ML20062K041

Forwards Safety Evaluation of Remaining Open Items of Amend 35 to DPR-35 Covering Fire Protection.Requests Tentative Schedule for Implementing Open Items

ML20062K041
Person / Time
Site:	Pilgrim
Issue date:	10/07/1980
From:	Ippolito T Office of Nuclear Reactor Regulation
To:	Morisi A BOSTON EDISON CO.
References
TAC-11077, NUDOCS 8011190499
Download: ML20062K041 (7)

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October 7, 1980 Docket No. 50-293 TAC #11077 i

Mr. A. Victor Morisi Boston Edison Company M/C MUCLEAR 800 Boylston Street Boston, Massachusetts 02199

Dear Mr. Morisi:

Enclosed is a safety evaluation on the remaining open items of Amendment 35 (to DPR-35, Fire Protection), We have discussed the results of this evalu-ation with your staff (telecon Williams / Keys, October 2,1980) and determined that additional information is required to complete the resolution of items 3.2.4 and 3.1.19. Therefore, these items have been deleted from this evalu-ation. BECo also stated that all items of Tables 3.1 and 3.2 of our December 21, 1978 letter, with the exception of 3.1.2, 3.1.18, 3.1.19, 3.2.1, 3.2.4 and 3.2.7 are completed and that item 3.1.2 would be completed by October 20, 1980. Items 3.1.18, 3.2.1 and 3.2.7 are under NRC review.

It was noted during our discussion that item 3.1.9 (Fire Barriers) had not been addressed. This item is now considered acceptable and is addressed in the safety evaluation.

You are requested to provide us with the additional information regarding items 3.1.19 and 3.2.4 as soon as possible. The proposed resolution of these items should include a tentative schedule for completion of installa-tio'n (3.1.19) or testing (3.2.4). A basis for continued interim operation should be included for those items which will exceed the deadlines imposed by Amendment 35. .

Sincerely, -

&e 1&

h ThomasIppolito,

' "dcXC Chief Operating Reactors Branch #2 Division of Licensing

Enclosure:

Safety Evaluation cc w/ enclosure:

See next page

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Mr. A. Victor Morisi '

Boston Edison Company October 7,1980 CC:

Mr. Richard D. Machon Pilgrim Station Manager Boston Edison Company RFD #1, Rocky Hill Road Plymouth, Massachusetts 02360 Henry Herrmann, Esquire Massachusetts Wildlife Federation 151 Tremont Street i Boston, Massachusetts 02111 Plymouth Public Library North Street Plymouth, Massachusetts 02360 Resident Inspector c/o U. S. NRC P. O. Box 867 Plymouth, Massachusetts 02360 O

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r ENCLOSURE 1 CHEMICAL ENGINEERING BRANCH / FIRE PROTECTION SECTION ADDITIONAL FIRE PROTECTION INFORMATION REVIEW PILGRIM NUCLEAR POWER STATION, UNIT NO. 1 00CKET NO. 50-293 Exoosed Steel Protection, Section 3.1.14 In the Fi. e Protection SER the concern was that unprotected steel structural memoers in many areas of the plant were not prctected adecuately, and could f ail if exposed to.the effects of fires. Such failure and structural collapse could affect the availability of safe shutdown systems.

By letters dated March 14, July 6, 1979 and September 11, 1980 the licensee preposed to provide three-hour rated fire protection for exposed structural

- steel in the needed areas of the plant. .These areas incluce the recirculat-ing pump motor-generator set room en elevation 51 feet, the cable spreadir.g room, switchgear rooms A and B, and major parts of the reacter building open areas on elevation 23 feet. The licensee proposed to acoly a fireproofing material in accorcance with basic cesigns snown by UL tests tc provice three-heer rated fire resistance for Deams and columns.

We find that tne licensee's proposal to protect the structural steel in the Orcoosed manner will provide adequate protection fer tne steel to prevent structural collapse from a fire and is, therefore, acce::able.

Self-Cc'ntainec Breathine Accaratus . Section 3.1.16

n the Fire Protection SER the concern was that insufficien reserve a.

su:cly was f rovided for the self-contained emergency brea:ning accaratus.

Ey letters dated July 6,1979 and Septemoer li,1980, the licensee stated inst the cascade air filling system has fcur (a) ASME Receivers in conjunction ai:n tne air compressor. With the com;ressor running, Storage Receivers are refilled as air is drawn from them providing completely fille: Receivers at all times. One bottle can be filled in 4-5 minutes frem eacn charging whip tc a total cf f our bottles at one time. The licensee.statad that they have '

resen-ly on site at least 20 scare bottles whicn revice ten men with two s:are bottles eacn (30 min. caoacity per bcttle),

ae find that :ne licensee's self-centained breathing a:paratus anc reserve air supply meet the guidelines cf Section D.4(h) cf Accencix ~ tc ETF 9.5-i an: is, -herefore, acceptable.

-munication Systems. Section 3.1.17

n the Fire Prctectier. SER the concern was that pertable racic ccamunications f cr fire brigade use during fire fighting were nc adecuate.

