ML20132C672
| ML20132C672 | |
| Person / Time | |
|---|---|
| Site: | LaSalle, 05000000 |
| Issue date: | 01/23/1985 |
| From: | Johnston W Office of Nuclear Reactor Regulation |
| To: | Novak T Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20132C675 | List:
|
| References | |
| FOIA-85-264, FOIA-85-265 TAC-55649, TAC-55650, NUDOCS 8501300675 | |
| Download: ML20132C672 (7) | |
Text
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MEMORANDUM FOR:
Thomas M. Novak, Assistant Director
."i-for Licensing H L E, / -
Division of Licensing
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FROM:
William V. Johnston, Assistant Director Materials, Chemical & Environmental Technology
/dbw Division of Engineering w
SUBJECT:
FIRE PROTECTION SUPPLEMENTAL SAFETY EVALUATION C LASALLE COUNTY STATION UNITS 1 & 2 - FIRE DAMPER
. L/J i SURVEILLANCE PROGRAM Plant Name:
LaSalle County Nuclear Station Docket Nos.:
50-373/374 Licensing Stage: OR Milestone No.: TAC #55649/50 Responsible Branch & Project Manager:
LB #3; A. Boarnia CMEB Reviewer:
R. Fercuson Requested Completion Date: January 1, 1985 Revi e n-Status: Complete In our SER, we indiccted that we would reassess the adequacy of the technical specifications for fire damper surveillance on a generic basis, prior to the fire pericdic sarveillance r(uQired by the LaSalle Technical Specification 4.7.6.1 to be conducted (June 1985). By letter dated August 21, 1984, the licensee superseded the Merch 15, 1984 letter and proposed a surveillance program in a report "Tcchnical Basis of the LaSalle County Station Fire Damper Surveillance Program" August 1984. We have reviewed the proposed program in light of a technical specification that would establish a periodic test program for fire dampers. We have concluded that because, at present, such a test program for certain fire dampers is voluntary, the proposed program is acceptable.
Our evaluation and SALP input is enclosed.
G Y
William V..khnston, Assistant Director Materials, Chemical & Environmental Technology Division of Engineering
Enclosure:
As stated j
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See next page
Contact:
R. Ferguson gl j x28005 m 281335
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.e e-s JANA31985 Thomas M. Novak ~cc:
R. Vollmer D. Eisenhut V. Benaroya R. Ferguson T. Wambach D. Kubicki S. Pawlicki T. Sullivan A. Bournia A. Schwencer F. Rosa M. Srinivasan
- 0. Parr J. Wermeil J. Taylor S. Ebneter, Region I T. Conlon, Region II C. Norelius, Region IL E. Johnson, Region IV D. Kirsch, Region V s
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Supplemental Safety Evaluation Report LaSalle County Station Units 1 E 2 Docket Nos.
50-373/374 9.5.2 Other Items Related to the Station Protection Program 9.5.2.2 Fire Doors and Dampers In Supplement No. 8 to our Safety Evaluation Report, we indicated that the licensee is committed to develop a surveillance program to ensure operability of the dampers prior to exceeding 5 percent power and that prior to the first periodic surveillance, required by Technical Specification 4.7.6.1, to be conducted 18 months after the issuance of the license (June 1985), the NRC staff intends to reassess the adequacy of this Technical Specification on a generic basis.
By letter dated March 15, 1984, the licensee proposed a surveillance program of the fire dampers. By letter dated August 21, 1984, the licensee super. reded the March 15, 1984 letter with a report,," Technical Basis of the tasalle County Station Fire Damper Surveillance Program".
Before evaluating the licensee's proposal, we will sumarize the development
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of NRC's guidance regarding fire dampers.
Following the Brown's Ferry fire in 1975, (ht' hl'f's Special Reviev 6t64 irede recommendatiMA concerning fire damperu "The Review Group recornends thet ventilati0ft systtrt it, 311 (4(t Hiry [In ts be reviewed and upgraded as appropriatt 10 H;Ure thf f r ((.htfbed fut+;toi itg i f i1lPd durinc e firt:.
l4 jf further liii Tended thet j resent 6iigt4 ht
$1 l ; i l l t t I { ' tl P ! h p f i i.
I deut snive5 br pa in bh d p ill ti t
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j Capability for the control of ventilation systems to deal with fire and smoke should be provided, but such provisions must be compatible with requirements for the containment of radioactivity. These provisions and requirements may not tt mutually compatible and in some cases may be in direct conflict with each other.
