ML20155C964
| ML20155C964 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 08/06/1984 |
| From: | De Agazio A Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| TAC-52156, NUDOCS 8810100309 | |
| Download: ML20155C964 (27) | |
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\\o, UNITED STATES P*
NUCLEAR REGULATORY COMMISSION g.3m
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August 6, 1984 Docket No. 50-346 LICENSEE: Toledo Edison Company FACILITY: ' Davis-Besse, Unit No. 1
SUBJECT:
SUMMARY
OF MEETING WITH TOLEDO EDISON COMPANY CONCERNING THE PROGRAM TO CORRECT FIRE PROTECTION DEFICIENCIES AT DAVIS-BESSE ON JUNE 12, 1984 Introduction On June 12. 1984, thestaffmetwithToledoEdisonCompany(TED)inBethesda, Maryland to review the status of TED efforts towards correcting deficiencies in plant fire protection features and non-compliance with respect to the requirements of Appendix R to 10 CFR 50. TED had supplied, prior to the meeting, certain draft material for the stiff to examine to facilitate the meeting. This material is not attached to this sumary because the mat) rial, in final fom, will be included as part of TED's femal submittals at a later date. The attendees list is shown as Enclosure 1. is a copy of the viewgraphs used at the me,eting. is a TED listing cf material which has been used in tMs and prior me9 tings for discussion purposes or which is available for review.
Discussion By letter of April 16, 1984, TED proposed a revised schedule for ccmpleting their evaluations addressing audit findings and reassessrent of Appendix R compliance at Davis-Besse. The NRC has withheld cement on the proposed schedule pending this meeting 50 that the staff can assess the progress being made. A for-al response to the TED letter will follew this meeting su r'ary.
TED has not yet proposed a schedule for the actual plant redifications resulting f rom the reevaluations. The NRC stated that it will be necessary to start discussions on modification schedules well before TED submits its first version of an integrated schedule to the staff. A reeting will be held to discuss this issue late July.
Upon submission of TED's reanalyses, those creas of rcr,-coroliarce with fire protection recuirerents will te reviewed to ceter-ine interim cer:ensatory reasures in place.
Cepending upon the schecule for irpleTenting ccrrecthe action, the NRC may recuire more stringent interim cerpensatory reasures to be in place.
8810100309 040006 PDR ADCCK 05000346
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O The staff, referring to a Bechtel Corporation letter to TED, questioned if all the fire wraps identified for the component cooling water purs room are in place. TED indicated that they are not all in place because TED is waiting for their consultants to complete the safe shutdown list to detemine the best approach.
With respect to conduit embedded in concrete, the staff stattd that 8 inches of cover generally has been accepted as a 3-hour fire barrier. TED indicated that they would like to consider such conduit as out of the fire area.
If a 3-hour rating cannot be justified something less-such as 2-hours might ha acceptable.
The deficiencies with fire wrapping include 1
test results 2
FCR sign-off vs. actual field condition 3
installation cf wrap vs. tested configuration The staff suggested that TED could benefit by submission of wrap test results to the NRC to determine acceptability before TED proceeds with the wrapping program.
At the next review meeting, TED plans to identify to the staff the requests for exemption expected to be submitted.
Emergency lighting surveys indicated 0 to 3 F.C.
Operators were asked to assess if the existing emergency lighting level was sufficient to perfom their functions. The staff stated that the 5-10 F.C. guidance will not be enforced unless first approved by CRGR since the rule is not specific. The j
staff also indicated that areas where manual actions are required for cold shutdown need not meet the 8-hour requirement unless the area is also used for hot shutdown actions. Reliance upon hand-carried lighting will require I
an exemption.
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$UlDe Agazio. Froject l'anager Albert L.
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Operating Reactors Branch 4. OL Enclosures 1.
List of Attendees l
2.
Viewgraphs 3.
