ML20235U733

Supplemental Response to Fire Protection Issues Identified in Insp Repts 50-373/86-04 & 50-374/86-04,per Discussion in 870402 Telcon.Deviation from NFPA 72D-1975 Re Unsupervised Fire Detection Circuits Sufficiently Justified

ML20235U733
Person / Time
Site:	LaSalle
Issue date:	04/15/1987
From:	Allen C COMMONWEALTH EDISON CO.
To:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
2974K, NUDOCS 8710140225
Download: ML20235U733 (5)

Text

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. , , Commtnw=lth Edison C A. One First National Plaza, Chicago, lIlinois Address Reply to: Post Office Box 767 Chicago, Illinois 60690 0767 April 15, 1987 i

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 Supplemental Response to Inspection Report Nos. 50-373/86004 and 50-374/86004 NRC Docket Nos. 50-373 and 50-374

References:

(a) Inspection Report No. 50-373/86004; 50-374/86004 NRC Docket Nos. 50-373 and 50-374.

(b) Commonwealth Edison response to Inspection Report 50-373/86004: 50-374/86004 (reference (a)) dated April 11, 1986.

(c) Letter from Cordell Reed to H.R. Denton dated January 27, 1984 (attached).

(d) Letter from A. Schwencer to D.L. Farrar dated March 14, 1984 (attached).

(e) Letter from A. Bournia to Commonwealth Edison dated April 24, 1984 (attached).

(f) Letter from D.L. Farrar to H.R. Denton dated June 14, 1984 (attached).

(g) Letter from R.L. Spessard to Cordell Reed dated March, 1985 (attached).

Dear Mr. Davis:

On April 2, 1987 a telephone conference call was held between Messrs. R. Gardner and J. Holmes of Region III and Commonwealth Edison. The following Fire protection issues identified in reference (a) were discussed; a) Supervision of circuits providing local alarms, b) Supervision of fire detection visual (annunciator) alarm circuits to the control room.

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Mr. A.B. Davis April 15, 1987 As a result of this conversation Commonwealth Edison (CECO) agreed to provide copies of historical correspondence with NRR concerning CECO's NFPA commitments and additional information in support of items (a) and (b) for further review. The applicable version of NFPA-72D referenced in these discussions is the 1975 issue for LaSalle County Station.

DISCUSSION The issue of which NFPA codes are applicable to LaSalle first arose in an inspection conducted in 1983. This was documented in Inspection Report 50-373/83-44; 50-374/83-38. This inspection led to several meetings between Ceco and the NRC, involving both Region III and NRR personnel. In reference (c), CECO appealed the imposition of all aspects of the NFPA Codes.

The response to this appeal contained in reference (d), regarding this particular item, concluded "the applicant should specifically identify the NFPA Codes that'are applicable and the significant deviations of his program from these codes."

An appeal meeting was held March 28, 1984 to discuss various aspects of.the fire protection appeal. In the meeting summary dated April 24, 1984 in reference (e), it was stated: "The licensee specified it had no problem with meeting those codes indicated by the FSAR, but had some hardship in meeting codes that would be changing during the life of the plant. The NRC Staff stated that the licensee should go back and specify the code with the date of the code it was meeting. They would then be held accountable only for that dated code. The licensee inicated that it would review its submittals and submit an update to reflect the date of the code."

Following the appeal meeting in Washington, D.C., CECO documented the resolution of the items of appeal in reference (f). 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." Reference (g) stated that the reference (f) letter was responsive to the issue.

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The NFPA code review LaSalle committed to has been completed and the l 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 license conditions). The entire project has taken longer than we originally anticipated.

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• Mr. A.B. Davis April 15, 1987 Discussion of Local Alarms [ Item (a)]

The local lights and sirens in the individual fire zones at LaSalle i are hardwired to an independent contact of the relay module at the central' supervisory panel which is located in the Auxiliary Electric Equipment Room (AEER). These local alarms receive their power supply independent of this panel. The detector circuits are also wired to this panel at a separate ,

I supervised ionization module. This arrangement assures that the local alarm circuits are electrically independent of the detector circuits. Thus, an open or ground fault in the local audible or visual alarm circuit cannot affect the supervised detector circuits.

NFPA-72D (1975), Article 240, Section 2441 states the following with regard to alarm signal sounding circuits:

"The electrical supervision shall include all circuits for operating alarm sounding devices and appliances except: (a) a circuit employed to produce a supplementary local alarm 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 circuit conductor results only in the loss of the supplementary signal."

The local alarms at LaSalle are supplementary to the main alarms in the AEER and control room and therefore are not required to be supervised as stated in the preceding code section. NFPA-72D (1975) does not define supplementary alarms. Consequently, the LaSalle NFPA code review for NFPA-72D did not document this as a deviation from the code. This judgement has been concurred with by Shirmer Engineering (Fire protection Consultant) and Sargent & Lundy Engineering's fire protection engineer.

The main function of local alarms is the evacuation of personnel in the event of a fire. This is true for a standard industrial occupancy; however, the majority of the areas at a nuclear power plant are unmanned and, as such, do not require evacuation. The LaSalle County Station has a I fire brigade which responds to all fire alarms as directed by the control  ;

room operators. This site fire brigade, trained and equipped for fire fighting is established to ensure adequate manual fire fighting capability for all areas of the plant.

In summary, the issue of the unsupervised local lights and sirens between the AEER fire detection system control panel and the local zones in the plant was reviewed and was determined not to be a deviation from NFPA-72D (1975).

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Mr. A.B. Davis April 15, 1987 Discussion of Control Room Detector Alarm Circuits [ Item (b)]

The fire detection system visual alarm annunciator circuits are electrically supervised from the local detectors to the ionization modules of the central supervisory panel located in the Auxiliary Electric Equipment Room, llowever, the circuits between the AEER and the fire detection system annunciator located in the control room are unsupervised. This deviation to 72-D (1975) was self-discovered during fire detection reviews performed in 1981 and documented during the recent NFPA code review performed by Commonwealth Edison.

