ML20115E973
| ML20115E973 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 10/16/1992 |
| From: | Beck G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| IEB-92-001, IEB-92-1, NUDOCS 9210220207 | |
| Download: ML20115E973 (2) | |
Text
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PHILADELPHIA ELECTRIC COMPANY NUCLEAR GROUP llEADQUARTERS 955-65 CllESTERBROOK BLVD.
WAYNE, PA 19087-5691 (215) 640-6c00 October 16, 1992 NUCLEAR SERVICES DEPARTMENT Docket Nos. 50-352 50-353 License Nos. NPF-39 NPF-35 U.
S.
Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, DC 20555
SUBJECT:
Limerick Generating Station, Units 1 and 2 Request for Approval to Reduce Technical Specifications Fire Watch Requirements Gentlemen:
The purpose of this letter is to request approval to reduce Technical Specifications (TS) fire watch requirements for three fire areas at Limerick Generating Station (LGS), Units 1 and 2,
containing fire barriers that were declared inoperable in response to NRC Bulletin (NRCB) No. 92-01, " Failure of Thermo-Lag 330 Fire Barrier System to Maintain Cabling in Wide Cable Trays and Smal)
Conduits Free from Fire Damage," issued on June 24, 1992. 'NRCB No.
92-01 requested 'icensees to promptly identify the areas of the plant which have Thermo-Lag 330 fire barrier material installed to protect either small conduits or wide cable trays that provide safe shutdown capability, and to implement compensatory measures, such as fire watches, in accordance -with either plant TS or an operating license condition for an inoperable fire barrier.
.TS Section 3.7.7, Action a.
requires establishing either: (1) a continuous fire watch when a fire area contains an inoperable fire barrier with no operable fire detectors, or (2) an hourly fire watch patrol when a fire area contains an jnoperable fire barrier with operable fire detectors on at loest one - side of the inoperable barrier.
Appropriate compensatory reasures (i.e.,
firo watches) were established.In accoroance s.ith LGS TS in those areas containing inoperable Thermo-Lag 330 fire barrier systems as a result of NRCB No. 92-01.
l l
220042
- 2go22eggan8gga 1 0_
U.S. Nuclear Regulatory Commission
-October 16, 1992-
' Document Control Desk Page 2 The following three areas of the plant fall within the scope i
of NRCB No. 92-01: (1) Fire ZLne 1N, Recombiner *. cess Room, Units 1 and 2 Contr Enclosure, Elevation 200', Room M39; (2) Firo Zone 64B, Isolation Valve Room, Unit 2 Reactor Enclosure, Elevation 201', Room 286; and (3) Fire Zone 67, Pipeway Area, Unit 2 Reactor En"losure, Elevation 217', Room 368.
These rooms contain Thermo-Lag 330 covered electric junction boxes for cabling associated with safe shutdown capability, and do not presently have-installed fire i
detectors.
Therefore, in responre to NRCB No. 92-01, a continuous fire watch was posted in these three areas in accordance with LGS TS.
4 In order to reduce the impact of NRCB No. 92-01 in terms of the cost and manpower requirements necessary to implement the required compensatory measures, we plan to install fire detectors in these three areas of the plant.
Therefore, we request approval from the NRC to take credit for the installation of these new fire
~
detectors to reduce the TS required fire watch from continuous to hourly as an interim compensatory measure until the Thermo-Lag 1
issue is resolved and fire barrier operability is restored in these three areas.
l Three (3) smoke detectors, Edwards, Model 6250B, - will be installed in Room 259, and two (2) smoke detectors will be j
installed in each of Rooms 286 and-368. These smoke detectors will be added to the existing fire detection system.
The fire detection
- system, as
- modified, will remain in compliance with-the a
requirements of National Fire Prc,tection Association (NFPA) l Standard 72D (1979),
" Proprietary Signaling-Systems,"
with exceptions and clarifications as described in LGS Updated Final Safety Analysis Report (UFSAR), Section 9.5.1.
The new detectors i
will be located in accordance with the requirements of NFPA 72E (1990), " Standard on Automatic Fire Detectors," and will be tested prior to being placed in service.
In addition, operability and i
periodic testing of these detectors will be administratively controlled in accordance with LCS TS.
In the event that all of the smoke detectors in one or more of these areas become inoperable,-a continuous fire watch will be posted in the affected area (s) in i
accordance with LGS TS unti) -operability-of at least one of the detectors is restored.
Because of the significant impact these continuous fire watches have on our resources, we request your prompt attention to i
this matter.
i i
i d
I
f s
U.S. Nuclear Regulatory Commission October 16, 1992
' Document Control Desk Page 3 If you have any questions, please do not hesitate co contact us.
Very truly yours,
' ff
/-
G.
J.s eck, Manager Licensing Section cc:
T. T. Martin, Administrator, Region I, USNRC T.
J. Kenny, USNRC Senior Resident Inspector, LGS
.