ML17309A118
| ML17309A118 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 01/26/1981 |
| From: | Maier J ROCHESTER GAS & ELECTRIC CORP. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8102020369 | |
| Download: ML17309A118 (25) | |
Text
REGULATORY ORMATION DISTRIBUTION SYi
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ACCESSION NBR; 8102020369 DOC, DATE: 81/01/26 NOTARIZEDg, NO DOCKET FACIL;,50 244 Rober t Emmet Ginna Nuclear Planti Unit li Rochester G
05000244 AUTH'YNAME AUTHOR AFFILIATION MAIER~J,E, Rochester Gas 8 Electric Corp.
RECIP ~ NAMEI RECIPIENT AFFILIATION DENTONiH.RB Office0 of Nuclear Reactor" Regulation~
Director'UBJECT:
Requests extension to June 1981 to complete, installation of approved fire protection featuressImjlementation dates for mods 8 status of incomplete items-provided.
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P. YORK, AND ELECTRIC CORPORATION o
89 EAST AVENUE, ROCHESTER, N.Y. 14649 JOHN E.
MAILER VICE PRESIDENT ZEI.EPHONE ARE* CODE 7IO 546.2700 January 26, 1981 Mr. Harold R. Denton Director, Office of Nuclear Reactor Regulation U.
S. Nuclear Regulatory Commission Washington, D. C.
20555 Re:
Rochester Gas and Electric Corporation Robert E. Ginna Nuclear Power Plant
Com-pliance with 10 CFR 5 50.48
Dear Mr. Denton:
Pursuant to 10 CFR section 50.48(d),
Rochester Gas and Electric Corporation
("RGaE" or "the Company" )
requests an extension of time to complete the installation of certain of the fire protection features accepted by the Nuclear Regulatory Commission Staff in its Fire Protection Safety Evaluation Report
("SER") for Robert E. Ginna Nuclear Power Plant and Supplement No.
1 thereto
("SER Supplement" ).
Section 50.48 of 10 CFR was adopted by the Nuclear Regulatory Commission on November 18, 1980, to become effective on February 17, 1981.
45 Fed.
Reg.
76602 (Nov. 19, 1980), corrected, 45 Fed.
Reg.
79409 (Dec. 1, 1980).
Subsection (d) of that section requires completion of the fire protection features accepted by the NRC Staff in the SER and SER Supplement by the completion date specified in the plant's license or technical specifica-tions or the date determined by paragraphs (d)(l) through (d)(4) of section 50.48, whichever is sooner.
If the earliest of these dates occurs before February 17, 1981 Ct>
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ROCHESTER CAS AND ELECTRIC CORP.
DATE January 26'981 To Mr. Harold R. Denton SHEET NO.
2 (the effective date of section 50.48),
we understand
- that, for purposes of section 50.48, the completion date for the affected fire protection features would be February 17, 1981.
HISTORY OF RG&E NRC CONSIDERATION OF GINNA FIRE PROTECTION MODIFICATIONS It is important to place this request for an extension of time in proper chronological perspective.
The development and implementation of the NRC's fire pro-tection guidance has been a complex, technically demanding
- process, the integrated requirements of which have evolved over the past four years.
The following recitation of the efforts of RGSE and NRC Staff in developing and implement-ing the Ginna fire protection program illustrates this point:
A prox. Ela sed Time Between Milestones March 1975 February 1976 Browns Ferry fire occurred Special Review Group released recommendations (NUREG-0050) ll mos.
May 1976 NRR issued Branch Technical Position (BTP) 9.5-1 3 mos
~
June 1976 August 1976 February 1977 BTP 9.5-1 guidance published for public comment as Reg.
Guide 1.120 Appendix A to BTP 9.5-1 published for use by plants docketed pr ior to 7/1/76 RGSE submitted document in response to BTP 9.5-1 1 mo ~
2 mos.
6 mos.
ROCHESTER GAS AND ELECTRIC CORP.
