ML20245J608
| ML20245J608 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 07/11/1989 |
| From: | Morgan W COMMONWEALTH EDISON CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 8908180087 | |
| Download: ML20245J608 (9) | |
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16 - f ; O'[' ' f-Ay)1 Commonwealth Edison :
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-,; 72 West Aduns Street. Chicago, lilinois N#
.A Address Reply to: Post Office bot 7BT
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N i Chicago, Iflinois 60690 - 0767-4 July.11, 1989 Mr.-A.~Bert Davis.
Regional Administrator.
U.S. Nuclear Regulatory Coinmission Region III 799. Roosevelt. Road:
Glen Ellyn, IL-60137
Subject:
- LaSalle County Station Units 1 and 2 Supplemental Response to Inspection Report Nos. 50-373/89027 and 50-374/87026 Fire Brigade Response Time NRC Docket Nos. 50-373 and 50-374 Reference (a)
W.E. Morgan letter to A.B. Davis dated April-28, 1989 Dear Mr. Davis
' Reference (a) provided an evaluation which identified areas at Commonwealth Edison's LaSalle County Station which would require immediate assembly of'the station fire' brigade upon receipt of a fire alarm'in the control room. This action was to be done on an interim basis until'a more in-deptn analysis was completed, reviewed and approved by the NRC.
The
-following attachment provides this in-depth analysis.
Based on the results of the attached analysis some areas.at the LaSalle Station require immediate assembly of the fire brigade upon receipt of a fire alarm in the Control Room during certain plant operating conditions.
During such conditions safe shutdown capabilities may become " vulnerable"
'(when the alternate safe shutdown method independent of the zone is unavailable-and the applicable unit is in power operation) to a single fire.
8908i80087 890711 3
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PDR ADOCK 05000373 A
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A.D. Davis July 11, 1989 i
Attachments A and B provide the Unit 1 and Unit 2 fire zones when they are vulnerable, that LaSalle Station will commit to require immediate.
assembly of the fire brigade upon receipt of a fire alarm in the control room.
This does not apply when alternate safe shutdown equipment is technically OOS/Inop for. planned maintenance or surveillance testing. During these periods, the alternate safe shutdown method could be readily restored if required.
Attachment C identifies the Safe Shutdown Systems and corresponding Technical Specification Action Statements that will constitute the above mentioned actions. Administrative controls to implement this commitment will be established by August 31, 1989.
If you have any further questions regarding this matter, please direct them to this office.
Very truly yours, (v
i 4 41 W. E. Morgan Nuclear Licensing Administrator 1m Attachments cc:
Region III Inspector - LSCS P.C. Shemanski - Project Manager, NRR D.
Kubicki - NRR J. U111e - Region III 0200T j
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LASALLE COUNTY STATION FIEE_I)RIGADE ASSEMBLY ANALYSIS IIIDEK SECTION PAGE 1
A.
Purpose B.
References 1
C.
Methodology.
1 D.
Analysis Method.
2 E.
Analysis' 2
F.
Limitation and Actions 2
ATTACHMENTS A.
' Unit 1 Fire Zones Containing Safe Shutdown Related Equipment and Their Corresponding Detection Zones.
D.
Unit 2 Fire Zones Containing Safe Shutdown Related Equipment and Their Corresponding Detection Zones.
C.
Listing of Safe Shutdown Systems, when unavailable, and Entry Into Technical Specification Action Statements Which Would Require immediate Fire Brigade Assembly.
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LASALLE_f00NTY STATIONJEE_DEISADI_ ASSEMBLY AN_AIJEIS A.
EUREOSE The purpose of this analysis is to identify plant operating conditions during which safe shutdown capability may become vulnerable to a single fire, therefore warranting the immediate assembly of the fire brigade upon receipt of a fire alarm in the control room.
B.
REFERENCES 1.
2.
July 20, 1988 letter from G. H. Holahan (NRR) to H. J. Miller (NRC Region III) concerning request for technical assistance-clarification of NRC position covering timeliness of fire brigade response.
3.
LaSalle Fire Protection Documentation Packages a.
Updated Final Safety Analysis Report b.
Historical Volume c.
Fire Hazards Analysis d.
Safe Shutdown Report e.
Safety Evaluation Reports (Original and Supplements) 4.
The November 3, 1981 letter from L. O. De1 George to-A..Schwencer.
5.
The "LaSalle County Station Fire Brigade Assembly Interim Evaluation", dated April 28, 1989.
6.
April 28, 1989 letter from W. E. Morgan (CECO) to A.
B. Davis (NEC Region III).
C.
MEIllDDDLDGY 1.
Only those fire zones and sub-zones which contain essential safe shutdown components (components and cables of the primary and alternate safe shutdown methods as described in the Safe Shutdown Report) have been analyzed. Delayed fire brigade response in all other plant areas is not considered significant from a fire protection standpoint. No safe shutdown division would be affected.
