ML20090G240
| ML20090G240 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 06/20/1984 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20090G227 | List: |
| References | |
| 8823N, NUDOCS 8407240288 | |
| Download: ML20090G240 (8) | |
Text
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'N Commonwealth Edison t
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Addrsss Riply to: Post Ofhce Box 767
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Chicago, Illinois 60690 June 20, 1984 Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
Byron Generating Station U"'ts 1 and 2 I&E Inspection Report Nos. 50-454/83-62 and 50-455/83-42 Reference (a):
April 17, 1984 letter from W. S. Little to Cordell Reed.
Dear Mr. Keppler:
Reference (a) provided the report of an inspection of Byron fire protection activities which was conducted in December, 1983, and January, 1984.
During that inspection certain activities were February and March, found to deviate from Commonwealth Edison's commitments to the NRC.
Attachment A to this letter contains Commonwealth Edison's response to the Notice of Deviation appended to reference (a).
Please direct further questions to this office.
Very ruly yours, I Z _ __
D'. L. Farrar Director of Nuclear Licensing im 8823N 6
8407240288 840737 Qh DR ADOCK 05000454 PDR
ATTACHMENT A RESPONSE TO NOTICE OF DEVIATION DEVIATION 1 Section 3.1.e.(1) of the Byron Fire Protection Report commits the licensee to comply with the NRC position from BTP CMEB 9.5-1 which states:
"The fire protection program (plans, personnel, and equipment) for buildings storing new reactor fuel and for adjacent fire areas that could affect the fuel storage area should be fully operational before fuel is received at the site.
Such areas include those whose flames, hot gases and fire-generated toxic and corrosive products may jeopardize safety and surveillance of the stored fuel."
Contrary to the above, the fire protection program for the buildings storing new fuel was not fully operational prior to receiving
-fuel onsite.
The licensee had no plan or program developed to evaluate the' fire hazards and determine what fire protection / prevention systems were needed prior to the receipt of fuel.
Response to Deviation 1 (and items 83-62-01, 02, 04, and 05)
Extensive efforts were taken to implement appropriate aspects of the fire protection program prior to receipt of nuclear fuel.
The inspector raised concerns regarding. demonstrations of operability for fire hose stations, fire pumps and water supplies, and fire detectors for the. fuel handling area.
These items are addressed individually.
A.
Fire Hose Stations:
1.
Finding:
The inspector stated that nothing had been done to verify that standpipe fire hose stations on the refuel floor had been tested and demonstrated to be operable in accordance with section 7-1.1 of NFPA 14.
Response
When regard to the' refuel floor standpipes, Byron Station will comply with the intent of Section 7-1.1 of NFPA 14.
The standpipe hose stations have been demonstrated to be operable in accordance with the requirements of ANSI N45.2.1 (1973) and ASME III.
. Project Engineering and our fire protection consulting engineer
.will evaluate these previously performed tests to determine whether they fulfill the intent of an NFPA hydrostatic test for the refuel floor standpipes by June 30, 1984.
}
.- 2.
Finding:
The inspector noted that section 4-4.3.1 of NFPA 14 requires fire hoses to be connected to their respective standpipes such that the stations will be ready for use.
Response
The standpipes on the refuel floor and the adjacent areas have been connected to their respective fire hoses and are ready for use.
3.
Finding:
Normal fire protection system water pressure is 150 psi.
The fire pumps are rated at 2500 gpm at 168 psi.
Therefore a pressure exceeding 100 psi exists at standpipe outlets on the refuel floor and adjacent fire areas and throughout the plant.
Pressure reducers were not provided on standpipe outlets on the refuel floor and throughout the plant.
Section 4-4.2 of NFPA 14 states that where the pressure at any standpipe outlet exceeds 100 psi, an approved pressure reducing device shall be installed at the outlet to reduce the pressure with required flow at the outlet to 100 psi unless specified by the Fire Department.
Response
Byron Station will utillze standpipes with outlet pressures which exceed 100 psi.