Listine of Material frem Previous Meetings j
cc w/r.clesures:
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MEETING
SUMMARY
DISTRIBUTION
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Licensee: Toledo Edison Company i
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- Copies also sent to those people on service (cc) list for subject plant (s).
Docket File 1,
NRC POR i
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ORBf4 Rdg
- l Project Manager - ADe Agazio
'j JStelz BGr*mes(Emerg.Preparednessonly) i OELD i
NSIC i
EJordan. IE JNGrace. IE ACRS-10 i
j NRC Meeting
Participants:
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Hberly NFioravante j
CRamsey j
TWambach I
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l LIST OF ATTENDEES l
FIRE PROTECTION REVIEW MEETING l
BETHESDA, MARYLAND, JUNE 12. 1984 i
Name Croanization j
A. De Agazio NRC/DL l
l R. Eberly NRC/DE
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N. Fi gavante NRC/DSI C. Xamsey NRC/ Region III T. Waebach NRC/DL D. Arnold Bechtel Power Corporation f
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C. X1et Bechtel Power Corporation 1
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S. Levine Bechtel Power Corporation i
l S. Kasturi Impel Corporation T. Hart Toledo Edison Company
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l J. Haverly Toledo Edison Company i
E. Johnsen Toledo Edison Company M. Furtha Toledo Edison Ceepany R., Peters Toledo Edison Coepany j
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TOLEDO EDISON - NUCI, EAR REGULATORY COMMISSION FIRE PROTECTION PROGRAM STATUS MEETING JUNE 12, 1984 PHILLIPS BUILDING - ROOM 422 TENTATIVE AGENDA 1.
SCHEDULE 2.
SUBMITTAL A.
INTRODUCTION - BACKGROUND B.
FIRE AREAS (TECHNICAL DISCUSSION OF AREAS REVISED FROM BTP 9.5 1, APPENDIX A).
C.
SAFE SHUTDOWN SYSTEMS (TECHNICAL DISCUSSION OF AREAS AND NON-COMPLIANCES THUS FAR IDENTIFIED).
METHODOLOGY RESOLUTION OPTIONS SCHEDULE D.
SUPPORT SYSTEMS (TECHNICAL APPROACH FOR SECURITY, CCMMUNICATIONS).
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E.
ASSOCIATED CIRCUlTS (IECHNICAL DISCUS $10N OF ISSUES l
AND PLANS).
F.
ALTERNATIVE SHUTDOWN CAPABILITY (IECHNICAL DISCUS-
$10N OF SUBMITTAL INFORMATION AND CONTENT OF SECTION),
G.
EMERGENCY LIGHTING (TECHNICAL DISCUSSION OF SUB-l MITTAL INFORMATION AND METHODOLOGY FOR RESOLUTION).
H.
0!L COLLECTION SYSTEM (RESTATEMENT OF POSITION -
STATUS OF EXEMPTION RE00EST).
3.
FIRE PROTECTION PROGRAM - NFPA SUBMITTAL STATUS 4.
ESTABLISH DATES FOR NEXT MEETING (AT DAvlS-BESSE?)
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FIRE AREA
SUMMARY
(PRELIMINARY STATUS - JUNE 11, 1984)
NO N.: N-COMPLIANCES EXF.MPTION REQUESTS d,0N-COMPLIANCES l
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NOTE 1 - (1)
DISCUSS NON-COMPLIANCES.
f (2) ' PROCEDURAL NEEDS FOR COLD SHUTDOWN.
i NOTE 2 - DISCUSS AREA CC.
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l SUBMITTAL SECTIONS
SUMMARY
l 1.
DRAFTS OF SECTIONS 1, 3, 4, AND 5, GIVEN TO NRR ON MAY 31, 1984.
2.
MAJOR AREA REDEFINITION DRAFT GIVEN TO NRR ON MAY 31.
j 1984.
SECT!ON 2 0F'THE SUBMITTAL WILL SUMMARIZE THIS.
3.
