ML20070E574

Application to Amend License DPR-35,requesting Relief from Tech Spec Re Fire Barrier Penetration Seals

ML20070E574
Person / Time
Site:	Pilgrim
Issue date:	12/15/1982
From:	Howard J BOSTON EDISON CO.
To:	Vassallo D Office of Nuclear Reactor Regulation
Shared Package
ML20070E578	List: ML20070E574 ML20070E589
References
82-315, VP-NE-82-155, NUDOCS 8212170305
Download: ML20070E574 (4)

Text

r b 4 EOSTON EDISON COMPANY 800 BOYLSTON STRErr SDSTON, MASEACHUBETTs 02199 J. EDWARD HOWARD

':-= ===== December 15, 1982 BECo Letter No.82-315 VP-NE No.82-155 Mr. Domenic B. Vassallo, Chief Proposed Change #82-13 Operating Reactors Branch #2 Division of Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 License No. DPR-35 Docket No. 50-293

Subject:

Request for Immediate Relief from Technical Specification Section 3.12.F

Reference:

(A) BECo letter # 77-23 dated March 9, 1977, "APCSB 9.5-1, Fire Protection System Review"

Dear Sir:

Boston Edison Company hereby requests relief from the Limiting Condition of Operation (LCO) delineated in Pilgrim Nuclear Power Station Technical Specifica-tion Section 3.12.F which currently requires establishing a continuous fire patrol when a penetration fire barrier is not functional. The requested relief is in the form of a change to the LC0 for one (1) specific fire barrier.

PROPOSED CHANGE Section 3.12.F, Penetration Fire Barrier, currently states, "with a penetration fire barrier not functional, a continuous fire patrol shall be established on at least one side of the affected penetration within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />."

The desired change consists of adding a note to the end of that sentence to allow an exception to be taken i.e...

... affected penetration within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />." (NOTE: In the case of the fire penetration barrier between the main steam tunnel and turbine building, substitute a "once per hour fire patrol" for the " continuous fire patrol").

BACKGROUND The NRC requires 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire resistant barriers between areas that contain either redundant Safety Related Systems or unacceptable fire hazards. Within this scope, BECo identified important fire areas and Barriers in our APCS 8 9.5-1, Fire Protection System Review, (Ref. a). The report was submitted to the NRC in March 1977. This report erroneously indicated two Fire Barriers existed between three Fire Areas. It implied that the Fire Areas were the RHR Valve Room, Main Steam Tunnel and the Turbine Building. Although the report showed a fire door between60I 8212170305 821215 l DRADOCK05000g

- N [0] TON EDl"DN COMPANY Mr. Domenic R. Vassallo, Chief December 15, 1982 Page 2 the Tunnel and the Valve Room and a barrier between the Tunnel and the Turbine Building, a disclaimer (p.10, Ref. a) was included as clarification which stated,

        ... in Figure I-5, three-hour fire barriers with a three-hour door were supplied in the basic initial design between the south-east RHR valve room and Main Steam and Feedwater piping tunnel. However, the combustibles are non fluid and adequate spatial separation exists between each area and to redundant areas in the other parts of the Reactor Building, thus a fire door is not necessary and the walls could be derated to less than a one-hour fire rating requirement."

