ML20150B621
| ML20150B621 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 05/25/1988 |
| From: | Bliss H COMMONWEALTH EDISON CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20150B607 | List: |
| References | |
| 4635K, NUDOCS 8807120090 | |
| Download: ML20150B621 (21) | |
Text
f;
. '. -.,f~'N Cosmonwealth Edloon
(
) One First National Plaza. Chicago, luinois
] Address Reply to: Post Office Box 767 (V Chicago,lilinois 60690 0767 v
May 25, 1988 Mr. A. Bert Davis Regional Administrator U.S. Nuclear Regulatory Commission Region III.
799 Roosevelt Road Glen Ellyn, IL. 60137
Subject:
Zion Nuclear Power Station Units 1 and 2 Response to NRC Inspection Report Nos.
50-295/87-034 and 50-304/87-035 NRC Docket Nos. 50-295 and 50-304 References 1: April 8, 1988 letter from H.J. Miller to Cordell Reed 2: September 22, 1987 letter from I.P. Warner (S&L) to D.B. Wozniak (Referenced in Violation 1) 3: December 17, 1987 letter from F.G. Lentine to J. Holmes (Referenced in Violation 2) 4: December 16, 1987 letter from F.G. Lentine to J. Holmes (Referenced in Violation 3) 5: May 9, 1985 letter from P.C. LeBlond to H.R. Denton (Referenced in Violation 4)
Dear Mr. Davis:
This letter is in response to the inspection conducted by J. Holmes, R. Hodor, and K. Parkinson of your office during the period of November 16, 1987 through March 14, 1988, of activities at Zion Nuclear Power Station.
Reference 1 jndicated that certain activities appeared to be in noncompliance with NRC requirements. Commonwealth Edison Company's response to the notice of violation is provided in Attachment A to this letter.
An extension of the due date for our response until May 20, 1988 was granted by telephone on May 2, 1988 by R. Gardner. Additional extensions were granted by telephone by F. Jablonski on May 20, 1989, and by J. Harrison on May 24, 1988.
6807120090 880706 PDR ADOCK 05000295 Q
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1 A.B. Davis May.25, 1988 For the reasons described in Attachment A, Commonwealth Edison does not believe that the item identified in Violation 2 is a violation of NRC requirements.
The item identified in Violation 4 is a licensee-identified item that appears to meet the tests of 10CFR 2 Appendix C for an item for which the NRC may elect not to issue a notice of violation.
Therefore, it is respectfully requested that these violations be withdrawn.
Reference 1 also requested an update to the schedule provided in our letter of January 21, 1988. A revised list of actions and schedules, which supercedes that of January 21, 1988, is provided in Attachme:.t B.
Although several of the items have been completed, the schedules for certain equipment modifications have been extended, due to recent changes that have increased the complexity of our modification process and outage scheduling considera-tions. Commonwealth Edison will continue its efforts to complete all Appendix R work in the most expeditious manner possible.
Attachment C contains References 2 through 5.
please address questions regarding this matter to this office.
Very truly yours, Henry Bliss Nuclear 1,1 censing Manager
/klj Attachments cc: Zion Resident Inspector J. Norris (NRR) f 4635K i
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ATTACHMENT A RESPONSE TO NOTICE OF VIOLATION VIOLATION 1.
10 CFR 50.48 requires that each operating Nuclear Power plant have a fire protection plan that satisfies criterion 3 of' Appendix A to 10 CFR 50.
Criterion 3 requires that structures, systems and components important to safety be protected against the effects of fires and explosions. To satisfy the requirements of Criterion 3, the Licensee was required to meet the technical requirements of Appendix R to 10 CFR 50.
Section III.L of Appendix R to 10 CFR 50 requires procedures to be in effect to implement the alternative shutdown capability. The licensee was also required to meet the technical requirements of Appendix R to 10CFR 50 in accordance with the 10CFR 50.48(c) schedule. The date required by this schedule was July 7, 1983.