Therefore, permitting a plant operator to respond first to an alarm in these areas is acceptable during all plant conditions.
2.
A fire zone or sub-zone is considered " vulnerable" when the alternate safe shutdown method independent of that zone is unavailable and the applicable Unit is running.
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-*'.e' a.
When a fire zone or sub-zone is vulnerable,-a fire in that j
zone could potentially threaten safe shutdown capability, j
therefore immediate assembly by the fire brigade upon receipt of a fire alarm in the control room for that zone is warranted.
3.
Credit has been taken for previous analysis and evaluations performed in the documents referenced in section.B.3 of this report.
All areas that contain significant fire hazards, regardless of whether or not they represent a threat to safe shutdown capability, l
have been previously analyzed and protected accordingly.
D.
ANALYE.IS E TliQR 1.
The steps outlined below were used in identifying plant operating conditions during which safe shutdown capability may become vulnerable to a single fire:
1 a.
The safe shutdown method which could be adversely effected by I
a single fire for each fire zone /sub-zone was identified.
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b.
The alternate safe shutdown method which would need to be I
utilized for each fire zone /sub-zone was identified.
c.
A comparison study of these safe shutdown methods versus plant I
Technical Specification Limiting Conditions for Operation (LCO's) was performed to identify " vulnerable" plant operating conditions which could exist when the Unit (s) is running.
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E.
ANALYSIE The results of the method outlined above were tabulated and are shown in Attachments A and B.
F.
LIMITATIONS AND ACTIONS 1.
This analysis is a supplement to, but does not supercede, the "LaSalle County Station Fire Brigade Assembly Interim Evaluation" dated April 28.,
1989. The recommendations from the April 28, 1989 l'
evaluation should continue to be implemented.
2.
Fire zones 2G, 4F1, 7A3, 7B3, 7B6, 7C3 and 7C6 are fire zones in Unit I that contain cables whic:. are necessary for operation of Diesel Generator "O" which feeds electrical Div 1 in Unit 2.
h fire in these zones could affect Unit 2 RCIC, ADS Div 1, and RHR l
Loop A.
HPCS, ADS Div 2, and RHR Loop B comprise the alternate safe shutdown method for Unit 2 independent of these zones.
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Therefore zones 2G, 4F1, 7A3, 7B3, 7B6, 7C3 and 7C6 are included in l
the appropriate sections of the Unit 2 assembly requirements.
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3.
The recommendations in this analysis dn ant apph when alternate-safe shutdown equipment is technically OOS/Inop for planned maintenance or surveillance testing. During these periods the alternate safe shutdown method could be readily restored if required.
4.
The recommendations in the analysis da App h when an alternata safe shutdown system is declared inoperable and an unplanned entry into its Technical Specification time clock is made, including an unplanned time clock entry due to an inoperable back-up diesel generator.
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ATTACIMENT A UNIT 1 FIfjli 2T,ES_COLUAUURG SAFE _S11UIRQWN RELATED EOUIPliDH_AllD -
CORRESPONDING Dt:TECTION ZONES Fire Enne Lanation Rel.gtglign_Zang 2B1 820' Reactor Building.
1-24 2D 786' Reactor Building
'l-36,1-37 2E-1 761' Reactor Building 1-34 2E-2 761' Reactor Building 1-35 2F-1 740' Reactor Building 1-17 2F-2 740' Reactor Building 1-17p
- 2G 710' Reactor Building 1-22
- 2G-2 710' Reactor Building 1-22p 2H1-1 694' Reactor Building 1-32 2H1-2 694' Reactor Ballding 1-33 2H4 694' Reactor Building 1-33 2H5 694' Reactor Building 1-33 211-1 673' Reactor Building 1-30 211-2 673' Reactor Building 1-31 2I2' 673' Reactor Building 1-30 213 673' Reactor Building 1-30 2I4 673' Reactor Building 1-31 215 673' Reactor Building 1-31 4C1 768' Control Room 1-5 4C2 760' Auxiliary Building 1-39 4D1-1 749' Auxiliary Building Water Flow Alarm 4D1-2 749' Aux 111ery Building Water Flow Alarm 4D3 749' Auxiliary Building 1-12 4El-1 731' AEER 1-27 4El-2 731' AEER 1-27 4ES-1 731' Auxiliary b.11dino 1-8 4El-2 731' Auxillery Build 8.og 1-8
