ML20087H126

Forwards Info & Rev 1 to Procedure LTS-1000-36, Fire Damper Visual Insp, Per NRC Request & IE Insp Repts 50-373/83-44 & 50-374/83-48

ML20087H126
Person / Time
Site:	LaSalle
Issue date:	03/13/1984
From:	Schroeder C COMMONWEALTH EDISON CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML20087H129	List: ML20087H126 ML20087H150
References
8268N, NUDOCS 8403200256
Download: ML20087H126 (5)

Text

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[' Commonwealth Edison

) one First National Pfizz, Chicago. lilinois

( O '7 Address Reply to: Post Offica Box 767 .

.y _ ,f / Chicago. Illinois 6%90 l March 13, 1984 Mr. Harold R. Denton, Director ,

Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission

- Washington, DC 20555

Subject:

LaSalle County Station, Units 1 and 2 Fire Protection NRC Docket Nos. 50-373 and 50-374 References (a): LaSalle County _ Station Unit 2 Facility Operating License NPF-18 (December 16, 1983).

(b): C.W. Schroeder letter to H.R. Denton dated November 23, 1983.

l (c): Inspection Report Nos. 50-373/83-4A and 50-374/83-48.

Dear Mr. Denton:

This letter and attachments were prepared in response to the following three items:

1) Reference (a) identified condition 2.C (15)(h) which states:

Prior to exceeding five percent power, the licensee shall provide a surveillance program for NRC staff approval to ensure operability of the fire dampers. 'This program.will include a periodic operability test of a sample popultion of accessible dampers.

2) Reference (b) contained issue 8(b) which states:

Commonwealth Edison Company meets all current requirements of Appendix R and the Standard. Technical ~ Specifications regarding H the operability surveillances of fire doors and fire dampers. I The NRC_has a concern, however,_that the current requirements  ;

may not be sufficient to assure operability.of fire doors and l

~l fire dampers for the forty: year life of the plant.

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H. R. Denton March 13, 1984 COMMITMENT Commonwealth Edison Company agrees to develop a surveillance program to assure the long term operability of dampers. This program, which will include periodic operation of a sample population _of accessible dampers, will be in place prior to

~ exceeding 5% power and will be reviewed for technical adequanny by a fire protection engineer. Surveillances as a result of this program will be initiated prior to startup following the first refueling outage.

3) Reference (c) identified unresolved items 50-373/83-44-13 and 50-374/83-48-19 concerning this matter and referred them to NRR for resolution.

It is reque=ted the above three matters be closed based on the following information.

1. The fire dampers at LaSalle County Station were purchased in 1976 and the applicable NFPA Standard is the 1976 edition of NFPA 90A.

Appendix B in NFPA 90A is not mandatory and is included in the standard for guidance only. According to Appendix B, Article B-7 of the 1976 standard, "Each fire door and fire damper should be examined once a year, giving attention to hinges and other moving parts, to see that it is in good operable condition". This requirement is satisfied by a periodic visual iraspection of all fire dampers. If the visual inspection reveals damage or corrosion, corrective action can be taken to resolve the problems. LaSalle County Station procedure LTS-1000-36 meets these requirements. A, copy of this procedure is included as Attachment A for information only (future revisions will Technical be controlled Specification in accordance with the LaSalle Unit 2 Administrative:Section).

2.

CECO's position identified in 1. above has been concurred with by

' Engineers: Engineering'in a March 1,-1984 letter to Sargent and-Lundy Schirmer

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"We have reviewed NFPA Standard 90A, Appendix B, regarding procedures to be utilized at LaSalle County Station (LSCS) and the scheme of  ;

operation of_the air handling systems serving selected areas.

We concur that a visual inspection program for-fire dampers at LSCS meets the intent of NFPA'90A~regarding periodic maintenance, provided that further investigation, including operation of the damper,'should be conducted if the visual inspection reveals signs of_ damage, wear

corrosion, etc., which may affect the operation of the damper. It Is my understanding that procedures in effect at LSCS incorporate the above.- Such procedures _would constitute good fire protection-t

' engineering the industry."~

practice'and would be consistent with actual practices in

W H. R. Denton March 13, 1984

3. A review of LER history of failed fire dampers, as maintained by INPO and included as Attachment 8, does not indicate problems that a good visual surveillance would not discover and correct.

CONCLUSION We are convinced that fire dampers which are initially tested for operability to verify correct installation can be maintained operable throughout their lifetims by a good visual inspection of all fire dampers. LTS-1000-36 satisfies this requirement.