In addition, Plant Operating Technical Specification No. 6.2.1.K requires written procedures and implementation of these procedures for the Fire protection program.
I Contrary to the above, safe shutdown procedures required by Section III.L of Appendix R to 10CFR 50 and plant operating Technical Specification No.
j 6.2.1.K were not implemented as follows; a.
As of November 18, 1987, no approved operating procedures were implemented to achieve hot shutdown following a fire in the Inner Cable Spreading Room and the Outer Cable Spreading Room.
b.
As of November 18, 1987, no approved procedures were established to mitigate spurious operation of equipment or high impedance faults in areas not required for remote shutdown.
Response to item (a)
Commonwealth Edison acknowledges this item as a violation of NRC requirements. The required schedule for implementation of alternate j
shutdown capability was specified in 10 CFR 50.48(c)(4) as "before startup after the earliest of the events given in paragraph (c)(3) commencing 180 i
days after NRC approval." The NRC has not yet approved our alternate shutdown capability. However, the NRC had approved on March 17, 1983, an earlier set of proposed modifications which were never implemented because it was later recognized that they would not achieve compliance with Appendix R (reference Generic Letter 83-33).
If one were to assume that the 50.48(c)(4) "clock" started on March 17, 1983, the resulting impleuentation dates would have been June 18, 1985 for Zion Unit 1 and July 10, 1984 for Zion Unit 2.
However, on November 21, 1983, commonwealth Edison notified the NRC of its intention to propose new compliance measures and requested a schedular exemption from the requirements of 10 CPR 50.48(c).
. Interim procedures for alternate shutdown were developed.in April, 1984.
These procedures were reviewed by NRR and walked-through in a subsequent NRC inspection in February, 1985, and were judged acceptable. Although an interim alternate shutdown procedure was not require 1 for the cable spreading rooms due to the presence of the permanently installed detection and suppression systems, it was noted that the interim alternate shutdown procedure for the main control room (FOP-1).was generally applicable to the cable spreading rooms as well.
As the Appendix R modifications were completed,-POP-1_was revised to incorporate the new hardware. The most significant revision resulted from the installation of isolation / transfer switches in the cable spreading rooms for certain indicators and.the power supply to the pressurizer l
3 PORV's.
Under the interim procedure, the operator obtained certain process readings by use of a digital volt meter in the auxiliary electric room and de-energized power to the PORV's by cutting a cable. Under the revised procedure, those actions were accomplished by operatio.; of the transfer switches.
As a result of an internal review conducted in September, 1987,-
Consonwealth Edison identified that the new FOP-1 procedure was no longer fully applicable to a fire in the cable spreading rooms, because access to i
the cable spreading rooms was required for operation of the new transfer switches.
j CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED Draft procedure revisions were prepared in September, 198'7.
These were prepared in the form of appendices which provide guidance that supplements or supercedes certain of the steps in FOP-1 for fires in the cable spreading.ooms.
In response to concerns raised in the NRC's inspecticn, i
l a Standing Order was issued on November 19, 198~1, and subsequently l
superceded by a February 2, 1988 Standing Order, which incorporates the necessary guidance until approved final procedures can be implemented.
i CORRECTIVC ACTION TO BE TAKEN TO AVOID FURTHER VIOLATION The procedures will be implemented by June 30, 1988.
- 1 DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED e
The station will be in full compliance by June 30, 1988.
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EESPONSE TO ITEM (b) j Commonwealth Edison acknowledges this item as a violation of NRC require-ments.
The response to Question 5.3.8 in Generic Letter 86-10 indicated that licensees should consider multiple high impedence faults (MHIP's) and recommended that written procedures for clearing them be developed.
Commonwealth Edison determined in September, 1987, that the alternate shutdown procedure (fop-1) already contained the recommended guidance (see reference 2).
As discussed with the NRC's contractor reviewer K.