In accordance with NFPA 14 (1981) 4-2.2 an our fire protection consultants and recommendations, Byron Station will post all standpipes with outlet pressures greater than 150 psi with a caution notice and has trained the Fire Brigade on the use of high pressure hose stations at up to 200 psi.
Implementation and installation of caution notices will be completed by July 22, 1984.
4.
Finding:
Section 2.3.12.1 of the fire hazard analysis (fuel handling building) states in part, "Non-fogging type nozzles are used for the manual hose stations located in t_his area to preclude conditions of optimum moderation of the new fuel storage racks".
The proper type of nozzles are required on fire hose stations under Section 4-5 of NFPA 14.
i Response:
Subsequent to this inspection, Byron Station has replaced the nozzle tips on.the refuel floor hose stations with the proper
- non-fogging type shut-off nozzles.
The installation of these non-fogging type, shut-off nozzles on the refuel floor includes all applicable hose statier. locations as identified during a previous NRC inspect!On.
J B.
Fire Pumps and Water Supplies Finding:
l
'- The inspector noted that he was not provided acceptable. documentation or. objective evidence that the station fire pumps and the backup fire suppression water supply system had been demonstrated operable in accordance with Chapter 12 of NFPA 20.
Also, portions of the fire protection' water supply system were not installed in accordance with NFPA 24.
Response
Subseauent to this inspection, dance with Chapter 12 of NFPA 20 tests demonstrating the o the station fire. pumps in accor (1983) were performed and are currently being reviewed by the station and by our fire protecton consulting engineer.
This documentation includes controller testing, pump vibration readings, pump curve
- verification and motor speed data.. Certified curves for the fire pumps are on-site and available for review.
An engineering analysis performed by our fire protection consultant has determined that our fire protection capability is not degraded by not having cross-tie isolation valves installed.
These valves are not necessary and are therefore not included in the. Byron fire protection system design.
With regard to demonstrating the operability of the backup fire protection water supply, the multiple redundancy of our fire protection water supplies fulfills the intent of the requirements of NFPA 20, Chapter 11.
With regard to acceptance, operation and E
maintenance testing of the backup fire protection water supplies, our fire protection consultant has determined that the non-essential
. service water system (WS) and essential service water systems (SX) are adequate backup fire protection water supplies.
Performance-
- testing of the SX pumps is complete.
The WS pumps will be tested to verify their performance.
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. Flow instrumentation to support verification of WS pump performonce,has been ordered, but has not been received.
Verification of manufacturer's pump curves for the WS pumps will
- be completed by September 1,1984.
C.-
Fire Detectors Finding:
Based upon inspection observations, the inspector felt that the fire detectors in the fuel handling building and adjacent fire areas were not properly installed with respect to the number and location of detector units.
He also believed that the ultraviolet detectors installed in the new fuel storage area at elevation 426 feet do not alarm and annunciate in the control room.
No ionization fire detectors are installed in this area.
Furthermore,yno preoperational test results or other documentation was provided to demonstrate the operability of fire detectors installed in the fuel handling building and adjacent fire areas prior to the receipt of fuel onsite.
Response
The Ultraviolet (UV)-detectors in the new fuel storage area provide control room and not local annunciation, contrary to the inspection report.
The UV detectors in the new fuel storage area are being supplemented with products of combustion (POC) type detectors as per the inspectors recommendation.
Also, new detectors will be added in this area to address NRC comments on the adequacy of detector locations.
Additionally, Byron Station had posted a continuous fire watch in the new fuel area to comply with this commitment on an interim basis.
This watch has been in effect since fuel was initially received.
Installation and testing of all detectors in the new fuel storage area will be completed by August 15, 1984.
8823N
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. t DEVIATION 2 i
Section 3.1.a.(5)(a) of the Byron Fire Protection Report commits the licensee to comply with the NRC position from BTP CMEB 9.5-1 which states:
"The position responsible for formulation and implementation of the fire protection program should have within his organization or as a consultant a fire protection engineer who is a graduate of an engineering curriculum of accepted standing and shall have completed not less than 6 years of engineering attainment...."
