ML20101E693

Requests Exemption from 10CFR50.48 Schedular Requirements for Implementation of Alternative Shutdown Capability in 10CFR50,App R,Subsection III.G.3 Re Fire Protection of Safe Shutdown Capability

ML20101E693
Person / Time
Site:	Peach Bottom
Issue date:	12/19/1984
From:	Boyer V PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Eisenhut D Office of Nuclear Reactor Regulation
References
NUDOCS 8412260349
Download: ML20101E693 (15)

Text

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h PHILADELPHIA ELECTRIC ' COMPANY 2301 MARKET STREET P.Oi. BOX 8699 PHILADELPHIA, PA.19101 I2IN 04I'4 V. S. BOYER

"$c't' [."7o',

December 19, 1984 n

Docket Nos. 50-277 50-278 Mr. Darrell G. Eisenhut

-Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C.

20555

SUBJECT:

Peach Bottom Atomic Power Station, Unit 3 Appendix R - Schedular Exemption Request

Dear Mr. Eisenhut:

This letter requests an exemption to the schedular requirements set forth in 10 CFR Part 50.48(c) (4) for implementation of the alternative shutdown capability requirements identified in 10 CFR 50, Appendix R, Subsection III.G.3., Fire Protection of Safe -Shutdown Capability

.(Alternative Shutdown Capabilty), and III.L., Alternative and Dedicated Shutdown Capability, for Peach Bottom Unit 3.

The alternative shutdown concept was previously identified as the only feasible method of implementing the safe shutdown _ requirements of Subsection III.G. for three areas of the plant: _ Control Room, Cable Spreading Area, and Remote Shutdown Panel Area.

On May 4, 1984, the NRC staff issued a modified Safety Evaluation Report granting final approval of the licensee's proposed design for an alternative shutdown system.

The schedule requirements of 10 CFR 50.48 (c) (4) call for implementation before startup af ter the earliest of the following events commencing 180 days after Commission approval:

(1)

The first refueling outage; or (2)

Another planned outage that lasts for at least 60 days; or (3). An unplanned outage that lasts for at least 120 days, f

Q0 8412260349 841219 l'A PDR ADOCK 05000277 I

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Mr.-Darrell.G. Eisenhut^

- December 19, 1984 1,

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Forf Peachf Bottom, ;this would be. the refueling outage for Unit' 2" scheduled t'o start in-late 1986,f and the -refueling outage L

tfor Unit 3 scheduled (to start ~early February 1985.. Accordingly,.

'inicorrespondence dated May. 16, 1984 c(V. S. Boyer,.PECo, to D.

G.

--Eisenhut,3 NRC),;we' committed to perform the Unit 3 modifications during the next'. refueling outage, thel Unit 2 modifications during "the 1986. refueling-outage, and the common plant ' systems ' (Diesel 1

Generator: Controls and Emergency Service Water System _ Controls)

during the~1986 Unit 2 refuelingLoutage. -Consequently, as stated inithe.May 16, 1984 commitment, alternative shutdown capability would:not be.available on either unit until the conclusion of the 19861UnitL2 refueling outage.-

.This exemption requests a deferral of alternative shutdown system modifications for Unit 3 until the subsequent refueling outage planned for early 1987.

The. exemption-would permit an eight-week refueling outage starting in February 1985,

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--in~ order to minimize operating time with leaking' fuel rods, reduce the' stress'on personnel required to support an. extensive-

. concurrent outage of Peach Bottom Unit 2, and reduce power replacement costs by an e'stimated 18 million. dollars over the Dnext test schedule alternative.

Fire watch patrols of the three areas associated with the alternative: shutdown system will be provided as an interim compensatory measure to preclude the

-possibility of a fire hazard.

Reason for Exemption Request The schedule for returning Peach Bottom Unit 2 to.

service'during its current outage has been extended due to the

. replacement of ten reactor vessel nozzle safe ends that have L

shown evidence of IGSCC, and other unexpected delays associated -

with replacement of RHR and Recirculation System pipe.

When Unit i

L 2's current outage was originally planned, the return to service i

~ was estimated to - be December 1984.

The IGSCC on the nozzles was not fully' identified until well into the outage.

The decision to replace the nozzles may extend the Unit 2 outage into late April 21985.