Parkinson during the November, 1987 inspection, in a telephone call on January 14, 1988, and as noted on page 15 of the Inspection Report, the NRC concurred with that determination.
i The response to Question 5.2.3 in Generic Letter 86-10 clarifies that post-fire operating procedures are only required for those areas requiring alternate shutdown. The response goes on to state that other areas of the plant should be covered by present operator training and operating procedures.
In a letter of January 13, 1978, Commonwealth Edison stated its position that MHIFs would be adequately covered by operator training and craft capability. The NRC accepted this position by reference to our letter in their March 10, 1978 SER for License Amendment Nos. 36 and 33.
In summary, for areas requiring alternate shutdown, MHIF guidance is contained in FOP-1.
For other plant areas, it has been determined that MHIFs have been adequately covered by operator training and craft capability. These provisions are consistent with the clarification of the Appendix R III.L.3 requirement contained in the response to Question 5.2.3 of Generic Letter 86-10.
However, as described in response to Item (a) of this violation, it may have been unclear as to whether FOP-1 was fully applicable to all areas 1
requiring alternate shutdown. As a result of an internal review conducted I
in September, 1987 Commonwealth Edison determined that it was desirable to develop a general, stand-alone guideline for MHIFs which could be used in all plant areas.
CORRECA.s; ACTION TAKEN.AND RESULTS ACHIEVED A draft procedure was prepared in September, 1987.
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CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER VIOLATION The procedure will be implemented by June 30, 1988.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED i
i The station will be in full compliance by June 30, 1988.
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VIOLATION 2.
Technical Specification No. 4.21 requires that each of the safety-related penetration fire barriers be verified to be functional by a visual inspection at least once per 18 months. The licensee was required by 10 CPR 50.48(c) to update procedures to encompass safety-related fire barriers by July 7, 1983.
Contrary to the above as of November 18, 1987, the inspector identified that the safety-related fire wall vtich separates the Auxiliary Building from the Turbine Building was not included in the surveillance requirements of Technical Specification No. 4.21.
In addition, no other documented surveillance was performed on this safety-related fire barrier.
RESPONS2 commonwealth Edison dcas not believe that this item is a violation of NRC requirements.
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As described in our letter of December 17, 1987 (enclosed) and acknowledged on page 23 of the NRC'u Inspection Report, it is our position that those portions of G-wall not currently addressed by surveillance procedures are not "barriers protecting safety related areas," as specified l
in Technical Specification 4.21.6.
The areas in question either do not contain safety-related equipment, or contain equipment for which specific protection has been provided without reliance on barriers (CCW and APW pumps in Fire Zones 11.2-0 and 11.3-0).
Therefore, we have been in compliance with Technical Specification 4.21.6.
10 CFR 50.48(c) provided the schedule for implementation of the features required by Appendix R, which for Zion are limited to those described in Sections III.0, III.J, III.0, and III.b.
The only procedures required by those sections are the procedures for alternate shutdown, as specified in III.L.3.
Therefore, there appear to be no existing requirements, either i
in our license and technical specifications, or in the applicable sections 1
of Appendix R, that cover the surveillance of any additional barriers.
Generic Letter 86-10 acknowledged the fact that for older plants, existing 4
license conditions may have been superceded by Appendix R, and that this has created problems for licensees and for NRC inspectors in identifying i
the operative and enforceable fire protection requirements at each facility. Section F of that Generic Letter provided the following guidance for this type of situation:
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, "The aforementioned problems, in general, exist because of the many submittals that constitute the fire protection program for each plant. The Commission believes that the best way to resolve these problems is to incorporate the fire protection program and major commitments, including the fire hazards analysis,.by reference into the Final Safety Analysis Report (FGAR) for the facility. In this manner, the fire protection program, including the systems, the administrative and technical controls, the organization, and other plant features associated with fire protection would be on a consistent status with other plant features described in the PSAR...The Commission also believes that a str..dard license condition, requiring licensees to comply with the provisions of the fire protection program as described in the PSAR, should be used to ensure uniform enforcement of fite protection requirements."
It has been Commonwealth Edison's intention to make such a submittal as part of the annual PSAR update following receipt of the NRC's SER which confirms our understanding of the features being relied upon for Appendix R compliance.
