ML19347F167

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Provides Preliminary Response to Util 810309 Exemption Requests from 10CFR50 App R.Requests Cannot Be Favorably Acted Upon Until Commitment to Specific Course of Action Re Fire Barrier Is Outlined
ML19347F167
Person / Time
Site: Pilgrim
Issue date: 05/04/1981
From: Harold Denton
Office of Nuclear Reactor Regulation
To: Morisi A
BOSTON EDISON CO.
References
NUDOCS 8105150378
Download: ML19347F167 (3)


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Mr. A. Victor Morist, Manager A

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Dear Mr. Moris1:

4 RE: Pilgrim I - Fire Protection Exemption Requests from 10 CFR 50 Appendix R By letter dated March 9,1981 (BEco 81-52), the Boston Edison Company (BECo) requested an exemption fmm the schedule requirements of 50.48(c), regarding implementation of Section III(G) of Appendix R to 10 CFR 50. BECo requested relief from the sui, mission dates for plans, schedules, design infonnation, exemption requests, and the implementation dates for plant modifications.

Approval of the BEco proposal would extend all such dates by approxi-taly 7 1/2 months.

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In addition, by letter dated March 18,1981 (BECo 81-59), BECo requested fourteen (14) specific exemptions fmm the rule. Boston Edison believes that such exemptions am justified on the ground that the fire protection measures prescribed in Section III(G) would not, if installed at Pilgrim,

" provide substantial, additional protection which is required for the public health and safety."

Our review of your March 9 letter is not yet complete. We expect to reach a final decision by mid-May 1981. However, we have completed a preliminary review of the March 18 exemption requests, and discussed the results with your staff in telephone conversations on April 8, 9, and 17,1981. We have determined that one (1) item,1B of Attachment B to BECo 81-59) has a sound technical basis which warrants further staff review, and, under the provisions of 50.48(c)(6), the schedule requirements of paragraph (c) will be tolled pending our final action on your request concerning item 18. Six (6) items (lC,1E,1F,1H, II, and lJ) are denied due to the submission of insufficient infonnation. The additional infonnation necessary for our further consideration of these itens consist, generally, of the following:

h 1.

In three of your requests (1.H. l.I. l.J) you state that you are "considering" the use of fire barriers as an alternate method of satisfying Section III(G) of Appendix R.

Your requests cannot be favorably acted upon until you have outlined, justified, and coamitted to a specific course of action meeting the intent of this section.

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Detailed technical justification will be required regarding the characteristics of certain fire barriers such as marinite board (1.E.1.F.1.H.1.I.1.J) and the fire risistive materials mentioned in 1.C.

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You must specifically justify not installing fixed suppression systems in areas containing redundant trains (1.C.1.E.1.F.

1.I.1.J).

Seven (7) itans (1A,10,1G, 2, 3, 4, 5 of Attachment B) are con-i sidsred by the staff to be unneesssary requests since these itens have either been resolved in previously issued safety evaluations (2, 3, 4, 5) or will be implemented in accordance with the sc'tedule of your alternate safe shutdown system under 50.48(d). Therefore, these itens are denied.

The normal fee schedules apply to these requests. Since you submitted a request regarding plans, schedules and fourteen (14) specific items (BECo 81-52 and 81-59), a class IV fee is appropriate. Please reference this fee in all further correspondence on the renaining items of these letters.

Sincerely.

Or(inal squad by 5.8.Bunten Harold R. Denton, Director Office of Nuclear Reactor Regulation cc: See next page Distribution:

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Detailed technical justification will be required regarding the characteristics of certain first barriers such as perinite board (1.E.1.F.1.H.1.I.1.J) and the fire resisti materials mentioned in 1.C.

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You must specifically justify failure to install f xed suppression systems in areas containing redundan trains

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1. E. 1. F. 1. I. 1. J ).

Seven (7) items (1A, ID,1G, 2, 3, 4, 5 of Attach t B) are con-sidered by the staff to be unnecessary requests nce these items have either been resolved in previously issued sdfety evaluations (2, 3, 4, 5) or will be implemented in accordance with the schedule of your alternate safe shut 4wn system under 5p.48(d). Therefore, these items art denied.