This revised schedule has greatly impacted the plans for the 1985 Unit 3 refueling outage.

The' Unit 3 refueling outage is currently scheduled to begin in early. February 1985 and run for approximately 17 weeks L

.until late May, 1985.

Eight weeks are necessary for refueling

-and an additional nine weeks would be required to implement Appendix R requirements.

The impact of having both Units in long concurrent outages for' February, March and April will greatly j

-impact.the cost of power to our. customers and will tax our human resources.

In order to minimize the impact of this situation, we rhave examined a number of schedule alternatives for refueling

. Unit 3.

There are two major constraints that impact the viability of the alternatives: 1) the performance of a variety of l

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Mr.'Da,rrell G.'Eisenhut

' December 19, 1984 Pager3 surveillanceLtests, such as instrumentation. calibration, Main.

LSteam' Isolation Valve testing,-Appendix J leak rate testing, and battery discharge test, that cannot be delayed beyond early February 1985 without exemption; and 2) the completion of certain

' modifications, to satisfy Appendix R of 10 CFR 50 requirements for alternative shutdown capability, which.were previously identified as scheduled.to' be performed during the 1985 Unit 3 refueling outage.

We have analyzed the surveillance work requirements and believe an exemption request is inappropriate due to.the number of exemptions and the length of delay needed

'forEthis option (i.e., delay of up to 3 months).

This has

removed several alternatives from further consideration.

The schedule alternative which has been chosen involves-an eight-week refueling' outage starting in early February 1985.

This is the most viable outage schedule for the following reasons:

1.

An outage starting in early February is necessary to accommodate the' surveillance testing required by the regulations.

Starting the refueling outage at this. time avoids the need to schedule separate outages for surveillance testing and refueling.

Separate outages would result in additional power replacement costs to

'the customer estimated at-18 million dollars.

2.-

.The development of leaking fuel rods has increased offgas radiation levels and resulted in a self-imposed power derate to stabilize.the offgas levels.

An early outage will minimize the period of operation with leaking fuel rods and permit timely replacement of the

,t defective fuel to permit restoration to full power operation.

1

3.

An early outage avoids refueling and startup activity interference between Units 2 and 3.

Reloading the Unit 2 reactor is expected in April 1985.

A Unit 3 outage, beginning later than February, would result in concurrent refueling activities and adversely impact y

startup activities on Unit 2.

These activities performed in parallel would significantly impact available human resources.

However, an eight-week refueling outage, starting in early February 1985, will require a postponement in completing alternative shutdown modifications until Unit 3's next refueling outage, scheduled for early 1987.

The necessary equipment for this modification is being expedited but will not be available in time to coksence outage work until late March 1985, thus adding

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' Mr.'Darrell G. Eisenhut-December L9, 1984 Page 4

. approximately nine weeks to the'eight-week refueling outage.

Postponing the refueling outage to accommodate-Appendix R modifications is unsatisfactory for the reasons listed above.

A delay in; implementing the : alternative shutdown modifications is

-- requested in-order to-avoid.approximately nine additional critical path weeks of outage.

iIf. relief on the' completion _date of the Unit 3 alternative' shutdown modifications is not granted, the next'best alternative is to perform the surveillance _ work during a three-week mini-outage:in February 1985 and then continue operation through power coastdown.until sometime in April, hopefully to just,after Unit 2 returns,to. service.

This alternative will increase the cost of power to our. customers by approximately 18 million dollars, will further extend the operating time period of Unit 3.with leaking fuel rods, and jeopardizes the availability cf the plant for the summer peak load. shows the

- various outage schedules discussed-in this letter.

Extent of Current Compliance Extensive modifications have been performed to-date at a cost of more than 32 million dollars, bringing the facility into

. near compliance with Appendix R regulations.

This work is

-described below and-in Attachment 1.

Automatic Fire Detection - Many additional ionization 1.

. type smoke detectors have been added to plant areas which previously had no detection.

Additional smoke detectors have been added in other safe shutdown areas to enhance detection capability.

2.

Safe Shutdown Capability - Extensive cable tray encapsulation and cable rerouting work have been completed'to provide adequate separation of safe shutdown methods.

3.

Emergency Lighting - Safe Shutdown areas as well as routes of access to and from those areas have had 8-hr.

battery pack units installed.

