ML20207L506

Advises That May 1986 Fire Evaluation Rept Submitted Per Insp Rept 50-249/86-06 Contains Statement Conflicting W/ Condition at Facility.Polyurethane Mechanical Penetration Seals in App R-rated Barriers Will Be Replaced

ML20207L506
Person / Time
Site:	Dresden
Issue date:	07/17/1986
From:	Farrar D COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20207L509	List: ML20207L506 ML20207L517
References
1855K, NUDOCS 8701120196
Download: ML20207L506 (2)

Text

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/ Commonwealth Edison

- 72 West Adams Street, Chicago, lilinois

1. f "_' )' Address Reply to: Post Office Box 767 g'

Chicago, Illinois 60690 0767 July 17, 1986 Mr. James G. Keppler Regional Administrator U.S.. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Dresden Station Unit 3 Drywell Fire-Correction to Fire Evaluation Report NRC Docket No. 50-249 References (a): NRC Inspection Report No. 50-249/86-006.

(b): Letter from D. L. Farrar to J. G. Keppler dated May 6, 1986.

Dear Mr. Keppler:

The reference (a) Inspection Report documented your staff's review of the Dresden Unit 3 drywell fire and requested we respond to concerns identified in the report. Our reference (b) transmittal provided our response in the form of a report documenting our evaluation of the fire. We have recently become aware of a condition at Dresden Unit 3 which conflicts with a statement made in our report.

On page 83 of the reference (b) report, as a response to an NRC ,

question, the following statement was made with regard to the use of polyurethane in other plant locations:

"Both polyurethane and polyethylene have been used as a filler material at the top of block walls and polyurethane is used to i seal penetrations. None of the block walls are considered rated fire barriers and in those walls that use polyurethane as a penetration seal, either the wall is not a rated barrier or, if it is, the polyurethane has been replaced with a fire rated or noncombustible material".

This statement is not completely accurate as the polyurethane has not been replaced in all Appendix R rated barriers. This was discovered recently at Dresden at elevation 589'-0" in the Unit 3 reactor building during ongoing Appendly R walkdowns. As a result of this discovery, we are currently conducting additional walkdowns to identify any other areas where previous walkdowns may not have identified polyurethane mechanical penetration seals in Appendix R rated barriers, h

P JUL 211986 1 ECV .

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Mr. J. G. Keppler July 17 1986 All polyurethane mechanical penetration seals discovered in Appendix R rated barriers will be replaced with appropriately rated seals. These activities will be completed in accordance with our existing schedule for sealing Appendix R penetrations at Dresden (completion by end of the next Unit 2, refuel outage). In the interim, we will implement the same compensatory measures we've committed to for other outstanding Appendix R modifications.

We will also be conducting additional walkdowns at Dresden Unit 2 and Quad cities Units 1 and 2 to identify any similar applications of polyurethane in Appendix R rated barriers. Any problems identified will be resolved in the same manner as described above.

We have discussed this situation with NRR (R. Gilbert, J. Stang) during a telecon on July 14, 1986. During that call, NRR concurred with our proposed resolution of this issue.

If you have any questions regarding this transmittal, please contact this office.

Very tru y yours, s

. L. Farrar Director of Nuclear Licensing im cc: H. R. Denton - NRR R. A. Gilbert - NRR R. B. Bevan - NRR NRC Resident Inspector - Dresden i NRC Resident Inspector - Quad Cities I

1855K

't - 4 Commonwealth Edison

. i ); 72 West Adams Street, Chicago, Illinois V

V[ Address Reply to: 60690 Chicago,lilinois Post0767 Othc3 Box 767 July 17, 1986 Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Comunission Region III

~199 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Dresden Station Unit 3 Drywell Fire-Correction to Fire Evaluation Report NRC Docket No. 50-249 References (a): NRC Inspection Report No. 50-249/86-006.

(b): Letter from D. L. Farrar to J. G. Keppler dated May 6, 1986.

Dear Mr. Keppler:

The reference (a) Inspection Report documented your staff's review of the Dresden Unit 3 drywell fire and requested we respond to concerns identified in the report, our reference (b) transmittal provided our response in the form of a report documenting our evaluation of the fire. We have recently become aware of a condition at Dresden Unit 3 which conflicts with a statement made in our report.

