ML20209E560
| ML20209E560 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Susquehanna |
| Issue date: | 06/21/1985 |
| From: | Thompson H Office of Nuclear Reactor Regulation |
| To: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20209D360 | List: |
| References | |
| FOIA-86-274 NUDOCS 8507050296 | |
| Download: ML20209E560 (3) | |
Text
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Y UNITED STATES f,.r[ j NUCLEAR REGULATORY COMMISSION
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'JUN 21 1985 MEMORANDUM FOR:
Stewart D. Ebneter, Director Division of Reactor Safety Region I FROM:
Hugh L. Thompson, Jr., Director Division of Licensing, NRR
SUBJECT:
SUSQUEHANNA UNITS 1 AND 2, FIRE PROTECTION UNRESOLVED ITEMS In your memorandum of April 9, 1985, you requested responses to several questions pertaining to the Susquehanna Unit 1 and Unit 2 license conditions covering Fire Protection and the licensee's existing fire-hazards analyses.
The questions and our corresponding response are as follows:
Question:
1.
With regard to License Condition 2.c(6) is 10CFR50, Appendix R applicable in its entirety to Unit 1:
If not applicable in its entirety to what extent is it applicable?
_ Response:
License Condition 2.c(6) states:
" Fire Protection Program (Section 9.5, SER, SSER #1, SSER #2 SSER #3)
PP&L shall maintain in effect and fully implement all provisions of the approved Fire Protection Review Report, as amended through Revision 2 dated November 1982.
In addition, PP&L shall maintain the fire protection program set forth in Appendix R to 10 CFR Part 50."
This license condition explicitly requires PP&L to maintain the fire protection program set forth in Appendix R in addition to the provisions of its approved Fire Protection Review Report.
However, we believe that full application of Appendix R should not be administered because it was never the staff's intention that PP&L meet Appendix R in its entirety.
In the SERs cited in this license condition, the staff stated that Appendix R is not a requirement for Susquehanna Units 1 and 2; however, in establishing the acceptability of the Susquehanna fire protection program for Units 1 and 2, the NRC staff accepted the licensee's commitment to implement Sections III.G,J and 0 of Appendix R.
On March 26, 1981 PP&L hh'd transmitted,a letter of commitment to the NRC staff stating that PP&L would implement the Susquehanna Fire Protection Program in accordance with l
Appendix R, particularly with Section III.G,- J and 0 of Appendix i
R.
This letter referred to both Units 1 and 2.
Contact:
~M.
Campagnone X27235' -
A/s
Based on our review of the program, including the above commitment, the staff imposed license condition 2.c(6) to Unit 1 with the intention of making the licensee's commitment to Section III.G, J and 0 of Appendix R a license requirement.
The license condition, as issued, satisfies this requirement; however, it goes beyond the staff's intention by requiring Appendix R in its entirety.
In a letter dated April 18, 1985 to PP&L, we suggested that the licensee seek revision of the condition to the standard fire protection provision.
If the licensee does not request the change, we intend to promptly issue an order modifying the condition to conform it to our original intent and the current format.
Question:
2.
Is Appendix R a legally binding regulatory requirement for Unit 2?
Response
License Ccodition 2.c(3) states that:
" Fire Protection Program (Section 9.5, SER, SSER #1, SSER #2, SSER #3 "PP&L shall maintain in effect and fully implement all provisions of the approved fire protection program."
As stated in the response to Question 1 the licensee's letter of commitment dated March 26, 1981 applied to Unit 2 as well and was relied upon by the staff in finding the fire protection program acceptable for Unit 2.
Only the licensee's commitment to Appendix R Sections III.G, J and 0 was relied upon by the staff in the referenced SERs which are a necessary part of the " approved fire protection program" as that phrase is used in Unit 2 license condition 2.c(3).
Therefore, the Unit 2 license condition requires the licensee to maintain and implement the approved fire protection program, which includes compliance with Appendix R, Sections III.G, J and O.
Question:
3.
Is the licensee's existing Fire Hazards Analysis adequate to demonstrate compliance with Appendix R?
Response
As stated previously the staff did not expect the licensee's compliance with Appendix R in total but only expected compliance of the Susquehanna Fire Protection Program to include implementation of Sections III.G, J and 0 of Appendix R.
Based on our site audit of March 18-21, 1985 the NRC staff finds that PP&L's existing Fire Protection Program does not demonstrate full compliance with Secticn III.G of Appendix R.