DATE January 26, 1981 To Nr. Harold R. -Denton SHEET NO. 3 June 1978 NRC Staff visited Ginna to evaluate fire protection program (a visit which had been rescheduled 10 times by Staff) 1/
16 mos.
February 1979 NRR issued Ginna Fire Protection SER which approved modification schedule providing for 6/81 completion of last items 8 mos.
April 1980 NRC Staff responded to RGEE submittals made pursuant to SER during 4/79-12/79 15 mos.
Nay 1980 June 1980 November 1980 NRC provided RGGE with a copy of proposed Appendix R; 10 CFR 5 50.48 proposed by NRC RG&E met with NRC Staff to discuss Staff response to RGGE submittals and Appendix R
NRC adopted 10 CFR g 50.48 and Appendix R, effective February 17, 1981 1 mo ~
1 mo ~
5 mos.
December 1980 NRC issued SER Supplement No.
1 accepting RGGE proposals with respect to previously incomplete SER items 1 mo.
1/
These ten changes in the site visit date occurred over a one year period.
We understand that plants in the Systematic Evaluation Program, like Ginna, purposely were visited toward the end of the Staff site visit program so that fire protection modifications could be put in the context of SEP modifications.
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ROCHESTER GAS AND ELECTRIC CORP.
OATE January 26, 19 81 To Mr. Harold R. Denton SHEET NO.
4 The foregoing events, of course, represent only the major milestones in the development and implementation of the Ginna fire protection program.
Numerous other written communications and oral discussions between the Company and the Staff transpired following RGGE's initial sub-mittal in February 1977.
The SER issued in February 1979 provided comple-tion dates for each fire protection item which RGGE was required to implement.
The implementation schedules, set out in SER Tables 3.1 and 3.2, specified that the last items were to be completed by June 1981.
Until recently, RGGE has been proceeding in accord with Tables 3.1 and 3.2.
Because of the heavy Three Mile Island-related work load with which licensees have been faced, there has been some slippage in milestone completion dates for several individual items addressed in the tables,& but the Com-pany had every expectation of completing the total modifi-cation program by June
- 1981, the end date specified in SER Table 3.1.
To that end, the Company had planned its own internal engineering schedule and had negotiated and con-tracted with architect-engineering firms for outside engi-neering work on the basis of the SER completion dates.
When it became apparent in May 1980 that the NRC was giving consideration to a requirement that all items be completed by November 1, 1980, notwithstanding a
specific plant's SER schedule, the Company compressed its engineering and construction schedules to the maximum extent possible.
As a result, much of the outstanding work has been or will be completed by February 17, 1981.
The completion status of the individual items is shown on Attachment l.
RGSE believes that it has exhausted every 2/
The NRC Staff was notified by letter of slippages; none was ever disapproved or questioned.
ROCHESTER GAS AND ELECTRIC CORP.
DATE January 26, 1981 Mr. Harold R. Denton SHEET NO.
= 5 feasible effort in bringing the fire protection program to the current degree of completion, including overtime work which has been authorized for both design and construction.
ITEMS FOR WHICH AN EXTENSION IS NECESSARY The SER listed fifty-eight items related to plant design and operation which are part of the Ginna fire pro-tection evaluation and modification program.
Two items (Items 3.2.1 and 3.2.2) relate to a safe shutdown system and are not impacted by the February 17, 1981 deadline.
Five items (Items 3.1. 11, 3.1.21, 3.1. 48, 3. 2.6, and 3.2.8) involve modifications which only recently have
- been, or are about to be, approved by the NRC Staff.
See SER Supplement at 2-3, 4,
5 (as to Items 3.1.11, 3.1.21, 3.1.48, and 3.2.6; we expect an SER Supplement for Item 3.2.8 to be issued in the near future).
We read sec-tion 50.48 as allowing a licensee a specified period of time following NRC approval to implement a modification, thus providing the Company with a deadline later than February 17, 1981 for the items approved by the SER Supplement and the work associated with Item 3.2.8.