SECTION 6, EMERGENCY LIGHT!NG SECTION DRAFT GIVEN TO i
NRR ON JUNE 12, 1984.
4.
SECTION 7, ALTERNATE SHUTDOWN SECTION, INCLUDING I
GENERIC LETTER 81-12 RESPONSES (DEPENDENT ON RESULTS OF SECTION 4).
5.
SECT!0N 8. RCP 0!L COLLECTION,
SUMMARY
OF EXEMPTION j
REQUEST ONLY.
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Enc 1 eure 3
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i DOCUMENTS GIVEN TO NUCLEAR REACTOR REGULATION (NRR), IN ADDITION TO I
DOCKETED INFORMATION.
At January 25, 1984 or March 21, 1984 Meetings 2 i
1.
Appendix R - Fire Area Checklist (being used during area evalua-tions).
2.
Safe Shutdown Components Listing Rev. A (draft of listing of all circuits and components being protected for Appendix R purposes).
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3.
Drafts (2) of Component Location Matrices (samples of listings l
j delineating locations of required components and circuits by Tire Area and Zone).
4.
Potential Deficiency Tracking Procedure (procedure to track all identified deficiencies within project, ipn, addition g NCR/AFR l
method).
4 5.
Discussion and format of all planned submittals.
6.
Per Task 1 and 2 September 1.1984 submittal Table of Contents with proposed sections 3 (Systems), 4 (Area Evaluations, thus far),
5 (Associated Cira.uits)(given to Tom Wombach f or R. Eberly and j
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N. Fioravante on May 31, 1984, in Bethesda).
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7.
Draft of 10 Fire Area positions, in addition to Appendix A approved
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Fire Areas (to be submitted on docket within 1-2 weeks), given to e
j Tom Wombach f or R. Eberly on May 31, 1984).
8.
Tornat of Information of Task 3 and Task 7 resolution submittal.
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Documents Planned to be Torwarded in the Ttturet 2
1.
All April !.6, 1984, Serial No. 1042, to NRC commitments (Tasks 1, 2, i
3, 5, 7).
2.
Fire Area discussion per icea 7 above.
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Analyses or Reports Available for In-house Reviews l
1.
Evaluation of TCR's impacting the Fire Hazards Analyses, Revisien 6 -
l Report No. 02-1040-1164, March 2, 1984.
2.
Associated Circuit Analyses - Report No. 02-1040-1153 (to be f or-varded within Section 5 of September 1, Appendix R submittal).
3.
Emergency Lighting Review - Report No. 02-1040-1145. December 6, 1983.
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4.
Evaluation of Kaowool as a fire resistant barrier - Report No.
01-1040-1262 Revision 1. January, 1984.
5.
Tire Protection Staffing Analysis - Report No. 02-1040-1156. Rev. O.
January, 1984 l
l JSHtnif 6/8/84 1
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i *,, # joe %,,k UNITED STATES NUCLEAR REGULATORY CCMMISSION I
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t MEl:0RAliOUM FOR:
William V. Johnston, Assistant Direr...'
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Materials & Qualifications Engineering, DE t
forLicensIng,sistantDirector Thomas Novak As
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DL Gus C. Lainas, Assistant Director for Operating Reactors, DL Frank Miraglia, Assistant Director for Safety Assessment, DL l
Lester Rubenstein Assistant Director I
4 Core and Contairie,nt Systems, DST i
FROM:
Darrell Eisenhut, Director
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Olvision of Licensing i
nichard H. Vollmer, Director l
t, Division of Engineering i
SUBJECT:
C0!!PLETION OF APPENDIX R EXEMPT!0 tis AND SHUTDOWN MODIFICATIONS l
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l NRR is to cceplete'the Appendix R exemption and shutdown modification reviews usir.g the procedure outlined in this mer.o.
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I During the technical review of licensees Appendix R exerptions and shut-down reviews by CI'EB and ASB, the PM will arrange for the reviewer to get r:eeded inforestion to co:plete the review.