The nomal fee schedules apply to these requests Since you submitted a request regarding plans, schedules and fourteen ji14) specific items (BECo 81-52 and 81-59), a class IV fee is appropriate (

Please reference this fee in all further correspondence on the remaining /itens of these letters.

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Docket No. 50-293 Mr. A. Victor Morist, Manager Nuclear Operations Support Dept.

Boston Edison Company M/C Nuclear

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800 Boylston Street Boston, Massachusetts 02199

Dear Mr. Morisi:

j Pilgrim I - Fire Protection Exemption Requests fme('10 CFR 50 Appendix R RE:

By letter dated Man:h 9,1981 (BEco 81-52) The Bostad Edison Company (BEco) requested an exemption from the schedule requirements of 50.48(c), regarding implerantation of Section III(G) of Appendix R to 10 CFR 50. BEco requested relief from the submission dates for plans, schedsles, design information, exemption requests, and the implementation daterfor plant modifications.

Approval of the BEco proposal would extend all,such dates by approximately 7 1/2 months.

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In addition, by letter dated March 18, 19811(BEco 81-59), BEco requested that such exemptions are justified on they/ rule.

fourteen (14) specific exemptions from the Boston Edison believes ground that the fire protection i

measures pmscribed in Section III(G) wonld not, if installed at Pilgrim,

" provide substantial, additional protection which is required for ths public health and safety."

/

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Our decision regarding your March 9/letm-is not yet finalized. We expect a final decision by mid-May 1981. /Howewr, we have completed a preliminary review of the March 18 exemption requests, and discussed the results with your staff in telephone conversa61ons on April 8, 9, and 17,1981. Wg have detensined that one (1) item, M of Attachment B to BEco 81-59) has a sound technical basis which warran further staff review, and, under the provisions of 50.48(c)(6), the schedule uirements of paragraph (c? will be tolled pending our final action on 1r request. Six (6) items 41C, IE,1F,1H, II, and 1J) are denied due the submission of insufficient information.

The additional information ecessary for our further ennsideratior, of these items consist, generally, f the following:

I 1.

In three of your quests (1.H.1.I.1.J) you state that you are "considering, the use of fim barriers as an alternate method of satisffring Section III(G) of Appendix R.

Your requests cannot be acted /upon until you have outlined, justified, and comunitted to a specific course of action meeting the intent of this section.

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i Docket No. 50-293 Mr. A. Victor Morist, Manager Nuclear Operations Support Dept.

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Boston Edison Company

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M/C Nuclear 800 Boylston Street Boston, Massachusetts 02199

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Dear Mr. Moris1:

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RE: Pilgrim I - Fire Protection Exemption Requests from 10 CFR 50 Appendix R i

By letter dated March 9, 1981 (BEco. 81-52), The Boston Edison Company (BEco) requested an examption from the schedule requirements of 50.48(c), regarding implementation of Section III(G) of Appendix Ri to 10 CFR 50. BEco requested relief from the submission dates for plans, schedules, design infonsation, exemption requests, and the implementation dates for plant modifications.

Approval of the BEco pwal would extend,all such dates by approximately 7 1/2 months.

/

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In addition, b 18, 1981 (BEco 81-59), BEco requested fourteen (14) y letter dated March specific exemptions fme.the rule. Boston Edison believes that such exemptions are justified on the gmund that the fire protection measures pmscribed in Section III(G)/would not, if installed at Pilgrim,

" provide substantial, additional protection which is required for the public health and safety."

Our decision regarding your March.9 letter is not yet finalized. We expect a final decision by mid-May 1981/ However, we have completed a, preliminary review of the March 18 exemptiory' requests, and discussed the results with your staff in telephone conversations on April 8, 9, and 17,1981. We have detemined that one (1) ites, of Attachment B to BEco 81G59) has a sound technical basis which warrant further staff review, and, under tha provisions of 50.48(c)(6), the schedul irements of paragraph (c) will be tolled pending our final action on r request. Sfx (6) items (1C, lE 1F, lh>

lI, and 1J) are denied due o the submission of insufficient infonnation.