In a
letter dated April 18, 1985 from T. M. Novak (NRC) to N. W. Curtis (PP&L) the staff transmitted its findings from the March 18-21, 1985 site audit to the licensee.
This letter outlined the major areas of concern.
In the April 18, 1985 letter the staff states that:
"We find that PP&L's supplementary information has not demonstrated compliance with Section III.G of Appendix R.
Also, the non-rated walls and floors / ceilings in the Reactor Building will not limit fire propagation.
If fire spread occurs beyond these assemblies, loss of redundant shutdown capability may occur. We also determined that the post-fire safe shutdown capability may not be adequate in the event of a control room fire."
Based on the above the staff has determined that either additional analyses and/or modifications to the Fire Protection Program must be undertaken in order for PP&L to demonstrate full compliance with Section III.G of Appendix R or justification must be provided for deviations from this section.
NRR has provided the April 18, 1985 letter as Enclosure 1.
The trip report is an attachment to Enclosure 1.
The NRR staff has provided you this memorandum in response to your April 9, 1985 memorandum from S. D. Ebneter, Region I to H. L. Thompson, NRR.
We have stated our position pertaining to the Susquehanna Fire Protection Program to give you a clear definition of the staff's requirements pertaining to Appendix R for Susquehanna Units 1 and 2.
We believe that this memorandum will allow you to resolve those inspection item findings which have been held in abeyance awaiting the NRR staff position.
If you have any further questions please contact the Licensing Project Manager, M. Campagnone at 301-492-7235.
f I?
@' g L. Thompson, Jr,
irector D ision of Licensi
, NRR
Enclosure:
As stated
Enclosure n
/pamm'o, 1
UNITED STATES 4
E NUCLEAR REGULATORY COMMISSION 2
E WASH WGTON. D. C. 20555
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A?R 18 E5 Docket Nos. 50-387/388 r
Mr. Noman W. Curtis, Vice President.
Engineering and Construction Pennsylvania Power & Light Company 2 North Ninth Street Allentown, Pennsylvania 18101
Dear Mr. Curtis:
SUBJECT:
RESULTS OF THE MARCH 18-21, 1985 SUSQUEHANNA FIRE PROTECTION PROGRAM DOCUMENTATION AUDIT In a meeting held on February 26, 1985, between the NRC staff and PP&L the l
results of the recent Region I Appendix R fire protection inspection at SSES i
were discussed. The staff infomed you that it was our position that the SER and Supplements did not approve PP&L's fire protection program as satisfying Appendix R, Sections III.'G., J. and O.
i On' Marcti 18-21, 1985 the NRC staff visited the SSES site to audit the docuEen-tation supporting the Susquehanna Fire Protection Program to enable PP&L to 1
present supplementary infomation that was not readily available during the i
previous inspection. The results of the March 18-21, 1985 visit are contained in the enclosed trip report.
We find that PP&L's supplementary information has not demonstrated compliance with Section III.G. of Appendix R.
Also, the non-rated walls and floor / ceilings in the Reactor Building will not limit fire propagation.
If fire spread occurs beyond these assemblies, loss of redundant shutdown capability may occur.
We also determined that the post-fire safe shutdown capability may not be adequate in the event of a control room fire.
During our post-audit exit briefing, PP&L co:::.itted to respond to our control room findings.
In your letter of April 8, 1985, you stated that you will re-access the adequacy of non-fire-rated construction.
However, this response does not adequately address our concerns because it does not establish that PP&Ls future efforts will confom with staff guidance documents or past precedent. We are providing the following guidance for fomulating your response to our site audit concerns:
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1.
The Fire Protection Review Report should be revised to reflect, in a compre-hensive manner, the degree to which SSES conforms with the technical require-ments of' Sections III.G., J. and O. of Appendix R to 10 CFR 50, as comitted in your letter of March 26, 1981.
(The staff understands that Section J.
and 0 compliance is not in question.) For each fire area, identify and justify the deviations from these requirements. This effort should reflect recent staff guidance as presented in our fire protection workshop and as contained in Generic Letters 83-33 and 85-01.
2.
The Control Rocm analyses should assume complete loss of function of control room systems after manual scram of the reactor. This analysis, G
2-along with the analyses of associated circuits throughout the plant, should conform to the guidance provided in Generic Letter 81-12 and its supplementary clarification.
3.