As a result of this deviation, CECO has taken the following action:

Each shift a lamp test is performed on the circuits which were reviewed and found unsupervised. This test consists of activating the lamp test switch on the fire detection system control panel in the AEER and having a operator verify that all lamps are lit on the fire detection system annunciator in the control room. This verification ensures that these fire detection system circuits have proper continuity and would perform accordingly if required to do so. The once per shift lamp test has been performed by CECO since 1981. Formal records of the test have been maintained for the last year.

Furthermore, Ceco has reviewed the installation of these unsupervised circuits and concludes that it would be unlikely that their disruption would occur, or if occured, would go undetected prior to the next once per shift lamp test. Under no circumstances should a circuit failure go undetected beyond the next once per shift lamp test. The basis for these conclusions are as follows:

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a. All cables used for these circuits is routed in rigid steel conduit or solid bottom cable tray.

b. All cables used for these circuits is of the same high quality and type as those used for safety-related circuits in harsh ,

environments.

c. There are no intermediate terminations in the cables that are used for these circuits between the AEER and control room,

d. All cables used for these circuits are routed only with low energy control cables and never come in contact with any power cables.

e. No failures of these circuits have been reported since the once per shift lamp test was begun in 1981.

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Mr. A.B. Davis April 15, 1987

f. All cables used for these circuits are routed in one path relative to supervised circuits leaving the AEER fire detection system panel for individual detection zones.

g. Station modification and work request procedures strictly control all wiring to this equipment. They require that all landing and lifting of leads for Fire Protection circuitry be independently verified. Functional tests are also required to verify operability following all maintenance on these circuits.

h. Modifications to this circuitry are infrequent and currently no modifications are' outstanding against these circuits.

In summary, the unsupervised fire detection circuits between the AEER fire detection system control panel and control room fire detection annunciator are a deviation from NFPA 72D-1975. This deviation has been reviewed and based on the information above, and by the once per shift lamp ,

test, sufficiently justified.

Summary of Violation Appeal Based on the discussion above, Ceco believes that neither item of Inspection Report 86004 is a violation. We have complied with Appendix A

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(fire detection) to Branch Technical Position 9.5.1 which states for plants under construction and operating plants " deviations from the requirmeents of NFPA-72D should be identified and' justified". That has been done in accordance with commitments and agreements reached with the NRC Staff and

' identified in the documentation discussed above.

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

Very truly yours,

&& C. M. Allen Nuclear Licensing Administrator 1m Attachments cc: NRC Resident Inspector - LSCS l

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, 'Of fice of NucicarL Reactor Regulation '

U.S. Nuclear:0C Regula tory' Commission

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Subject:

LaSalle County Station ' Units 1 and 2 Appeal of Certain Fire Protection Positions -

NRC. Docket Nos. 50-373 and 50-374. A:15. BY _  !

References (a):

j LaSalle County Station Unit 2 Lice (DATE

' NPF-18, dated December: 16, 1983. nea

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-L 2 (b):- NRC. Inspection Report Nos.'  !

50-373/83-44 and'50-374/83-3BLdated December 12, 1983.

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Dear Mr.10enton:

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'The purpose 1_of this letter is to request that we meet .withtaken your by I

stafff; Nuclear- promptly Reactor to discuss'certain 1 Regulation and Inspection positionsand recently Enf e Of fices 1re protection reviews and inspections regarding Firin_their*

LaSalle County. Station. It orcement i documented in References (a)isand noted (b),that these positionse Protection at which are dGgrees, to .other' Commonwealth Edisonc Company es.

fa ilitiare also b Regulation (NRR)Ourarequest is directed to the Office of Nuclear R .

have been;taken,,inalthough part,- the positions with which exception is noted En forcement- (I&E) 'by-both NRR and the Of fice of Inspection and The imposed re

• desires to discuss are:quirements that Commonwealth Edison Company 1

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Commonwealth Edison Company belApplication'or ment.

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. 'our. position.to Fire Protection Systems ano ieves thac GCC 1 does nec equipment.

, SRP 9.5.1 supports 2). ,

i Impositi'on . of all aspects o f all NFPA codes of NFPA ~ codes which have not been As to provisions.

" adopted by the NRC regulations, Commonwealth Edison Company believess that -

compliance is'only required in those cases unere we have ma specific commitments, and that the codes allow {

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~ judgement to be utilized in application of the NFPAfor engineer cy

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Imposition of surveillance tests in excess of those currentl prescribed This by the NRC specifically BWR Standard Technic.al Specifications.y includes:

a)

Requirements with NFPA-20. that periodic fire pump tests be in accordance b) .

periodic operability test of a sample include a population o accessible dampers.

Commonwealth Edison Company believes that new, previously unimposed requirements should be processed through the normal regulatory channels.

We think it is inappropriate and u impose these requirements during the inspection process.nfair to 4)

Commonwealth Edison Comany believes that .

"(see NFPA 51b)" in the guidance document to which we have committed, line compliance to :all aspects of NFPA 51b end is no for enforcement action.

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Each of the above positions is addressed in detail in the enclosures.

staff on November Es previously 29, discussed with Mr. D. Eisenhut, et al, of your tiously resolved. 1983, it is requested that these issues be especi-February 10, 1984 Specifically, resolution of these issues no later than the extenced cue date for response to Reference (b),wouldwith allow co license issue for Byron Station Unit 1. licence issue for LaSalle Cou i Finally .

it is noted that substantial effort is currently underway Important to Sa fety. on sever,al fronts regarding the issues of Safety-Related and connection with the four appealed positions.There is no need to resolve that issue Similarly we are not disputing the NRC's authority to regulate nuclear power, plant protection.

fire Rather, as addressco in the enclosures, we believe that appropriate reviews as new generic issues are identifiec.reg e

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January 27, 1984

. If there are any questions in this matter, please contact the i Commonwealth Edison Company Nuclear Licensing Depart.T.ent.

j copies ofEnclosed this letterfor'your and theuse are one (1) signed original anc forty (40) enclosures.

Very truly yours, Cordell Reed Vice President CWS/im ' '

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. Enclosures

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'c c : Mr. T. Novak (Federal Express)

Mr. V. Stello (Federal Express)

Mr. J. G. Keppler, Region III .