4.

Alternative Shutdown Capability -

A consultant was retained to help identify and design the required t-separations of cable / equipment or additions of redundant cable / equipment for the Control Room, Cable Spreading Room, and Remote Shutdown Panel Area.

5.

Fire Barrier Cable Penetration Seal Qualification - A major program to upgrade fire barrier seals was

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!Mr. Darrell G.lEisenhut Decembe'r'19,E1984 S.

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undertakendwithLa qualified seal' installer._

(tray and This-program not only1 included cable penetrations

' conduit).;but all penetrations including. piping and duct. '

This upgrade' program is:more than 98% complete.

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Fire' Doors - An' inspection programLrev'lewed allLfire

- barrier' doors for, correct fire rating qualifications.

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LHVAC Duct Fire. Dampers

.As part of the-fire barrier i

upgrade. program,' ducts passing through safe shutdown

_ barriers which do not now have, dampers either have had i

foxemptions requested.or dampers installed or. scheduled cto be-installed..

r 8.

Miscellaneous. Items - In several areas dikes have been installed to prevent; oil' spills / fires from spreading, and in a-several cases, associated suppression systems have teen added.

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. Justification for-Relief-The schedule for the' Alternative Shutdown modifications is' tabulated in attachments 2, 3, and.4.

This schedule is

-consistent with the commitment transmitted in a letter dated May 16,;1984 (V. S. Boyer, PECo, to D. G. Eisenhut, NRC), and the

' schedule attached to a letter dated September 17, 1984 (V. S.

Boyer to:D. G. Eisenhut).

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. As defined in the commitment and schedule, some

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? equipment-that'is, common for both Units' Alternative Shutdown capability is not scheduled for implementation until the next p

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n Unit 2 refueling outage.

The primary component affecting this b,

Lcapability is the Emergency. Service Water Pump that provides cooling' water for_the diesel generators.

To make this pump 4

. available for Unit 3 Alternative Shutdown would require almost total completion of Unit 2 modifications 1352B, C, D,E and F.

This work. represents'approximately 40% of the scope of the Unit 2 modifications.

The three fire areas for which Alternative Shutdown is i

being installed (the cable spreading room, the remote shutdown lpanelEarea, and the main control room) are common for both Units a

2 and 3.

For Alternative Shutdown to be effective for a major fire in any of these areas, both units must be complete.

There

are no installed fire barriers that would restrict an exposure fire to one unit.

'Upon completion of the modifications outlined in L

Attachments 2 and 3, alternative shutdown capability for Unit 3 i

would only exist for selected fires in the Unit 3 half of the three fire areas listed above.

This assumes that there is no

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o vn Mr.iDarrell G. Eisenhut:

Dscamber. 19,-1984.

Page 6

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coincident 11oss' of 'of fsite power,.the. fire restricts 'itself to ithe Unit 3: side _of the common fire _ areas and itldoes not. affect.

g the DC distribution-panels and circuits located in the area, rIf'the, modifications outlined in Attachments 2 and 3 werel postponed:until the Unit 3 outage in early 1987,~ shutdown.

scapability for Unit'3 would only' exist for selected firestin the

' Unit 3 half,of the three fire areas.

Under this' condition,'the

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fire would have'to be restricted to non-safeguard equipment plus

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only one division of safeguard equipment.

Under either of thettwo above conditions, alternative

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sh'utdown capability would only exist in Unit 2 for these areas for those Unit 2 fires that-are_ restricted to non-safeguard

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equipment plus only one division of safeguard equipment.

As described above, implementation of the Unit 3 modifications during the upcoming refueling outage will not provide alternative shutdown capability until 40% of the Unit 2

~ modifications are completed during 1996 Unit 2 refueling outage.

Consequently, deferral.of the Unit 3 modifications until the subsequent refueling outage '(early 1987) represents an actual delay in establishing Alternative Shutdown capability of less than six months.

Recent improvements in the fire protection features associated with these three areas, as well as the use of IEEE 383

. qualified cables selected for installation in the facility, provides sufficient' compensatory measures to ensure safe shutdown capability until_the alternative shutdown system is operational.

The improvements included an automated suppression system in the Cable Spreading' Room, additional fire detection devices in all three areas, and the installation of qualified penetration seals inLthe fire barriers bounding these three areas.

