ML20195E463
| ML20195E463 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 06/02/1986 |
| From: | Miosi A COMMONWEALTH EDISON CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| 1732K, NUDOCS 8606090089 | |
| Download: ML20195E463 (8) | |
Text
.
.e N Commonwe:lth Edison p ]V '/ One First National Plaza, Ch>Cago. Ilhnois Address Reply to. Post Office Box 767
\\
Chicago, Ilknois 60690 June 2, 1986 Mr. Harold R.
Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC.
20555
Subject:
Braidwood Station Unit 1 NFPA Code Deviations NRC Docket No. 50-456
Dear Mr. Denton:
Attached for your review is a listing of NFPA deviations.
Deviations from all applicable NFPA codes are not included at this time because we have not completed the reviews necessary for some of these codes.
However, the deviations from the major codes covering the majority of the fire protection features in the plant are included in the attachment.
When all of the code reviews are complete these NFPA deviations will be put into a tabular format much like Table 3-1 currently in the Fire Protection Report for Byron Unit #1.
We intend to file the complete table of NFPA deviations for Braidwood Unit #1 as an Amendment to the FPR in September immediately preceeding Fuel Load, in accordance with what was done for Byron Unit #1.
The difference between this submittal for Braidwood Unit #1 and Table 3-1 of the FPR for Byron Unit #1 are the following:
1.
All code reviews are reflected in Table 3-1 for Byron, whereas for Braidwood only the codes shown in this submittal are covered.
2.
Table 3-1 for Byron includes NFPA deviations which could affect non-safety related areas.
This submittal for Braidwood does not include deviations affecting non-safety related areas.
3.
Table 3-1 for Byron includes temporary NFPA deviations which were being worked on at the t'-9 of the submittal.
This Braidwood listing only contcins permanent deviations for which stetus is not expected to change.
86060900s9 860602 PDR ADOCK 05000456 d
Pnn L
i The attached list includes reviews of the following NFPA codes:
NFPA 13 - 1985, Standard for the Installation of Sprinkler System NFPA 14 - 1983, Standard for the Installation of Standpipe and Hose Systems NFPA 15 - 1985, Standard for Waterspray Fixed Systems for Fire Protection NFPA 20 - 1983, Standard for the Installation of Centrifugal Fire Pumps NFPA 24 - 1984, Standard for the Installation of Private Fire Service Mains and Their Appurtenances NFPA 72E
,1984, Standard on Automatic Fire Detectors Please direct any questions you may have regarding this matter to this office.
One signed original and fifteen copies of this letter and enclosure are provided for your review.
Very truly yours, Qdmp.iosiHlsi A.
D.
Nuclear Licensing Administrator
/klj cc:
J. Stevens
(
encl.
t 1732K
.l t
l I
r
M&M Protection Consultants Item Re ference Deficiency Comuments 1.
NFPA 13, para. 3-14.1.1, ne Powell, Anchor-Darl'ng, 11T ne valves are extra heavy i
and 3-14.2, Grinnell and Rockwell Edwards valves type built to ANSI Standards All valves shall be are not listed.
and are acceptable per listed.
MinMPC's letter of 2-18-86.
2.
NFPA 13, para. 3-15.1.2, Hangers in safety related areas are In Containment, Auxiliary Hanger assemblies shall not listed.
Building and Fuel Handling be listed, all piping supports are seismically designed by Sargent & Lundy and are acceptable.
3.
NFPA 13, chapter 4, During system walkdown deviating Partially obstructed sprin-Spacing, location and positions and locations of sprin-klers will provide protection position of sprinklers klers were noted and docuuented.
to the hazard in addition to shall be made in ac-overlap coverage from adjacent cordance with this sprinkler heads. It will not chapter.
be necessary to relocate or repipe the system. (Reference M6MPC letters of 11-27-85 and 4-10-86).
4.
NFPA 13, para. 2-7.1, A fire department ptssper ne only source of water is A fire department con-connection is not provided.
the cooling lake. Dere-nection shall be pro-fore, a pumper connection vided.
would be of no value with-out a municipal water supply.
5.
NFPA 13, para. 3-10.3.4, Some portions of piping pasp through Sargent & Lundy has designed Clearance shall be pro-concrete without clearances.
anchor points on the fire vided around all piping protection piping. Dere-extending through walls fore clearances need not be and floors.
provided.
6.
NFPA 13, para. 3-11.2.5, Drain is not provided at each Drainage provisions are made Each interior sectional sectional valve.
throughout piping system valve shall be provided other than at each sectional with a sectional drain valve. H is is adequate to valve.
drain portions of the system.
1 l
I 4
)
i
M&M Protection Consultants Item Re ference Deficiency Comunents 7.
