ML20234F189

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Responds to Violations Noted in Insp Repts 50-373/87-27 & 50-374/87-26.Disagrees W/Violation Re Fire Protection Program Requirements.Explicit Language in App R Clarifies Any Ambiguity in Earlier 1977 Document
ML20234F189
Person / Time
Site: LaSalle  Constellation icon.png
Issue date: 10/13/1987
From: Butterfield L
COMMONWEALTH EDISON CO.
To: Davis A
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20234F153 List:
References
NUDOCS 8801110372
Download: ML20234F189 (5)
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Text

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CN f ) Commonwealth One First Nuional Plaza. Chicago, Edison Illinois

, , * [\ V Address R2 ply to: Post Office Box 767

\ Chicago, Illinois 60690 0767 October 13, 1987 Mr. A. Bert Davis Regional Administrator ~

U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

LaSalle County Station Units 1 and 2 Response to Inspection Report Nos. 50-373/87-027 & 50-374/87-026 NRC Docket Nos. 50-373 and 50-374 Reference (a): J. J. Harrison letter to Cordell Reed dated September 11, 1987

Dear Mr. Davis:

This letter is in response to the inspection conducted by Mr. J. M. Ulie on July 13-15, August 10-11 and September 8, 1987 of activities at LaSalle County Station. Reference (a) indicated that certain activities appeared to be in noncompliance with NRC requirements. The Commonwealth Edison Company response to the Notice of Violation is provided in Attachment A.

Commonwealth Edison disagrees that this item is an item of violation for the reasons discussed in Attachment A. We discussed these items in a conversation with Mr. R. N. Gardner and J. M. Ulie of your staff on l September 8, 1987 in which we were urged to include our objections in our l

written response. We would welcome the opportunity to meet with the NRC staff to discuss our response to the Notice of Violation in reference (a) in a more detail.

If you have any further questions on this matter, please direct them to this office.

V truly you n

w-r-w L. D. Butterfield bf" Nuclear Licensing Manager es 8801110372 880104 PDR G ADOCK 05000373 Attachment PDR cc: NRC Resident Inspector - LSCS 00T 151987

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ATTACHMENT A ITEM OF VIOLATION IR 373/87-027-02; 50-374/87-026-02 Amendment No. 1 of Facility Operating Licenses No. NPF-11 (Unit 1),

Section 2.C (24) and No. NPF-18 (Unit 2), Section 2.C (15) require the licensee to maintain in effect all provisions of the approved fire protection program for LaSalle Unit 1 and Unit 2 describing that those provisions are included in the Safety Evaluation Report (SER) and in Supplement Nos. 1, 2, 3, 5, and 7. As described specifically in the SER and Supplement No. 2, the LaSalle fire protection program includes commitments to the NRC document,

" Nuclear Plant Fire Protection Functional Responsibilities, Administrative {

i controls, and Quality Assurance." Attachment No. 6 (Paragraph 2.0) of this document states in part, ". . . administrative controls . . . that govern the fire protection program shall be prescribed by documented instructions (and) procedures." In addition, Attachment 5 states in part that, "The fire fighting procedures should identify . . . the need for brigade assistance upon

. . . receipt of an alarm on the control room annunciator panel . ."

Contrary to the above, Procedure No. LOA-FP-01 entitled " Fire Alarm Response" did not prescribe the need for brigade assistance upon receipt of an alarm in the control room. It provided for an unacceptable time delay in fire brigade response to a fire through the allowed and established practice of dispatching an individual to an alarmed area without alerting and assembling the fire brigade after the annunciator in the control room of the activation of a fire detector.

RESPONSE

Commonwealth Edison does not believe this to be a violation. As noted in the inspection report, LaSalle County Station Operating License contains a commitment to the 1977 NRC document entitled " Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls and Quality Assurance". We believe we satisfy that commitment based on the following:

various supplements.

  • The LaSalle procedures are in accordance with Appendix R which is a subsequent rule that clarifies any ambiguities in the 1977 document committed to and supersedes any inconsistent interpretations of those commitments.

A survey of other nuclear utilities conducted by NUS, Licensing Informat!on Service indicated that the majority employ practices similar to those followed by Commonwealth Edison.

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Moreover Edison's understanding of the 1977 commitment is consistent with the safety intent of the license condition because:

- the present system allows screening of false alarms by a fire brigade qualified operator.

- fire suppression systems are located in areas of high fire loading to insure the fire is contained and not allowed to j spread.