This information should be of the confirmatory or clarification nature on the present submittal.
It i
shouldnotbenewora)ternateproposalstoresolvetheproblem.
This 1
information may be received by telephone or meeting, however, the licensee
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I should document this information within a reasonable per!od of time, which we define as no later than three weeks f' rom the date of the tele-j phone conversation or the meeting with the licensee.
When the SER doeur.enting the results of the technical reviews is l
I received in OL a copy of the evaluation of the exemption, as signed by'theapproprIateA/DinDOEorDSI,shouldbeshowntothelicensee as soon as possible.
The licensee should be given three weeks to inform l
the PM of the action he plans to take, i.e., 1) appeal denials to NRR management (R. Vollmer or R. Mattson, as appropriate), only on the I
results of the technical review; 2) propose another alternative that i
, requires an exemption; or 3) make modifications to meet the specific 1
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requirements.
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AS IfanappealmeetingtoR.Vollmerisrequested,itshouldbearrfGed g
y within six weeks from the date the evaluation was signed. M as a o
result of the appeals meeting, any changes to the evaluation e
made by the reviewer, the revised evaluation will be y the A/D within two weeks after the appeals meeting.
T PM should prepare r
y the package which will be sent to the licensee no later than eight
- y,weeksfromthetimetheA/DinDOEorOSIhassignedtheinitial j'
evaluation.
If the licensee does not request an appeal meeting, the Appendix R licensing action should be completed by granting and denying exemptions as recomme,nded in the SER.
If, for denied exemptions, the licensee proposes an alternative which.
g also requires an exemption, they should be filed under the 3rovisions of paragraph 50.12.
A separate TAC should be issued when tiese are rece,ived for the technical review.of these alternatives.
'f, f:r dir. icd ext:ptiens, the licensee pr: posed to make c0difications, to meet our specific requirements, no additional submittal is necessary.
I Darrell Eisenhut, Director Division of Licensing Richard H. Vollmer, Director Division of Engineering l
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H. Denton R. Mattson V. Benaroya O. Parr R. Ferguson
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V. Panciera
- 1. Sullivan S. Pawlicki T. Wambach D. Crutchfield W. Russell S. Varga
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R. Clark J. Stolz J. Youngblood A. Schwencer F. Miraglia E. Adensam C. Thomas O
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l UNITED STATES l
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'o NUCLEAR REGULATORY COMMISSION i
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i SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGUL_ATION_
1 SUPPORTING AMENDf/ENT NO.
TO FACILITY OPERATING LICENSE NO. OPR-38 AMEND!!ENT NO.
TO FACILITY OPERATING LICENSE NO. DPR-47 l
MENDf1ENT_ NO.
TO FACILITY OPERATING LICENSE NO. OPR-55 DUKE POWER COMPANY _
l OCONEE_ NUCLEAR STATION. UNITS NOS
- 1. 2 AND 3 l
DOCKETS NOS. 50-269, 50-270 AND 50-287 I
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l 1.0 Introduction I
By letter dated March 18, 1981, Duke Power Comany (DPC) requested that License Condition 3.E. of Facility Operating Licenses DPR-38, DPR-47 and DPR-55 for the Oconee Nuclear Station, Units 1, 2 and 3 (ONS) respectively, be modified l
to be consistent with the requirenents of 10 CFR 50.48.
In addition. DPC submitted proposed changes to the comon Technical Specifications (TSs) for i
the ONS by letter dated May 15, 1981, in response to an NRC request dated October 7,1980.
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Durin0 a telephone conversation, a number of misunderstandings and interpre-tation problems related to thn August 11, 1978 Fire Protection Safety Evalua-t tiun Report (SER) were discussed with the NRC staff. By letter dated May 15, 1981, DPC submitted the results of the review of the SER.
