ML20127C724
| ML20127C724 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 08/31/1992 |
| From: | Beck G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9209100069 | |
| Download: ML20127C724 (5) | |
Text
ag ~ p PHILADELP'HIA ELECTRIC COMPANY NUCLEAR GROUP HEADQUARTERS 955-65 CHESTERBROOK BLVD.
WAYNE, PA 19087-5691 (m) sesm August 31, 1992 Docket Nos.
50-277
+
50-278 License Nos. DPR-44 DPR-56 U.S. Nuclear Regulatory Commission
--Attn: Document Control Desk Washington, DC-20555-s
SUBJECT:
Peach Bottom Atomic Power Station, Units 2 & 3 Request for Temporary Waiver of Compliance from the
-Technical' Specifications Section 3.14.D.2, " Fire
. Barriers"
Dear Sir:
LAs. discussed with the NRC on August 28 and August 31, 1992, this letter is being submitted to document two requests: 1) thatLthe NRC issue a Temporary Waiver of Compliance (TWoC) to
. temporarily 1 suspend the requirement to have a continuous fire watch for a safe shut down area with inoperable fire barriers and 2)-that the:NRC approve the interpretation that Closed Circuit
. Television:(CCTV).is an acceptable means of satisfying the Technical-Specification (TS) fire watch requirements.- The TWoc was requested to_ apply until' August 29, 1992; at which time a
- continuous fire watch by use of CCTV was installed in the Unit 3 Pipe' Tunnel, Room 19.
A'similar request was-made and approved __on July 17, 1992.
This-new' request was made because of-a new understanding a
.of the deficiencies of the Thermo-lag 330-fire barrier system.
.The NRC issued a supplement to.NRC Bulletin (NRCB) No. 92-01, y
LSupplement;1, " Failure of Thermo-Lag 330 Fire Barrier System to
- Perform,Its-Specified Fire "ndurance Function," on August 28, 1992, which. questioned the. capability of Thermo-lag in any configur. tion.
In response to the supplement, Philadelphia
! Electri-Company'(PECo) identified two additional areas in which Thermo-lag.was_used as a fire barrier: the Unit 3 Pipe Tunnel,
-Room,19 and the High.-Pressure Service Water (HPSW) Pump Structuro..
ThenTWOC requested relief _for Room 19; identified as Lan-area of concern._'An hourly fire watch was immediately r
' established for the HPSW Pux.p Structure which along with the operable smoke detectors' in ttuat area natisfied our TS requirements.
However, because of radiation dose rates in tha L
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t JU. S.ENuclear' Regulatory Commission August 31, 1992-Document Lontrol Desk-Page 2 Pipe-Tunnel'and ALARA concerns a CCTV was installed rather than a manned fire _ watch.
Tne. request was made to waive the requirement
'for-a continuous fire watch until the in.stallation of the CCTV could-be completed.
In1accordance with the guidance contained in the February 22,1 1990-memo from T.
E. Murley (Director, OffJce of Nuclear Reactor Regulation), Philadelphia Electric Company (PECo) requested:a Temporary: Waiver of Compliance from the requirements of Peach Bottom Atomic Power Station, Units 2 & 3 Technical' Specifications.(TS) Section 3.14.D.2, " Fire Barriers".
Technical Specification 3.14.D.1 details the plant areas and the operability requirements _for fire barriers.
Technical Specification 3.14.D.2 states:
"If the requirements of
-3.14.D.l'cannot be met, within one hour establish a continuous fire' watch on at least.one side of_the affected fire barrier, or verify the operability of fire detectors on at least one side of the inoperable fire barrier and establish an hourly fire watch patrol.
Reactor 1startup and continued reactor operation is permissible.".
PECo requested a Temporary Waiver of Compliance
'from this Technical. Specification requirement until a CCTV could be: Installed in the Unit 3 Pipe Tunnel.
The February-22, 1990 memo requests Licensees to provide the following:
1)
A discussion of the requirements for which a waiver is requested Technical Specification 3.14.D.1 details the plant areas and the_ operability requirements _for fire barriers.- Technical LSpecification'3.14.D.2 states:-
"If the requirements of 3.14.D.1:cannot be met, within one_ hour establish a continuous fire watch on at least one side of:the affected fire barrier, Lor, verify the' operability of fire detectors an at least;cne side of'the-inoperable _ fire. barrier and establish'an' hourly'. fire watch patrol.
Reactor startup'and continued.reac*.or operation is permissible.:".
PECo requested a.Tomporary Walver of Compliance"from this Technical; Specification requirement until a CCTV could be installed in the Unit 3 Pipe Tunnel.
2)
A discussion of the circumstances surrounding the situation including the need for prompt action, and a description of why the situation-could not have been avoided.
- The NRC. issued Bulletin 92-01, Supplement 1 on. August 28,
'1992.-
PECo'immediately identified two' areas which were a concern the, Unit-3 Pipo Tunnel (Room 19) and the HPSW Pump Structure ~.
.A hourly fire watch was established in the HPSW L
~ Pump Structure which also has operable smoke detectors.
. Room 19 does not have smoke detectors and because of ALARA I
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,c U.1S." Nuclear hegulatory 'ommission August 31, 1992 Document Control Desk Page 3
= concerns a continuous fire watch was considered impractical.
After discussions with the NRC, Station Operations and PECo 1
Engineering, it was decided that a CCTV installed-in the Pipe-Tunnel would be a practical solution.
The CCTV was
. installed by midnight' August 28, 1992 and the CCTV system 1has been continuously monitored since that time.