If the NRC's SER is received by December 31, 1988, the fire protection submittal can be incorporated into the June 30, 1989 FSAR update.
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4 VIOLATION 3.
10 CFP. 50.48 requires that each operating nuclear power plant have a fire protection plan that satisfies criterion 3 of Appendix A to 10 CPR 50.
Criterion 3 requires that structures, systems and components important to safety be protected against the effects of fires and explosions. To satisfy the requirements of criterion 3, the licensee was required to meet the technical requirements of Appendix R to 10 CFR 50.
Section III.J of 10 OPR part 50, Appendix R, requires emergency lighting units with at least an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> battery power supply to be installed in a?
areas needed for operation of safe shutdown equipmenc and in access and egrous routes thereto. The licensee was required.5y the 10 CFR 50.48(c) schedule to install the emergency lights by March 7, 1984.
Contrary to the above, the inspector identified, on November 19, 1987, that emerJency lighting was not installed or was inadequate in the following areas:
617' Auxiliary Building, General Area (inadequate lighting installed)
MCC 2391 Switch Gear Room (inadequate lighting installed)
MCC 2381 B Switch Gear Room (inadequate lighting irstalled)
Mainstream Valve House (inadequate lighting installed)
Unper Valve House (no lighting installed)
RESPONSE
Commonwealth Edison acknowledges this item as a violation of NRC requirements. As noted on page 19 of the NRC's Inspection Report, by letter of November 21, 1983, Commonwealth Edison requested a schedular exemption from the requirements of 10CFR 50.48(c).
By letters dated August 31, 1984, an.d December 16, 1985, Commonwealth Edison provided amended schedules which indicated that emergency lighting modifications would be completed by May 15, 1986.
In February, 1985, the NRC conducted an inspection of Zion's implementation of Appendix R modifications and interim compensatory measures, which included emergency lighting.
During that inspection, commonwealth Edison committed to perform a "verification walkdown" following completion of the emergency lighting modifications to ver ify that the modifications had achieved their objective of providing sufficient illumination.
Installaticn of the modifications was completed by May 15, 1986, as scheduled. However, due in part to the demands of the two refueling outages that occurred in late 1986 and eerly 1987, the verification valkdown was not performed until August, 1987. That walkdown identified the need for some additional lighting.
Some of the deficiencies identified were the result of changes that had been made in the components and strategies used for alternate shutdown, as a result of the continuing NRR review of our Appendix R report.
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t CORRECTIVE ACTION TAK2N AND THE RESULTS ACHIEVED Design.and procurement activities for the additional lighting were initiated in August, 1987. The interim compensatory measures originally i
instituted in April, 1984, which were judged acceptable in the NRC's f
Februtry, 1985 inspection and which were restated in our letter of December 16, 1987 (enclosed) remain in place, j
CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER VIOLATIONS l
Installation of the additional lighting will be completed by March 31, 1989.
If additional lighting requirements are identified as a result of NRR's review of our Appendix R Report or due to a second verification walkdown planned at the completion of installation of t',te additional lighting, modifications will be designed and implemented as soon as practicable.
DATE WHEN FULL COMPLIANCE WILL BE ACI:IEVED The station will be in full compliance by March 31, 1989, i
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. VIOLATION 4.
Amendment No. 36 to Facility Operating License do. DPR-39 and Amendment No. 33 to Facility Operating License No. DPR-48 requires the licensee to complete the modifications identified in Paragraphs 3.1.1-through 3.1.20 of the NRC's Fire Protection Safety Evaluation dated February 1978 by the end of the third refueling outage for Zion Unit 2 and prior +o return to operation for Cycle 4 (April 18, 1979).
Paragraph 3.1.5 states that an approved controller which conforms to the requirements of the NFPA 20 will be provided for the electric motor driven fire pump.
Contrary to the above, on December 4, 1987, an approved controller which conforms to the requirements of NPPA 20 was not provided for the electric motor driven fire pump.