I 2.0 Otscussion and Evaluation l
i 2.1 License Condition 3.E.
s On February 17, 1981 Paragraph 50.48(c) of 10 CFR Part 10 became effective.
i Item (4) of 10 CFR 50.48(c) require, in part, that fire protection nodifica-l tions related to dedicated shutdown systems be implemented 30 months after i
NRC approval of final design. License Condition 3.E. which was included in t
the ONS licenses by License Amendments issued on August 11, 1978, requires j
detailed dest n information on shutdown systens to be submitted within 15 L
nonths from N C approval of the system concept.
By letter dated March 18, 1981, DPC requested License Condition 3.E. be revised to reflect the requirenent of I
50.48(c)(4).
l The design description of the Oconee Standby Shutdown Facility ($$F) was sub-mitted on March 28, 1980, and is under NRC staff review.
The S$r is currently under construction and is expected to be completed within the tino required by 10 CFR 50.48(c)(4). We have reviewed the DPC request and find that the pm-j psed revision will clarify NRC requirements and remove any confusion or con-j tradiction of the regulation requirements.
Since this change will ensure compliance with a regulation, we conclude that it is acceptable, j
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2.2 Technical _ Specificatio_ns In addition to the License Condition ncntioned above, the Amendments issued on August 11, 1978, contained a Safety Evaluation Report (SER) related to the conpletion of certain fire protection related nodifications.
Section 7 of the SER stated that the TSs would require upgrading upon completion of the modifi-cations to incorporate limiting conditions for operation and surveillance requirenonts for newly installed equipment.
(The TSs govonling the previously existing fire protection equipment were issued by License Arondments on Februa ry 13, 1978.) Cy letter dated October 7,1930, the flRC requested OPC to submit an application for amendment to upg.*ade the fire protection related TSs to reficct the changes made in this area at the ONS in accordance with our August 11, 1978 SER.
de requested that the applicable nodel TSs be imple-t mented by administrative controls as quickly as possible and that the proposed revisions to the TSs be submitted by January 15, 1981.
DPC, by letters dated January IS, flarch 16, and April 16, 1981, stated that the proposed TSs were being reviewed and presented revised dates for subnittal.
By letter dated i
n, 15, 1981 DPC submitted proposed, upgraded TSs for the fire protection j
features installed in the ONS.
j We have reviewed the proposed changes and additions tc the TSs related to the fire pmtection features at the ONs and find that they adequately address the j
NRC concerne and are in substantial agreement with the Standard TSs for B&W reactors, which were provided as guidance for their preparation.
The DPC i
application proposes to incli.de, in the comon ONS TSs. the CO II#' 5'PPI'55I "
system for the turbine. generators at the Keowee Hydto Station,2a number of fire detectors, sprinkler ar.d spray systens and fira hose stations, which were installed in accordance with the NRC staff's fire protection SER issued on i
August 11, 1978.
Based on the above, we conclude that the proposed additions l
and revisions to the TSs are acceptable.
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2.3 Clarification of August 11,1974SERRequirerents As mentioned above, the Fire Protection SER issued by the NRC on August 11 1978, required DPC to complete stated nodifications to enhance the fire pro-i 1
tection featurcs at the ONS. As a result of a detailed corparisoie of the I
completed fire protection related modifications and the NRC's SER, it was deter-mined that sone nisunderstandings existed on what was actually required. Curing j
a telephone conference between rembers of the NRC and DPC staffs on fiay 5,1981, l
these misunderstandings were substantially resolved.
The areas of confusion were:
a) HVAC Room Doors, b) Water Flow Alams, c) Communication Systens, d) j Sprinkler and Spray Systems, and e) Hiscellaneous Fire Doors and Hatches. By j
letter dated itay 15, 1981, DPC subnitted verification of the statener;ts made during the May 5,1981, telephone conference.
We have reviewed this letter and l
i find the clarification provided to be acceptable for the fo11 ewing reasons, a.
The doors between tne able spreading rooms and their associated HVAC rooms i
need not function as fire doors since the HVAC rooms can be included in the fire l
zone of the cable spreading room.