%- NRC Resident Inspector - LSCS Mr. P. P. Steptoe, IL&B 4

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• Applic3tICO equipment, of GOC 1 to Fire Protection systems an In Inspection Report Nos. 50-373 philosophy applied noncompliance is that:by the NRC in sup/83-4 A and 50-374/83-38, the

, port of four of the items of to fire protection systems, 0 isstructuCriterion applicaele 1o such as those requireo by 10 CFR 50 48res and components requires commensurate with the safety functions tco quires records o be performed.

. Staff's In some cases this finding that there has been interpretation appears to be es  ;

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applies Commonwealth to f Edison disagrees that c ian item of noncom {

j Cakes clear, ire protection systems. r terion 1 of 10 CFD Part 50 fire protection systems are provid

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stems amd components important ed toto safety", butAs protect C

. emselves are not " structures, systems Moreover, the interpretation suggestonents im:ortant and comp fire prote!

" structures N3s. 50-373/83-44 protection and 50-374/53 48 l systems are " structures eaos safety" then fire protection system,s wo lsystems and components to absurd results:ed if e ort in Ins:e fire protection systems.

u d be requireo to protecttant to the Sa fety Function as systems which a,reA review of 10 C

, 3 Shutdown, or Design basis Accicents Section recuireo for Hot I reveals Shute:wn, a definition of 1 does not apply. equipment performFire none of these function protection systems anc Cold s and, there fore, again GOC-1 protection is inconsistent on Action, CLI-78-6 with the StFinally, that GOC-1 aoplies to firewe note t and the icentify le Commission's 7 NRC 400, A06-Eus, cecision anoardin Petiti Review on For Emer encyPlan, Section 9.5.1 44a, aze-aec sAs<o)sne 8 enecial protection. gal re,quirements, not including sota orCOC-1, anich ap e to fire With respect to the SRP -

tidely listed compliance with COCit is noted that the NRC h

< sections of the SRP. The NRC, however as freely and cFncur with this' published f*%

position of thapply resented in Section 9.5.1.ecision to not e NR,C. We I

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Position:

Imposition of.all aspects of all NFPA codes There is a second, in-Inspection a Report Nos..50-373/83-44 independent problem with the applicatio Report 'pparently takes the position that GDC 1and 50-374/83-48. n of GCC-1 The Inscecticn

. jell NFPA Codes legally binding on Commonwealth makes a Edison (

Commonwealth Edison considers applicable and hin - even thcugh

implement).

as committec to:e NPFA codes th

follow all'" generally recognized codes and standaButplicants must GCC hat:

rds."

It merely states j

Where-cenerally , ,

they snall oe applicability, ioentifiec.ano evaluateo to catreccanized cod adequacy, ermine tnelr and suf ficiency a. nc-snail

- supplemented product in-keeping or

/ modified as necessary tobeaassure y a qu lit (emphasis added).J. with the required safety function.

The use of GDC-1 to require unreferenced cod j clear industry is legally unsupportaole.' es and standards on the 1 a ministration and^ sanctions Procedure:Act governing 5 U.S.C.A. SS 552 553 anc 558.

e provisions rules, rulem publication of'the Commission's A4173 (September 28, 1983) recent policy statement u e,-10 CFR 50.109, on propoinc the

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I seo backfits referred to in the Policy Statement.and its backfitting directions ,to the Sta f {f 1 An example of the I&E application of GOC 1 t -

all portions of all- NFPA coces, even though there iso require como portions of all- NFPA codes, is found on page 30 no commitment to all ,

of the inspection report:' I

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S'ee also December 19 III, Esq. of Hunton a,nd Williams, whichDenton statesto1983 T. S.letter Ellis frcm H.

"'...CDC-1 , in pertinent part: ,

mandates the application of quality sta d programs'" commensurate with the importance n ards of and ey the saf '. t functions to be performec" and expressly allows the i

" generally and. sufficient." recognizec codes and stancarcs_" pplicaole (emphasis acced) wnefeuse ofa l

T ' *and Note'whatthe it allows. distinction Mr. Denton makes between what GCC-1 mancates 1

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J' "NFPA Standards (protection) specify requirements for surveillance testing of committed tosystems, develop equipment, and and components.

The licensee re accordance with NFPA codes a.nd standards throughout the The licensee failed to establish adequate quality assurance acceptance for the following / rejection criteriatests:

surveillance as required by NFPA codes and stand (1)

LES test. FP03, Hydrogen seal oil deluge initiation circuit functional Does not incorporate NFPA 13 requirements.

(2) LOS FPA1, incorporate NFPA 24 requirements. fire protectionDoes flownot path val (3) LOS FPA2 fire p~rotection system function test.' Does not inenrpora,te NFPA 20 requirements in that it only requires verification of flowing 2500 gpm at 108 psi.

• (4) LMS F006, l

flow verification. fire protection. hose station valve operability and Does not inceiporate NFPA 14 requirements.

(5) LMS FP09 not incor,porate NFPA 10 requirements. yearly maintenance Does of AF (6) LOS FPA3, and cyclingfire protection sprinkler and deluge system drain f. low test.

Does not incorporate NFPA 13A requirements. i j

This is considered a violation of 10 CFR 50 i Design Criterion 1, and an example o f a nonc,omplianceAppendix A, Genera'l l (50-373/83-44-03h) and open item (50-374/83-48-24)." l Comm'onwealth Edison Company must disagree with the NRC positio

1. Tha,t CDC-1 applies to fire protection.

See Enclosure 1. j 2.

That commitments to use the guidance of a few specific portions of NFPA to all NFPAcodes in the FSAR is interpreted that we have committed codes.

Our commitments are not to all NFPA coces and engineering guidance. judgement is utilized in application of the 3.

That compliance is required to a set of codes and standards for which, \

to our knowlacge, the NRC has not pub 11sned endorsements or requirements. (

It has been our experience that in those cases that the NRC expects or desires or requires, compliance l with codes ano stancaros, the'NRC publishes offi or endorse with exceptions ano additions.

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i Position:

Imposition of surveill'ance tests in excess cf those currently prescribec Technical by the NRC BWR Standare Specifications.