On page 83 of the reference (b) report, as a response to an NRC question, the following statement was made with regard to the use of polyurethane in other plant locations:

"Both polyurethane and polyethylene have been used as a filler material at the top of block walls and polyurethane is used to seal penetrations. None of the block walls are considered rated fire barriers and in those walls that use polyurethane as a penetration seal, either the wall is not a rated barrier or, if it is, the polyurethane has been replaced with a fire rated or noncombustible material".

This statement is not completely accurate as the polyurethane has not been replaced in all Appendix R rated barriers. This was discovered recently at Dresden at elevation 589'-0" in the Unit 3 reactor building during ongoing Appendix R walkdowns. As a result of this discovery, we are currently conducting additional walkdowns to identify any other areas where previous walkdowns may not have identified polyurethane mechanical penetration seals in Appendix R rated barriers.

JUL 211986

'e Mr. J. G. Keppler July 17 1986 i

All polyurethane mechanical penetration seals discovered in Appendix R rated barriers will be replaced with appropriately rated seals. These activities will be completed in accordance with our existing schedule for sealing Appendix R penetrations at Dresden (completion by end of the next Unit 2, refuel outage). In the interim, we will implement the same compensatory measures we've committed to for other outstanding Appendix R modifications.

We will also be conducting additional walkdowns at Dresden Unit 2 and Quad Cities Units 1 and 2 to identify any similar applications of polyurethane in Appendix R rated barriers. Any problems identified will be resolved in the same manner as described above.

We have discussed this situation with NRR (R. Gilbert, J. Stang) during a telecon on July 14, 1986. During that call, NRR concurred with our proposed resolution of this issue.

If you have any questions regarding this transmittal, please contact this office.

Very tru y yours,

-^

. L. Farrar Director of Nuclear Licensing Im cc: H. R. Denton - NRR R. A. Gilbert - NRh R. B. Bevan - NRR NRC Resident Inspector - Dresden NRC Resident Inspector - Quad Cities 1855K

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% Commonwealth Edison  !

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>- 1F 72 Wet Adams Street, Chic'go,lilinois V A7 Address Reply to: Post Othee Box 767

-e Chicago,Ilknois 60690 0767 i July 17, 1986 Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Dresden Station Unit 3 Drywell Fire-Correction to Fire Evaluation Report NRC Docket No. 50-249 '

References (a): NRC Inspection Report No. 50-249/86-006.

(b): Letter from D. L. Farrar to J. G. Keppler dated May 6, 1986.

Dear Mr. Kepnler:

The reference (a) Inspection Report documented your staff's review of the Dresden Unit 3 drywell fire and requested we respond to concerns identified in the report, our reference (b) transmittal provided our response in the form of a report documenting our evaluation of the fire. We have recently become aware of a condition at Dresden Unit 3 which conflicts with a statement made in our report.

on page 83 of the reference (b) report, as a response to an NRC question, the following statement was made with regard to the use of I polyurethane in other plant locations:

"Both polyurethane and polyethylene have been used as a filler material at the top of block walls and polyurethane is used to seal penetrations. None of the block walls are considered rated fire barriers and in those walls that use polyurethane as a Penetration seal, either the wall is not a rated barrier or, if it is, the polyurethane has been replaced with a fire rated or noncombustible material".

This statement is not completely accurate as the polyurethane has not been replaced in all Appendix R rated barriers. This was discovered recently at Dresden at elevation 589'-0" in the Unit 3 reactor building during ongoing Appendix R walkdowns. As a result of this discovery, we are currently conducting additional walkdowns to identify any other areas where previous walkdowns may not have identified polyurethane mechanical penetration seals in Appendix R rated barriers.

JUL 211986

f

. 1

's ,

Mr. J. G. Keppler July 17 1986 All polyurethane mechanical penetration seals discovered in Appendix R rated barriers will be replaced with appropriately rated seals. These activities will be completed in accordance with our existing schedule for sealing Appendix R penetrations at Dresden (completion by end of the next Unit 2, refuel outage). In the interim, we will implement the same compensatory measures we've committed to for other outstanding Appendix R modifications.