3)
~A discussion of compensatory actions There'are no transient combustible materials located in this
' fire area.-
Administrative controls implemented by Administrative (A) procedures, a.g.,
A-12.2, " Control of Combustible Materials, Flammable and Non-flammable Compressed Gases," and A-30, " Housekeeping," prohibit storage and limit the amount of combustibles permitted in the plant, and ensure that potential fire hazards are kept to a minimum-in all areas of the plant including those areas where Thermo-Lag fire barriers are required to meet fire protection safe shutdown requirements.
Therefore, instantaneous spreading of a fire throughout this fire area is highly unlikely.
In addition, when the Unit 2 Pipe-Tunnel was identified in July 1992 as an area of concern under the original NRC Bulletin all Fire Brigades were notified of this' condition during shift turnover and a fire drill was staged on July 17, 1992 to help ensure the response time to a fire in the Pipe Tunnel would be minimized.
Further, water hose stations and other fire fighting equipment ~has been located just outside the area.
Both the Unit 2 & 3 Pipe Tunnels are in the same general area'of-the. plant and the fire drill and the equipment staticned in this area will ensure the response time to a fire.in'either pipe tunnel is minimized.
The shift was informed that Unit 3 Pipe Tunnel is affected by the Thermo-lag deficiencies.
4)
A preliminary evaluation of the cafety significance and potential consequences of the proposed request It is unlikely that a fire should occur in this area because therc are no ignition scurces and minimal combustible material.
Further, the fire fighting equipment and the fire brigade training and drill will ensure that the response time to a fire in_the pipe tunnel is minimized.
- 5) _ ~ A-discussion which justifies the duration of the request
'This TWOC was requested to apply until August 29, 1992; at which time a-continuous fire watch by use of CCTV in the Unit 3 Pipe Tannel, Room 19, was initiated.
An alternative to a person performing a continuous fire watch in this room is considered good ALARA practice, because this is a locked
-high radiation area with dose rates in excess of 1000 mR/hr.
Therefore, as interim compensatory measures, until the final corrective actions to restore the inoperable fire barriers
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U. S.: Nuclear Regulatory Commission-August 31, 1992 Document 1 Control Desk Page 4
+e to an operable stat.us'are implemented, we request approval to use a CCTV to perform an continuous fire watch of room No. 19.
The viewing monitor would be located just outside
-the locked high radiation area where the general area dose rate would:be-2 to 20 mR/hr.
Use of a CCTV to satisfy TS fire watch requirements has previously been approved by the
-NRC, e.g.,
NRC approval for Philadelpnia Electric Company's Peach Bottom Atomic Power Station, dated July 17, 1992.
6)
The basis for the licensee's conclusjon that the request does not involve significant hazards consideration The requested-temporary waiver of-compliance to Technical Specification 3.14.D.2-did not involve a significant hazards consideration because operation of Peach-Bottom Atomic Power Station with-this change did not:
(1)- involve a significant increase l'n the probability or consequences of an accident previ~ously evaluated.
The probability of-a fire is related to the presence of combustible material and ignition sources.
Both of these factors were minimized before this request was made.
Tne Unit.3. pipe tunnel has minimal combustible materials-and ignition sources.
The camera adds an insignificant amount of combustible material.
Therefore, the-probability of a fire in the pipe tunnel is extremely remote.
In the unlikely event of such a fire, the consequences are also likely to be minimal; the lack of combustible' material would minimize the intensity of a fire and the consequences.
(2)
. create the possibility of a new or different kind of accident from any accident previously evalu ted.
The requested temporary waiver did not_ involve any changes
-to plant equipment or effect any accident precursors and therefore in and'of itself did not create the possibillty of a new or different kind of accident.
(3)
- involve a significant reduction in a margin of safety.
-Thc minimal combustible material and ignition sources-in-the pipe tunnel provided a similar margin of safety as previously existed.
7 )-
The basis for-the licensee's conclusion that the request does not involve irreversible environmental consequences.
1The requested temporary waiver of compliance to the
- Technical Specifications did not-have an environmental impact since the change:did not result in any increase in
-theLamoant or: result-in any change in the type of effluent
-which'may be released off-site, and there was no significant increase in^1ndividual occupational radiation exposures.
U.
S.
Nuclear Regulatory Commission August 31, 1992 Document Control Desk Page 5 The Plant Operational Review Committee reviewed this requested temporary waiver of compliance and concluded that it did_not involve a significant hazards consideration and would not endanger the health and safety of the public.
Discussion of CCTV The CCTV equipment being used for the remote fire watch for the inoperable fire barriers in the Unit 3 Pipe Tunnel area consists of a television camera and a monitor.
The CCTV monitor is an eight (8) inch diagonal black and white display unit.
Testing requirements and acceptance criteria for the camera and the monitor are met if the designated fire barriers are clearly visible and positively identified on the remote monitor.
The camera provides the capability for a person performing the fire watch to visually monitor the inoperable fire barriers and the o
general area surrounding the fire barriers.
Regardless of any affects of radiation on this equipment, any degradation in video transmission would be readily detected.
Should the quality of the video transmission become degraded, the appropriate corrective action will be taken to ensure that the area of concern is maintained under visual surveillance consistent with good ALARA, practice.
The use of a CCTV reduces personnel radiation exposure incurred during-a fire watch.
Posting a fire watch to monitor the inoperable fire barriers in the Pipe Tunnel area by using a CCTV provides a level of protection equivalent to the posting of a fire watch in the room.
Locating the fire watch outside of the high radiation area using the CCTV does not reduce the level of protection required by TS, and conforms with accepted ALARA
-practices.
Very truly yours,
%h b G.
J. Beck Manager Licensing Section cc:
T. T. Martin, Administrator, Region I, USNRC J.
J.
Lyash, USNRC Senicr Resident Inspector, PBAPS t
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