RESPONSE
Commonwealth Edison acknowledges this item as a violation of NRC requirements. However, this was a licensee-identified item that appears to meet the tests of 10 CFR 2, Appendix C for an item for which the NRC may elect not to issue a notice of violation.
Commonwealth Edison did install a new tire pump controller in response to requirement cited. At the time of installation, Commonwealth Edison mistakenly believed that the new controller met the requirements of NFPA-20.
Contributing to our misunderstanding was the fact that we had submitted specific details on the new controller to the NRC by letter of October 31, 1979 and that the NRC had acknowledged our letter by reference in their SER cf December 9, 1980. Commonwealth Edison later determined, as part of the NFPA Code Conformance review which the Company had voluntarily undertaken, that the controller installed did not meet the requirements of NFPA-20.
The NRC was informed of the results of our review by our letter of May 9, 1985 (enclosed).
CORRECTIVE ACTION 'rAKEN AND RESULTS ACHIEVED Following a review of altornatives for resolving the code nonconformonce, in August, 1986 design and procurement activities were initiated for the installation of a new contrc21er.
CORRECTIVE A~rION TO BP TAKEN TO AVOID FURTHER VIOLATION Installation of the new controller is ccheduled for March 31, 1989, contingent upon equipment delivery.
DATE WHEN PULL COMPLIANCE WILL BE ACHIEVED The station will be in full compliance by March 31, 1989.
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ATTACHMENT B j
l UPDATED SCHEDULE FOR CORRECTIVE ACTIONS as transmitted in the January 21. 1988 letter i
from F.G. Lentine to A.B. Davis Item 1 1
Implementation of certain safe shutdown procedure revisions not completed.
a.
b.
Some operators displayed a lack of familiarity with safe shutdown procedures during the November 18, 1987 walk-through.
l Actions Completed:
1.
Draft procedure reviaions were prepared in September, 1987.
2.
Glidance on PORV fuse pulling was implemented by Standing Order on November 19, 1987, and subsequently superceded by a February
- 2. 1988 Standing Order.
3.
CECO committed on November 20, 1987, to provide additional
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training to all operators. This training has been com,nleted.
l Actions to be taken:
1.
The procedure revisions will be implemented by June 30, 1988.
Item 2 Emergency lighting enhancements not completed.
Actions completed:
1.
CECO committed in February, 1985, to perform a "verification walkdown" fol': ) wing completion of the emergency lighting I
modifications.
2.
Modifications were completed in May, 1986 (98 battery packs with associated 230 lamp heads).
3.
Verification walkdown was completed August, 1987.
4.
Additional modification designs and equipment procurement were initiated chortly thereafter (26 new battery packs).
5.
On December 16, 1987, Ceco provided a schedule for the installation of the additional modifications and a description of interim compensatory _ measures that will remain in place until completion.
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1 Actions to be taken:
1.
The additional-modifications will be installed by March 31, 1989.
2.
A second "verification walkdown" will be. performed following completion of the additional modifications.
Item 3 Certain fire bari ars had been omitted from the station's technical specification sur.eillance procedure.
Actions completed:
1.
Upon identification on November 18, 1987, the station immediately instituted a roving fire watch and began performing the surveillance.
2.
CECO committed on November 20, 1987, to revise the surveillance procedures to include the subject barriers.
3.
On December 17, 1987, CECO provided a written evaluation stating the posicion that the omission of the subject barriers was consistent with the licensing basis.
4.
On January 14, 1988, CECO provided excerpts from CECO's January 13, 1978 submittal and the NRC's March 10, 1978, SER that further supported the above position.
Actions to be taken:
1.
Ceco will submit a request for FSAR and license amendment in accordance with GL 86-10 on the schedule described in our response to IR 50-295/87-034 and 50-304/87-035.
Item 4 Failure to meet 1977 licensing commitment to install an NFPA approved fire pump controller.
i 1
Actions completed:
1.