NFPA 14, para. 4-2.1 &
Anchor-Darling, An-The valves are extra heavy 4-4.2, Valves at the derson Greenwood, Powell, type built to ANSI Standards main riser including and ITI Grinnell valves and considered acceptable hose valves shall be are not listed.
per M6MPC's letter of approved.
2-18-86.
8.
NFPA 14, para. 4-7.1, Pressure reducing devices Fire brigsde members have Where pressure at hose are not installed at each been trained for hose pres-outlet exceeds 100 psi, hose outlet.
sures in excess of 150 psi, an approved device With proper training, pres-shall be installed to sure reducers are not nec-reduce the pressure to essary for fire brigade use.
100 pai.
9.
NFPA 14, para. 3-3.1, Standpipes are located In order to provida adequate Standpipes shall be throughout the plant.
distribution of hose stations located in fire rated throughout the facility, it stair enclosures, pipe is not possible to enclose shafts, or other ap-the entire standpipe system.
propriate locations.
Sectionalizing valves are provided to isolate a min-imum number of hose stations if necessary. This design is considered acceptable.
10.
NFPA 14, para. 7-6.1.1, Pipe hangers in safety In Containment, Auxiliary Pipe hangers shall be related areas are not Building and Fuel Handling approved.
listed.
all piping supports are designed seismically by Sargent & Lundy in accor-dance with ASME/ ANSI.
2herefore, hanger design is acceptable.
11.
NFPA 15, para. 2-7, The Anchor-Darling, Target Rock The valves are extra heavy All valves shall be solenoid, Rockwell Edwards, and type designed to ANSI and approved.
IIT Crinnell valves on the charcoal are acceptable per M6MPC's filter units, are not listed.
letter of 2-18-86.
12.
NFPA 15, para. 2-1.2, The Spraying Systems Co. nozzles on The unique configuration Only listed devices the charcoal filters, are not listed.
of each charcoal filter re-shall be employed.
quires a specialized nozzle for adequate water apray ap-plication. There are no listed nozzles available for this purpose. The exis-ting equipment is acceptable.
l l
RP2 2
m M&M Protection Consultants Item Reference Deficiency Comments 13.
NFPA 15, para. 2-6, Hangers not listed in safety Hangers in Containment Hangers shall be related areas.
Auxiliary Building and Fuel approved.
Handling are seismically designed by Sargent & Lundy and considered acceptable.
14.
NFPA 15, para. 2-8.4 The following charcoal filters The United Electric devices Automatic detection utilize United Electric or Conax are U.L. listed for hazardous equipment shall be heat detection devices that are atmospheres and the Conax RTD listed.
' not sp6cifically listed for fire thermocouples are standard protection services industrial / nuclear grade 1VP05FA & FB, 2VP05FA & FB, heat sensing devices. The OVC05FA & FB, OVC06FA & FB, detectors are an acceptable OVF04F, IVQ09F, 2VQ09F, design for alarm purposes since the water spray systems are actuated manually.
15.
NFPA 20, para. 2-10.5, Powell gate valves are Valves are extra heavy Listed valves shall be not listed, type designed to ANSI installed on the system Standards and are ac-side of the check valve.
ceptable per M6MPC's letter of 2-18-86.
16.
NFPA 20, para. 2-13.3.1, Vogt gate valves are Valves are extra heavy Hose valves shall be not listed (test header).
type designed to ANSI listed.
Standards and are ac-ceptable per M6MPC's letter of 2-18-86.
.'.7.
NFPA 20, para. 2-13.3.1, A 10" pipe is installed.
Existing 10" test Test header pipe shall header pipe provides be 12".
adequate flow as re-corded on all previous tests. Therefore, 10" line is satisfactory.
18.
NFPA 20, para. 6-3.1.1, Some conductors are not All conductors are in Fire pump feeder con-in concrete (elec. pump).
heavy steel conduit that ductors inside buildings will provide limited shall be enclosed by 2" fire resistance.
of concrete or equivalent Existing routing is 1-hour fire resistance.
adequate and not ex-posed.
19.
NFPA 20, para. 7-1.1.1, Electric motor con-Justification is pro-All controllers shall troller is not listed.
vided in T. R. Trase's be listed for electric letter of 12-14-83 to motor driven fire pump H.
R'. Denton.
service.
maa 3
=
M&M Protection Consultants Item Re ference Deficiency Comments 20.
NFPA 20, para. 7-1.1.3, All electrical infor-Complete electrical in-7-3.7.1, 7-3.8 & 7-3.9, nation is not attached formation including dia-Wiring diagrams, marking to the controller on grams, ratings, and ven-of each motor control the electric motor-dor manuals are permanently device, and instructions driven fire pump.
on file at the station.
l shall be mounted on the Necessary data can be ob-l controller.
tained via equipment iden-tification number. There-fore, pertinent data is available, but not specifi-cally at the controller.