ADDITIONAL INFORMATION l

NFPA.90A (1983)

Although the 1983 edition of NFPA_90A is not applicable to the LaSalle Station. fire dampers, we have also reviewed the requirements of Appendix B, Article B-7, to the 1983 standard. The following requirement i

- was added to this latest edition: " It is desirable to operate doors or dampers with normal system airflow to assure that they are not held open by the air stream". NFPA 90A technical committee's unofficial interpretation of this requirement is as follows (an official interpretation from the the committee has been requested by S&L letter dated March 7, 1984):

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l. Fire dampers in systems that shutdown upon detection of smoke need not be tested ender airflow conditions.

2. Fire dampers in engineered smoke control systems that are designed to continue operation upon detection of smoke'should be

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tested under air flow conditions.

s BACKGROUND There are 292 fire dampers in the plant at the LaSalle County-

- Station. 102 of these are in systems that automatically shutdown on detection of-smoke. The following 190 dampers are in systems that do'not-

- shutdown automatically with smoke in the plant._ Areas' served by these-systems have smoke detectors that alarm locally and in the Control Room.

System Total

VC-(Control Room) 19 VE (Auxiliary Electrical Equipment Rooms) 27 VH-(Lake Screen House) 1 VR (Reactor Building). 24 VT (Turbine Building) 51~

1VW (Radwaste Building) 15 l VX (Switchgear1 Rooms) 1651 VYf(Equipmenth Core Cooling

. Systems)-

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71

. Total IPU e- - ,- ,w - g ,

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4 H. R. Denton March 13, 1984 1

COMMITMENTS

, 1. The 102 fire dampers in systems that automatically shutdown on smoke

,. detection (VA, VD, VL,.VV) need only be visually inspected i

. periodically in accordance.with Procedure LTS-1000-36.

2. The VT, VW, VX, and VY systems should remain operational on area smoke detection and be shutdown at the discretion of personnel l- responding to a smoke' alarm. To accomplish manual shutdown of these systems, LaSalle's fire fighting procedures will incorporate this j requirement prior to startup following:the first refueling outage.at Unit 2. Therefore, the 138 fire dampers in these systems need'only be periodically inspected visually in accordance with Procedure

. LTS-1000-36.

3. Systems VC and VE should not be shutdown upon detection of smoke.

These systems are designed to continuously operate to protect IEEE-323 qualified electrical equipment in the Control Room'and Auxiliary Electrical-Equipment. Rooms. In the event of-serious' fire

} these ventilation systems can be shutdown by-trained personnel.

The two lake screen house (VH) fire dampers are in walls-betweeen the pump house and diesel-driven fire pump rooms. 'These dampers need not be shutdown on detection of smoke, they will close on temperature

.(1650F) . :With a fire damper closed, cooling air for the diesel engine and pump is obtained from outside the building through a louver with a-control-damper on the inside..

To control contaminants,'the Reactor Building System (VR) will j

continue.to operate in. order to maintain a negative. pressure in the

. Containment Building. The fcur fira dampers.in the VR system are-in the

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supply ducts to the two elevator machine rooms,=and .n openings'.betweenf the. elevator machine rooms and the-fueliloading bay.

. Thetaccessible dampers in VC, VE, VH and VRESystems~willsbe

.testedLwith systems = operating'tol assure'that,they_will.close under

-airflow conditions 1priorato startup following the first refueling' outage

, at Unitt2. ~If-the dampers fail-to:close during this' test, they willLbe.

1 modified or. the system will be manually L shutdown -in1accordance with'

' Commitment No'. 2. Having demonstrated that these dampersiclose!under. ~

system airflow,.there is-no need=for-periodic operability testing;-

L however periodicivisua11inspectionxin1accordance/withLProcedure-LTS-1006-36 will be : performed. -

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H. R. Denton March 13, 1984 To the best of my knowledge and belief the statements contained herein and in the enclosures 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 and contractor employees.

Such information has been reviewed in accordance with Company practice and I believe it to be reliable.

If there are any questions regarding this matter, please contact this office.

Enclosed for your use are one signed original and ten (10) copies of this letter and the enclosure.

Very truly yours, W M &M C. W. Schroeder Nuclear Licensing Ad.inistrator 1m 4

cc: Dr. A. Bournia - Federal Express NRC Resident Inspector - LSCS 8268N

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