Actually, the Steam Tunnel could be included with either of the other fire areas.- The Main Steam Tunnel was originally considered part of the Turbine Building and separated from RHR Valve Room in the Reactor Building by a Class A (i.e. 3 hour fire resistant) fire door. During plant modifications for a high energy pipe rupture outside of containment, a blowout panel with fire resistive characteris-tics was constructed between the Steam Tunnel and the Turbine Building. The Steam Tunnel could then have been associated with either the Valve Room or the Turbine Building, as it has a very limited fire loading and it is not redundant to either area. All BECo Drawings except for one (1) were so revised. This particular omission ultimately led to the confusion that caused both the fire barrier and fire door to be listed and taken credit for when the Fire Protection System Review was later completed. The fire barrier installed in the Steam Tunnel was not tested by U.L. and there-fore it is not listed by U.L. However, the material comporents of this barrier are similar to U.L. Designs and a Factory Mutual (FM) approved design. These assemblies are listed or approved for 2 or 2 1/2 hr. rating. By comparison, the Steam Tunnel Barrier has been concluded to be able to resist the thermal effects of fire for the same duration. In addition to fire resisti've materials, fire barriers must meet construction requirements (i.e. must be fastened together and to support members) sufficiently to withstand the fire and the standard Fire Hose Stream Test. The existing panel fastening detail is supported with " pressure relieving" fasteners instead of conventional rigid fasteners. The panel's ability to pass the Hose Stream Test is in doubt. However, large diameter hose streams cannot be played against either side of this fire barrier because of physical plant configuration and excessively (400-500 f t.) long distances to the nearest large diameter hose connecticn. The fire protection design objectives for safeguarding the reactor and turbine buildings on the basement level (e.g. the Main Steam Tunnel) consisted of a three level defense in depth. They are:

1) No fixed (i.e. installed) combustible loading in the Steam Tunnel and no transient combustible loading (e.g. controlled by Admin Controls).

2) Low combustible loading (i.e. less than 10 lbs of equivalent wood per sq. ft. Ref a) in the turbine bldg basement, and an installed fire sup-pression system (e.g. sprinklers) to provide adequate and reliable mitigation.

and 3) A three hour Fire Resistance Rated Fire Barrier.

[OOTON EDlION COMPANY Mr. Domenic B. Vassallo, Chief December 15, 1982 Page 3 The fire barrier is not a 3 hr. barrier and is therefore not considered functional at this time. Pilgrim Station was made aware on 12/3/82 by our Engineering Dept., that Technical Specification action requirements (section 3.12.F) should be initiated because of the missing fire door and non-rated blowout panel. As such, a continuous fire patrol was established, which has thus far resulted in radiation exposure to the personnel involved in the patrol which is contrary to the concepts of ALARA. REASON FOR CHANGE The " continuous fire patrol" in this instance is overly conservative from a safety standpoint and undesirable from ALARA considerations. JUSTIFICATION FOR CHANGE The results of our fire protectior evaluation of the steam tunnel areas show that: (1) Only one fire barrier between the Turbine Building and reactor building is required. Thus, the steam tunnel can be included with either the RHR "A" Valve Room or Turbine Building fire areas. (2) The existing configuration (ie. no door and an unrated blowout assembly) provides adequate fire separation and protection capabilities on the following bases: (a) Combustible loadings in the areas of concern are very low. Transient loadings are administrative 1y controlled. (b) The blowout panel is constructed of materials consistent with

                        " rated" fire barriers offering protection up to 2 hours.

(c) A fire detection system exists in the RHR Valve Room and a fire suppression system exists in the Turbine Building. (Installed subsequent to the Ref. a submittal) SCHEDULE OF CHANGE Boston Edison Company requests expeditious approval of this proposed Technical Specification change in order that it may be put into effect as soon as possible. FEE CONSIDERATION, In accordance with Section 170.12 of the Commission's Regulations, Roston Edison proposes this change as Class III. Accordingly a check for Four Thousand Dollars ($4,000) will be forwarded to your office in the near future. l I 1

, A CD3 TON EDIYON COMPANY Mr. Domenic B. Vassallo, Chief December 15, 1982 Page 4 Your immediate attention to this request would be greatly appreciated. Attachments: Revised Tech Spec Page 3 signed originals and 37 copies Very truly yours, Commonwealth of Massachusetts) fg County of Suffolk ) r Then personally appeared before me J.E. Howard, whd, being duly sworn, did state that he is Vice President - Nuclear Engineering of Boston Edison Company, the applicant herein, and that he is duly authorized to execute and file the submittal contained herein in the name and on behalf of Boston Edison Company and that the statements in said submittal are true to the best of his knowledge and belief. My Commission expires: [u// 4, /98g bdA/In Y. e a,1) Notiry Public /--

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