6.
10 CFR 50.48 requires each operating plant to have a fire protection plan that satisfies Criterion 3 of Appendix A to 10 CFR 50.
Criterion 3 of Appendix A to 10 CFR 50 establishes that fire protection structures, systems and components including fire detection and fire fighting systems be designed and provided to minimize the probability and ef fect of fires and explosions.cn1 structures, systems and components important to safety.
Criterion 1 of Appendix A to 10 CFR 50 is applicM)le "to fire protection systems, and components such as those required by 10 CFR 50.48 and requires quality standards and records commensurate with the safety functions to be performed.
Amendment 49 of the FSAR, dated May 1980, states, "LaSalle County Station follows the staff supplemental guidance contained in Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls, and Quality Assurance", dated August 29, 1977."
The N RC staf f supplemental guidance " Nuclear Plant Fire Pretnction Functional Responsibilities, Administrative Controls, and Quality Assurance", Attachment No.
4, Section 2.0(b)(3) requires that a fire watch trained and equipped to prevent combat fires, is presnet throughout any operations in which there is potential for fire that might damage safety related equipment during welding, grinding cutting and open flame work and references (NFPA 518).
Paragraph 431 of NFPA SlB adopted in 1977 states that, " Fire watchers shall have fire extinguishing equipment readily available and be trained in its use, including practice on test fires."
Contrary to the above, there is no documented evidence that offsite contractor personnel performing fire watch duty are required to be trained in the use of fire protection equipment, including adequate classroom and hands-on training on test fires.
This is a Severity Level V violation (Supplement I) (Units 1 and 2).
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Response
Commonwealth Edison Company does not believe-that this item is an item of non-compliance.
First, we take exception with the referencing of GDC-1 as the basis 'or this violation.
Reference (a) and its enclosure 1 provide an in-depth discussion of our. position in this matter.
- Second, we disagree that a requirement exists which imposes NFPA 51b_ training l
requirements for fire watches.
Reference (b)'and its Enclosure 4 provide en in-depth discussion of our position in this matter. ' Finally, it is our understanding, per a telecon between Hr. W.
S. Little and D. L.
Farrar, that this item. is not considered an item of noncompliance on Unit 2 because the unit was not licensed at the time of the inspection.
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. Notwithstanding our disagreements with the staff on this issue, we stated in C. W.
Schroeder letter to J.
G. Keppler dated December 22, 1983 that:
" Commonwealth Edison Company agrees that for NFPA 51b type situations, fire watches at LaSalle County Station will be provided in accordance with guidance Paragraph 43, NFPA 51b (1977 edition).
This has been implemented and will be continued unless other resolution is obtained through the regulatory process."
This commitment stands, pending completion of our discussions with NRR regarding Reference (b), Enclosure 4.
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