Of the remaining fifty-one items, the Company has identified the following fourteen items as being ones which may not be completed in all respects by the date required by section 50.48:
Item 3.1.1; Item 3.1.2; Item 3.1.3; Item 3.1.5; Item 3.1.7; Item 3.1.8; Item 3.1.9; Item 3.1.12; Item 3.1.19; Item 3.1.37; Item 3.1.39; Item 3.1.42; Item 3.1.49; and Item 3.2.3.
The Company currently is pursuing an engineer-ing/construction schedule which contemplates completion of a high percentage of work relating to these items by February 17, 1981, followed by expeditious completion of the remaining work thereafter.
However, for a number of
- reasons, RGSE does not believe it reasonable to predict further schedule improvements.
First, the current schedules are ones which already have been compressed to the maximum extent possible.
- Second, the Company is encountering delays in procuring some materials required for completion of several items.
Third, Company resources must also be allocated in this time frame to preparation for a major shutdown scheduled to begin in April 1981 and
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ROCHESTER GAS AND ELECTRIC CORP.
DATE January 26, 1981 To Mr. Harold R. Denton SHEET NO.
6 to certain other engineering and construction tasks mandated by the NRC.
Consequently, the Company requests that you approve an extension to June 1981 for completion of the fourteen items required to be completed by February 17, 1981.
An extension to this date will not exceed the dates determined by 10 CFR sections 50.48(c)(l) through (c)(4).
It is conceivable, of course, that many, if not all, of the outstanding items will be completed in advance of June 1981.
- However, the Company believes it preferable at this time to seek an extension to a date which it has every confidence of meeting.
Work, nonetheless, would continue on the schedules currently being pursued.
THE STATUS OF THE INCOMPLETE ITEMS As noted before, Attachment 1 lists the percent-age completion of each fire protection item which is not yet complete.
A discussion of the work remaining to be done for each item follows.
With respect to seven of these items, particular note should be taken of the fact that the completion date authorized by the SER since February 1979 is June
- 1981, the very date to which the Company now must seek an extension as a result of the promulgation of section 50.48.
The items which had SER completion dates of June 1981 are Water Suppression Sys-tems and Equipment (3.1.2);
Gas Suppression Systems and Equipment (3.1.3); Water Spray Shields (3.1.7); Fire Dampers (3.1.9); Diesel Room Water Suppression System (3.1.19); Fire Dampers (3.1.37);
and Reactor Coolant Pump Lube Oil Collection System (3.1.39).
Su ression S stems (Items 3.1.2, 3.1.7 3.1.19 3.1.21, 3.2.3 RGGE expects that all major piping and most of the deluge system associated with the suppression systems will be complete by February 17, 1981-Work to be com-pleted includes installation of the deluge systems in the intermediate building and the relay room; installation of spray shields and the control room water curtain; and the testing of all systems, including the relay room halon
ROCHESTER GAS AND ELECTRIC CORP.
DATE January 26, 19 8 1 To Mr. Harold R. Denton SHEET NO.
system test.
The SER completion date for all these
- items, with the exception of the control room water curtain, is June 1981.
As for the water curtain, the Company's design was not accepted by the NRC Staff until the issuance of the SER Supplement in December 1980.
SER Supplement at 3-4.
Likewise, it was not until the issuance of the SER Supplement that several of the features of the water sup-pression system were approved.
SER Supplement at 2.
Detection S stems Items 3.1.1 3.1.3, 3.1.12, 3.1.42)
By February 17, 1981, approximately 85 percent of the detection system work will be completed.
The remain-ing work with respect to these items involves installation of the main control panels and terminations, making the interface with existing systems, and final testing.
Delays have been encountered because of labor unavail-ability and difficulty in procuring smoke detectors.
Fire Doors (Item 3.1.5 Ninety percent of the work on this item will be completed by February 17, 1981.
Installation of the fire doors will be completed in conjunction with installation of new pressure doors to serve both pressure and security functions.
Pressure door installation was delayed by the NRC approval process.