During final review of fire protection issues 6

that surveillance testing be imposed on LaSalle County St ti' the NRC of theficarequirements Speci tions . provided in the publisheo NRC a SWR Stancaro on in excess o f the guidance in H. 'R. echnical Denton's Of fice Letter No. 35 ano is iThis with the Commission's published positions, guicance on m i

sack fi t ting. ,

inconsistent  ;

01rcumventec the prescribed methods forrequirements, w imposing The StaffneThesehas j

that it is inappropriate and unfair to impose .

We think ements during these re the ' inspection process process within required internally withoutthebenefit NRC. of the prescribec ri gorous review imposed-are: The specific examples of additional surveillance requirem ents being a)

Requirements NFPA-20. that periodic Technical fire pump Specification A.7 tests be in accord

1. ) lance requirement for the fire pumps. 5.1.1 lists the surveil-ance with Commonwealth Ecison Company believes that the appropriate requirements for the  ;

. technical specifications are those necessary to verify acequ t system operation. ae '

of other Stancard Technical Specifications.This is consistent with t however, requirec and imposed NFPA-20 150% requirementsThe NRC . It is rather that' the fire pumps would be installec per

, position, especially in view of the apparent lack published endorsement of all aspects of NFPA-20.

b)

Requi'rements that fire damper surveillance include a periodic operability test of a sample population of accessible damcers The original Unit 1 technical specifications and tne Common w eal Edison Company procosed Unit 2 technical soecificatiens were exactly tions. the same as the NRC BWR Standard Technical Specifica -

2.C.15.(h) is a clear example of a ratchet that the circu  ;

prescribed NRC procecure for imposition of new generic recuire ments, including cost / benefit determinations anc approval by CRGR. .

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Enclosure 4 Position:

Imposition of NFPA Slb training requirements for fire watches.

Functional Responsibilities" document per Amendment 63 o A i

review of how the 1977 guidance incorporates NFPA guicance reveals: .

Section 1.0.b.(2) "

... Using the following NFPA publications for guidance No. 4..." to develop the fire protection program:

Section 1.0.f.(5) ...

"The recommendations for organization, training, and equipment of " Private Fire Brigaces as specifisc in NFPA No. 2 7-1975 . . .'a r e considered an appropriate criteria...".

In this case, however, we note that nowhere does the 1977 guidance document state bor that NFPA that NFPA 51b recommendations are to be used as guidance 51b is considereo appropriate acceptance Sections 2.0.(b).(1), 2), and (3) criteria.

Sib)". There is no req (uirement for are followec simply by "(See NFPARather, compliance.

legal basis for requiring compliance with a There document. vague seems to be no in a reference e guicanc We further note that the Standard Ceview Plan SRP 9.5.1 clearly states program. the NRC's acceptance criteria for a fire pr(otection )

NRC Slb fire stafwatch fSRP 9.5.1 is silenthave and management criteria.

on the issuenot formally of required fire watches. Thus, the compliance o NFPA t

This is without question a generic issue. "

the prescribed methods for im osing new The staff has circumvented benefit determinations and approval by CRGR. . We think that it isrequirements, i inappropriate anc unfair to impose this requirement during the last moments review process priorrequired to license issue without internally within thebenefit NRC. o' the prescribed rigoro us S

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March 14,1984 r

. Docket Nos.: 50-373/374 Mr. Dennis L. Farrar Director of Nuclear Licensing Commonwealth Edison Company P. O. 00x 767  ;

. Chicago ' Illinois 60690 {

Subject:

Staff's on Position with respect- to Commonwealth Edison App Fire Protection i

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Enclosed is, the staff's position with respect to certain u itemk are appealing in the fire protection area.as indicated in your lettei January 27, 1984 These positions are being transmitted to you f'or your .

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. cognizance prior.to holding the appeal meeting.

Sincerely, jtv-Lb p A. Schwencer, Chief {

l Licensing Branch No. 2 i N ivision of Licensing  !

Enclosure:

As stated

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See next page- .

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Mr. Dennis' L.; Farrar Director of Nuclear 1.icensing

- Commonwealth Edison' Company

.P. 0. Box:767; Chicago..' Illinois 60690 .

cc: . Philip P. Steptoe, Esquire

Suite 4200 One First National Plaza-

-Chicago, Illinois'60603 Dean;Hansell, Esquire

-Assistant Attorney > General

• -188 West Randolph Street

'Sulte'2315' -

Chicago,<!111nois 60601 William G Guldemond, Resident Inspector LaSalle NPS,' U.S.N.R.C.

P.'O. Box 224 *

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SRP 9.5.1 supports NRR Response OurCHEE 8TP requirements 9.5-1. for. QA programs are delineated in paragraph C.4 o This paragraph also includes those requirements previously stated in paragraph C of Appendix A'to BTP ASB 9.5-1, paragraph. C.3 of proposed Regulatory Guide 1.120, and Attachment 6

, to " Nuclear Plant Fire Protection Responsibilities, Administrative -

Controls' and Quality Assurance," dated July 14, 1977.

By Amendment 49, the applicant committed to meet the guidelines for Administrative Control and Quality Assurance," 14, 1977, dat which is referenced in paragraph 50.48(a).

All applicants program. have committed to provide a QA program for the fire prot The fire protee' tion progr;am and associated suppression and detecti are a provided to prevent the release of radioactive material as a result of fire.

All recent PRA's have identified fire as a dominant contrib to _ risk if. fire protection features that meet out guidelines are.not provid GDC-1 states " Structures, systems and components" (i.e., fire protection ~

tested to quality standards commensurate with the im safety functions to begerformed."

The fire protection program is considered in our regulations (550.48, GDC-3 Appendix R) and plant Technical Specifications. Therefore, because i of the important function that fire protection system serves, it is our opinion that GDC-1 should be applicable. ,

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Fire protection systems, as most. mechanical systems, are subject to va  !

amounts of deterioration when they are installed for the protection of a plant over the life of the plant.  !

in service, that is, they are only operated during an emergenc scheduled surveillance test.

It is, therefore, essential that effective {

QA/QC procedures are established to ensure the continued reliable operation!

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[ of the system.

