ML20148G642
| ML20148G642 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 12/17/1987 |
| From: | Lentine F COMMONWEALTH EDISON CO. |
| To: | Holmes J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 3972K, NUDOCS 8801260560 | |
| Download: ML20148G642 (4) | |
Text
C:mm:nw:alth Edis:n One First National Plaza. Chicaco. Illinois Accress Repfy to. Post Off:ce Box 767 Chicago, lilinois 60690 0767 December 17, 1987 Mr. J. Holmes U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137
Dear Mr. Holmes:
During the NRC Audit of November 16 through November 20, 1987, a potential violation was identified with respect to the implementation of Technical Specification criteria for required fire barriers.
The purpose of this letter is to address the technical issues associated with this item and to show that Zion Station has been in compliance with its existing technical specifications for required fire barriers.
Mr. Dennis Kubicki of NRR was concerned that fire barriers required to comply with the criteria of Appendix A to BTP 9.5-1 were not being periodically surveilled in accordance with technical specification criteria.
Based on a review of this issue, which involved reconstructing the thought processes initially utilized to identify barriers which require surveillance,
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we have concluded that Zion Station is in compliance with technical specification criteria for required Appendix A barriers.
The basis for our conclusion is provided as follows.
Technical Specification criteria / Appendix A Fire Barriers section 3.21.6 and 4.21.6 of the technical specifications for Zion i
Station identify the Limiting condition for operation (LCO) and Surveillance l
Requirement, respectively, for Penetration Fire Barriers.
The technical specifications require that the following criteria are met:
(a)
"All penetration fire barriers protecting safety related areas shall be functional at all times."; and (b)
"Each of the safety-related penetration fire barriers shall be verified to be functional by a visual inspection."
The technical specifications go on further to identify the LCO's associated with identification of non-functional barriers and the criteria for performing visual inspections.
The technical specifications do not, however, provide a specific identification of those barriers which require review.
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J. Holm5s Dscambar 16, 1987 In order to ensure that the technical specification criteria for Appendix A penetration fire barriers are met, tabular listings of those safety-related barriers which must be surveilled have been provided in ZAP-04 (previously identified as ZAP-02A) and PT-207.
Per technical specification 3.21.6, all penetration fire barriers E.r.otecting safety-related areas shall be functional.
It is necessary to review the 1977 Fire Protection Report (otherwise referred to as the 1977 Fire Hazards Analysis) and BTP 9.5-1 Appendix A criteria in order to identify those penetration fire barriers which have been relied upon to protect safety-related areas.
Mr. Kubicki's concern related to those portions the Turbine / Auxiliary Building dividing wall (commonly referred to as G wall) not currently addressed by surveillance procedures. Given the bases for fire areas and fire zones as identified in the 1977 Fire Hazards Analysis and the guidelines of Section F of Appendix A, it can be demonstrated that these portions of G wall which are not currently surveilled do not require surveillance to comply with Appendix A technical specification criteria. Those portions of G wall, not currently surveilled, separate the following plant locations (identified based on the Appendix R designations for each location) from the Turbine Building:
El. 642 Non-ESS Switchgear Rooms (Fire Area 5.4-1 and Fire Area 5.4-2)
Auxiliary Building Offices and Kitchen (Fire Zone 18.6-1)
Shift lEngieers Office / Tech Support Center (Fire Zone 18.6-2)
Unit 2 Enclosed Stairwell (Fire Area 18.6A-2) l El. 617 Waste Gas Room and Spent Resin Storage Area (Fire Zone 14.4b-0 and Fire Zone 14.4D-0)
Auxiliary Building, Mezzanine Level (Fire Zone 11.5-0)
Unit 1 Enclosed Stairwell (Fire Area 18.6A-1)
Rad Protection Offices and Laboratories ' Fire Zone ll.5D-0) l Unit 2 Enclosed Stairwell (Fire Area 18.6A-2) 1 El. 592 Drum Fill Area (Fire Zone 14.3B-0)
Radwaste Annex, Truck Loading Zone (Fire Zone 14.3C-0)
Auxiliary Building, Ground Floor (Fire Zone 11.4-0)
Unit 1 Enclosed Stairwell (Fire Area 18.6A-1)
Unit 2 Enclosed Stairwell (Fire Area 18.6A-2)
Auxiliary Building Radwaste Storage Room (Fire Zone 11.4D-0)
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J. Holmas Dscambar 16, 1987 El. 579 Drum Storage Area (Fire Zones 14.2A-0 and 14.2B-0)
Auxiliary Building, Miscellaneous (Fire Zone 11.3-0)
El. 560 Auxiliary Building, Basement Level (Fire Zone 11.2-0)
With the exception of Fire Zone 11.2-0 and 11.3-0 (Auxiliary Building Basement and Miscellaneous Levels, respectively), the plant locations identified above do not contain safety-related equipment.
As a result, the penetration fire barriers which separate these plant locations from the Turbine Building do not protect safety-related areas. Therefore, the barriers of concern did not, and currently do not, require surveillance in order to be in compliance with technical specifications sections 3.21.6 and 4.21.6.
Fire Zones 11.2-0 and 11.3-0 do contain safety-related equipment.
The component cooling water (CCW) pumps and auxiliary feedwater (AFW) pumps are located on the 560 ft. and 579 ft. elevations of the Auxiliary Building in Fire Zones 11.2-0 and 11.3-0, respectively.
The G wall separates these zones from the Turbine Building.
However, a review of the protection which is provided and a detailed comparison of the protection with the criteria of Section F.ll of Appendix A, along with the relevant documentation associated with the NRC's review of the 1977 Fire Hazards Analysis, clearly shows that those portions of G wall separating Fire Zones 11.2-0 and 11.3-0 from the Turbine Building were not relied on to pro,tect the CCW and the AFV pumps.
Section F.ll of Appendix A to BTP 9.5-1 states that rooms housing safety-related pumps should be protected by automatic sprinklers unless a fire hazards analysis can demonstrate that a fire will not endanger other safety-related equipment required for safe plant shutdown. CECO proposed to utilize local application CO2 systems in lieu of sprinklers to protect the CCW and AFW pumps. Subsequent correspondence between Ceco and the NRC eventually resulted in the NRC's acceptance of local application CO2 suppression systems for the CCW and AFV pumps.
Therefore, the criteria of Section F.ll of Appendix A to BTp 9.5-1 was met by the provision of the local application CO2 suppression systems.
No reliance was placed on fire barriers.
(In fact, with the pumps located in the open floor areas and not in enclosed rooms, any discussion of barriers would have been inappropriate.)
Therefore, the non-surveillance of those portions of G wall separating Fire Zones 11.2-0 and 11.3-0 from the Turbine Building does not violate existing Appendix A technical specification criteria for penetration fire barriers.
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s J.' Holmes December 16, 1987-j In' summary, those portions of G-wall not currently addressed by j
. surveillance procedures are no_t "barriers protecting safety related areas."
The areas in questions either do not contain safety-related equipment, or contain equipment for which specific protection has been provided wihout i
reliance on barriers (CCW and AFW pumps).
The list of barriers provided in the surveillance procedures correctly accounted for these facts, and is consistent with the licensing basis. The plant remains in compliance with Technical Specifications 3.21.6 and 4.21.6.
i If there are any questions regarding this matter, please contact this office.
Very truly yours, j
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F. G. Lentine PWR Licensing Supervisor 1m cc:
E. Fuerst D. '.fozniak W. Stone i
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