CECO identified the fact that the installed controller was not NFPA approved in October, 1985, as part of its NFPA code conformance review program.
2.
In August, 1986, it was determined that this code deviation could not be technically justified, and preliminary design I
activities were initiated shortly therafter.
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. Actions to be taken:
1.
The modification will be installed by March 31, 1989,. contingent on equipment delivery.
Item 5 Source range neutron flux monitor (SRM) not included in list of safe shutdown components.
Actions completed:
1.
CECO provided justification for use of boron sampling in lieu of SRM iJ its July, 1984, Appendix R submittal.
2.
Draft NRC SER provided to CECO on November 12, 1987, indicated NRC approval of CECO position.
3.
On January 5 and 1986, the issue was discussed with the NRR reviewer, who c
.med his finding of the acceptability of CECO's position.
Actions to be taken:
1.
No additional actions will be taken by CECO.
Issuance of the final SER will close this issue.
Item 6 Evaluation of current transformer (CT) saturation curves not performed for every model CT at Zion.
Actions completed:
l.
CECO evaluated the potential hazard of current saturation for a representative CT in April, 1985.
2.
CECO committed, on Ncvember 20, 1987, to obtain the manufacturer's CT curves for every model CT used at Zion to confirm the results of the original evaluation.
3.
All CT curves have now been obtained and evaluated, as reported to the NRC in our letter of March 17, 1963.
4-Item 7 Auxiliary building ventilation fans not included as safe shutdown components.
Actions completed:
1.
In April, 1985, CECO provided an analysis of the "limiting case" for loss of HVAC (the charging pump cubicles), as a'
-justification for not including HkAC components.
2.
Draft NRC SER provided to CECO on November 12, 1987, stated that ventilation would.be provided by the "unaffected unit."
3.
Discussions were held on January 5 and 13, 1988, in which NRR clarified its position that auxiliary building ventilation fans must be considered safe shutdown components. CECO agreed to perform additional analysis and respond to NRR.
This analysis has been completed.
Actions to be taken.
1.
CECO will submit a description of new proposed modifications and/or revised exemption requests by June 30, 1988.
Item 8 Evaluation of Ruskin fire damper part 21 concern (closure under 61rflow) not extended to other dampers of different manufactuer.
Actions completed:
1.
A review was conducted of how the other CECO stations responded to this issue.
It was learned on January 5, 1988, that this action will be closed on Braidwood by a commitment to procedure revisions to trip ventilation fans.
2.
CECO committed on January 15, 1988, that, if feasible, Zion will implement the Braidwood corrective action.
3.
A Standing Order was issued on May 23, 1988 to address this concern.
Item 9 Ceco has not yet applied for an PdAR amendment as recommended by Generic Letter 86-10, which should include identification and justification of all NF?A Code deviatons.
l
, Actions completed:
1.
CECO completed a NFPA code review in October, 1985.
2.
CECO performed an assessment of.the general requirements for such an amendment in April, 1987.
3.
CECO committed on November 20, 1987, to make the submittal recommended by Generic Letter 86-10, which will include the NFPA code review..
Actions to be taken:
1.
The subject submittal will be provided on the sciledule described in our response to IR 50-295/87-034 and 50-304/87-035.
Item 10 Fire detector system design not adequate with respect to electrical supervision and annunication.
Actions completed:
1.
On December 16, 1987, CECO provided excerpts from CECO's April 29, 1977 submittal and the NRC's March 10, 1978 SER that approved the design of this system.
Actions to be taken:
1.
Because the subject features have been previously approved, no additional action will be taken by CECO.
l Item 11 Evaluation of TSC HVAC duct penetration not adequate.
Actions completed:
1.
In accorance with Generic Letter 86-10, CECO had performed an evaluation of the acceptabilly of the undampered TSC HVAC duct penetration prior to the November, 1987, inspection.
2.
Upon notification that the evaluation was unacceptable, CECO committed on November 20, 1987, to provide plans and schedules for installation of a rated fire damper.
. Actions to'be taken:
1.
