ML20235U438
| ML20235U438 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 04/11/1986 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 1551K, NUDOCS 8710140090 | |
| Download: ML20235U438 (4) | |
Text
(
~~'N Comm:nwrith Edison
) One First National Plaza. Chicago, Illinois 4
~~'
J Address Reply to. Post Othee Box 767
/ Chicago, Illinois 60690 i
April 11, 1986 i
Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
LaSalle County Station Unita 1 and 2 Response to Inspection Report Nos.
50-373/86-004 and 50-374/86-004 NRC Docket Nos. 50-373 and 50-374 Reference (a):
C. J. paperiello letter to Cordell Reed dated February 28, 1986.
Dear Mr. Keppler:
This letter is in response to the inspection conducted by Messrs W.
)
Guldemond, C. Ramsey, J. Holmes and Z. Falevitz on January 13-27, 1986, of j
activities at LaSalle County Station.
Reference (a) indicated that certain j
activities appeared to be in noncompliance with NRC requirements.
The Commonwealth Edison Company response to the Notice of Violation is provided in Attachment A.
This response is timely with the extension granted by telecon with J. J. Harrison on March 20, 1986.
Commonwealth Edison disagrees with the examples in the Notice of Violation on items numbered IR 50-373/86-004-01 and 50-374/86-004-01. We I
request you review your conclusions in light of the additional information
{
provided in this report.
1 If you have any further questions on this matter, please direct them to this office.
Very truly yours, p'nERBMOP y E. <d 7
ennis L. Farrar J
DLweetor of Nuclear Licensing 1m Attachment cc: NRC Resident Inspector - LSCS 1551K 1
APR 24isSS i
b_
1 ATTACHMENT i
ITEM OF VIOLATION Condition No. 24 of Amendment No. 1 of Facility Operating License No. NPF-ll (Unit 1) and Condition No. 15 of Facility Operating License No.
NPF-18 (Unit 2) require the licensee to maintain in effect all provisions of the approved fire protection program for LaSalle Unit 1 and Unit 2.
As part of their approved fire protection program, the licensee committed to install fire detection and alarm systems in accordance with National Fire Protection Standard No. 72D.
Contrary to the above, the licensee failed to install fire detection and alarm systems in accordance with the stated requirements in that:
l a.
Unit 1 and Unit 2 local fire alarm circuits are not electrically I
supervised.
b.
Unit 1 and Unit 2 control room fire detection system visual alarm annunciator circuits are not electrically supervised.
DISCUSSION AND ADDITIONAL INFORMATION LaSalle County Station (LSCS) is currently completing an NFPA Code Review to document deviations in our fire protection program from the applicable codes of construction.
This is an effort on our part to analyze significant deviations and take corrective action where necessary. The NRC is aware of our code review and intentions to document the adequacy of the j
fire protection system.
The references to the NFPA Codes in this violation identify the latest version which was not available to Commonwealth Edison during the design of the Fire Protection (FP) System.
Specification J-2978, which procured the equipment and design of the fire detection system, was issued in 1976. This specification required the contractor to design the fire detection system to the latest revision of the applicable NFPA Codes. The applicable version of NFPA-72D is the 1975 issue for LaSalle County Station.
Item a.
The local light and siren circuits for the fire detection and evacuation system at LSCS are not electrically supervised.
In our judgement this is not a deviation from NFpA-72D (1975).
NFPA-72D (1975) Article 240 discusses electrical supervision.
Section 2411 i
l states; "Except as otherwise permitted in this standard a system shall be electrically supervised..." Section 2441 r.tates, "the electrical supervision shall include all circuits for operating l
alarm sounding devices except:
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.. a.
A circuit employed to produce a supplementary local alarm l
signal to indicate the operation of an automatically operated alarm transmitter or a manual fire alarm box provided that an.
open or ground fault of the signal conductor results only in th loss of the supplementary signal."
At LSCS an open or ground fault in the local audible or visual alarm circuit cannot affect the supervised detector circuits.
These two types of circuits are electrically independent. NFPA-72D (1975) does not define supplementary alarms. We consider our local lights and sirens to be supplementary to the audible and visual alarm indications at the control room.
LaSalle's NFPA Code review for NFPA-72D did not document this as a deviation from the code.
This judgement has been concurred with by Schirmer Engineering (Fire Protection Consultant).
Item b.
This item addresses the requirement for supervision of the detectors. The ionization detector circuits are supervised from the detectors to panel 1(2)FPO4JA in the Aux 111ary Electric i
l Equipment Room (AEER). Between the AEER and Control Room Panels 1(2)FPO4JB and 1(2)4B04JC (the central supervised station per NFPA-72D) there is no supervision. A program is in place that tests the circuits between these panels once per shift. This practice has been followed since 1981.
However, records are only available for the past year.
We do not believe this to be an item of violation. Appendix A (Fire Detection) to Branch Technical Position 9-5.1 states
" deviation from the requirements of NFPA-72D should be identified and justified." One item from Inspection Report Nos. 50-373/83-44 and 50-374/83-38 included in the January 24, 1984 appeal (C. Reed to H. Denton) was the " imposition of all aspects of all NFPA Codes".
The letter from A. Schwencer to D. Farrar dated March 14, 1984 regarding this particular item of appeal, concluded "the applicant should specifically identify the NFPA Codes that are applicable and the significant deviations of his program from these codes." Following the appeal meeting in Washington, D.C., CECO documented the resolution of the items of appeal in a June 14, 1984 letter from D. Farrar to H. Denton.
On the issue of significant deviations from NFPA Codes the NRC agreed the codes allow for engineering judgement and CECO committed "to specifically identify the NFPA codes that are applicable to our stations and any significant deviations of our program from the codes.... Final resolution of any noted NFPA code deviations will involve either justifying or correcting the deviations.
All justifications will be based on fire protection engineering judgement and will be documented."
R. Spessard's letter to C. Reed dated March, 1985 stated that the June 14, 1984 letter was responsive to the issues, e____________
,. LSCS committed to perform the NFPA code review. This review has been completed and the project is in the final documentation stages. The review will have required over 4000 manhours (not including the extensive reviews concurrently being done on water systems, detector locations, dampers, and other 110'nse conditions).
The entire project has taken longer thav originally anticipated.
The unsupervised circuit from the main pacel in the AEER to the annunciator in the control room is considered to be a deviation from NFPA 72D(1975). A once-per-shift surveillance to confirm continuity is sufficient, in our judgement, to justify the deviation. This judgement will be further documented when the NFPA i
code review deviation package is completed. To supervise these f
circuits would be very expensive and result in routing hundreds of I
additional cables through the AEER, the Cable Spreading Room, and the control Room.
The quality of our cable and the infrequent interference (Modifications or maintenance) with the current configuration results in a low' probability of removing or damaging the circuits.
Should that happen, the once-per-shift surveillance would discover it in a timely manner.
The final documentation package for all the NFPA code reviews will l
be prepared and reviewed by the Station Nuclear Engineering Department (SNED) by August, 1986. Modifications to correct significant deviations (if required) will be scheduled in i
accordance with their impact on Fire Protection Safety and the 5 Year Modification Plan.
This documentation package will be available at the Station for NRC review.
Based on this information, the examples cited in the Notice of Violation are not contrary to the LaSalle Approved Fire Protection Program.
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