For example, operating ventilation blowers to remove smoke may fan the fire; the same action may also result in a release of radioactivity, either directly by transport of radioactive particles with the smoke or by decreasing the effectiveness of the filters provided to contain the radioactivity.
It is obvious that some compromise will be necessary and that flexibility of operation may be needed, depending on the nature of any event that may occur. The pros and cons of each provision and requirement should be considered in the development of detailed guidance."
(NUREG-0050,pg.25)
The NRC's guidance adopted this recommendation:
"(J) Floors, walls and ceilings enclosing separate fire areas should have a minimum three hour fire rating.
... Penetration for ventilation systems should be protected by a standard " fire door damper" where required.
(Refer to NFPA 80, " Fire Doors and Windows.")"
(BTP APCSB 9.5-1, Section B.l.(j) ).
This same guidance was set forth in Appendix A to BTP APCSB 9.5-1.
In the
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July 1981 guidance, this guidante was revise slightly:
"(4) Penetration openings f~ vertilation sy,tems should be protected by fire dampers having a ratir; e:;u+calent to : at required of the t arr ier (see NFPA-90A
- Air Conditic-
- g ard Ventilar mg Systems").
Fles itie air duc-coupling in ventilatic-c filter syst; should be nonctebust:nie."
l (BTP CMEB 9.5-1, Secti.
5.a.(4).)
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At th6 time LaSalle was licensed, the Standard Technical Specifications required that fire dampers associated with gas suppression systems be tested for operation at least every 18 months. They also required a visual inspection of all fire dampers in fire rated assemblies at least once every 18 months.
At present, the staff is considerinc r" vising the s'endard 5t chnical Specifications to require that at 152 - 101 of all ite fire dampers be tested at least every 18 months.
This revision.as initiatec because sever Regiona~
spections revealed inoperable danpers due to t nding, dust a:cumulatirr;, or air flow.
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'm ari es fc es:
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The licersee's r ted ;rt;rar car There are 308 fir < daapers in the -. e barrit -r c' c : ' ' ' i The 1 see has t elistui te
'oups cf fire dimpers, i.e., (1) e t'
be tested end (2) tk that wilt inspected. Group 1 (;ntains per, Group 2 contains 265.
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For those t pers that wi"1 be tes-the licensee propose-a ter* frequency J
based on AS:"Section XI, RJ1es -
Servicetr(45ectiffifn
.r Power Plant Cr ronents, Subarticle IWB-2400. Table :
-2417-1 (Inspection Progr em B).
Thus,f:
a 10 year inspection interval 'cr 43 cc -
. the sample size would be:
Inspection
[i 31e Sire i 5 ample Size feo, Period (years) in.
rax.
rin.
max.
3 16 34 7
14 7
50 67 21 29 10 100 100 43 43
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The licensee states that (1) modifications will be required on 15 dampers to permit the visual inspection required by the present technical specifications at an estimated cost of $9,770, (2) modifications will be required on 22 dampers to permit the test of Group 1 dampers as proposed by the licensee at an estimated additional cost of $19,680, and (3) modifications will be required on 88 dampers to permit tests of all dampers as may be required by the staff's recommended test program at an estimated additional cost of $82,050.
At the present, time the licensee's testing program for fire dampers that are not associated with gas suppression system is voluntary. However, the staff is ir, the process of revising such test requirements and the need for back-.
fir.ing such requirements. The proposed program is not as thorough as the staff's proposed program.
Because the test prcgram is voluntary, we conclude that it is acceptable.
v LaSalle Units 1 & 2 Input to the SALP Process A.
Functional Area:
Fire Protection - Fire Damper Surveillance Program 1.
Management involvemer>t in assuring quality:
The applicant's activities exhibited evidence of prior assignment of priorities to fire protection safety. A qualified fire protection engineer was retained to resolve technical issues.
Rating Category 2 2.
Approach to resolution of technical issues: The applicant's submittal shows a clear understanding of the specific fire protection principles involved with the resolution of technical issues. The applicant's additional fire protection commitments reveal a conservative approach toward providing an adequate level of safety.
v Rating Category 2 3.
Responsiveness to NRC Initiatives: The applicant provided timely l
responses to our requests for information.
I Rating Category 2 I
.