Further, to assure that safe shutdown capability is maintained, a fire watch patrol will be established to inspect the' Cable Spreading Room and Remote Shutdown Panel Area at an average frequency of once per hour until the 1987 Unit 3 refueling outage.

The fire watch will not apply to the Main Control Room since this area is already continually manned.

The

fire watch assures that no unnecessary transient combustibles are present in these areas.and will routinely examine the trays containing safeguard equipment for evidence of a fire.

Due to the nature of developing fires in cable trays containing IEEE 383 Jgualified cables (long-term smoldering), the fire watch and the

' existing smoke detection systems in these areas will provide prompt detection of any developing fires.

A procedure will be developed to specifically detail the fire watch duties with specific attention to critical areas.

Additionally, fire protection procedures are already in effect for use by the fire brigade in responding to fires in these areas.

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Mr. Darrell G.:Eisenhut

,Dacsmber 19,.1984 Page 7-p.

Accordingly,: Philadelphia Electric Company,' pursuant to 10 CFR 50.12, hereby' requests an exemption to the schedular.

' requirements"of 10 CFR. Part 50.48 (c) (4),for implementation of the

. alternative shutdown system on Peach Bottom Unit 3 by deferring-

'the modification from the 1985-refueling' outage untilithe early

'1987 refueling' outage. 1TheHexemption' enhances safe operations by minimizing operating 1 time with leaking fuel rods, and. reducing personnel. stress associated:with concurrent' refueling' activities.

Recent simprovements in~ fire protection design-features,- and the

.' application of fire watches, provide sufficient compensatory measures to ensure safe shutdown capability until the alternative shutdown system is operational.- Considering the safety benefits and compensatory measures described, and the actual delay of less thanLsix months in meeting the safe shutdown criteria.of Appendix R, the requested schedule change is appropriate and will not

- Lendanger the health'and. safety of the public.

We are prepared.to meet with the staff to discuss and' cprovide'any clarification' deemed necessary regarding-this exemption request.

Should you have any questions, please do not

. hesitate to contact us.

Very truly yours, Attachments cc:

'J.

II. Williams, Resident Inspector-7 i

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ATTMMENT fl PEACH BOTTOM ATOMIC POWER STATION - FIRE PROTECTION MODIFICATIONS Docket Nos.50-277 50-278 1

Modification Scope Schedule Extent of Work Cost Status i

Penetration Seal Upgrade Penetration A penetration seal Approximstely 6250 Total Cost is estinated 6150 seals have been completed.

Ubgrade Progra seals In barriers contractor began an penetration seals to be $20,231,000. The Construction I>Iv. Is currently separating redwulant engineering survey In through 341 barrlers work force at the height Installing the renmining 100 trains of safe shut-September, 1982.

have been or will be of activity totaled 199, seats plus 650 smoke and hot-l dome) equipment to Installation began In upgraded. Approxi-Including 134 craft on gas seals In the Control Room.

satisfy 3-hour fire Fetwvery 1983. The mately 200 seals were 2 shifts.

4 resistance require-contractor demobilizoc. removed during the monts.

November 1984 program to accomodate Construction Div. Is other Mods and had to performing cleanup be re-Installed.

work. Work Is expected Approximately 650 smoke to be ccmplete May 1, and hot gas seals are 1985.

required in the Control

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Rocan floor.

4 Fire Darmer Upgrade Install 3-hour rated Damper Insta11atlon 55 despers require to-Total cost Is estinated 27 dampers have been Installed Progran fire dampers In IWAC began In February 1984. grading to satisfy to be $1,486,000. The to date, duct through barriers It Is expected that 3-hour fire resistance work force has reached 11 separating redundant work will be couplete requirements.

craft working one shift.

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trains of safe shut-by May of 1985.

down.equipnent to

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satisfy 3-hour fire j

resistance require-monts.

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1 Fire Detection Install Fire The detection tegrade 337 anoke detectors Total cost is appront-Line type heat detectors remain Detection In plant began in February 1980 and 8 heat detectors motely $1,000,000 for to Installed In cable tray In j

areas e lch present and continued through were Installed procurement and the control structure fan room, j

an exposure hazard 1983.

throughout the plant installation, subject to MC approval of an to safety related (Approx. 35 plant emenotion request sdsnitted as equipment or areas),

part of the Alternative Shutdom congonents.