The re-assessment of non-rated construction should be in accordance with geidance presented at the site audit. That is, to provide reasonable assurance that fire propagation will not occur beyond non-fire-rated zone boundaries, the boundaries should be upgraded to be continuous barriers with a fire rating sufficient to withstand the effects of a fire involving in-situ and transient combustibles, with conservative margin.
If boundary construction is not upgraded, your re-assessment should assume that fire spread will occur into'the next most immediate fire zone.(horizontally and/orvertically).
In addition, it has become apparent tnat the fire protection license condition for SSES Units 1 and 2 are not in conformance with the Commission's policy.
We request that such conditions be revised to be in conformance with.the NRCs standard fire protection license condition as stated in GL 85-01~.
If you have any questions relating to this subject please contact the Licensing Projec, Manager, Mari-Josette Campagnene (301) 492-7235.
Sincerely, Thomas M. Novak, Assistant Director for Licensing i
Division of Licensing 4
cc: See next page l
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l Chemical Engineering Branch / Fire Protection Section Susquehanna Steam Electric Station, Units 1 & 2 Docket Nos. 50-387/388 The Region I fire protection inspection during the week of February 11, 1985, identified potential violations and deviations from the conr.itments contained in the licensee's fire protection program.
A meeting was held on February 26, 1985, in Bethesda, Md. to discuss the SSES fire protection requirements and congitments.
PP&L expressed their opinion that they were in compliance with the NRC's requirements and cited as the basis for this position the information contained in Revision 2 to PP&L Fire Protection Review Report and the staff's SER and Supplements.
Following the discussion, the staff provided PP&L with the following staff position:
1.
PP&L shoulc not construe our SER and supplements as explicitly er implicitly approving PP&L's fire protection program as satisfying l
Appendix R Sections III.G, J and O.
2.'
To the extent PP&L chooses to use the analysis, either in whole or\\in part, that fermed the basis for the Appendix A fire protection evaluation, PP&L should be cognizant that the staff indicated j
during its audit that the Appendix A evaluation would not be sufficient to demenstrate compliance with Sections III.G of Appendix R.
3.
The staff suggested that to the extent that PP&L needs to go beyond their Appendix A fire protection evaluation to demonstrate compliance with Section III.G., then the scope and completeness of any re-analysis should be in accordance with the guidance presented in the regional fire protection workshop.
During the week of March 4, 1985, PP&L indicated that they had some additional analysis to supplement their Appendix A evaluation.
A staff review team was sent to the site during the week of March 18, 1985.
On March 18, 1985, the staff review team met with PP&L representatives to establish the purpcse of this site visit and on March 2,1, 1985, to present the results of our audit. The participants in,these meetings are listed in enclosures 1 and 2.
The purpose of this site audit was to enable the licensee to demonstrate compliance with Section III.G. ca the basis of information that was not readily available at the ' time of the original Region'I inspection.
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The licensee's su'pplemental information consisted of two calculations:
1.
" Justification for 45 min rating equivalent - non-rated walls",
DK-C-DJK-009. D.J. Kahn, March 15, 1985.
2.
" Structural evaluation of Reactor Bldg Floor Slabs with Beats at 1500*F", FK-C-JDV-031', J. D. Vernan, February 22', 1985.
The licensee provided a copy of three of the fourteen, references to calculation 1 above.:
g 2)
Technical Report, " Evaluation of Selected Fire Door and Door Frame Assemblies", FM Under No. 38492.55, S.M. Knight, January 1985.
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9)
" Fire Research for Steel HVAC Systems, NFPA Fire Journal", Vol. 78, i
No. 6. R. G. Gewain, November 1984 1
(13)
" Fire and Hose - Stream tests,of Seismic Gap Simulation Test No. 1",
M. Gillen and M. Abrams, Construction Technology Laboratories, i
August 1979.
The licensee also provided a copy of the following:
a)
"hireandHose-streamtestsofSeismicGapSimulationTestNo.2*,
M. Gillen and M. Abrams, Construction Technology Laboratories.
October 1979 l
B.
Ltr to A. Zaccaria, Bechtel, from G. Buxton, Middle South Services, Re. AN1 Approval of Seismic Joint Seals, November 7,1980, Attached was " Fire Test of Sanolastic Sealant Material, Bechtel Power Corporatien, August 11, 1980.
The staff evaluateh the following specific concerns during the site audit to detemine compliance with Section III.G.:
1.