.systems It is alsoisournot opinion the mainthat issue.the applicability of GDC-1 to fire protection '

The issue is whether the applicant's QA program for fire protection has implemented its commitments. features is adequate and whether the applicant 4

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8 Commonwealth Edison Issue -

2). ." Imposition of a11' aspects of all NFPA codes. As to provisions of NFPA~ codes which have~not been adopted by the NRC in its regula-tions, Commonwealth. Edison Company believes that compliance is only require ( in those cases wher. we have made specific commit-i ments, and that the codes allow for engineering judgement to be utilized in application of the NFPA guidance."

NRR Response The NRC does not' impose all aspects of all National Fire Protection Association (NFPA) codes. . Out. guidelines identify approximately 34' NFPAl codes that we deem applicable to fire protection programs in nuclear power plants.

We agree with the applicant that where generally recognized codes and standards are used, they shall be identified and evaluated to determine their applicability, adequacy, and sufficiency and shall be supplemented or modified as necessary to assure a quality product in keeping with the required safety function.  !

In- the applicant's' FSAR; Ainendment 23, paragraph 9.5.1.1.5, the appli- ,

-cant provided regulations, codes and standards that are applicable to

'the fire protection program:

" Applicable Regulations, codes and Standards ...

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. National Standards." Fire Protection Association - Fire Prevention .

In addition, other FSA8 sections contain specific references to NFPA standards. For exampid: -

o Section 9.5.1.2.1 (concernino fire pumps)

"This installation conforms to NFPA 20, " Standard for tha Installation of Centrifugal pumps."

o Section 9.5.1.2.1 (concerning sprinkler systems) 8

" Sprinkler Systems are designed to NFPA 13 and fixed water spray systems to NFPA 15 "

o Section 9.5.1.2.1 (concerning standpipes)

"The design of the standpipe system follows NFPA 14."

Further, the comparison of the fire protection program to our guidelines (Appendix A to BTP 9.5-1) indicates that the program complies with the NFPA codes specifically identified in our guidelines.

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p Dur safety evaluation was developed based on these sta n s. We' con-strued in them to mean the app,licable NFPAthat the code. fire protection installed operated, system ned, and ma u ance contained significant that the applicantdeviations has committedfrom tothe mee.NFPA the provisions codes, of our s uch codes.

The applicant agree. states that the codes allow forent;engineering During our review we technical interpretations., we usually need to resolve differences in .

agree on the interpretations. Occasionally, we and the applicant do not is requested from the NFPA committee.In such cases, a formal interpretation The from NFPA A'egion's codes. inspection has identified several significant ons de There may be others. To resolve this issue the cable and the significant deviations of his pr .

-i Commonwealth Edison Issue 3)

" Imposition of surveillance tests in excess of those currentl

• prescribed This by the specifically NRC BWR Standard Technical Specifications. y includes:

a) t Requirements with NFPA-20. that periodic fire pump tests be in accordanc b)

Requirements periodic that fire damper surveillance include a operabilit accessible daqpers.y test of a sample population of Commonwealth Edison CoJapany believes that new, previou We during thethink it isprocess."

inspection inappropriate and unfair to imp .

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NRRRes}ponse The fire damper and fire pump testing requirements in the appifcab NFPA Technical codes are in excess of the surveillance required in the Stand Specifications, a) Fire Pump Periodic Tests Based on the applicant's commitment in Amen of Centrifugal Fire Pusps," without taking any exceptions to the NFPA 3 point criteria. testing, we anticipated that the pumps use these three points for acceptance criteria.We expected that the a

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one point..on the performance curve be demonstrated.ons specify that on This is on the curve to assure that the' pump is ope o' .

4 rating ~and its performance is af designed.

achieved by running the pump at off-design .

We under-co

' stand the running that-the pum applicant meets the Tech Specs flow requirem

' head and flow. p at a higher than rated' speed to achieve rated As a result, the applicant has had to replace Thus,. the licensee's former program for survei pump was; assure to pump reifable simplyoperation.

meet the Technical Specifications;~ not to Apparently regarding periodicthe applicant wishes to modify its recent commitment-fire pump tests.

To resolve this issue the point fire pump tests in accordance with the cur Technical Specifications.

-flow, head and speed. This test should be performed at. rated rating condition should be monitored,The pump parameters indicative  :

b) Fire Damper Surveillance The present standard Technical specifications for fire dampers are deficient in that they'do not require periedic functional .

tests. .We have received several LER's from licensees

-performed th function. periodic functional tests in which dampers failed to reported damper We areslooking fatlures. into the safety significance of the i that licensees have a. testing program forThis dampers.

is also Based on t the apparent opinion of the NFPA technical committee as recommend in NFPA Standard 90A:

"8-7 Fire Door Assemblies, Fire Dampers, Smoke Dampers, and CellindDampers.

Each. door or damper should be examined once a year, see thatgiving it is inattention good o to hinges and other moving parts,-to )

links ~(where applicable)perable condition. Remove fusible

, operate door or-damper, check latch (if provided) and lubricate moving parts if necessary.It is desirable to operate doors or dampers with normal system. air flow to assure that they are not held open by the air stream."

Apparently the applicant wishes to modify its recent commitment ing the operational testing of a fraction of the fire dampers.To resolve.this issue, the applicant should provide a description of the fire damper surveillance program he deems appropriate to assure reli-

'able' damper operation over the life of the plant.

indicated that some of the dampers are not accessible for test orThe licens inspection.

inaccessible fire dampers.The analysis should evaluate the safety sig

Commonwealth Ediso'n Issue

4) t t

' Imposition of NFPA 51b training requirements for fire watch .

"(see NFPA 51b)" in the guidance document ,

committed, line compliance does to allnot as represent a formal requirement for line by

. for enforcement. action." pects of NFPA 51b and is not a basis NRR Response It is not clear for which fire watches the training is in dispute .

Based on our discussions with Region III and the licensee, the is  :

this instance is whether the extinguishers oninthe types of fire fires watch that couldshould be ignited be during traine and cutting operation safety areas.

such training.