Fire Barriers (Item 3.1.8 Ninety-five percent of the work on this item has been completed, with construction of the barrier between the cable tunnel and the intermediate building the remain-ing task.
Approval of RGS,E's proposal for this barrier was not provided by the NRC Staff until December 1980 when the SER Supplement was issued.
Batter Room Ventilation Item 3.1.11)
Completion of this item required NRC Staff approval of RGGE's use of flow switches in the battery room exhaust ducts.
That approval was given in December
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ROCHESTER GAS AND ELECTRIC CORP.
DATE January 26, 1981 To Mr. Harold R. Denton SHEET NO. 8 1980.
SER Supplement at 2.
The construction work asso-ciated with this item will be approximately 15 percent complete by February 17, 1981.
Fire.Dam ers (Items 3.1.9,-3.1.37)
Approximately 15 percent of the construction effort associated with these items will be completed by February 17, 1981.
The SER completion date for these items is June 1981.
Reactor Coolant Pum Lube Oil Collection S stem Item
. 1; 9)
One RCP lube oil collection system was installed during the November 1980 shutdown, and the system for the second pump will be installed during the Spring 1981 shut-down.
The SER completion date for this item is June 1981.
H dro en Pi in (Item 3.1.48)
Fifty percent of the installation associated with this item will be completed by February 17, 1981.
NRC Staff approval of the hydrogen piping routed through the auxiliary building was only recently given.
SER Supple-ment at 4.
RG&E has also encountered delays in instrument delivery.
Kitchen Area (Item 3.1.49)
The construction associated with this item will be undertaken during the Spring 1981 shutdown to avoid disruption of plant operation.
Earlier construction schedules were deferred due to a number of other NRC-mandated modifications in the control room (e.g.,
electrical anchor bolts, fire detection and suppression)
Fire hazards in the kitchen area will be removed by Febru-ary 17,
- 1981, and not returned until the fire barrier is constructed.
Backflow Penetration Evaluation (Item 3.2.6)
RG&E's proposal for modifications to alleviate the NRC Staff concern about the spreading of combustible liquids through the drain system was only approved in
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ROCHESTER CAS AND ELECTRIC CORP.
DATE January 26, 1981 To Mr. Harold R. Denton SHEET NO.
9 December 1980.
SER Supplement at 6.
The necessary modifications to containment and the auxiliary building will be completed during the Spring 1981 shutdown.
Ex osed Structural Steel Stud (Item 3.2.8)
Modifications resulting from the NRC Staff's evaluation of RGGE's Exposed Structural Steel Study will be in progress on February 17,
- 1981, but may not be com-pleted until June 1981.
We understand that an SER Sup-plement regarding this item is under preparation by the NRC Staff.
GRANTING THE EXTENSION WILL NOT ADVERSELY AFFECT PUBLIC HEALTH AND SAFETY With respect to Ginna, the NRC Staff concluded in February 1979 that the o eration of the facilit,
endin reso-lution of the incom lete items and the im lementation of all facilit modifica-
- tions, 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 rotection alread made at the facilit since the Browns Ferry fire.
These include establishment of administrative controls over combustible materials and use of igni-tion sources, training and staffing of a fire brigade, and,issuance of technical specifications to provide limiting condi-tions for operation and surveillance requirements on fire protection systems.
SER at 8-2 (emphasis added).
In its subsequent Supple-ment to the SER, the NRC Staff concluded that "all of the incomplete items in the lSER], except the design of the dedicated safe shutdown capability, have been acceptably resolved subject to implementation of the approved modifi-cations."
SER Supplement at 6.
As of February 17,
- 1981, at least 37 of the 56 required modifications to the plant or to Company procedures will have been accomplished.
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ROCHESTER GAS AND ELECTRIC CORP.
DATE January 26, 1981 To Mr. Harold R. Denton SHEET N0,10 Given that the operation of the plant did not present an undue risk to the health and safety of the pub-lic at the level of fire protection achieved by Febru-ary 1979, and given that the level of protection has been significantly enhanced since then, the approval of an eighteen week extension for completion of the fire protec-tion program at Ginna certainly poses no undue risk to health and safety.