The additional infonnati necessary for our further consideration of these items consist, generally of the following:

1.

Establishment BEco cosenitments regarding their " considered" i

alternate ma to satisfy the requirements.

(1H,11,1J) 2.

Justificati regarding the characteristics of certain fire barriers -

rinite board for use as a one hour barrier (1E,1F,

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Addressing the installation or exemption request for fixed suppmssion systems in areas containing redundant trains.

(lC,lE,IF,II,1J)

Seven (7) itans (l A,10,1G, 2, 3, 4, 5 of Attachment 91 are con-sidered by the staff to be unnecessary requests since>/ hese items t

have either been resolved in previously issued safety evaluations (2, 3, 4, 5) or will be implemented in accordance with the schedule of your alternate safe shutdown system under 50.fe(d).

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u The normal fee schedules apply to these requests. Since you submitted a request regarding plans, schedules and fourteen (14) specific items (BECo 81-52 and 81-59), a class IV fee is appmpriate../Please reference this fee in all further correspondence on the remaining items of these latters.

Sincerely,

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Harold R/Denton, Director Office,of Nuclear Reactor Regulation l

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Dear Mr. Morisi:

RE:

Pilgrim I - Fire Protection Exemption Rpests from 10 CFR 50 Appendix R By letter dated March 9,1981 (BEco. 81-52)[The Boston Edison Company (BEco) requested an exemption from the schedule requirements of 50.43(c), regarding implementation of Section III (G) of Appendix R to 10 CFR 50. BECo. request-ed relief from the submission dated for plans, schedules, design infomation, i

exemption requests, and the implementatfon dates for plant modifications. Ap-proval of the BEtof pmposal would exte ' all such dates by approximately 71/2 months.

In addition, by/1;.tter dated March

,1981 (BECo 81-59), BECo requested four-teen (14) specific exemptions from he rule.

Our decision regarding your March letter is not yet finalized. We expect a final decision by mid4 fay,1981. However, we have completed a preliminary review of the March 18 exempti requests, and discussed the results with your staff in telephone conversations on April 8 and 9,1981. We have detemined that three (3) items (lA,18, nd 1G of Attachment B to BECo 81-59) warrant further staff review, and, un er the provisions of 50.48(c}(6), the schedule requirements of paragraph (c' will be tolled pending our final action on your requests. Seven (7) items SC,1D, lE,17,1H, II, and lJ) are rejected due to the submission of insuff cient information. The additional infomation necessary for our further nsideration of these itaus consist, generally, of the following:

1.

Establishment BEco comitments regarding their " considered" altemate met to satisfy the requireinents. (lH, II, lJ) 2 Justificati regarding the characteristics of certain fire barriers -

marinite ed for use as a one hour barrier. (lE, IF,1H, II, lJ) and the fi resistive raterials of item 1C.

3.

Address g the insta~1ation or exemption request for fixed suppression

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systems in areas containing redundant trains.

(1C,10,IE,IF, II,IJ)

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Four (4) items (2, 3, 4, 5 of Attachment B) are consNered by the staff to be unnecessary requests since these itens have been resolved in pmviously issued safety evaluations. There-fore, these items are rejected.

/

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The normal fee schedules apply to these requests. for each item reviewed by the staff (items 1A,1B, and 1G) a Class III fee should be submitted.

If you provide the aforement.idnad additional information for the seven items (i.e., more than 3 items) a Class IV fee shoulcVbe submitted for the group.

Sincerely

/

Harold R. Denton, Director Offi_ce of Nuclear Reactor Regulation cc: See next page

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May 4, 1981 Docket No. 50-293 Mr. A. Victor Morisi, Manager Nuclear Operations Support Dept.

Boston Edison Company M/C Nuclear 800 Boylston Street Boston, Massachusetts 02199

Dear Mr. Moris1:

E.

