ML20004B830
| ML20004B830 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 05/27/1981 |
| From: | Stolz J Office of Nuclear Reactor Regulation |
| To: | Bauer E PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| References | |
| NUDOCS 8106010109 | |
| Download: ML20004B830 (4) | |
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UNITED STATES y
e( 3 g NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20$55
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L c'g "ay 27, 1981 Dockets Nos 50-277 and 1-278 Ti ECU1 Mr. Edward G. Broer, Jr.
BI MAY 2 81981
- c Vice Presidea' J General Counsel Philadelphia c.sectric Company
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s 2301 Market Street 50=4m Philadelphia, Pennsylvania 19101
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Dear Mr. Bauer:
c By letter dated March 20, 1981 you requested an exemption to 10 CFR 50 Part 48(c)(1) for the Peach Bottom Atomic Power Station Units 2 and 3.
Your request related to a delay in procuring equipment for the Station Fire Brigade.
Part 48(c)(1) of the Rule relates solely to administrative controls, nanpower changes and training. The equipnent you are pro-curing, according to 10 CFR 50 Part 4S(c)(2), is not needed until nine months after the effective date of the Rule; therefore,'no exemption is needed as it appears from your letter you will have the equipment before the nine months are up.
By letter dated July 3,1979 you provided infonnation on an alternate
. safe shutdown system.
Enclosure No.1 provides our Interim Safety Evalua-tion of your submittal. Our Final Safety Evaluation will be. issued after our review of your submittal of the design description required by 10 CFR 50.48(c)(5).
You are requested to resolve the concerns raised in the enclosed evaluation in that submittal. The schedule.,nequirements for your response will be specified in our response to your March 20, 1981 request for exemption from the submittal date requirement of 10 CFR 50.48 (c)(5).
Sincerely,
/
Jo F. Stolz, Chief /
Op rating Reactors Branch #4
. vision of Licensing Enclos ure:
1.
Interim Safety Evaluation cc w/ enclosure:
See next page 4
9 8106010jd
Philadelphia Electric Company ccw/ enclosure (s):
Eugene J. Bradley U. S. Environmental Protection Agency Philadelphia Electric Company Region III Office Assistant General Counsel ATTN: EIS COORDINATOR 2301 Market Street Curtis Building (Sixth Floor)
Philadelphia, Pennsylvania 19101 6tn and Walnut Streets Philadelphia, Pennsylvania 19106 Troy B. Conner, Jr.
1747 Pennsylvania Avenue, N.W.
M. J. Cooney, Superintendent Washington, D. C.
20006 Generation Division - Nuclear Philadelphia Electric Company Raymond L. Hovis, Esq.
2301 Market Street 35 South Duke Street Philadelphia, Pennsylvania 19101 York, Pennsylvania 17401 Government Publications Section Warren K. Rich, Esq.
State Library of Pennsylvania Assistant Attorney General Education Building Department of Natural Resources Commonwealth and Walnut Streets Annapolis, Maryland 21401 Harrisburg, Pennsylvania 17126 Philadelphia Electric Company ATTN: Mr. W. T. Ullrich Peach Bottom Atomic Power Statiuh Mr. R. A. Heiss, Coordinator Delta, Pennsylvania 1*i314 Pennsylvania State Clearinghouse Governor's Office of State Planning Albert R. Steel, Chairman and Development Board of Supervisors P. O. Box 1323 Peach Bottom Township Harrisburg, Pennsylvania 17120 R. D. !1 Delta, Pennsylvania 17314 Curt Cowgill U.S. Nuclear Regulatory Commission Office of Inspection and Enforcement Peach Bottom Atomic Power Station P. O. Box 399 Delta, Pennsylvania 17314 I
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5/27/81 INTERIM SAFETY EVALUATION
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POST FIRE SHUTDOWN CAPABILITY PEACH BOTTOM 2 & 3 NUCLEAR POWER STATION Section 3.2.1 of the SER, Safe Shutdown Analysis, states that the licensee's analysis would address the post fire capability to achieve and maintain both hot and cold shutdown and consider the effects of loss of off-site power on this capability.
By letter dated July 3,1979, the licensee addressed these concerns in an enclosure entitled " Supplement to the Peach Bottom Safe Shutdown Analysis" dated June 1979.
The licensee has selected two methods of bringing the plant to a safe hot shutdown condition. The first method utilizes the high pressure coolant injection system, the residual heat removal system, and the high pressure service water system. The second method utilizes the main steam relief valves, the core spray system, the residual heat removal system, and the high pressure service water system. These methods were chosen because of their inherent physical separation, redundancy, on site power supplied and minimal equipment requirements. The licensee has undertaken to demonstrate the avail-ability of at least one of these method: during the most extreme postulated fire; however, only the capability of achieving a hot shutdown condition fol-lowing a fire in the cable spreading room, primary containment, general areas in the reactor building and in the area of the remote shutdown panel is des-cribed.
Such capability for the balance of the fire areas in the plant has not been described and these methods have not been shown to be independent of these fire areas.
The normal shutdown method is used to achieve cold shutdown once hot shutdown conditions are achieved. This method utilizes the residual heat re-moval system and the high pressure service water system. The post fire cap-ability for bringing the plant to cold shutdown has been analyzed for all fire areas.
We have evaluated the post fire shutdown capability using NRC guidelines in " Staff Position Safe Shutdown Capability" dated June 19, 1979 and HRC re-quirements in Section III L of Appendix R to 10 CFR Part 50. We have found l
that:
l 1.
The post fire capability to achieve hot shutdown conditions by at l
1 east one method has not been shown to be free of fire damage for any areas of the plant.
2.
The post fire shutdown capability depends on fire protection measures in the following areas: Primary Containment, Reactor Building - 135 ft., Reactor Building - 155 ft., Remote Shutdown Panel Area, Cable Spreading Room an9 Fire Zones Sc, 24, 78A,108, 135,144, and 146. Al n, Fire Zones 32, 72A, 78A, 78H,108,134, 143, and 146. These protection faatures should meet the NRC requirements of Section III G of Appendix R to 10 CFR Part 50.
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3.
The post fire process monitoring function has not been shown to be capable of providing direct readings of the process variables neces-sary to perform and control shutdown functions.
4.
The post fire support functions have not been shown to be capable of providing the auxiliary systems such as process cooling or lubrica-tion necessary to permit the operation of equipment used for shut-down functions.
5.
The post fire shutdown capability has not been shown to be isolated from associated circuits so that fire damage to associated circuits in a fire area may prevent the operation of shutdown equipment.
6.
In some areas,. fire damage to systems necessary to achieve co7d shutdown must be repaired to achieve cold shutdown within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after the fire, however, repair procedures are not in effect and materials are not on site.
7.
In many fire areas, the cables necessary for shutdown have not been located; therefore, fire damage to cables of both shutdown methods has not been precluded.
Based on the above findings, we conclude that the post fire shutdown capability does not meet NRC guidelines and requirements. We recommend that a dedicated shutdown system be installed that meets the requirements of Section III G of Appendix R to 10 CFR Part 50, taking into consideration all of the above listed concerns.
Dated: fiay 27,1981 s
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