Contrary to the above, at the time of the inspection, a fire protection engineer was not employed within the licensee's onsite organization or as an outside consultant to provide input into the plants design, and formulation and implementation of the fire protec-tion program.
The fire protection engineer who participated in writing the fire protection report had no input in the formulation and implementation of the fire protection program at the site.
Response
Byron Station has contracted Marsh and McLennan, Protection Engineers.
This firm meets FPR requirements, and will review fire protection design, pre-operational tests, acceptance tests, surveillance tests and development and implementation of the fire protectjon program.
Byron Station has also placed a degreed fire protection engineer in its Technical Staff.
His expertise will be utilized in the areas of review and writing of fire protection surveillance tests, fire protection pre-operational tests and in the development of the fire protection program.
In order to comply with commitments made in the FPR, Byron Station will continue to employ the use of a fire protection consultant or an of f-site fire protection engineer until such time that a qualified cngineer exists at the station.
8823N
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DEVIATION 3 Section'3.1.a of the Byron Fire Protection Report describes the
.NRC position on the Fire Protection Program.
The licensee's response states, " comply" and in their response in Section 3.1.b.3 and 4, state that during the construction and operating phase the Fire Protection Coordinator will see that tests of new -fire fighting equipment and automatic fire. protection systems are conducted to ensure each is in good condition and operating satisfactorily and is maintained in good operating. condition.
Contrary.to the above the licensee had not tested and had no plans for-inspecting or testing to assure the following were in good operating-condition prior to obtaining an operating license or initial fuel ~1oading:
(1)
Fire doors and dampers
'(2)
Fire penetration seals (3)
-(4)
Underground loops,_ fire hydrants and-primary fire protection water supply (5). Fire hose and fire hose stations in combination with the automatic sprinkler system (6)
Fire pumps Response:-
(1) & (2) - Fire doors, fire dampers and fire penetration seals will not be pre-operationally tested for operability under the FSAR pre-operational ~ testing program.
However, fire doors, fire dampers, structural steel firepronfing, electrical penetration seals and mechanical. penetration seals will be verified to be operational during periodic surveillance conducted in accordance with technical specification requirements.
Initial verification of the operability of the fire doors,
. fire dampers, structural steel fireproofing and mechanical penetration seals will be performed by September 15, 1984.
Initial verification of the operability of the electrical penetration seals will be performed by Project Construction Department by September 15, 1984.
(3) - Additional emergency lighting is being installed to satisfy NRC comments and will be tested under system demonstration LL-48.20.
Installation and testing of emergency lighting will be completed by September 1, 1984.
e.
. (4) - Byron Station will comply with the intent of Section 7-1.1 of NFPA 14.
The underground loops, hydrants and the primary water supply system have been hydrostatically tested in acordance with NFPA 14, with the exception of the fuel handling building and auxiliary building portions of the primary water supply.
Project Engineering Department and our fire protection consulting engineers will evaluate previously performed tests to determine if these tests fulfill the intent of an NFPA hydrostatic test by June 30, 1984.
(5) - The sprinkler system has now been hydrostatically tested in accordance with NFPA.
Additionally, an analysis of the fire protection water demand with concurrent use of sprinklers and hoses has satisfactorily demonstrated the system to be adequate.
(6) - As previously stated, we feel that the multiple redundancy of our fire protection water supplies excuse us from the requirements of NFPA 20, Chapter 11 with regard to acceptance, operation and maintenance testing of the backup fire protection water supplies.
- However, calculations have been performed by our fire protection consulting engineer to demonstrate the suitability of non-essential service water (WS) and essential service water (SX) as the backup fire protection water supplies.
Performance testing of the SX pumps is complete.
The WS pumps cill be tested to verify their performance.
Flow instrumentation has been ordered to support performance
- verification of the WS pumps, but has not been received.
Verification of manufacturer's pump curves for the WS pumps will be completed by September 1, 1984.
CS23N
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