NRC guidelines regarding cutting and welding proce areWelding.

and basedProcesses.

on NFPA 518 - Standard for Fire Prevention in Use of C .

shall use, have practice including fire extinguishing on test fires." Our equipment available and =

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guidelines re j watch be traired and equipped to prevent and combat fires. quire Our a fire guidelines  !

assume the training delineated in NFPA 518. j 1

In our opinion extinguisher an,d has not had the experience in extinguish -

fires isornot cutting, anhot other acceptable work.' fire watch for activities including welding, '

This is due to the potential need for immediate

' first-aid fire-fightings For other fire watch activities, not involving hotrequired.

be work, hands on traintng on use of portable fire extinguishers need the Technical SpecificationsIn addition, fire watches are required for other j 3 detection system, fire suppre;ssion system, or fire barrier.usually to c l published guidelines for the qualifications of t.hese fire watches.The NRC has in We assume '!

can develop reasonable training programs for such fire i I Summary j

\

Because the need for a quality assurance program, design and installation requirements, been in the public' maintenance, record since surveillance, and training requirements have i requirements backfitting, 1976-77, we do not deem any of these '

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4 Docket'Nos.: 50-373 and 50-374 ,

1 LICENSEE: 1 Commonwealth Edison Company FACILITY: La Salle County Station, Units 1 and 2

SUBJECT:

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SUMMARY

OF MARCH 28, 1984, MEETING WITH COMMONWEALTH '

EDISON COMPANY ON FIRE PROTECTION POSITIONS

Background

In a letter dated January 27, 1984, Coninonwealth Edison Compan a meeting with the Office of Nuclear Reactor Regulation (NRR) y requested the following positions 'of the staff in the fire protection area:to appeal i 1.

Application of GDC 1 to Fire Protection Systems and Equipment I 2.

Application of all aspects of all NFPA (Fire) Codes

3. i Surveillance Tests not identified in BWR Standard Technical Specifications a.

Requirement that periodic fire pump tests be in accordance with.NFPA-20

b. Requirements that fire damper surveillance test of a sample population include a periodic 4

- Application of NFPA 51b Training Requirements for Fire Watches. 4 As a result of pressing problems that arose on March 28, 1984, between the staff and licensee that this meeting would not be an appealit was agreed meeting but to discuss primarily the technical issues which were: a) fire watch test. training, (2) fire damper surveillance, and (3) periodic fire pump A list of attendees is provided in the Attachment.

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?_iscussion' D d The.first item of discussion was the fire watch training position. The licensee; indicated that within its own personnel, the fire watch training is- ,

meetingsthe,NRC staff's requirements.. Nevertheless, the licensee was having-E its; problem with training the contractor personnel, especially in the area of K

hands'on the training. The licensee indicated that'from a cost stand point. j it was costingL $237/ man for hands-on-training, and CECO could not see the cost J 1

benefit?of this training. The licensee presented an alternative program D for contractor only personnel which consisted of the,following.

1. A film which-showed how to use the different fire. extinguishers 'on-all kinds ~of fire, i

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.Fami11arity of the facility and fire alarms, and.

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.3. A presentation on duties of the fire watch.

j However after ~some discussion on the alternative program, the NRC staff indicated that' hands-on training was essential even if only. the. individual used the extinguisher just to get the. feeling of the extinguisher. The staff indicated that a train'ing program should be developed whereby the. individual- could q

use hands-on training to put out.a fire with an extinguisher and to use dumy j extinguishers on' site.-

for operation and ~get' the. feeling of other types of extinguishers 1

,The second item was' fire damper surveillance. The licensee indicated that two

, submittals dated Narch 13, 1984 and March 15, 1984 were made'in response to the NRC concern. The March 13th submittal was a fire damper program which indicated an initial operability' test to verify correct installation and a. q visual = inspection for surveillance of all fire' dampers-for the' lifetime of the 1

plant. This was CECO's initial response to the License Condition 2.C.(15)(h) )

which was not acceptable to'the staff. In' the March 15th submittal, 'the-licensee presented a fire damper surveillance program which, in addition to  !

using the. surveillance program indicated in their March 13th submittal, would

~a lso include a random' sample of all ff re dampers, except those that are spring

, loaded'and completely enclosed in ductwork, for operability surveillance. The licensee, nonetheless, was reluctant to commit to such a program and indicated

'that is.why it was appealing this position. The NRC staff indicated that the .

1 March

'is in the15th prncess submittal addressedthis of reviewing thesubmittal.

License Condition 2.C.(15)(h) and that it l CECO stated that presently all

. fire dampers:are not accessible but with some modification can be made accessible?once a program is: established. The staff pointed:out that this area of fire damper surveillance for operability is new and. guidance has not been established. Therefore, the staff requested that i the licensee go.back and review both submittals and see whether it could

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accept;its March 15th' submittal or develop a surveillance program that is somewhere inbetween the two submittals.

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The third item had to do with the periodic fire pump surveillance test.

.ofPresently, the pump the staff's requirement is for the test to be performed for 3 points curve.  ;

the normal speed. The Technical Specifications requires only one point at '

In accordance with Section 11.3 of NFPA-20/1983, the require ,

ment is that the test be perfonned at 150 percent'of speed. The staff indicated

-that the initial test should be performed confirming 3 points of the curve; I

however for the rest of the surveillance test only the 150 percent point is required. The licensee agreed to such a test.

Some discussions were held with respect to the applicability of all the NFPA codes.

It was indicated to the licensee that the FSAR had indicated that many NFPA codes were being met. The licensee specified it had no problem with meeting those codes' indicated by the FSAR, but had some hardship in meeeting codes I that would be chan that the 7 censee.ging during the life of the plant. The NRC staff stated should go back and specify the code with the date of the l code it wts meeting. They would then be held accountable only for that dated code.

an updateThe to.kensee indicated r,7ect the that date of theit code.

would review its submittals and submit Finally, it was specified to the licensee that if it wishes to continue the appeal-on these issues he was more than welcome to again request a director's level of appeal meeting.