Unrated fire :ene boundaries 2.
Criteria for' fire protection of safe shutdown systems within a fire i
- ene which do not comply with the requirements of Section III.G.
S.
The independence of the Alternate Shutdown Capability from the Control
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Room 4.
The analysis of associated circuits within fire zones.
l 5.
The safety significance of deviations
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6.
The confomance of the re-analysis t'o.the workshop guidance.
The results of the staffs review team's evaluation is sumarized as foilows:
I Unrated fire zone boundaries So=e fire renes are bounded by floors, ceilings and walls which are not rated as fire barriers.
A' number of these assemblies do not have rated fire doors, fire proofing on structural steel, penetration seals in pipe l
and ventilation duct penetrations, or fire dampers in ventilation ducts.
In addition, the sealing of seismic gaps between such assemblies varies l
from open space to a full depth of rodofoam. The licensee has stated that the unrated assemblies would be equivalentIto a fire resistance of 45 minutes.
i The staff reviewed the licensee's iustification for the unrated assemblies:
The walls, floors, and ceilings are constructed of concrete that varies from 8" concrete block to 24" reinforced concrete.
The staff finds this acceptable.
l l
. The unrated fire doors vary in construction details.
The licensee has had some of these doors evaluated b'y'the Factory Mutual Research Corporation (FM).
FM concluded that labeled,. fire doors are expected to pr"6 vide the level of fire resistance stated on the label. The staff ' finds.this acceptable.
FM did not clearly state their decision on unlabeled doors.
The staff finds this unresolved pending clarification by FM.
I FM did not evaluate the hollow core metal doors which are also. located in the' subject walls.
The licensee justifies these doors on the basis of solid wood doors being listed by U1. with 20 and 30 minutes fire ratings.
The licensee simply concludes that the hollow core metal doors would have a rating of at 45 minutes, if tested.
The staff does not agree that this is a valid method l
for assessing the rating of these hallow core doors.
/..
l The HVAC ducts are not sealed into the asse.blies.
The licensee's calculation does not address this issue. The staff finds this unacceptable. All HVAC ducts in the unrated walls.do not have a fire damper. The licensee justifies this in the basis that (1) NFPA 90A,1981, does not require fire dampers in all penetrations and (2) fire tests have shown that 24 gauge sheet metal ducts without openings will pass NFPA 251 for one hour.
The licensee has not shown that his penetration cpenings are within the size limitations of NFPA 20 or t
aiewithoutopeningswithin'thefire:ene. The staff finds this unacceptable.
The cable and conduit penetration are sealed with 3-hour rated fire seals. The staff find this acceptable.
Some moveable pipe are provided with boot seals but are not fire rated.
The licensee justifies this on the basis that:
The space between the pipe and the assembly is relatively small (i.e.,
a.
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13" annulus or less) and 21 to 24" long.
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b.
Cable fires within these fire zones would not cause temperatures to be greater than 325'F en the unexposed side.
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The staff does not agree that this is a valid method for assessing the fire rating of such seals.
The structural steel " supporting the assemblies is unprotected.
The licensee's calculation proposes to show that if the steel reaches 1500*F it retains 2C%
i of its original strength 'and that strength is adequate to supp, ort the loads during a fire.
Since the air temperature in the room would not reach 1500*F for 30 minutes, if the temperature follows the standard time temperature curve, the licensee assumes a 45 minute fire resistance because of the conservative assumption. The staff finds this issue unresolved pending completion of the staff's evaluation of the calculation.
h The seismic gaps filled with rodofoam are justified on the basis of test results of certain configurations.
The staff observed that plant confige-ration are not similar to the testad configuration, and, therefore, the results of the test are not directly applicable.
The staff's finds this unacceptable.
i The seismic gaps with a water seal (rubber membrane at 1/2 the assembly depth) that contain no Rodofoam are justified of the basis of their similarity to movable pipe penetrations.
The staff does not agree that this is a valid method for assessing the fire rating of such seals.
The licensee's calculation does not address the seismic gaps that are completely The staff observed one such seismic gap in an 8"' concrete block wall.
open.
The staff finds this unacceptable.
The licensee's' construe' ion drawings which control plant features, such 'as l
penetration seals in walls and floor / ceiling assemblies, stipulate no require-l ments for fire protection on these unrated zone boundaries; therefore, the i
fire resistance of such boundaries is due to chance rather than design.
