ML17258B131

Requests Time Extension Until 811117 to Bring Fire Detection Sys Into Operation.Last Items of Physical Const Will Be Completed by 810630.Panel-related Design Problems Have Made Sys More Difficult to Put Into Operation

ML17258B131
Person / Time
Site:	Ginna
Issue date:	06/19/1981
From:	Maier J ROCHESTER GAS & ELECTRIC CORP.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
NUDOCS 8106240283
Download: ML17258B131 (8)

Text

REGULATORY ORMATION DISTRIBUTION SY M (RIDS)

ACCESSION NBR:8106240283-DOC ~ DATE.; 81/06/19 NOTARIZED:,NO. DOCKET' FACIL:50 244 Robert Emmet Ginna Nuclear PlantE Unit" ii Rochester G

05000244 AUTH,NAME AUTHOR AFFILIATION MAIERgJ' E ~

Rochester Gas 8 Electric Corp'ECIP

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RECIPIENT AFFILIATION DENTONPH ~ R ~

Office of Nuclear Reactor Regulationr DirectorI SUBJECT; Requests time extension until 811117 to bring fiire'etection>>

sys into operation, Last items of physical const will be'ompleted by 810630

~ Panel related design problems have made'ys more difficult to put into operations DISTRIBUTION CODE:

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ITfLIC ROCHESTER GAS AND ELECTRIC CORPORATION o

89 EAST AVENUE, ROCHESTER, N.Y. 14649 JOHN E.

MA IER VICE PRESIDENT TCLCPHONC ARCA COOC old 546-2700 Mr. Harold R. Denton Director, Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C.

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June 19, 1981 C

Rochester Gas and Electric Corporation

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Robert E. Ginna Nuclear Power Plant Compliance with 10 CFR 50.48

Dear Mr. Denton:

On January 26, 1981, Rochester Gas and Electric Corporation

("RG&E" or "the Company" ) wrote you to request an extension of time, until June 30, 1981, to complete the installation of certain of the fire protection features which had been accepted by the Nuclear Regulatory Commission Staff in its Fire Protection Safety Evaluation Report

("SER") for Robert E. Ginna Nuclear Power Plant and in Supplement No.

1 thereto.

By letter dated February 13,

1981, you approved our request, finding that good cause existed for the extension and that the public health and safety would not be adversely affected thereby.

Notice of your action was published in the Federal Register on February 23, 1981.

46 Fed.

Reg.

13617 (Feb.

23, 1981).

We are pleased to report that the last items of physical construction covered by the extension will be completed by June 30, 1981.

Consequently, one hundred percent of the components of the fire protection system covered by the SER and Supplement No.

1 now have been, or will soon be, physically installed.

Unfortunately, circumstances beyond the Company's control will prevent the completion of start-up testing of the detection system prior to June 30, 1981.

These circumstances require us to request an extension until November 17, 1981 to bring the detection system into operation.

A number of difficulties have been encountered in the design and installation of the fire detection system control panel.

In an effort to meet earlier commitment dates, RG&E took early delivery of the fire control panel.

The unit was delivered prior to final wiring and panel check-out.

Further, a production change implemented by the manufacturer after delivery of our unit has only been made known to us within the past week.

In addition, we have encountered a number of other panel-related design problems.

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ROCHESTER GAS AND ELECTRIC C RP.

DATE June 19 19 8]

Mr. Harold R. Denton SHEET NO.

2 The result of these factors is that it has been far more difficult to make the system operational than we had anticipated.

Although we believe we understand the cause for the system inoperability, we have been unable to complete the 'testing and turnover of any of the detection systems.

Thus, we cannot be assured that, all system-related problems have been resolved.

Even following resolution of system-related

problems, substantial additional testing will be required.

The Company's inability to test out the system because of these control panel problems is not for lack of trying.

As noted

before, the Company took early delivery of the panel in late 1980.

Testing specifications were developed by Company engineers, and wiring of the panel was completed at the plant.

Testing of the system was started on May 10, 1981 and continued until June 12,

1981, when it was decided to halt testing until the control panel problems could be resolved.

For the better part of this approximately one month period, ten men working 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> a week were devoted to system testing.

Toward the end of the period, a

six man back shift, again working 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> a week, was added.

At present, we are aggressively pursuing a solution to the control panel problems with the manufacturer.

Modifications to the panel modules have been identified and are in the process of being installed and tested.

However, we cannot be certain of overall system operability until further testing is completed to assure that all other aspects of the system also are operating properly.

A system of this magnitude and complexity requires an extensive program of startup testing, check out, and acceptance testing.

It is always difficult to estimate how long this program will take and it is highly desirable to perform these activities on a schedule which permits full evaluation of all discrepancies.

On this basis, we think it reasonable to request an extension until November 17, 1981.

We, of course, will keep NRC project personnel informed of our progress.

Due to the integrated nature of the design, several SER items are impacted, specifically, items 3.1.1, 3.1.2, 3.1.3, 3.1.12, 3.1.19, 3.1.21, 3.1.42, 3.2.3.

In the interim, substantial detection and suppression capability is available.

First, compliance with the existing Ginna Technical Specifications requires operability of certain detection and suppression systems.

Any inoperability of these

systems, such as during conversions to the new detection and suppression control system, requires compensatory meaures (e.g.,

fire watches or backup suppression).

Detection instrumentation required by the existing Technical Specifications provides coverage of most safety-related areas including both diesel

rooms, the

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intermediate building basement, the cable tunnel, the relay room, the computer room, both battery rooms, the control room, and the auxiliary building.

ROCHESTER GAS AND ELECTRIC RP.

oATE June 19, 1981 To Nr. Harold R. Denton SHEET NO.

Further, all suppression

systems, both those addressed by the existing Technical Specifications and those new systems required by the SER, are installed and will be available, by June 30, 1981, for operation by local manual actuation.

Typically, actuation would be accomplished by opening a manual isolation valve and operating a deluge valve.

Finally, additional detection capability is provided by the normal surveillance of all areas of the plant.

Plant operators tour all areas of the plant several times each shift.

Security personnel also inspect areas of the plant each shift.

During periods of construction, construction personnel are working in many areas of the plant.

The Company submits that good cause exists for the granting of the extension and that the extension will not adversely affect, public health and safety.

As noted both in our January 26, 1981 letter and your February 13, 1981 response, the NRC Staff concluded in February 1979 that the operation of the facilit,

endin resolution of the incom lete items and the im lementation of all facilit modifications, does not resent an undue risk to the health and safet of the public based on our concurrence with the Browns Ferry Special Review Group's conclusions identified above,

-as well as the si nificant im rovements in fire rotec-tion alread made at the facilit since the Browns Ferry fire.

These include establishment of administra-tive controls over combustible materials and use of a fire brigade, and issuance of technical specifica-tions to provide limiting conditions for operation and surveillance requirements on fire protection systems.

SER at 8-2 (emphasis added).

Given that the operation of the plant did not present an undue risk to the health and safety of the public at the level of fire protection achieved by February

'979, and given that the level of protection has been significantly enhanced since then, the approval of a four and one-half month extension for completion of the fire protection program at Ginna certainly poses no undue risk to health and safety.

We look forward to your favorable response.

Very truly yours,

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