- 4F1 710' Auxiliary pas 1 ding 1-9
- 4F3 710' Auxiliary Building Water Flow Alarm 5A4 749' Cable Tunnel Area 1-18 5D1 687' HPCS Switch Gear Room 1-10 7Al 731' HPCS DG Vent Room 1-29 7A2 731' Div 2 DG Vent Room 1-29
.* 7 A3 731' Div 1 DG Vent Room 1-29 7B1 710 HPCS DG Room Heat Det/CO2 System 7B2 710' Div 2 DG Room Heat Det/CO2 System
- 7B3 710' Div 1 DG Room Heat Det/CO2 System 7B4 710' HPCS Day Tank Room Water Flow Alarm 7BS 710' Div 2 DG Day Tank Fater Flow Alarm
- 7B6 710' Div 1 DG Day Tank Water Flow Alazm 7C1 674' HPCS DG Fuel Tank Water Flow Alarm 7C2 674' Div 2 DG Fuel Tank Water Flow Alarm
- 7C3 674' Div 1 DG Fuel Tank Water Flow hlarm 7C4 674' HPCS DG Pump Room 1-28 7CS 674' Div 2 RHR WS Pump 1-28
- 7C6 674' Div 1 RHR WS Pump 1-28
- Indicates zone contains Unit 2 Safe Shutdown Equipment 0200T:7
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' ATTACIMEEE_R 1
Ul{1T 2 FIRK_20llES CONTAINING_ SAFE SHUTDOWN RELATED EOUIPMENT AND CORRESPONQll1G DETECTION ZONES j
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i fire Zong Location Eglection Zqng 3B1 820' Reactor Building 2-24 3D 786' Reactor Building 2-36,2-37 3E-1 761' Reactor Building 2-34 3E-2 761' Reactor Building 2-35 3F-1 740' Reactor Building 2-17 3F-2 740' Reactor Building 2-17p 3G-1 710' Reactor Building 2-22 3H1-1 694*
Reactor Building 2-32 3H1-2 594' Reactor Building 2-33 3H4 694*
Reactor Building 2-33 3H5 694' Reactor Building 2-33 311-1 673' Reactor Building 2-30 3I1-2 673' Reactor Building 2-31
.312 673' Reactor Building 2-30 313 673' Reactor Building 2-30 3I4 673' Reactor Building 2-31 315 673' Reactor Building 2-31 4C3 768'. Aux 111ery Building 2-39 4D2 749' Auxiliary Building Water Flow Alarr 4D4 749' Auxiliary Building 2-12 4E2-1 731' AEER 2-27 4E2-2 731' AEER 2-27 4E4-1 731' Aux 111ery Building 2-8 4E4-2 731' Auxiliary Building 2-8 i
4F2 710' Auxiliary Building 2-9 4F3 710' Auxiliary Building Water Flow Alarm SD2 687' HPCS Switch Gear Room 2-10 BA1 731' HPCS DG Vent Room 2-29 BA2 731' Div 2 DG Vent Room 2-29 0B1 710' HPCS DG Room Heat Det/CO2 8B2 710' Div 2 DG Room Heat Det/CO2 BB3 710' HPCS Day Tank Room Water Flow Alarm BB4 710' Div 2 DG Day Tank Water Flow Alarm BC1 674' HPCS DG Fuel Tank Water Flow Alarm BC2 674' Div 2 DG ruel Tank Water Flow Alarm BC3 674' HPCS Diesel Pump Room 2-28 BC4 674' Div 2 EllR WS Pump Room 2-28 BCS 674' Div RilR WS Pump Room 2-28 0200T:8
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AITACERIENI_C i--
SZEIEM IECH SPEC (
ACTION STATEMEt{I 4
HPCS 9.5.1.c.1 With ECCS division 3 inoperable, restore the inoperable division to OPERABLE status within 14 days (provided RCIC and ECCS Div 1 and 2 are OPERABLE).
3.5.1.c.2 Otherwise, be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
j' RCIC 3.7.3.b With the RCIC system inoperable, operation l
may continue provided the HPCS system is OPERABLE; rertoro RCIC system OPERhBLE status within 14 days or be in at least HOT SHUTDOWN within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
ADS 1&2 3.5.1.e.2 With two or more of the required ADS valves inoperable, be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> RHR A 3.5.1.a.2 With tTe LPCI sub-system "A" inoperable, restore the inoperable LPCI sub-system "A"
to OPERABLE status within 7 days.
3.5.1.a.3 Mith the LPCS system inoperable and LPCI sub-system "A" inoperable, restore at least the inoperable LPCI sub-system "A" or the l
inoperable LPCS system to OPERABLE status I
within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
3.5.1.a.4 Otherwise, be in a least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
RHR B 3.5.1.b.1 With either LPCI sub-system "B" or "C"
inoperable, restore the inoperable LPCI sub-system "B" or "C" to OPERABLE statue within 7 days.
3.5.1.b.2 With both LPCI sub-systems "B" and "C"
inoperable, restore at least the inoperable LPCI "B" or "C" system to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
3.5.1.b.3 Otherwise, be in at least HDT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
RHR A&B 3.5.1.d.1 With the LPCI sub-system "A" and either LPCI sub-system "B" or "C"
inoperable, restore at least the inoperable LPCI sub-system "A" or inoperable LPCI sub-system "B".
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