We will also be conducting additional walkdowns at Dresden Unit 2 and Quad Cities Units 1 and 2 to identify any similar applications of polyurethane in Appendix R rated barriers. Any problems identified will be resolved in the same manner as described above.

We have discussed this situation with NRR (R. Gilbert, J. Stang) during a telecon on July 14, 1986. During that call, NRR concurred with our proposed resolution of this issue.

If you have any questions regarding this transmittal, please contact this office.

Very tru y yours,

_m

. L. Farrar Director of Nuclear Licensing Im cc: H. R. Denton - NRR R. A. Gilbert - NRR R. B. Bevan - NRR NRC Resident Inspector - Dresden NRC Resident Inspector - Quad Cities 1855K

1 ,

) .C Commonwealth Edison Q* I 72 West Adams Street, Chicaco. Illinois i

V [r , Address Reply to: Post Othee Box 767 Chicago, Illinois 60690 0767 July 17, 1986 i

Mr. James G. Keppler Regional Administrator  !

U.S. Nuclear Regulatory Commission l Region III l 1 ~199 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Dresden Station Unit 3 Drywell Fire-Correction to

, Fire Evaluation Report NRC Docket No. 50-249 References (a): NRC Inspection Report No. 50-249/86-006.

(b): Letter from D. L. Farrar to J. G. Keppler dated May 6, 1986.

Dear Mr. Keppler:

The reference (a) Inspection Report documented your staff's review of the Dresden Unit 3 drywell fire and requested we respond to concerns identified in the report. Our reference (b) transmittal provided our l response in the form of a report documenting our evaluation of the fire. We have recently become aware of a condition at Dresden Unit 3 which conflicts with a statement made in our report.

On page 83 of the reference (b) report, as a response to an NRC question, the following statement was made with regard to the use of polyurethane in other plant locations:

"Both polyurethane and polyethylene have been used as a filler material at the top of block walls and polyurethane is used to seal penetrations. None of the block walls are considered rated fire barriers and in those walls that use polyurethane as a penetration seal, either the wall is not a rated barrier or, if it is, the polyurethane has been replaced with a fire rated or noncombustible material". ,

This statement is not completely accurate as the polyurethane has not been replaced in all Appendix R rated barriers. This was discovered recently at Dresden at elevation 589'-0" in the Unit 3 reactor building

) during ongoing Appendix R walkdowns. As a result of this discovery, we are currently conducting additional walkdowns to identify any other areas where previous walkdowns may not have identified polyurethane mechanical penetration seals in Appendix R rated barriers, i

I JUi. 211986 L------. - -- __--_- _ . _ _ _ _ _ - _ _ . . _ . . -

. \

i Mr. J. G. Keppler July 17 1986 All polyurethane mechanical penetration seals discovered in Appendix R rated barriers will be replaced with appropriately rated seals. These activities will be completed in accordance with our existing schedule for sealing Appendix R penetrations at Dresden (completion by end of the next Unit 2, refuel outage). In the interim, we will implement the same compensatory measures we've committed to for other outstanding Appendix R modifications.

We will also be conducting additional walkdowns at Dresden Unit 2 and Quad Cities Units 1 and 2 to identify any similar aFPlications of polyurethane in Appendix R rated barriers. Any problems identified will be resolved in the same manner as described above.

We have discussed this situation with NRR (R. Gilbert, J. Stang) during a telecon on July 14, 1986. During that call, NRR concurred with our proposed resolution of this issue.

If you have any questions regarding this transmittal, please contact this office.

Very tru y yours,

. L. Farrar Director of Nuclear Licensing la cc: H. R. Denton - NRR R. A. Gilbert - NRR R. B. Bevan - NRR NRC Resident Inspector - Dresden NRC Resident Inspector - Quad Cities i

I l

1855K i

N ' /Commonwealth Edison 72 West Adams Street, Chic"go, Illinois s'

\ V 8 Address lieply to: Post Offica Box 767 U Chicago, Illinois 60690-0767 h July 17, 1986 Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Dresden Station Unit 3 Drywell Fire-Correction to Fire Evaluation Report NRC Docket No. 50-249 References (a): NRC Inspection Report No. 50-249/86-006.