The damper will be installed by Fabruary 28, 1989, contingent upon equipment delivery.
Item 12 Additional fire detectors installed in support of pending exemption request not installed per the spacing requirements of NFPA 728.
Actions co,apleted:
1.
In support of a pending exemption request, in July, 1985, CECO installed additional detectors in the CCW pump area.
2.
Following a site visit by NRC/FRC. reviewers in December, 1985, Ceco docketed information in February, 1986 on the design and location of the additional detectors.
3.
The draft TER provided to CECO in August, 1986, and the draft SER provided on November 12, 1987, approved the exemption request based en the information provided.
4.
Following notification and subsequent confirmatio7 by ;iRR that additional detectors would be required for issuance of the final SER, CECO committed on January 13, 1988, to install additional detectors.
Actions to be taken:
l 1.
Ceco will install the additional detectors in the CCW Pump area by March 31, 1989.
Item 13 1977 Fire Hazards Analysis (FHA) no longer accurate.
Actions completed:
1.
CECO committed on November 20, 1987, to make the submittal recommended by Generic Letter 86-10, which will include an update to the FHA.
Actions to be taken:
1.
The above submittal will be provided on the schedule described in our response to IR. 50-295/87-034 and 50-304/87-035.
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Item 14 Not clear if plant fire protection staffing meets licensing commitments.
Actions completed:
1.
On January 15, 1988, CBCo provided copies of its' submittal of April' 30, 1980, and the NRC's SER of November 24, 1980, approving plant staffing.
2.
Because of confusion regarding title and organizational changes that have Occurred over the years, CECO committed on' January 15, 1988, to provide a description of how the current organizattu: accomplishes the required fire protection functions. This des:ription was provided to the NRC on March 2, 1988.
Item 15 If an inadvertant actuation of the cable spreading room halon system occurs due to a fire in another plant area, operators may be reluctant to enter the cable spreading room to perform required safe shutdown actions.
Actions completed:
1.
CECO committed on November 20, 1987, to revise procedures and training to provide approprie... cautions and guidance for this possibility.
Actions to be taken:
1.
The revised procedures will be implemented by June 30, 1988.
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ATTACHMENT C i
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September 22,.1987 P roj ect tio. 8054-00 Cormonwealth Edison Company ShL Le tte r tio, Zl29E Zion S tation - Units 1 and 2 High Impedence Faults Mr.
D. D. Wo:niak
?WR Engineering Department Cctr.onwealtn Edison Company Post Office Sox 767 Chicago, Illinois 60690
Dear Mr. Notnisk:
One of the questions raised in Generic Letter 86-10 (Section 5. 3. 8),
deals with how the stations will cope with multiple high impedence faults.
This question was originally addressed in a December 30, 1987 letter from Mr. J. Gering of Sargent 5 Lundy to Mr.
H. Stolt of Commonwealth Edison Company.
Page 2 of the attached letter deals with the questior..
7aking into account tae Appendix "R" procedures which have been developed for tion, my answer to the question would be somewhat modified from the December 30, 19377 response and would be as follows:
A concern is that simult.meous f aults will occur during a fire that will cause the less of a main power supply to a Motor Control Center, for example, because of calcoordi-nation of the 'overcurroht or short circuit protection provided for the circuits and for the main power supply.
That ia, the summation of fault currents caused by multiple faults on the circuits being supplied power would trip the main supply breaker before the individual circuits would trip to clear the individual faults.
If this event were there would be no impact on Zion's response to to occur, a fire since the Zion procedures (FOPS) call for all breake rs (main and f eeder) en a 4kV or~480V ESF bus to i
be tripped and then, if required, manually closed.
If the main supply breaker we:e already tripped due to a lack of coordination, than after all control power fuses have~heen pulled, the.~.ain breake r could be reclosed with no dif ficulty.
CARGENT Cr LUNDY KNQtHEERS A
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.'4' September 22,.1987-Mr. D. B. Nozniak
'l
' Commonwealth Edison Company
.Page 2 If'you have any questions regarding the above-mentioned. subject,.
