ML20205F334

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Discusses List of Addl NFPA Deviations,Supplementing List Encl w/860602 Ltr.Review of NFPA Codes Led to Permanent Deviations from NFPA 12-1985,37-1984,72D-1979,80-1983 & 90A-1985
ML20205F334
Person / Time
Site: Byron, Braidwood, 05000000
Issue date: 08/08/1986
From: Miosi A
COMMONWEALTH EDISON CO.
To: Harold Denton
Office of Nuclear Reactor Regulation
References
1965K, NUDOCS 8608190163
Download: ML20205F334 (7)


Text

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- Commonwealth Edison One Fird National Plaza Chicago, Illirris Address Reply to: Post Offica Box 767 Chicago, Illinois 60690 - 0767 August 8, 1986

?

E Mr. :tarold R. Denton, Director i 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 L

Reference:

June 2, 1986 A.D. Miosi letter to H.R. Denton

Dear Mr. Denton:

Attached for your review is a listing of additional NFPA deviations J that supplements those deviations listed in the referenced letter. That listing was comprised of deviations for some of the major NFPA codes reviewed at the Station and only contained those deviations which affect safety-related areas. We pointed out that deviations from all NFPA codes were not included within the listing because not all NFPA codes were reviewed at that time.

Subsequent to that letter, Marsh and McLennon has completed their reviews of the other NFPA codes and we have compiled another list of permanent deviations affecting safety-related areas (attached). There may be more permanent NFPA deviations identified for safety-related areas when all construction is complete and M&M has had a chance to do a final NFPA review.

When all 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 fer Byron Unit #1. We intend to file the complete table of NFPA

= deviations for Braidwood as an amendment to the FPR In accordance with what was done for Byron Unit #1.

The attached list includes the following NFPA codes:

NFPA 12-1985 Standard on Carbon Dioxide Extinguishing Systems b

8608190163 860808 PDR ADOCK 030004S4 $

F PDR g i

5 i

. NFPA 37-1984 Standard for the Installation and Use of Stationary Combustion Engines and Gas Turbines NFPA 72D-1979 Standard for the Installation Maintenance and Use of Proprietary Protective Signaling Systems NFPA 80-1983 Standard for Fire Doors and Windows NFPA 90A-1985 Standard for the Installation of Air Conditioning and Ventilating Systems For NFPA codes 11, 12A, 16, 27, 30, and SOA, we have not identified any permanent deviations thus far in our review.

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 our review.

Very truly yours, NW A. D. Miosi Nuclear Licensing Administrator

/klj cc: J. Stevens encl.

1965K

M&M Protection Consultants ITEM NO. REFERENCE DEFICIENCY COMHENTS

1. NFPA 12, para. The fuel supply to the The continued operation 1-8.3.8 The diesel generators and of this equipment may source of fuel auxiliary diesel feed- be necessary for operating shall be auto- water pump do not shut safety-related equipment.

matica11y shut off automatically upon No action necessary.

off. system actuation.

2. NFPA 37, para. The following tanks do An automatic shutoff 5-4.2, Tanks not have a high level will not be provided shall be pro- automatic shutoff: on the safety related vided with a high 1D002TA & TB, OD006T, tanks or security diesel level automatic ID010T. day tank.

shutoff.

3. NFPA 37, para. The following tanks The clearance is suffi-5-3.7.1, At least have less than 15 in. cient for maintenance and 15 in clearance clear space: and inspection activities.

shall be left ID002TA, ID002TB, around the tank. 1D010T.

4. NFPA 72D, para. The secondary power Bus 134/234 is normally 2.6.2.3 The secon- supply is provided from fed from Bus 144/244 which dary (standby) Bus 134/234 in lieu of is supplied from the supply shall be storage batteries or system auxiliary trans-provided and shall generator. former, and it also has consist of storage a diesel generator backup batteries with a in case of a loss-of-24 hour supply, offsite pwoer. This engine driven supply is as reliable as generators or a was intended by the NFPA combination of code, and is considered engine driven to be acceptable as is.

generators and batteries.

5. NFPA 72D, para. Trouble signals are Bus 132/232 (ESF Bus) is 2-6.2.4 A sep- fed from the primary the primary power supply arate power sup- source. to the proprietary alarm ply, independent systems. Due to the high of the main power reliability of the primary supply shall be power supply, this is provided for the considered to be operation of trouble acceptable.

signals. (may use the secondary power supply.

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m M&M Protection Consultants ITEM NO. REFERENCE DEFICIENCY COMMENTS

6. NFPA 72D, para. Common trouble alarm Upon receipt of a trouble 3-6.2.2 Signals indications are provided. alarm, an operator is transmitted shall dispatched to the area indicate distinc- and fire watch may be tively the par- initiated until the ticular function trouble is cleared. This (such as valve is considered acceptable.

position, pressure, etc) of the auto-matic sprinkler system which'is abnorm'al and its restoration to a nor-mal condition.

7. NFPA 72D, para. Distinctive audible The Unit I and Unit 2 4-4.1 Provide sep- alarm and trouble in- fire alarm panels are not arate, distinc- dications are not adjacent to one another tive, audible provided between Unit in the Control Room. It trouble and alarm 1 & 2 panels. will be obvious to an signals at the operator responding to a Control Room panels fire alarm which unit is IPM09J/2PM09J affected. The existing design is considered adequate.

l 8. NFPA 72D, para. Ionization detection sys- Upon receipt of a trouble 3-5.1.2 Auto- tems do not have this alarm an operator is matic fire de- trouble feature. dispatched to the area and tectors which have and a fire watch may be l integral trouble initiated until trouble is contacts shall be is cleared. This is wired on the considered to acceptable.

initiating device circuit so that a trouble condition on one detector will not impair the alarm opera-tion from other in-itiating devices.