Moreover, for approximately ten of those eighteen
- weeks, the plant will be shut down for refueling and a turbine generator overhaul, further mini-mizing whatever minimal risk might be said to exist.
Granting this request is also in the public interest.
Should the extension be denied and plant opera-tion be prohibited until the remaining fire protection items are completedg the cost to the Company's customersg as a result of higher fuel charges and replacement power
- costs, would be approximately
$ 24 million (for the period February 18 April 3 and June 3
June 30, 1981).
In conclusion, the Company believes that the foregoing materials and attachments establish that good cause exists for extending the completion dates as requested herein and that the public health and safety would not be adversely affected by the extension.
Ne look forward to your favorable response.
Very truly yours, Jo n E. Maier
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ROCHESTER GAS AND ELECTRIC CORP.
DATE January 26, 1981 To Harold R. Denton SHEET NO.
11 ATTACHMENT 1 TABLE 3.1 IMPLEMENTATION DATE FOR MODIFICATION ITEM 3.1.1 3.1.2 3.1.3 3.1.4 3.1.5 3.1.6 3.1.7 3.1.8 3.1.9 3'.10 3 '.11 3.1.12 3.1.13 3.1.14 3 '.15 3.1.16 3 '.17 3 '.18 3-1.19 3.1.20 3.1.21 3.1.22 3 '.23 3.1.24 3.1.25 3.1.26 3'.27 3 '.28 Fire Detection System Water Suppression Systems and Equipment Gas Suppression Systems and Equipment Curbs Fire Doors Computer Room Ceiling Water Spray Shields Fire Barriers Fire Dampers Halon Storage Battery Room Ventilation Fire Alarms Relocation of Gas Meter Diesel Generator Room Manhole Covers Flame Retardant Cable Coating Door Closure Adjustment Turbine Oil Reservoir Area Physical Examination Diesel Room Water Suppression System Service Water Piping in Diesel Room Control Room Separation Exterior Hydrants Emergency Lights Piping and Duct Penetrations Construction Joints Exterior Hose Houses Special Purpose Fire Fighting Equipment Fire Fighting Equipment Storage STATUS 2/17/81 85% comp.
75% comp.
85% comp.
Complete 90% comp.
Complete 15% comp.
95% comp.
30% comp.
Complete 30%
85% comp.
Complete Complete Complete Complete Complete Complete 80% comp.
Complete 30% comp.
Complete Complete Complete Complete Complete Complete Complete COMPLETION DATE 6/81 6/81 6/81 6/81 6/81 6/81 6/81 6/81 6/81 6/81 6/81
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ROCHESTER GAS AND ELECTRIC CORP.
DATE January 26 ~ 1981 Harold R. Denton SHEET NO 12 3.1.29 3.1.30 3.1.31 3.1.32 3.1.33 3.1.34 3.1.35 3.1.36 3.1.37 3.1.38 3.1.39 3.1.40 3.1.41 3.1.42 3.1.43 3.1.44 3.1.45 3.1.46 3.1.47 3'.48 3.1.49 Diesel Fire Pump Testing S
Surveillance Fire Door Supervision Brigade Training Control of Combustibles Control of Ignition Sources Prefire Strategies Off-Duty Brigade Recall Hose Stretch Tests Fire Dampers Fire Barriers Reactor Coolant Pump Lube Oil Collection Systems Fire Water Piping System Manual Hose Stations Inside Containment Signaling Circuits Supervision Detector Testing Exterior Hydrant Freeze Protection Working Permit Involving Ignition Source Auxiliary Boiler Transient Combustibles Hydrogen Piping Kitchen Area Complete Complete Complete Complete Complete Complete Complete Complete 30% comp.
Complete 70% comp.
Complete Complete 85% comp.
Complete Complete Complete Complete Complete 65% comp.