(b): Letter from D. L. Farrar to J. G. Keppler dated May 6, 1986.

Dear Mr. Keppler:

The reference (a) Inspection Report documented your staff's review of the Dresden Unit 3 drywell fire and requested we respond to concerns identified in the report. Our reference (b) transmittal provided our response in the form of a report documenting our evaluation of the fire. We have recently become aware of a condition at Dresden Unit 3 which conflicts with a statement made in our report.

On page 83 of the reference (b) report, as a response to an NRC question, the following statement was made with regard to the use of polyurethane in other plant locations:

"Both polyurethane and polyethylene have been used as a filler material at the top of block walls and polyurethane is used to seal penetrations. None of the block walls are considered rated fire barriers and in those walls that use polyurethane as a penetration seal, either the wall is not a rated barrier or, if it is, the polyurethane has been replaced with a fire rated or noncombustible material".

This statement is not completely accurate as the polyurethane has not been replaced in all Appendix R rated barriers. This was discovered recently at Dresden at elevation 589'-0" in the Unit 3 reactor building during ongoing Appendix R walkdowns. As a result of this discovery, we are currently conducting additional walkdowns to identify any other areas where previous walkdowns may not have identified polyurethane mechanical penetration seals in Appendix R rated barriers.

1 JUL 211986

, .---._.--._.,_m

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T Mr. J. G. Keppler July 17 1906 All polyurethane mechanical penetration seals discovered in Appendix R rated barriers will be replaced with appropriately rated seals. These activities will be completed in accordance with our existing schedule for sealing Appendix R penetrations at Dresden (completion by end of the next Unit 2, refuel outage). In the interim, we will implement the same compensatory measures we've committed to for other outstanding Appendix R modifications.

We will also be conducting additional walkdowns at Dresden Unit 2 and Quad Cities Units 1 and 2 to identify any similar applications of polyurethane in Appendix R rated barriers. Any problems identified will be resolved in the same manner as described above.

We have discussed this situation with NRR (R. Gilbert, J. Stang) during a telecon on July 14, 1986. During that call, NRR concurred with our proposed resolution of this issue.

If you have any questions regarding this transmittal, please contact this office.

Very tru y yours, e

. L. Farrar Director of Nuclear Licensing 1m cc: H. R. Denton - NRR R. A. Gilbert - NRR R. B. Bevan - NRR NRC Resident Inspector - Dresden NRC Resident Inspector - Quad Cities 1855K

., , D.- ' Commonwealth Edison e

72 West Adams Street, Chicroo, Illinois f4 V [J. Address Reply to: Post Office Box 767 Chicago, Illinois 60690-0767 4

July 17, 1986 Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission i Region III 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Dresden Station Unit 3 Drywell Fire-Correction to Fire Evaluation Report NRC Docket No. 50-249 References (a): NRC Inspection Report No. 50-249/86-006.

(b): Letter from D. L. Farrar to J. G. Keppler dated May 6, 1986.

Dear Mr. Keppler:

The reference (a) Inspection Report documented your staff's review of the Dresden Unit 3 drywell fire and requested we respond to concerns identified in the report. Our reference (b) transmittal provided our response in the form of a report documenting our evaluation of the fire. We have recently become aware of a condition at Dresden Unit 3 which conflicts with a statement made in our report.

On page 83 of the reference (b) report, as a response to an NRC question, the following statement was made with regard to the use of polyurethane in other plant locations:

"Both polyurethane and polyethylene have been used as a filler I material at the top of block walls and polyurethane is used to I seal penetrations. None of the block walls are considered rated fire barriers arvi in those walls that use polyurethane as a penetration seal, either the wall is not a rated barrier or, if )

it is, the polyurethane has been replaced with a fire rated or noncombustible material".

This statement is not completely accurate as the polyurethane has not been replaced in all Appendix R rated barriers. This was discovered

, recently at Dresden at elevation 589'-0" in the Unit 3 reactor building during ongoing Appendix R walkdowns. As a result of this discovery, we are currently conducting additional walkdowns to identify any other areas where previous walkdowns may not have identified polyurethane mechanical penetration seals in Appendix R rated barriers.