In addition, these unrated fire zone boundaries are not included in the fire protection technical specifications.
The staff finds this unacceptable.
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6-Criteria for fire protecticn of safe shutdown systems within a fire :ene which do not c::= ply with t'he requiremer.ts of Sect 1;on III.E.
r Section 2.11 Minority Division Essential Cable Protection, FPRR, Rev. 2, sets forth the criteria, designated as items (a) through (g), for protecting essential safe shutdown cables located in the same fire area:
l
" Protection of essential minority division raceway is accomplished by item (a) plus one or more of the following protective features:
(a)
Fire /scoke detection is provided in all fire zones containing safety related raceways.
i t
f (b)
If redundant essential safe shutdown raceways are separated by a I.
horizontal distance of at least 50 feet, no further protection is provided.
(c)
If redundant essential safe shutdown raceways, are separated by a hori-zental distance of less than 50 feet, fixed automatic fire suppression shall be provided to pnteet ar area at len.;t 50' feet hori:enta11y on either side of the essential minority raceway.
i N
(d)
If redundant essential safe shutdown raceways are separated by less l
than 50 feet and not protected by fixed automatic fire suppression, the I
raceways of one division will be enclosed in a fire barrier having a 3-hour fire rating for a projected horizontal distance of 50 feet.
l (Either side of the essential minority raceway).
(e)
If redundant essential safe shutd6wn raceways are separated by less than 20 feet and protected by fixed automatic fire suppression., the raceways of one division will be enclosed in a fire barrier having a 1-hour fire rating for a projected horizontal distance of 20 feet.
(Eithers'ide
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the essential minority raceway).
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(f)
Specific technical justification may be developed for special cases not covered.
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-7 (g)
If the equivalent fire severity is less than 10 minutes and the redundan.:
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essential safe shutdown raceways are separated by less than 20 feet, the raceway of one division will be enclosed in a fire barrier having a 1-hour fire rating for a projected horizontal distance of 20 feet.
i (Either side o,f the essential minority raceway).
Ite=s (a) and (e) above are consistent with the licensee's concitment to.
meet Section III.G, the other items are not.
The other items say be justifiable crtieria for certain configurations which deviate from the Section III.G can' figuration.
However, the licensee has not adequately analy:ed or documented the separation / protection of redundant shutdown systems to enable the staff to conclude that these configurations are acceptable. These criteria are not acceptable for all configurations in the plant.
\\
During this site audit, we did not identify any new concerns over the iEplementation of these critaria that are beyond those prSviously. identified in the Region I inspection report.
i 1
The independence of the Alternate Shutdown capability from the control room.
l The isolation of the Alternate Shutdown capability from the control room was evaluated.
The control circuits from the control room were satis-factorily fused with separated fused circuits or coordinated fused circuits. The staff finds this acceptable.
i The analysis of associated circuits within fire zones.
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In genera'1, only the " minority" division in any fire area was analyzed I
(See FPRR' Rev. 2, pg 4.1-7):
...The cables in all listed minority raceways are checked, and any not connected to a safe shutdown systems (as given in Table 6-4) or component
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.g.
are deleted.
All cable left is reviewed for its ' support of the systees safe shutdown function (s)~ and for the effects of failure caused by fii1t.
These effects inclu,de open circuits, shorts to ground, and contact with live conductors..."
For such a fire area, the analysis assumes the " majority" division in the area is lost and shutdown is to be accomplished by the " minority" division.
i The methodology analyses associated circuits for the " minority" division but not for the " majority" division.
The licensee's separation criteria is adequate to assure that the " minority" division is not associated electrically l
with the " majority" division.
However, the mathedology is not adequate to j
identify systems interactions that could associate the " majority" division with the " minority" division shutdown cacability for the area. 'The licensee did analyze two special cases at high-low pressure interfaces related to RHR sys. tam and ADS valves.
1 The " minority" division analysis was not conducted for the control room fire.,
In the licensee's FPRR, Rev. 3 (12/84) the on1y fire postulated is in a
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single tray or single panel fire (0NLY 1 DIV. LOST). ' In the sample cocponent cables reviewed two problems were identified for a control room fire:
Loss of 40 H.P. diesel generator HVAC fuses.
These are required for safe shutdown.
A control room fire would cause the control fuse to blow bringing about the loss of these fuses.
The licensee has not provided an analysis showing,the D.G's would survive j
the subsequent temperature rise in the D.G. room.