Analysis In Septenber 1983.

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l Modification Scope Schedule Extent of idork Cost Status l

Structural Steel Provide structural A structural steel The amomt and extent Engineering and Consultant 'As soon as the nothodology was Firo Protection steel fire protection survivability analysis of Structural Steel fees are approximately approved for use at Limerick -

a equivalent to that methodology was sub-fire protection remains

$130,000 to date, work began evaluating the steel

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required of the fire mitted to the MtC In to be determined.

at Peach Bottom. The Unit 3 1

berrier.

September 1983. It evaluation is complete, the.

was approved for use at.

. remainder of the plant Limerick Generating evaluation is in progress.

Station in Supplement 2 to the Limerick Safety l

Evaluation Report.

i Cable SeoaratIon Encapsulation Protect cables Encapsulation began in 2945 linear feet of Total cost is estinated.

2943 linear feet of raceway

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i required for one May of 1983. It is raceway have been to be $3,550,000. The ca plete. The remaining 2

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train of redundant empacted that work will identified as requiring work force has reached 30 linear feet require a thlt 1

safe shutdcun equip-be ca pleted by Mid-May encapsulation craft working one shift.

outage.

ment In an envelope of 1985.

An exceptional meet of i

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of 3-hour rated engineering time a s also i

fire barrier required for this modifl-notorial. Required

' cation.

l to satisfy Appendix R 3-hour fire resistance require-i monts.

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Rercutes Reroute cables it is expected that 85 cables have been Total cost is estimatgd.

About 50 cables associated required for one train the work will be Identified as.

to be $1,250,000, with thIt 3 equipment of red 6mdant safe co pleted by the end requiring rerouting.

have been rerouted.

shutdown equipment to of the thIt 3 satisfy AppendIn R refueling cutage.

separation require-a monts.

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Modification Scope Schedule Extent of Work A t_

Status Emergency Install bettery Total cost is estimated Congleted.

Lighting stepiled 8-hour to be $100,000.

emergency lighting to comply with the lighting require-monts of Appendix R.

Miscs11aneous Modiff-cetions MG Set Romi $prinkler Install a proaction Estimated Cost Conplete.

SyItem sprinkler system of Misc. modifications over the MG sets to

$800,000.

protect against a lube oil fire.

Oli retention Install curbing in the Conglete.

J areas listed below to contain an oil fire In i

a localized arec: MG Set Rooms, Diesel Generator Recus, H Seal 9

Oil thit, and Diesel Fire Purp Room. Floor crains in the MG Set Room must be plugged tG prevent oil flow through the drains.

1 RJ1ocate Conbustibles Relocate Anti-C Conglete.

Storage from elevation 116' to reduce hazard.

Relocation Is in lleu of a sprinkler system.

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l Modification Scope Schedule Extent of Work Cost

,Statur' Install a Hose Cart Install an additional Coglete.

House hose cart house out-j side of the plant 1

within security.

1 Autanate Cable Cable Spreading Rocm Ca glete.

Spreading Room CO System modified 2

CO System to provide automatic 2

actuotton.

FIra Door Several fire doors Complete.

S e rvislen were electrically supervised to monitor 4

operability.

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Watcr Curtains Install water Installation began In A water curtain has been Installation of circultry.

4 curtains in the December 1982 and ended Installed In each Reactor associated with automatic thIt 2 & 3 Reactor In September of 1983.

Building corridor.

A-actuatlan and sprinkler Building corridor Work to automate the deluge VJlve,86 snDke.

guards remin.

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elevation 135' to water curtain and detectors and local

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prevent the passage Install sprinkler alarms are required for of fire from one gueros has not each unit. Nearby.

side of the Reactor ce menced.

equipment was protected Building to the against water inpInge-other.

ment. Each system is to be autcmatically actuated.

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Additional Electrical Miscellaneous This category All engineering work Safe shutdom analysis, Total cost is estimated Modification work 95%

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1 Modifications includes all is espected to be Identification and to be $3,450,000, complete. Engineering i

miscellaneous co plete by July of preliminary design of work 75% couplete.

modifications.