Q wv A. Bournia, Project Manager Licensing Branch No. 2 Division of Licensing

Attachment:

As stated cc w/ attachment:

See next page

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ATTACHMENT NRR l Anthony lBournia Robert: Purple *

.W S..Little~

$ J. M.-Ulie e -

' W.:V. Johnston r - Victor Benaroya R. L..Ferguson i

EEf2 John C. Renwick Denny Farrar Louis DelGeorge Herb Massin Tom Heyer Brent Shelton

- Carl F. Baldassarra y :IE' L. E. Whitney Bechtel Babak'Ameli Sargent & Lundy '

-Herman F. Behls E. P..Richohermoso Part time i

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• i La Salle Mr. Dennis L. Farrar L' Director of Nuclear Licensing Commonwealth Edison Company P. O. Box 767

• Chicago,' Illinois 60690 cc: Philip P. Steptoe, Esquire Suite 4200 I One First National Plaza Chicago, Illinois 60603 Dean Hansell, Esquire Assistant Attorney General 188 West Randolph Street Suite 2315 I Chicago, I'111nois 60601 William G. Guldemond, Resident Inspector LaSalle NPS, U.S.N.R.C.

P. O. Box 224 Marseilles, Illinois 61364

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/ @ao Bust tahonal Prara Cmcago m,no g NGNd 0 e, ,

s AdoreSs Reply to Post Othee Sox 767 j

y. - Chicago Hhnors 60690 '

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June 14, 1984 l '

Mr. Harold R. Denton, Director Of fice of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

LaSalle County Station Units 1 and 2 Appeal of Certain Fire Protection Positions NRC Occket Nos. 50-373/374 References (a):

LaSalle County 16, dated December Station 1983.Unit 2 license NPF-18, ,

(b): NRC inspection report Nos. 50-373/83-44 and r 50-374/83-38 dated December 12, 1983 (c):

Cordell January Reed letter to H. R. Denton dated 27, 1984 (d):

Cordell dated Reed letter February to James Keppler, Region III 15, 1984 (e): A.

22, Schwencer 1984 letter to D. Farrar da ed March ,

Dear Mr. Denton:

taken by the Offices of Nuclear Reactor Regulation and In and Enforcement in the fire protection reviews of LaSalle County Station.

In reference (c), Commonwealth Edison requested.a meeting with the NRC staff to discuss our concerns with those positions.

Reference (c) also noted that the NRC positions were b ,

On March 28, 1984, we met with your staff to discuss these fire protection issues.

may be possible to reach a mutually acceptable rest 11ution of ourA concerns without further meetings.

pro' vide a basis for reaching those resolutions.The purpose of this letter is to l i

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s believe are Attached acceptable.to this letter.are the resolutions which we-If the ' attachments do not meet with.your stas approval, we request that an appeal meeting on the issues be hela at the Division Directors level.

Very uly your , ,

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Dennis L. Farrar Director of Nuclear Licensing Attachment  ;

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H. R. Denton June 14, 1984 Attachment Concern #1: The applicability of General Design Criterion 1 to Fire Protection In reference (d), Commonwealth Edison expressed concern over the use ofinGeneral noncompliance DesignReport NRC Inspection Criterion-1 Nos. as the basis for items of 50-374/83-48. 50-373/83-14 and The current redefinition of the regulatory term "important-to-safety" is likely to have pervasive consequences for

' licensing and regulation of Commonwealth Edison nuclear units.

Given the extensive use of the term in NRC. Regulations, and other documents, a sharp departure from the industry's long standing interpretation of the term "important-to-safety" would be a largely unexamined documents. Additional and inappropriate expansion of the scope of these regulation by the NRC as a result of this issue should generic issues are identified. proceed in an orderly manner with appropriate review as e

resolution We ofare thisparticipating issue. Upon in the effort to achieve a generic resolution, we will implement whatever additional actions may be required and we feel that the applicability 1ot be finally of GDC-1 resolvedto fire protection at this time. sy, stems and equipment need Concern #2: Imposition of All Aspects of All NFPA Codes In Reference (c), Commonwealth Edison objected to the apparent NRC Staff. position that GDC-1 makes all provisions of each of the 34 NFPA Codes referenced in NRC Fire Protection Guidance legally. binding on Commonwealth Edison Company. It was our position .

l that for those NFPA Codes which have not been expressly adopted by

-the NRC in its regulations, Commonwealth Edison Company compliance was only required where we had made a specific bommitment.

ce believe that NFPA Codes allow for engineering judgement toFurther be 2 utilized in the application of the NFPA guidance. I The NRC staff maintained that because Commonwealth Edison i had not identified significant deviations from the NFPA Codes, the  !

SER as written committed us to meet all the provisions of each of these NFPA codes. In Reference (e), the NRC staff indicated their agreement that the NFPA Codes allow for engineering judgement, and that the appropriate resolution of differences in technical interpretations in the codes should be a matter for subsequent review and possible referral to NFPA committees.

To finally resolve this issue, we agree to work with your staff to specifically identify the NFPA codes that are applicable to our stations and any significant deviations of our program from these codes. We have begun a review of our LaSalle County, Byron, and Braidwood Stations to document the applicable NFPA codes and

.any significant deviations of our programs.

review will be completed by December 31, 1984 We expect that this  !

and prior to receipt'of an operating license at Braidwood.for LaSalleWeand Byron stations following completion of their final 10 CFR 50 App reassessments to identify the applicable NFPA codes for these stations and any significant deviations.

review for these stations by March 1, 1985.We expect to complete the i noted NFPA correcting Code the deviations will involve either justifying orFinal resolution of an{

deviation.

Protection engineering-judgement and will be documentedAll justifications w Concern #3: Imposition of Surveillance Tests in Excess of Those Currently Prescribed by Standard Technical Specifications the NRC staff required that surveillance testing be imposed on LaSalle County Station in excess of the requirements provided in the ,

published NRC BWR Standard Technical Specifications.

specific examples of additional surveillance requirements imposed. There were two being '

The first involved an apparent misunderstanding between I Commonwealth Edison and the NRC staff that periodic fire pump tests would 11.3, at have to be performed eighteen in accordance with NFPA-20/1983, section month intervals.

staff was referring to the initial acceptance test for theWe now understand that the N installation of these centrifugal fire pumps, which requires three i points on the pump performance curve be demonstrated to assure that j the pump is-operating within its design performance rating. As j committed in References (a) and (d), Commonwealth Edison has .

performed tests of both diesel fire pumps 'at LaSalle which met the 3 requirements of sections 11-2.3, 11-2.4, and 11.2.5 of NFPA.20/1983.