The requirement to have fire protection procedures is contained in Attachment No. 5 to the NRC document, " Nuclear plant Fire Protection Functional Responsibilities, Administrative Controls and Quality Assurance" entitled Fire Pichting Procedures. It states that: " Fire Fighting Procedures should be established to cover such items as notification of a fire, fire emergency procedures, and coordination of fire fighting l activities with off site fire departments. The fire fighting procedures should identify:

a... l b) actions to be taken by the control room operator and the need i for brigade assistance upon report of a fire or receipt of an )

alarm on control room annunciator panel, such as: announcing location of fire over the PA system, sounding fire alarms and notifying the shift supervisor and fire brigade leader of the type, size and location of the fire, j c... j The structure and subject matter of this requirement all address l procedures for specific actions to be taken by the control room operator to ascertain the extent of the fire and to perform actions to protect the plant and equipment in the event of a valid alarm. Nevertheless, the NRC has interpreted this provision as requiring the procedures themselves to identify that there is always a need for fire brigade assembly in the event of any fire alarm. Not only is that interpretation inconsistent with the structure of the requirement, it is also inconsistent with the clarification that has 1,een issued subsequently in 10 CFR 50, Appendix R. That rule, adopts the more natural interpretation of this provision by explicitly stating that the operator is to determine the need for assembling the fire brigade before calling for its assembly. This is stated explicitly in 10 CFR 50 Appendix R section III.K which states " Administrative controls shall I i be established to minimize fire hazards in areas containing structures, systems, and components important to safety. These controls shall establish

! procedures to:

". 10. Control actions to be taken by the control room operator to determine the need (emphasis added) for brigade assistance upon I report of a fire or receipt of an alarm on control room I annunciator panel, for example announcing location of fire over l

PA system, sounding fire elarms, and natifying the shift supervisor and fire brigade leader of the type, size and location of the fire."

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The Appendix R language clearly shows that the control room operator is "to determine the need for brigade assistance" rather than being required to immediately assemble the brigade. Thus, the commitment simply requires procedures that have the control room operator identify the need 1 for brigade assistance. That commitment does not require a procedure directing the operator to immediately assemble the fire brigade on the receipt of a single fire alarm. Therefore, for the commitment to be interpreted consistently with Appendix R it should be given this natural reading.

Commonwealth Edison's commitment to " Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls and Quality Assurance", Attachment 5 are implemented by procedure LOA-FP-01 which states under section b, OPERATOR ACTIONS, "if alarm indicates fire, go to hazard area and CHECK for fire." This is the same determination required to be l performed in Appendix R. This process not only satisfies the explicit language in Appendix R but also better fulfills its intent. The operators who initially investigate the fire alarms are all fire brigade qualified; they can make an on the spot assessment of the type, size, and location of  !

the fire. If assistance is needed, the report from the operator at the I scene of the fire provides the control room operator with the information }

necessary to determine the need for fire brigade assistance.

Furthermore, by not requiring the fire brigade to respond to '

false alarms, Commonwealth Edison believes that the attitude and alertness of fire brigade members is enhanced.

Sinceinitialalarmresponsgscreens the nuisance alarms, the fire brigade members are better mentally Trepared for their response because they know when they assemble that the alarm is not a false alarm. Thus it is our belief that response to single alarms in this manner enhances fire brigade performance.

Additionally, we take strong exception to the suggestion that Edison's 1 procedures could result in the uncontrolled spread of a fire. The referenced inspection report states that:

"The present Station Policy creates the potential for a delay in alerting and assembling the fire brigade after an unplanned actuation of a fire alarm has occurred and allows the potential fire to freely spread unsuppressed."

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This is inaccurate. The design basis fire in any fire zone will be kept from spreading to other areas by fire barriers or adequate physical i separation. In addition, areas of high fire loading are protected by fire suppression systems of water spray, water deluge or CO 2 . This design of LaSalle Fire Protection provisions has been reviewed and found acceptable by your staff. Second if an operator received multiple fire protection alarms simultaneously (ie, smoke Detector, Sprinkler Actuated and Diesel Fire Pump Running alarms), definately indicating that a fire is present, he would act immediately to sound the fire alarm, while simultaneously sending a fire brigade qualified operator to investigate.

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l l Your staff has reviewed the LaSalle fire protection program several times. j The resultant Safety Evaluation Report (NUREG 0519) and Supplements number 2 j and number 7 to it document the acceptability of Edison's program. Indeed, l these references specifically noted the program meets the requirements of l Appendix R, even though Appendix R does not apply to LaSalle. Under these I circumstances, the NRC's interpretation of Edison's commitment appears to be j a backfit.

To summariz_e_: Commonwealth Edison does not believe this to be a violation. The explicit language in Appendix R clarifies any ambiguity in the earlier 1977 document. Appendix R explicitly states that the control room operator is to " determine the need for brigade assistance" before assembly of the fire brigade. Thus any alternate interpretation of the commitment to require the procedure to automatically provide for assembly of the brigade on receipt of a fire alarm is contrary to the Commission's rules. Moreover safety is enhanced by investigating the fire prior to sounding the alcrm as this improves the performance of the fire brigade by screening out nuisance alarms and by preparing them to deal with the i particular circumstances of a fire. l l

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