1 Spurious signal (hot shorts / grounds) would cause the loop A and loop B E5W inlet water D.G. valves to close.
This'would cause the 1
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-g-loss of water cooling to the D.G's.
The licensee stated that three procederes, i.e., E0-024-001, EO-100-030 and EO-200-030, would be used I
and this would resolve this problem.
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l These procedures are in addition to the three procedures walked down during the recent Appendix R inspection. There was not enough time to walk down these procedures during this inspection.
Other problems may exist that, have not been analyzed by..the licensee.
)
Zone Fires Zone 1-36-Access Area. The RHR valves (027A, B and 028 A, B) were selected as sa=ples to review.
These are RHR suppression pcol return valves that are used for safe shutdown and are all located in Zone 1-3c.
Our concern 1
is that they are not shown in the FPAR, Rev. 3 with other components needed for safe shutdown.
(Seepg.4.3-3'0).
It, appear that'they were
' missed in the analysis.
Zones 2-4A and 2-5A were reviewed to see the effect of a fire through the hatchway joining these zones. The recun' dant cooler within 50 feet of the hatchway in Zone 2-5A would be lost with the loss of the majority cables in Zone 2-4A with no adverse effect on safe shutdown.
i
'ones 1-20 and 2-2A were reviewed to address the concern of a fire in this -
area from an associated circuits point of view. The principal cou:ponent that can be controlled from this p'anel (ESW valves Div. II, RHR valves Loop B) were reviewed and their circuits were traced from the valves to the power source and to the remote ' shutdown panel. The circuit did not go through any zones where a fire could affect safe shutdown.
The safety' significance of deviations.
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The post fire shutdown capability may not be adequate in some cases because of: (1) the lack of a systematic analysis of the " majority" i
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i division syste= interaction with the "c:inority" division shutdown
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syste=; (a) the lack of an~' associated circuits. analysis for the control room and (2) the loss of certain support, systems dUring control roem fire.
The licensee agreed to scope this problem and infom the staff within a week.
The licensee agreed to develop interim emergency operating procedures as problecs are identified until resolStion is achieved.
The redundant division o RHR may be involved in a single fire-if the associated non-rated fire zo'ne boundary does not contain the effects of a fire.
The conforman:e of the re-analysis to the workshop guidance.
The guidanct for re-analysis given at the workshops was sumarized in
]
Gl. 85-01.
We found the licensee's re-analysis deficient in many aspec+a.
1.
FFRR, R'ev. 2. Section 4.0, states that evaluation was done using Appendix A to STP APCSE 9.5-1.
There is no mention'of a re-analy, sis to the require-ments of Section III.G of Appendix R.
2.
The licensee stated th'ere was no additional analysis other than the afometioned calculations.
3.
The licensee had no ongoing analysis at the time for the site audit.
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11 4.
The control room fire and the associated circuits analyses are not adequate.
,e 5.
The justification of unrated fire zone boundaries is not adequate.
6.
The re-analysis c,ontains no justifications for partial coverage suppression systems.
Based on the above, we conclude that the re-analysis does not conform to the i
workshop guidance.
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SUSQUEHANNA Tr o-l R.L.Fekusen NRR/DE/CMES Dennis Kubicki NRR/DE/CMES i
L. S. Weed PP&L C. T. Coddington PP&L
- 5. V. Pu11ani NRC/RO: I T. Baileys PP&L/P.S.
E. D.'MacDougall BNL Rick Jacobs NRC/SRC Llyod Smith Bechtel 4
Don Kohn PP&L
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Ken Backenstoe PP&L NPE-Elect.
PP&L Licensing
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Bill Will.iams R. J. Prego QA SUPV-OPS R. Byram PP&L e
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l' Attendance NRR Fire Protection Program NAME Precresentinc PP&L R. Paley S. V. Pu11ani NRC/RO: I
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L. E. Smith Bechtel R. Jacobs NRC Ed. MacDougall BNL L. E. Whitney NRC/IE Dennis Kubicki NRC/NRR Den Kohn PPR
?P&L.NPE.,
Ken Backenstoe QA SUPV-OPS /PP&L R. S..Prego i
Bill Williams PP&L Licerising C. T. Coddington PP&L Licensing T. Baileys' y PP&L/ Plant Staff D. J. Thompson Assist. Sup of Plant M. Catpagnone NRC/ Project Manager e
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