The testing of one of the diesel fire pumps was uitnessed by a representative of the manufacturer of the pump as cell as by our fire protection consultant (Schirmer Engineering).

We understand that these tests resolve the concern of the NRR staff. {

We also understand from Reference e that the NRR staff feels only one point on the in the periodic tests of fire pumps. performance curv(e)n,eed be demonstrated This one point test is considered adequate once the three point acceptance test has been performed.

LaSalle Station will meet or exceed the Standardized 4 Technical Specification requirements for periodic fire pump tests, and we believe on this basis that this issue is resolved.

Commonwealth Edison was also concerned that the imposed requirements for fire damper surveillance at LaSalle included periodic operability tests of accessible dampers.. The original Unit 1 ano Unit 2 technical specifications were the same as the NRC BWR Standard Technical Specifications which permitted a visual inspection of fire dampers to suffice for the periodic surveillance.

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3 4dequacy of ne existing Standardized c Ternsh with SAsthea result of assurance Specs throu;7t's- they are seeking revisions pecs, and their to those Stand committ. to appropriate NRC review procedures ardized Tech evelop a periodic testing program on, LaSalle Station program wil.' include periodic operability tests offire dampers. This dampers.

commitment, .e will categorize fireselected dampers s fire into sev specify the surveillance frequency sdepending a f e t y-rela tutra their significance e: equipment.

of the dampersa withi with resp groups and n each group ect to safe shutdown and Concern 4: ~

3fouirements for Fire Watches;mposition of NFPA-51B T position ths; actual experience extinguishing staff a test fiC necessary or other hot work. frr fire watches supervising welding, cutting re is

, grinding, extinguish small the case of extinguish it.s fires,incipient but tofiredetect and report them should the fire . Only in promptlyT stations are small Class A fires.Most cutting and welding related fires iwatch a An Ansul Corporation documentn generating which establishes the industry ratings as important e for certain

.perience for Class A fires asisfor Class B fires "actualt n que is not catches. es-inguishing fires of only minimal Thusvalue o fire The NRC staf f disagrees.

firetrained bo watch af:r: welding, cutting, grinding andNRC guidelines require that a equipped to prevent and combat fires.open flame work must apparently as delineater in f.rther assumes in their guidelines that ThethStaff been trainec :s NFPA operat518 e a. In their opinion e training is fire actual watch experience of fire extinguisher extinguishing a a,ndfire test has is notn had t thea person who has Work. o an acceptable frr activities of welding, cutting, grinding or other hot agree to implement attempt to resolve this item Commonwealth a Corporate policy onson Edi traininIn a the will fire watches e71ch will include the following items:g of contractor (a) *ne use of fire extinguishers.

(b) "amiliarity fire alarms. with the facilties and the l ocations of the

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(c)_ The duties of fire watches. This includes the need to remain in the area for thirty minutes after welding is complete and a search when possible of the other side of the walls or floors where sparks could fall through cracks or other openings in the floor or wall.

(d) Hands-on' fire extinguisher training and practice by extinguishing a small Class B fire.

(e) Hands-on classroom familiarization in the procedure for operating the extinguishers including practice on discharged fire extinguishers.

Th!,s contractor fire watch training program will be implemented by December 31, 1984 for our operating stations and upon receipt of an operating license for stations now under construction.

Commonwealth Edison already trains appropriate' Company personnel annually. This extinguishing test fires.

training includes the actual practice of

• Also note that this conmitment to provide hands-on practice in extinguishing test fires for fire watches for welding, cutting, grinding and open flame work is applicable only at our operating stations.

BTPAPCSB 9.5-1 Appendix A Section A.8 and No. 3.1.e.3 established that on multiple reactor sites where there are operating reactors and construction being completed,.the fire protection program should include additional fire protection capability and administrative construction controls fire necessary to protect the operating unit from hazards.

To meet this objective when construction activities involve welding and/or cutting.in areas containing significant fire loading, such as diesel oil storage tank rooms, this activity shall be performed to provisions permits in accordance withwhich include the use of welding and cutting NFPA-518.

When construction activities involve welding and/or cutting in fire areas or zones within the security area a fire watch shall be in place except as specified below. In areas where only a minor fire might develop, a fire watch will man each area / elevation on each shift when such construction activities are being performed.

This fire watch will remain cognizant of all welding or cutting activities within the specified area or elevation. Fire watches may not be provided for conditions less hazardous than those described in paragraph 3-3 of NFPA 51.B (1984).

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i. Docket No. 50-373 Docket.No. 50-374 Commonwealth Edison Company ATTN: Mr. Cordell Reed Vice President Post Office Box 767 Chicago, IL 60690 Gentlemen:

By 1984letter responsedated letterMarch 6,1984, to Inspection Reports weNo. acknowledged 50-373 rec ~eipt of your Our acknowledgement letter stated that since you were/83-44 and 50-374/83-48.

appealing the legal basis of some of the. items of noncompliance in the subject reports we w not respond to those issues until action was completed on your appeal. It is conducted between members of your staff and renow our understa Nuclear Reactor Regulation on March 28,'1984 preventatives of the Office of Based on the results of the March 28, 1984 meeting and your letter date 14, 1984 to Mr. H. R. Denton (NRC) it is our concl compliance contained in Inspection Reports No. usion that the items of non-do. represent valid regulatory and technical issues.50-373/83-44 and 50-374/83-48 described in your February 15, 1984 The corrective actions with those actions you have undertaken as documented in the aforem June 14, 1984 letter are responsive to these issues. We will examine yo implementation of these actions during a future inspection.

Your cooperation with us is appreciated.

Sincerely, R . s

• s -, G R. L. Spessard, Director cc: D. L. farrar, Director Division of Reactor Safety of huclear Licensing G. J. Diederich, 5tation Superintendent DMB/ Document Control Desk (RIOS)

Resident inspector, Rlll Phyllis Dunton, Attorney General's Office, Environmental Control Division

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