ML20031F769
| ML20031F769 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 10/14/1981 |
| From: | Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Eisenhut J Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8110200406 | |
| Download: ML20031F769 (4) | |
Text
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O PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 y
1881 1981 PHILADELPHI A. PA.19101 JOSEPH W. G ALLAGHER s6setnic e=oc uct o capanrusur October 14, 1981 Docket Nos. 50-277 50-278 Mr. Darrell G.
Eisenhut, Director A i Ef)D g
Division of Licensing g
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US Nuclear Regulatory Commission
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Washington, DC 20555 J-
SUBJECT:
Implementation of Appendix R f
OCT 101981"
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Fire Protection Requirements I
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for Peach Bottom Atomic Power cw Station
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Dear Mr. Eisenhut:
J3' This letter requests exceptions to the implementation schedule identified in 10CFR 50.48 for the Peach Bottom Atomic Power Station and thereby modifies the commitments made in a letter dated March 20, 1981 (S.
L.
Daltroff, Philadelphia Electric Company to D.
G.
Eisenhut, NRC).
Additionally, we are proposing a revision to a commitment in the refer. 'ced letter that is consistent with the provisions of 10CFR 50, appendix R.
The schedule adjustments requested involve some of the modifications required by 10CFR 50.48, as well as the commitments in the March 20, 1981 letter referenced above, to be implemented by November 19, 1981.
Completion of the modifications are contingent on many factors, including the timely delivery of equipment and material utilized in the installation.
We propose a revised completion date of January 19, 1981 for the subject modifications, provided the necessary equipment is delivered by November 2, 1981.
We will advise the Commission of any slippage in this proposed schedule resulting from procurement delays beyond November 2, 1981.
The revised schedule would apply to the following modifications:
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8110200406 811014 DR ADOCK 05000277 PDR
Mr. Darrell G.
Eisenhut, Director Page 2 1.
Sprinkler systems in the recirculation pump M-G set lube oil pump rooms, and in the M-G set rooms.
2.
Carly warning detection systems (smoke detectors) in the areas discussed in the March 20, 1981 letter.
3.
Breathing air bottle charging system.
All of the modifications mentioned above are currently in
- progress, However, a short extension in the schedule has been necessitsueu by delays in equipment procurement and manpower restrairsts resulting from extended outage activities, and the proliferation of plant modifications required by the NRC.
A typical example of the impact of procurement delays on the completion of mandated modifications is the failure of the supplier to provide prompt delivery of the automatic coding transmitters required for completion of the smoke detector system (item 2 above).
This component is not expected to arrive until late October, delaying completion of these modifications in spite of the fact that most of the detector sensors and cables will be in place within schedule.
Considering the schedule delays, we are proposing the following compensatory measure:
patrol the cable spreading room, M-G set room, M-G set lube oil room, 13 kV switchgear area, Reactor Building 135' elevation, Reactor Building 165' elevation, and Radwaste Building (116', 135', 165' general area) once per shift until the smoke detector and suppression system modifications pertaining to these areas are completed.
This commitment would become effective on November 20, 1981.
Patrol of other areas is not deemed to be necessary since they contain only low to moderate levels of combustibles, and many methods of safe shutdown remain following the loss of all equipment and cable in the specific area, or a suppression or smoke detector system presently protects the area.
This conclusion is based on the information presented in the Fire Protection Program Report, Peach Bottom Atomic Power Station Units 2 and 3, dated March, 1977.
Electrical cable represents the primary source of combustibles in these areas.
The fire retardant characteristics of these cables, as well as the lack of combustibles necessary for an exposure fire, provide confidence that fire damage in these areas is a very low probability event.
Additionally, administrative procedures have been improved to reduce transient combustibles and ignition source hazards.
The presence of personnel in or near the control room offices
Mr. Darrell G. Eisenhut, Director Page 3 precludes the need for additional compensatory measures in these areas.
The remainder of this letter deals with a proposed revision to a commitment made in the March 20, 1981 letter.
The NRC requirement, as we understand it, is as follows:
Correspondence dated November 24, 1980 (D.G. Eisenhut, NRC to All Power Rer.ctor Licensees) identified mechanical and electrical penetration seals through fire barriers as an open item for Peach Bottom.
It further stated that compliance with the electrical penetration seal design criteria specified by 10CFR 50, appendix R, section III M, and the fire resistance criteria for mechanical penetration seals identified in section III G was necessary to resolve this issue.
The schedule requirement (10CFR 50.48) for ensuring adequate fire barrier protection between alternative shutdown systems is 30 months after NRC approval of the licensees proposed safe shutdown analysis.
In the March 20, 1981 letter, we proposed a March 1, 1984 schedule for completing the alternative shutdown system which conforms with the intent of the NRC's 30 month schedule.
I On page 11, item E, of the March 20, 1981 letter, we proposed to examine and upgrade the fire barrier electrical penetration seals to meet the appendix R design criteria by November 19, 1981.
We neglected to propose a schedule for upgrading the mechanical penetration seals.
In lieu of the commitment made in our March 20, 1981 letter, we propose to substitute the following commitment that addresses e
both electrical and mechanical penetration seals, and integrates the penetration seal issue with the fire barrier requirements for safe shutdown capabilities.
"The electrical and mechanical penetration seals on those barriers whose integrity is required to ensure safe shutdown capability will be upgraded to meet the design criteria identified in 10CFR 50, appendix R, sections III G and III M.
The upgrade of the seals is currently in progress and will continue at a pace dependent on the availability of qualified l
seal designs, and identification of vital barriers by the safe shutdown analysis.
Completion of the upgrade effort will be consistent with the schedule for implementing the alternative shutdown modifications (March 1, 1984)."
The revised commitment conforms with the NRC's requests in the November 24, 1980 letter referenced above, the design criteria identified in 10CFR 50, appendix R, section III G and III M, and the schedule required in 10CFR 50.48.
We welcome further discussion of these matters should you need additional
1 Mr. Darrell G.
Eisenhut, Director Page 4 information, and we would appreciate your prompt attention regarding the exceptions requested to the schedule in 10CFR 50.48 for selected fire proi.ection modifications.
Very truly yours,
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