ML19350B765
| ML19350B765 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 03/09/1981 |
| From: | Morisi A BOSTON EDISON CO. |
| To: | Hendrie J NRC COMMISSION (OCM) |
| References | |
| 81-52, NUDOCS 8103230654 | |
| Download: ML19350B765 (7) | |
Text
,
g.
COSTON EricO N COMPANY an===4a. ornes. Soo movseron eTeser SeeTON. MassasmustTTe D2199 A. V. M O Rt SI MANAGER NUCLEAR OPERATION 5 SUPPORT DEPARTMENT N:=
March 9,1981 BECo. Ltr. #81-52 Joseph M. Hendrie Chairman U.-S.
Nuclear Regulatory Commission Washington, D.C.
20555
Subject:
Request for Exempi. ion from Implementation Schedule for Commission's Fire Protection Regulations (10 CFR Part 50, Appendix R)
References:
(a)
License No. DPR-35 (Docket No. 50-293)
- (b)
US NRC letter to Boston Edison Company dated November 24, 1980 (c) 10 CFR Section 50.48 and Appendix R
Dear Chairman Hendrie:
On November 19, 1980 the Nuclear Regulatory Commission promulgated amendments to 10 CFR Part 50 regarding fire pro-tection programs for operating nuclear power plants.
45 Fed. Reg. 76602.
Those amendments, which became effective on February 17, 1981, contained a number of complex require-ments for actions to be taken by p'. ant operators following the effective date of the rule.
Since the issuance of the rule Boston Edison Company has reviewed those requirements and has initiated an extensive action plan to meet each re-quirement in as expeditious a manner as feasible. A copy of Boston Edison Company's action plan is attached.
- However, one of those requirements,Section III(G) of Appendix R (and f
Section III(L) to the extent governing the mode of imple-0 01 menting Section III(G)), because of its inherent complexity 3
and due to the short time permitted for committing to a manner of compliance, has causco Boston Edison considerable 7/
difficulty in determining an appropriate response. Con-sequently, for the reasons set forth more fully below, we g/m D sh submit that an exemption from the schedular requirements i
I governing the implementation of Section III(G) of Appendix R g y g g 5y for Boston Edison's Pilgrim Nuclear Power Station is necessary l
end appropriate.
3C t
81032 30 h6f g
Cc; TON E! CON COMPANY l
March
- 9. 1981 Page Two Therefore, pursuant to 10 CFR 550.12(a) and 10 CFR 550.48(c)(6), Boston Edison Company hereby petitions the Commission for an exemption to the schedular provisions of 10 CFR 550.48(c) governing the implementation of Section III(G) of Appendix R to CFR Part 50.
The specific require-ments from which exemption is sought at this time include 10 CFR 550.48(c)(2), (3), (4), (5) and (6) both insofar as those paragraphs establish dates for the submiss 4ca of plans, schedules, exemption requests or de*ign descriptions of modifications required to meet the provisions of Section III(G) of Appendix R and insofar as those paragraphs establish implementation dates for such modifications.
Specifically, we request that the March 19, 1981 deadline established by 10 CFR 550.48(c)(5) be extended to October 31, 1981, on the basis described below.
Other implementation dates would be established based upon the October 31 submittal.
The essential reason for this request is that insuf ficient time is allotted by 10 CFR 550.48(c) for Boston Edison to investigate adequately the requirements of Section III(G) of Appendix R or to determine the optimum manner of meeting such requirements.
It should be noted that Boston Edison does not at this time-seek an exemption from the entire Section III(G) or from particular substantive provisions of Section III(G) as applied to particular plant areas.
It is probable, however, that Boston Edison will have specific substantive exemption requests as the reviews and analyses are completed for all plant areas.
As basis for this exemption request, it is Boston Edison's primary concern that modifications made to Pilgrim in the interest of reducing fire safety hazards be accomplished in a thorough, comprehensive. manner and that the resources allocated for such safety improvements be optimized.
Our initial review of Section III(G) indicates that there are several design modification options which may satisfy the requirements of Section III(G) for Pilgrim Station.
Each of those options is being extensively evaluated to ascertain design and implementation feasibility as well as the impact upon resource and manpower availability.
The results of those evaluations will be assiduously reviewed in order to achieve an integrated design which will best enhance plant safety while avoiding unnecessary costs or plant outage cime.
We submit that unnecessary forced haste for response by March 19, 1981 would necessarily preclude the evaluation of all options whi.ch might provide maximum protection against plant fires and other common mode type of events.
.-~J--
i...
a
.CDOTIN E'; CON COMPANY March 9, 1981 Page Three 2
Because of the large subs 5;ansive gains Boston Edison has,already made in reducing f ura hazards over the last few years, we submit' that the extension o'i a response time to permit full evaluation of each option is thoroughly justi-fled. The several hardware and prccedural modifications we have made in our fire protection program to date have al-ready cost in excess of $6,000,000 and have substantially reduced the potential for fires in critical areas, added fire resistant protection to critical equipment, and upgraded and expanded fire detection and suppression systems. The implementation of administrative procedures, including addi-tional training, institution of fire prevention and response procedures, establishment of a trained fire brigade, addition of a staff Fire Protection Engineer coupled with a strong management commitment to fire protection have also sub-stantially reduced potential fire hazards at Pilgrim Station.
Boston Edison submits that the requested exemption, resulting solely in an extension of time to adequately evaluate options, can be granted without compromising plant safety
- and, if granted, may well lead to safety improvements which otherwise
~
would not be considered adequately.