JUL 211986 i

( . .

Mr. J. G. Keppler July 17 1986 P

All polyurethane mechanical penetration seals discovered in Appendix R rated barriers will be replaced with appropriately rated seals. These activities will be completed in accordance with our existing schedule for sealing Appendix R penetrations at Dresden (completion by end of the next Unit 2, refuel outage). In the interim, we will implement the same compensatory measures we've committed to for other outstanding Appendix R modifications.

We will also be conducting additional walkdowns at Dresden Unit 2 and Quad cities Units 1 and 2 to identify any similar applications of polyurethane in Appendix R rated barriers. Any problems identified will be resolved in the same manner as described above.

We have discussed this situation with NRR (R. Gilbert, J. Stang) during a telecon on July 14, 1986. During that call, NRR concurred with our proposed resolution of this issue.

If you have any questions regarding this transmittal, please contact this office.

Very tru y yours, p-

. L. Farrar Director of Nuclear Licensing In cc: H. R. Denton - NRR R. A. Gilbert - NRR R. B. Bevan - NRR NRC Resident Inspector - Dresden NRC Resident Inspector - Quad Cities 1855K a

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<  ! 72 West Adams Street, Chicico, Illinois .

'k k '1 )" 2 Address Reply to: Post Office Box 767 e V' Chicago, tilinois 60690-0767 July 17, 1986 Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Dresden Station Unit 3 Drywell Fire-Correction to Fire Evaluation Report NRC Docket No. 50-249 References (a): NRC Inspection Report No. 50-249/86-006.

(b): Letter from D. L. Farrar to J. G. Keppler dated May 6, 1986.

Dear Mr. Keppler:

The reference (a) Inspection Report documented your staff's review of the Dresden Unit 3 drywell fire and requested we respond to concerns identified in the report. Our reference (b) transmittal provided our response in the form of a report documenting our evaluation of the fire. We have recently become aware of a condition at Dresden Unit 3 which conflicts with a statement made in our report.

on page 83 of the reference (b) report, as a response to an NRC question, the following statement was made with regard to the use of polyurethane in other plant locations:

"Both polyurethane and polyethylene have been used as a filler material at the top of block walls and polyurethane is used to seal penetrations. None of the block walls are considered rated fire barriers and in those walls that use polyurethane as a penetration seal, either the wall is not a rated barrier or, if it is, the polyurethane has been replaced with a fire rated or noncombustible material".

This statement is not completely accurate as the polyurethane has not been replaced in all Appendix R rated barriers. This was discovered recently at Dresden at elevation 589'-0" in the Unit 3 reactor building during ongoing Appendix R walkdowns. As a result of this discovery, we are currently conducting additional walkdowns to identify any other areas where previous walkdowns may not have identified polyurethane mechanical penetration seals in Appendix R rated barriers.

JUL 211986

Y f

Mr. J. G. Keppler July 17 1986 All polyurethane mechanical penetration seals discovered in Appendix R rated barriers will be replaced with appropriately rated seals. These activities will be completed in accordance with our existing schedule for sealing Appendix R penetrations at Dresden (completior. by end of the next Unit 2, refuel outage). In the interim, we will implement the same compensatory measures we've committed to for other outstanding Appendix R modifications.

We will also be conducting additional walkdowns at Dresden Unit 2 and Quad Cities Units 1 and 2 to identify any similar applications of polyurethane in Appendix R rated barriers. Any problems identified will be resolved in the same manner as described above.

We have discussed this situation with NRR (R. Gilbert, J. Stang) during a telecon on July 14, 1986. During that call, NRR concurred with our proposed resolution of this issue.

If you have any questions regarding this transmittal, please contact this office.

Very tru y yours,

. L. Farrar Director of Nuclear Licensing Im cc: H. R. Denton - NRR R. A. Gilbert - NRR R. B. Bevan - NRR NRC Resident Inspector - Dresden NRC Resident Inspector - Quad Cities 1855K L_