1985. Modification

- Alternative Shutdown j

required to comply work nearly caplete.

capability, equipment with the criterla

. relocation, circuit specified In Appendix breaker. coordination 4

R and all engineering (study and modiff-i{

and adninistrative cations). Fire door time required to Installation and other l

Identify this work.

work.

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l Peach Bottom At'omic Power Station:

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Attachment. 2. '

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y Scope : of work-presently ; scheduled to be complete'd ~ during April,-

- 1985, Unit.3 refueling outage-(All mods:in Unit 3).'

51.

Mod 1353A.- HPCI'ACS --Installs'a new local' control panel" that permits -HPCI to be operated separate from the.. three '

. fire" areas..

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-Mod ^1353B - ; Instrumentation - Provides'; diagnostic

-instrumentation for Unit 3 Alternative-Shutdo'wn Equipment.

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Mod"1353C - RHR ACS - Provides local control of the:3D RHR' pump from its,switchgear compartment and local control of:

-system valves at the HPCI ACS,

~4.

I Mod 1353DE-HPSW ACS. - Provides local control of-the 3D HPSW :

. pump from ~its switchgear compartment and local control of

. system valves.at-the-HPCI:ACS.

5.

Mod.1353E - AC Power -- Provides control of the 3B and 3D

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'switchgear-breakers from_the B and D diesel generators and-to the 3B and 3D load centers.

6..

Mod 1353F - DC Power

Provides. feeds from the. 3D battery to

..the-2D and 3D switchgeari:the HPCI ACS and the D DG ACS.

7.:

Mod 1353G - ADS ACS - Provides control of three ADS valves

'at the HPCI ACS.'

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Mod 1353H - Instrumentation:- Provides process monitoring at the HPCI ACS.-

9.

Mod 1353I - Emergency Lighting - Provides emergency lighting at.ACSand' access and egress thereto.

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4 Peach Bottom Atomic Power Station

.. Scope of work presently' scheduled to be completed during'the next'.

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.; diesel. generator outage.

1.

Mod 1351A - DG ACS _ Installs a new local control panel that permits the B and D diesel generators.to be started 'Lud operated.

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Peach Bottom Atomic Power Station Scope of_ work presently scheduled _to'be completed during 1986, Unit 2 refueling outage (All mods in Unit 2).

1.

Mod 1352A

_HPCI ACS - Installs a new local control panel that permits HPCI to be operated separate from the three -

fire areas.

2.-

' Mod 1352B Instrumentation Provides diagnostic instrumentation.for Unit 2 Alternative Shutdown Equipment.

'3.

Mod 1352C RHR ACS - Provides local control of the 2B RHR

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pump from its switchgear compartment and local control of system valves _at the.HPCI ACS.

4.

Mod 1352D - HPSW ACS - Provides local control of the 2B HPSW pump from its switchgear compartment and local control of system valves at the HPCI ACS.

5.

Mod 1352E - AC Power - Provides control of the 2B and 2D switchgear breakers from the B and D diesel generators and to the 2B and 2D load centers..

.6.

' Mod-1352F - DC Power - Provides feeds from the 2B battery to the 2B,and 3B switchgear, the HPCI ACS and the B DG ACS.

7.

Mod 1352G - ADS ACS - Provides control of three ADS valves at the HPCI ACS.

O.

Mod 1352H - Instrumentation - Provides process monitoring at the HPCI ACS.

9.

Mod 1352I - Emergency Lighting - Provides' emergency lighting at ACS' and access and egress thereto.

10.. - Mod 1351D - ESW ACS - Provides local control of the A ESW

-pump from its switchgear compartment.

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PEACH BOTTOM ATOMIC POWER STATION UNIT 3 OUTAGE OPTIONS ATTACHMENT 5 I.-

Current Schedule Activities:' Refueling, Alt. Shutdown Mods, Surveillance Testing 17 Weeks i

i Feb.

Mar Apr May II.

Preferred Alternative (requires requested exemption)

Activities:

Refueling, Survel'llance Testing 8 Weeks Feb' Mar III.

Second Alternative (exemption denied) 3 Weeks 8 Weeks L

Feb.

May Surveillance Refueling, Alt. Shutdown Mods Testing (start after Unit 2 startup) t.

I IV.

Unit 2 Schedule M

Pipe Work rlc Reload Core S Startup={

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Feb Mar Apr May 4

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