21.
NFPA 20, para. 7-4.3, Overcurrent device is Overcurrent protection is An overcurrent pro-not located within the provided from 4160V switch-tective device shall fire pump controller.
gear buss 144, cubicle 000 be located within the per Sargent & Lundy letter fire pump controller.
of 7-17-85.
22.
NFPA 20, para. 7-4.6, Line power monitored Loss of power on the 4160V Alarms shall be pro-on feeder source and bus which feeds the fire vided for (b) loss of no phase reveral alare.
pump actor is annunciated line power, and'(c) on control roca panel phase reversal.
1PM07J. Phase reversal is highly improbable and not i
necessary for alarm pur-I poses.
23.
NFPA 20, para. 7-6.2, An ammeter is attached For testing purposes, i
Ar moeter and volt-to the electric pump provisions are made to meter shall be pro-controller, but not record volts and amps.
vided on the controller.
a voltmeter.
Therefore, permanently attached equipment is not necessary.
24.
NFPA 20, para. 8-2.7.2, The solenoid valve is A listed valve is not The automatic electric not listed.
available in the re-solenoid valve in the quired pressure rating cooling water line for for the diesel engine the heat exchanger shall pump. The existing be listed for fire pro-valve has proven satis-tection service.
factory during pre-op testing, and is con-sidered acceptable.
i l
AP2 4
_._--_._ __...._.._ _~-.._._ _.. -,_ _...,. _. ~..
M&M Protection Consultants Item Reference De ficiency Cossents
^
25.
NFPA 20, para. 9-4.2.2, The off and manual Control room alars re-An alarm shall be pro-positions on the sponse procedure BWAR-vided indicating that diesel engine pump 0-38-C7 addresses the controller switch are combined with trouble conditions in-has been turned to off other trouble condition cluding controller po-or manual position alarms.
sition "off".
Since (separate signal).
all trouble conditions will be promptly inves-tigated, a separate sig-nel is not necessary.
26.
NFPA 20, para. 2-4, Nameplate data on Accurate brake horse-Pumps shall be pro-electric motor-driven power data is provided vided with a name-pump indicates BHP-on vendor drawings and 1
plate.
3202.
manual.
27.
NFPA 24, para. 3-1.1, Powell and Anchor-Darling The valves are extra heavy d
All control valves valves are not listed.
type built to ANSI Stan-shall be listed.
dards and considered accep-table per MEMPC's letter' of 2-18-86.
28.
NFPA 24, para. 3-2.2, Check valves are not installed The valves are normally i
A check valve shall at the connections to essential closed and do not serve be installed in each service water (SX), make-up the fire protection system.
water supply connac-domineralised water, and the In lieu of check valves, tion.
station air compressors.
procedures are written to monitor potential leakage free the existing valves.
29.
NFPA 24, para. 3-3.2, The following valves are less The valves are located Post indicator valves than 40 ft. from a buildings along blank walls and shall be located not OFP579 0FP591 are readily accessible.
less than 40 ft.
OFP580 0FP592 This is considered adequate, from buildings.
OFP581 0FP593 OFP582 0FP602 30.
NFPA 24, para. 7-2, Pipe is not lined.
Periodic flow tests will All ferrous metal monitor the interior con-j pipe shall be lined.
dition of the pipe. Hy-draulic calculations will also Let11se a conservative C factor of 100 to account for extended age. This is adequate in lieu of lining pipe.
4 ftP2 i
{
5
p.
o M&M Protection Consultants Item Re ference Deficiency Coassents 31.
NFPA 24, para. 8-6.2.10, Insufficient documentation Procedure BwVs 100-4 will Thrust blocks or other to determine thrust restraint monitor any unusual system suitable means of re-locations.
leakage. Thrust blocks are straint shall be pro-being provided as necessary vided at each change during routine maintenance in direction of a or hydrant repositioning, pipeline, tees, plugs, caps, and bends.
32.
NFPA 72E, para. 2-5.1.1, The following charcoal tilters The United Electric devices All fire detection de-utilize United Electric or Conax are U.L. listed for hazardous tection devices shall be heat detection devices that are atmospheres and the Conax RID
- listed, not specifically listed for fire thermocouples are standard protection service industrial / nuclear grade heat IVPC5FA & FB, 2VPO5FA & FB, sensing devices. These de-OVC05FA & F3, OVC06FA & FB, vices are an acceptable de-OVFD4F, IVQ09F, 2VQ09F, sign for alars purposes since the water spray systems are actuated manually.
(NFPA3/9) e O
+
RP2 6
-