15% comp.
6/8 1 6/81 6/81 6/81 6/811/
1/
A 1-hour rated fire barrier will be installed during the next refueling outage.
Fire hazards in the kitchen will be removed prior to February 17, 1981 and remain out of the kitchen until the 1-hour rated fire barrier is installed.
ROCHESTER GAS AND ELECTRIC CORP.
DATE January 26 g 198 1 To Harold R. Denton SHEET NO. 13 TABLE 3.2 COMPLETION DATE FOR INCOMPLETE ITEMS ITEN8 3.2 '
3.2.2 3.2.3 3.2.4 3.2.5 3.2.6 3'.7 3.2.8 3.2.9 Shutdown Analysis Cable Separation Relay Room Halon System Test Electrical Cable Insulation Electrical Cable Penetration Backflow Protection Evaluation Fire Pump Performance Exposed Structural Steel Fire Brigade Size STATUS
~2/17 81 Complete>/
(Study)
Completely/
(Study) 0% comp.
Complete Complete Complete>/
(Study)
Complete Complete4/
(Study)
Complete COMPLETION DATE Upon com-pletion of wall 1/
SER Supplement No.
1 states that evaluation of the safe shutdown will be reported in a subsequent safety evaluation.
2/
SER Supplement No.
1 states that item 3.2.2 shall be included under item 3.2.1.
3/
Modifications resulting from the Backflow Protection Evaluation will be installed during the next refueling outage.
Scheduled completion date is 6/81.
+4 Modifications resulting from the Exposed Structural Steel Study are scheduled to be complete in 6/81.
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i IILagi U.S. NUCLEAR REGULATORYCOMMISSI REACTOR FACILITYFEE DETERMINATION 1
FEE. FORM TY Cneca one:
RELIMINARY FINAL AMENDEO INSTRUCTIONS. Fill initems 1ihrough I ~. as apphcaDie.'and send the original copy to Ihe License Fee Management Brancn.
2 DOCKET NUMBERLSi 4
LICENSEE 3.
CCESSIDNNUMBER d~6~
S PLANT NAME ANO UNITiS) 6 OATEOFaPPMCATiON Ed 7
EE REMITTED YES NO CLASSI CLASSX CLASS ix CLASS rv CLASSV CLASS Vi
- a. LICENSEE FEE DETERMINATION EAEMPT rrbrr1 SUB C
ig. TAC NUMBER ASSIGN EDtlraxarrabrel 11 APPROVAL DATEOF IS UANC LETIER OnDEP AMENDMErrtrruMstnlsi
- 12. NRCF EOE1ERMI ATION The above application has been reviewed in accordance with Section 170 22 of Part 170 and is pioperly categorized.
The above application has been revi wed in accordance with Section 170 22 of Pari 170 and is mcorrectly classified.
Fee should be classtesl:
JU ICATIONFOR CLASSIFICATIONOR RECLA SIFICATION This application is a Class type of action and is exempt from lees because it is:
Filed by a nonprofit educational institution, Filed by a Government agency and is nol for a power reactor.
For a Ciass I. II. or III amendment which results from an NRC request dated tor the application and the amendment is to simplify or clanfy License or Technical Specifications: has only minor safety significance: and is being issued for the convenience of NRC fmust meal all ol the Critehal.
Other lSlate reason lherelorl 13 SiGNATUREIBrancnCnielr ia iNALcERTIFicATIoN Tnepreiiminary teederermrnatronnasDeenraassessedandisnerebyaihrmed.
SIGNATURE rrrrorecr Manager Or Brancn Cnieri DATE/2/S DATE FOR LICENSE FEE MANAGEMENTBRANCH USE ONLYIAllOtherS dOnOt Write belOw lhrS linel The above exemption reouesi has Deen revieived and is hereby accepted as being exempt SIGNATUREICniel LFMBr DATE Records Services Brancn DL Brancncniet DISTRIBUTIONBY LFMB
'FM8 Exemption File LFMBReactor Fae
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