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b.
The water flow alarns need a uniqueness in that an alarm for each system must 1
be provided.
It is not our intent that a unique alarin to te be provided.
Since i
separate alarns have been provided, this is acceptable.
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FdR:
The Commiss.f oners' FROM:
William J. Oircks y
Executive Oirector for Opera'tions
SUBJECT:
SECY-82 FIRE PROTECTION RULE SCHEDULES AND EXEMPTIONS (QUARTERLY REPORT NO. 4) i y
DISCUS $10N:
'In response to the memora'ndum to me from Mr. Chilk dated February 8 l
1952, enciesed are samples of the letters that we are preparing to i
send to all licensees that have. requested a schedular exemption or are proposing o'r have preposed alternative shutdown capability as a i
means of teeting Aependix R.
A sheple. exemption is also enclosed.
The substance of the exemption and the ';;ondition for meeting the exer; tion are given in the last SectNn,(IV) of the exemption. A l
steple exemption is presented rather than a generic exemption because the exemptions reque'sted differ.
Although test of.the discussion given in the sample will be approprtate for all exemptions, each
- exemptien will have to be tailored to fit the request.
l In En:losure 1 to Quarterly Report No. A we indicated that 30 days frem the cate of exemption issuance be allowed as a grace. period
.l for these licensees who had already made su%ittals. Reconsidera-i tion has led us to the con:1usion that this is insufficient time i
for a licensee to corre:t deficiencies in~.a response. We have,
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therefore, increased the grace period to 60 days.
Five ty;es cf letters are being used.
Letter No.1 is fer these licenstes requesting an.4xenstion until a date in the future more i
than 60 cays fr:: the date of the exer?*ien issuance. Letter Ns. 2 is fCr these licensees re: Westing an f,xt?ptien until a cate in the future less than 60 days frc-tre date f exte;;ien issuan:v.
l Letter No. 3 is fCr thCse licensees wh0 rt;ues*,ed a d' te *,htt is s
already ;assec.
Letter NC. 4 is for th0se litennets who requested ne exe ;; fen, but whose submittals were inco plete.
Letter No. E is fer these licensees that have renested a sub:stt 1 date beyond July 1, 1952.
It grants the re;uest,ed exe ptien in : art, i.e.,
i until July 1,1952.
Our basis for not ; ranting the remainder of tne tire is itat it c es n:t a;; ear that the litersee is a;;1ying e
its test effort at, reselving an
- ca;1eting ',his is sue, tased en 3," /
the resp 0nse of the great majority cf the incustry.
e We intend to issue all of tha letters centerning txen;* ions fCur
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weeks from tJday and letter he. 4 t'e thCse who did BCt request exenstion but have in;Ceplett submittals t=0 weeks frcm tocay.
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We will preceed en this schedule unless instru:ted otheNise.-
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T. Y. Vattach Ext. 27072 l
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.* i k'ith regard to your instruction to increase our resources applied to this program for review of these submittals, we believe we have sufficient resources, including the contractor personnel at Brookhaven National 1.aboratory, to complete the review of design descriptions of the al,ternative shutdown modifications within six months.
Since our meeting with you ta January, we have increased the number of Fire Protection Engineers in the Chemical Engineering Erane5 to three and additional personnel;within that Branch are also available to assist in.the review of exemption requests.
Therefore, if the. number of exemption requests filed with these delayed submittals is not excessive.; we feel that we new have sufficient resources also for the review of the fire protection aspects of exemption requests.
Wilitam J. Dircks i
Executive Director for Operations i
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Letter No.1 s
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Gentlemen:
SUBJ ECT':
EXEP.PTION RE0 VEST - FIRE PROTECTION RULE SCHEDULAR REQUIREMENTS OF 10 CFR 50.4S(c) - (Plant Name)
The Fire Protection Rule (10 CFR 50.48) publ.ished on November 19, 1980, became effective on February'17,1981, and required the results of certain tasks to be submitted to the Nuclear Regulatory Comqissien (NRC) by March 19, 1981.