In the following paragraphs, Boston Edison briefly discusses the status of its efforts with respect to Section III(G) and sets forth a reasonable schedule for achieving compliance with those requirements.
Basically, the purpose of Section III(G), Fire Protection of Safe Shutdown Capability, is to protect the plant's safe shutdown capability by ensuring that at least one means of achieving and maintaining a safe shutd r, condition will l
remain available during and after any postulated fire within i
the plant.
Prior to determinir.g which of the options pro-l vided in Section III(G) will be satisf actory for Pilgrim
)
Station, an initial comprehensive analysis must be performed for all safety related circuits and all associated non-I safety related circuits of each of Pilgrim's 64 fire zones.
This analysis will identify the critical circuits, equip-ment, and fire zones and will assess the potential adverse impact the loss of each may have on the plant's ability to achieve and maintain hot shutdown within the Section III(G) l l
criteria.
l We would note that as of December 15, 1980 the NRC l
Staff had issued a Safety Evaluation Report which essentially left the safe shutdown analysis requiref by Section III(G) l as the only open item for Pilgrim Station.
i b
CQ5 TON EotEON COMPANY March 9, 1981 Page Four
=:
Boston Edison has completed the extensive review of the safety related circuits; however, the similar review of the nonisafety related associated circuits is currently underway and is not projected to be completed until March 25, 1981. '
This effort has been complicated by the lack of adequate guidance as to the precise scope of the associated circuits requirement.
When the final results of these reviews are available, a fire zone analysis will be performed to identify the critical fire zones and any modifications required.
The projected completion date for this effort is June 1, 1981.
With respect to Section III(G)(2), 3 Hour and 1 Hour Fire Barriers, a paramount difficulty has been the lack of specific criteria for qualifying fire barriers for a par-ticular rating to protect raceways.
In anticipation of performing qualification tests prior to utilizing fire barriers, Boston Edison Company has retained an architectual/
engineering firm to evaluate available industry-accepted fire barrier materials and to develop qualifying criteria for typical Pilgrim Station raceway configurations.
The magnitude of this task makes it a major contributor to our schedule planning.
This evaluation is currently 30% complete with a projected end date of August 1,1981.
With respect to the provisions of alternate shutdown capability as required by Section III(G)(3), a thorough walkdown is required by each of the fire zones determined to be critical in order to identify possible alternate paths for alternate shutdown means for critical circu its.
In anticipation of possibly utilizing this option, Boston Edison Company has initiated a walkdown of those plant areas which are accessible during normal operation.
This will be completed by July, 1981.
A similar walkdown of those areas which are inaccessible during normal plant operation (e.g.,
high radiation areas) can be performed only during a major outage and is presently schedulad to begin coincident with the 1931 refueling outage commencing in September, 1981.
Another of the evaluations being performed by Boston Edison Company involves the consideration of a dedicated shutdown system.
We believe that the complexity and magnitude of such systems requires care ful evaluation of alternatives, selection criteria, reliabil; y and risk reduction, capital cost, and operating impact.
The time allowed for a thorough investigation is far too restrictive and will of necessity result in elimination of this option from consideration i
Crrrow roisaw company March 9,1981 Page Five
~
since insufficiant information has been prepared in the
- g brief period ali wed for reasonable analysis and responsible
'r management action.
Furthermore, we believe that several alternatives to a dedicated system design may be beneficial for reducing plant risk from other common mode and.clant trans.ient events These benefits when combined with the benefits from improved fire mitigatien capability could justify an otherwise economically unjustifiable system.
Only a thorough program of problem definition, specification of criteria and development and evaluation of alternatives can be a valid basis for installing a potentially multi-million dollar system.
To accc=plish this adequate time is needed.
We have developed and at this time are implementing an evaluation plan for an independent shutdown system.
This plan is in itself resource intensive and will require either 4 months for completion if only response to fire protection is considered or 8 =cnths if a more ecmprehensive total plant risk with respect to other common mode events is attempted.
Therefore, we are requesting (1) an extension of the response time for an independent shutdown system design commitment until September 30, 1981
-at which time we believa that a thorough study and recommended approach can ha outlined for Pilgrim Station and (2) an extension up to October 31, 1981 for the filing required under 10 CFR 550.4 3(c) ( 5).
At that tine we will also be prepared to discuss an implenentation schedule for reccmmended
=
modifications as well as any further specific exempticas er extensions which may be warranted.
In conclusion, we wish to emphasize that basically all that we are requesting is additional time to implement the requirements cf Section III(G).
Because of the manner in which Section 50.4S(c) establishes time periods for such from i=plementation, we believe that an exemption request the schedular provisions of that section is the appropriate manner to make this request.
This request is authcrized by 10 CFR 550.43(c)(6), will not endanger life and property and, for the reasons we have given, is fully in the public interest.
If particular substantive exemptions for specific plant areas are eventually required as a result of further analyses, such exemptions will be requesced separately.
We t
believe this exe=ption request is justified and is clearly l
in the public_ interest -- in essence 3csten Edisen mere y seeks the time to do the job right.
we u--
t" t
F
.....,......... '. *.* T-}. *:;: ':, :,
- - i ~ :,
_.~
~
- s
.:C3CJon Eam?Lu ca eAnr Ma: ch 9,1981 Pagt Six Should further 'information be required, please let us know.
++:.
==-
Very truly yours, A. V. Morisi AVM/mg ATTACHMENTS:
APPENDIX R, IIIG/IIIL TASK FLGi CHART CC:
Messrs. John F. Ahearne Peter A. Bradford Victor Gilinsky Samuel J. Chilk Harold R. Denton Thomas A.
Ippolito 7
W "-
m c
r
--