'ilgrim I'- Fire Protection Exemption Requests from 10 CFR 50 Appendix R By letter dated March 9,1981 (BEco 81-521, the Boston Edison Company (BECo) requested an exemption from the schedule requirements of 50.48(ci, regarding implementation of Section III(G1 of Appendix R to 10 CFR 50. BEco requested relief from the submission dates for plans, schedules, design information, exemption requests, and the implementation dates for plant modifications.

Approval of the BECo proposal would extend all such dates by approximately 7 1/2 months.

In addition, by letter dated March 18,1981 (.BECo 81-59), BEco requested fourteen (14) specific exemptions from the rule. Boston Edison believes that such exemptions are justified on the ground that the fire protection measures prescribed in Section III(G) would not, if installed at Pilgrim,

" provide substantial, additional protection which is required for the public health and safety."

Our review of frour March 9 letter is not yet complete. We expect to reach a final decision by mid-May 1981. However, we have completed a preliminary review of the March 18 exemption requests, and discussed the results with your staff in telephone conversations on April 8, 9, and 17,1981. We have determined that one (1) item,18 of Attachment B to BECo 81-59). has a sound technical basis which warrants further staff review, and, under the provisiens of 50.48(c)(6), the schedule requirements of paragraph (c) will be tolled pending our final action on your request concerning item 18. Six (6) items (1C, IE,1F,1H, II, and 1J) are denied due to the submission of insufficient infor nation. The additional information necessary for our further consideration of these items consist, generally, of the following:

1.

In three of your requests (1.H. l.I. l.J) you state that you are "considering" the use of fire barriers as an alternate method of satisfying Section III(G) of Appendix R.

Your requests cannot be favorably acted upon until you have outlined, justified, and comitted to a specific course of action meeting the intent of this section.

. /

2.

Detailed technical justification will be required regarding the characteristics of certain fire barriers such as marinite board (1.E.1.F, l.H. l.I. l.J) and the fire resistive materials mentioned in 1.C.

3.

You must specifically justify not installing fixed suppression systems in areas containing redundant trains (1.C,1.E.1.F.

1.I,l.J).

Seven (7). Items OA,10,1G, 2, 3, 4, 5 of Attachment 31 are con-sidered by the staff to be unnecessary requests since these items have either been resolved in previously issued safety evaluations (2, 3, 4, 5) or will be implemented in accordance with the schedule of your altemate safe shutdown system under 50.48(d). Therefore, these items are denied.

The nonnal fee schedules apply to these requests. Since you submitted a 81-52 and 81-59)g plans, schedules and fourteen 04) speciffe items (BECo request regardin

, a class IV fee is apprcpriate. Please reference this fee in all further correspondence on the remaining items of these letters.

Sincerely, s

Harold R. Centon, Director Office of Nuclear Reactor Regulation cc:

See next page t

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Mr. A. Victor Morist Boston Edison Company

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cc:

Mr. Richard D. Machon U. S. Environmental Protection Pilgrim Station Manager Agency Boston Edison Company Region I Office RF0 #1, Rocky Hill Road ATTN:

EIS COORDINATOR Plymouth, Massachusetts 02360 JFK Federal Building Boston, Massachusetts 02203 Energy Facilities Siting Council 14th. Flour One Asburton Place.

Boston ' Massachusetts 02108 Henry Herrmann, Esquire Massachusetts Wildlife Federation 151 Tremont Street Boston, Massachusetts 02111 Plymouth Public Library North Street Plymouth, Massachusetts 02360 Massachusetts Departnent of Public Health ATTN: Commissioner of Public Health 500 Washington Street Boston, Massachusetts 02111 Water Quality & Environmental Commissioner Department of Environmental Quality Engineering 100 Camoridge Street Bosten, Massachusetts 02202 Mr. David F. Tarantino Chairman, Board of Selectmen 11 Lincoln Street Plymouth, Massachusetts 02360 Director, Criteria and Standards Division

' ' Office of Radiation Programs (ANR-460)

U. S. Enviramnental Protection Agency Washington, D. C.

20460 Resident In:pector c/o U. S. NRC P. O. Box 267 Plymouth, Massachusetts 02360

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