By le::er cated Sectemoer 11, 1930, tne licensee stated tha: :ne in-clant antenoa commumcation system is cacacie of communicating between the Transmitter /

Receiver anc the 3ase Radio Staticn (located in the guardhcuse) and pertable

units in all areas of the plant including the Control Room and centainment.

The physical routing of the communication antenna through the plant is such that it precludes the antenna from being subjected to a ccmmon fire with the fixed communication system.

Ne find that with the licensee's clarification, the portable communications systems meets the guidelines of Section D.5(d) of Appendix A to BTP 9.5-1 and is, therefore acceptable.

Penetration Seals, Section_3.1.19 DELETED (Response conti ngent on additional BECo information)

Testine Fire Detectors. Section 3.2.2 -

In the Fire Frctection SER, we requested that the licenses confirm the adequacy of new and existing fire detector sys ems by testine in plant areas where:

(1) ceiling heights are greater than 12 feet, (2) ceilinc cbstructions, such as joists and beams, are grsater than 2 inches d2ep (4 inches in the case of hea cetectcrs), or (3) ventilation rates are grea:er than 9.5 air char.ges per hour.

By letter dated February.29,1920, the licensee infccmed us that, with fcur ,

3:nar utilities, they have retained the ':UTE:H c:r;cra-icn to de.e.cc ar. in-situ test of smoke detectors. The licenses statec that further action en this task was centingent upon our response regarding an in-situ fire detectcr test.

The required methodolccy for an in-situ fire detectcr test to confirm the adecuac~v cf new and exIstinc fire ce:ector systems is beycnd the current state-cf $ne-art anc, therefore, the test cannot be cerferred at this time. ';e are of the cpinien that with acceptable bancn testing of sacke detectcrs and con-si 2 ring state-cf-the-art tec' iicues , the in-situ tests are not requirec.

Cable Combustibility, Section 3.2.4-1 DELETED (Response conti ngent on additional BECo information) 9 Suceression of Charcoal Fire in Aucmented Off-Gas System. Section 3.2.6 In the Fire Protection SER, it was our cencern that i enarcoal fire inside the augmented off-gas system (A0GS) charcoal vessels may result in an unaccept-able radioactivity release. -

By letters dated January 16, 1979 and July 5,1979, the licensee provided the' results of a cose calcuiation wnich demcnstrates that suen a fire would result in a cose of less than 5 rem.

Our evaluatien Of releases in the ACGS was given in our recor: entitied "Tecnnical Recert en Operating Experience with 3ciline Water React:r.Cffgas Systems" (NUREG-0442). We state that calculations using very censervative assumotions nave determined that no fire in :ne offgas system would result in radiation exocsures to memoers of :ne pu:lic above a small fraction cf the guidelines in 10 CFR Part 100 and theref:re tne AGG1 as it exists is acceptable.

C07 System Discharge Test, Section 3.2.8 In the Fire Protection SER, we requested the licensee te prohide calculations and. reference prototype testing of the C07 system in the Cable Spreading Room-to verify that a design concentratien of 50% is achieved in all parts of the room, and a concentration of 30% is achieveo within 1 minute and 30 seconds of actuation. If calculations and prototype testing are inconclusive, an in-situ discharge test should be performed.

By letter dated Fecruary 29, 1980, the licensee. expressed concern regarding the deleterious effects that are reported to nave occurrec to sensitive electronic / electric equipment and associated cabling in the Cable Spreading Rooms at other plants where full-scale CO2 discharge tests have taken place.

The licensee has requested that the test be performed during the next refuel-

- ing. We agree with the licensee that the CO2 system discharge test be scheduled to be perf ormed when the plant is in a refueling outage (scheduled f er fievember , 1981) .

Fire Barriers, Section 3.1.9 In the December 21, 1978 Safety Evaluation Report, it was our concern that the fire barriers enclosing the cable spreading room were inadequate since they contained an unrated fire door.

By letter dated March 30, 1979, the licensee proposed to upgrade the existing glass panel door in the cable areading room. Subsequently, the licensee indicated that the existing glass panel door will be replaced witn a 3-hour fire rated door.

The licensee's proposal to replace the existing glass panel door with a 3-hour fire rated door meets Section D.l.(j) of Appendix A to Branch

- Technical Position APCSB 9.5-1 and, therefore, is acceptable.

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ENCLOSURE 2 FIRE. PROTECTION REVIEW STATUS PILGRIM NUCLEAR STATION, UNIT 1 DOCKET NO. 50-293 ITEM DESCRIPTION STATUS

• 3.1.14 Exposed Steel Protection C 3.1.16 Breathing Apparatus C 3.1.17 Communication Systems C 3.2.2 Testing Fire Detectors C 3.2.6 Charcoal Fire In ACGS C 3.2.8 CO2 System Discharge Test C 3.1.18 Alternate Shutdown Capability UR 3.2.1 Safe Shutdown Analysis UR 3.2.7 0.C. Power System Hazard Analysis UR 3.1.19 Penetration Seals R 3.2.4 Cable Coccustibility R

= C - Completed UR - Under Review R - Requirements e

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