'please do not hesitate to contact'me at 2695 2094.
J Yours-very truly, j
l 4 f. Ajm I.
P. Werner Senior,_?.;trical IPW:ds
. Project Engineer' In duplicat)
Enclosure copies:
D. Brecken (1/1)
A. Walser (1/0)
R.
A. Hameetman (1/0) 4 9
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Revision 3
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December 1977 ZIOtt 1 &
_2_
MRC RESP 0t4SE 48 (Cont'd)
Coordination between a load center feeder b: caker and b.
its source breaker does not exist in the design of the Zion Auxiliary Power System for overload protection.
Thus backup protection is provided in the unlikely case of failure of the primary overcurrent protection device.
A concern is that simultaneous faults will occur during a fire that will cause the loss of a main power supply to a Motor Control Center (MCC), for example, because of malcoordinc. tion of the overcurrent or short circuit protection provided for~the circuits That is, the summation of fault I
and for the main power supply.
currents caused by multiple faults on the circuits being supplied power would trip the main supply breaker before the individual..
circuits would trip to clear the individual faults.
The possibility of this happening is remote since during a fire the probabilitv of the faults occurring within seconds of one another is remote.
it in likely that a time interval Multiple faults could occur but of more than a few seconds would exist between the occurrence of-faults on scwarate circuits.
that a main power supply breaker did trip because of' In the event malcoordination of the breaker tripping, there is a reasonable 1
time to dispatch an operator to the t1CC or switchgear to reset the main power supply breaker and restore power to the unfaulted loads supplied from a particular MCC or switchgear.
,j The normal operating routine for restoring service to a bus after an event as described above is as follower 1.
The operator opens all the circuit breakers connected to the bus.
2.
The main power supply breaker is closed to toot energiae the bus.
.'. 3.
After the bus is energized individual circuit breakers are closed one at a time to restore
{,'powertotheloadssuppliedfrom'thatbus. --
- 4..The breaker or breakers that trip out when they are.re-energized are then left open and further investigation into those individual circuit faults is initiated.
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The above is a description of the normal operating routine for restoring service to a bus after a trip out for any reason.
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C:mm:nwealth Edisan
.t i y/ Ons First National Plaza, Chicago, lihnois
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7 Addre33 Peply to. Post Office Box 767 v
q,/ Chicago,Imnois 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 identiLied 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 specification; 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, 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 Station identify the Limiting Condition for Operation (LCO) and Surveillance Requirement, respertively, for penetration Fire Barriers.
The technical specifications require that the following criteria are met:
(a)
"All penetration fire barriers protecting safety related areas shall j
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 90 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. Holmes Dacember 16, 1987 In order to ensure that the technical specification criteria for Appendix A penetration fire barriers are m2t, 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 gr.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 eact location) from the Turbine Building:
El. 642 Non-ESS Switchgear Rooms ( ire Area 5.4-1 and Fire Area 5.4-2)
Auxiliary Building Offices and Kitchen (Fire Zone 18.6-1)
Shift Engieers Office / Tech Support Center (Fire Zone 18.6-2)
Unit 2 Enclosed Stairwell (Fire Area 18.6A-2)
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)
Unit 2 Enclosed Stairwe'1 (Fire Area 18.6A-2)
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. Holmes Dactmbar 16, 1987 El. 579 Drum Storage Area (Fire Zones 14.2A-0 and 14.28-0)
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-re, lated _egulpme_n.t.
As a result, the i
locations from the penetration fire barriers which separate these plant 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 ard 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 Tprbine 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 u11ess a fire l
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 AFV 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 AFW 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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J. Holmes December 16, 1087 In summary, those portions of G-wall not currently addressed by surveillance procedures are.n_ot "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 reliance on barriers (CCW and AFV 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.
If there are any questions regarding this matter, please contact.this office.
Very truly yours, F. G. Lentine PWR Licensing Supervisor Im cc:
E. Fuerst D. Wozniak W. Stone i
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