9. NFPA 80, para. These doors are security The justification for the 1-6.1 Only label- doors that are either use of non-labeled doors l ed or listed doors oversized or provided "A construction" is con-shall be used, with a modified two- tained on pages 2.1-8 l point latch and electric through 2.1-9b of the I

strikes. The doors are Braidwood Fire tection not labeled: Report.

an - _ __ _ _ _ _ _ _ _ _ __ __ _ _ __ _ _ _ _ _ _ _ . . _ _ . _ .

L/

M&M Protection Consultants ITEM NO. REFERENCE DEFICIENCY COMMENTS 319, 348, 351, 373 377, 380, 396, 397 411, 415, 420, 427 428, 434, 445, 447 453

10. NFPA 80 para. These are oversized doors The justification for the 1-6.3 Authorities which are not labeled: use of non-labeled doors having juris- of "A construction" is diction shall be 319, 348, 351, 373 contained on pages 2.1-8 consulted as to 377, 380, 411, 415 through 2.1-9b of the the size of over- 420, 427, 428, 432 Braidwood Fire Protection sized doors which 434, 440, 447, 453 Report.

may be deemed ac- 463, 474, 724, 725 ceptable in a given location.

11. NFPA 80 para. These frames are for The justification for the 2-5.1 Only label- security doors and have use of these frames is ed door frames been modified with provided on pages 2.1-8 shall be used. security hardware: through 2.1-9b of the 225, 226, 234, 319 Braidwood Fire Protection 325, 348, 351, 373 Report.

377, 380, 381, 383 392, 396, 397, 411 415, 427, 428, 434 445, 447, 453, 461 476, 477, 551, 552 555, 648, 649, 650 651, 670, 671, 701 729, 730, 731, 732 SD-165, SD-166 SD-167, SD-168 SD-169, SD-170 SD-171, SD-172 SD-174, SD-175 SD-180, SD-181 SD-182, SD-183

12. NFPA 80 para. The gaps around these These doors are considered 2-5-4 The doors were measured to to be within the manufact-clearance be- be between 1/8 and 1/4 urer's tolerances for tween the meeting inch: doors and door frames as edges of doors specified by the Steel swinging in paire 2, 6, 7, 10, 11 Door Institute. This is shall not exceed 12, 16, 17, 25 considered acceptable.

1/8 inch. 30, 32, 34, 35 38, 39, 40, 41 63, 64, 72, 76 an l

_3_

M&M Protection Consultants ITEM NO. REFERENCE DEFICIENCY COMMENTS 77, 112, 1145, 125 140, 142, 153, 158 167, 185, 187, 192 193, 210, 211, 213 292, 317, 320, 349 370, 378, 397, 400 401, 411, 417, 425 428, 430, 432, 435 440, 489, 490, 523 .

524, 542, 544, 608 670, 671, 682, 685 695, 698, 701, 778 780, 781, 782, 802 820, 823 SD-181, SD-183

13. NFPA 80 para. These are doors provided The justification for 2-8.2.1 Only with security hardwarde: non-labeled hardware for labeled locks for security' doors is and latches 225, 226, 234, 319 contained on pages 2.1-8 shall be used. 325, 348, 351, 373 through 2.1-9b of the 377, 380, 381, 383 Braidwood Fire Protection 392, 396, 397, 411 Report.
415, 427,'428, 434 445, 447, 453, 461 476, 477, 551, 552 555, 648, 649, 650 670, 671, 701, 729 730, 731, 732 SD-165, SD-166 SD-167, SD-168 SD-169, SD-170 SD-171, SD-172 SD-174, SD-175 SD-180, SD-181 SD-183
14. NFPA 80 para. These doors are provided Gasketing is installed to 2-9 Gasketing on with gasketing around the assist the HVAC air flow /

fire doors or frame: pressurization within the frames shall be plant 3.e gasketing does furnished only in 6, 7, 16, 17 not affect the operability accordance with 25, 63, 187, 192 of the door and is con-the published 210, 211, 212 317 sidered acceptable.

listing of the 318, 319, 320, 340 door frame or 348, 349, 350, 351 gasketing 377, 378, 380, 383 l material manu- 394, 395, 396, 397 t

facturer. 400, 411, 412, 415 t -- -

r- .

3 M&M Protection Consultants .

ITEM NO. REFERENCE DEFICIENCY COMMENTS 419, 420, 425, 427 Exception: Where 430, 431, 432, 434 acceptable to 440, 445, 446, 447 the authority 453, 461, 475, 490 having juris- 501, 523, 524, 537 diction, gas- 542, 543, 544, 648 keting of noncom- 649, 650, 651, 682 bustible material 685, 695, 698, 701 may be applied to 729, 730, 731, 732 the frame provi-ding closing and SD-169, SD-170 latching of the SD-171, SD-172 door is not SD-174, SD-175 thereby. inhibit- SD-180, SD-181 ed. SD-183

15. NFPA 80, para. Doors 677 & 678 are double Justification is 14-L2 Fire doors hinged doors (on both sides contained on page 2.1-9 shall be oper- and are normally bolted of the Braidwood Fire able at all closed. Protection Report.

times.

16. NFPA 90A, para. The duct detectors alarm The common fire / trouble 4-5.1.4-5.2, and in the main control alarm in the main control 4-5.3 Detectors room HVAC panel as room also records a shall be install- common fire or trouble printed message which in-ed in accordance alarms and are not in- indicates the local HVAC with NFPA 72E stalled per NFPA 72E or panel. The local HVAC and shall sound 72D. panel indicates separate an alarm in a nor- fire and trouble alarms.

mally occupied Operating procedures area or through address these alarm the building conditions. This is fire alarm system. adequate for the duct detector alarm system.

(SJC1/35)