By letter dated
, you applied 'for exemotion from some of these ' schedular requirements of 10 CFR 50.4S(c).
The exemption requested.
related to the time allowed to ec p1.ete a reassessment of the fire pretection features at yeur plant for conformance to the specific requirements of Section III.G of Appendix R to 10 CFR 50; to evaluate the difference determined for each area; and to design modificat' ions to meet the require-ments or provide a' justifiable basis by means of a fire ha:ards analysis for an exemption from such requirements.
For reasons as stated in your exemption request, you requested additional time to complete the abcve reassessments, l
evaluatiens and designs.
(By letters dated
, you revised your request.)
The Commission has granted ycur request as descr'ibed in the enclosed exemption.
The exe : tion is cenditienal upon a recuirement that the submittal be cemplete, as cefinte in the'exem;; ion.
If the Directer of the Office of Nucle-ar Reactor Regulation shculd determine that your' submittal is net cer:1ete, you will be found in viciation of 10 CFR 50.4E(c).
Such a violation will be a continuing en* f r0" the cate grantec by the exem;tiCM and a Civil ;tntity may be imposed fe' Jac' day the vi0lati0n CCntinues.
A c0ry c' inis ett'; tion is being filec with tne Office cf the Fectral Register f0r ;.D1ica'ien.
Sincerely,
Enclosure:
E xtNptio n ec w/enciesure:
See nex* ; age
Letter 2 - Same as letter 1 except for sentences 3 and 4 of 2nd paragraph.
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Exemption to be changed accordingly.
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Gentlemen:
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SUBJECT:
EXEMPTION REQUEST - FIRE PROTECTION RULE SCHEDULAR REQUIREMENTS 0F 10 CFR 50.4B(c) - (Plant Name)
The Fire Protection Rule. (10 CFR 50.48) published en Noven.ber 19, 1980, became effective on February 17, 1981, and ' required the results of certain l
l tasks to be submitted to the Nuclear Regulatory CesT.ission (NRC) by March 19 f
~1951.
By letter dated
_. ycv applied for exemption from some i
J of these schedular requirements of 10 CFR 50.4B(c).
The exemption requested related to the time allowed to complete a reassessment of the fire protection i
features at your plant.for conformance to the specific requirements of i
i Section !!!.G of Appendix R to 10 CFR 50; to evaluate the difference i
l determined for eat.h area; and to design modifications to meet the require-l j
ments or provice a justifiable basis by means of a fire hazards analysis for l
1 an exemp* ton from such requiremen'.s.
For reasons as stated in ycur exemption j
request, ycu requested additional time to complete the above reassessments.
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evaluations and designs.
(By letters dated
, you revised your request.)
The Cc=ission has granted your request as <!escribed in the enciesed exemption.
f The exemption is conditional upon a requirement that the submittal be complete.
h as cefined in the exer;tien.
Since the submittal date granted by this exe%. tion i
j is within 60 csys' of the date cf.this' exemption, ycu are given a grace peried I
of 60 days af ter yeur receip* of t51s exerption *o ecmplete your submittal.
If l
the Director nf Nuclear Reacter Regulatien should Ce'er-itie af ter the 60 days i
i-has ela: sed that your suhittal is net com;1ete, yeu will be feund in vie. latten I
cf 10 CFR 50.4E(c). Sven o violation will te a continuin; che f rcm the
(
l cate granted by the exempticn and a civil ;enalty may be imposed for each j
c4y the violation CCntinues.
4 l
A ccpy of this exemctien is bein; filed with the Office of the f ederal l
j Register fer ;Ublicatien.
l l
j Sincerely, 1
\\
4 i
1 1
i i
Enciesure:
I j
Exerptien j
cc w/ enclosure:
j See next page h
fu
tetter 3 - Same as letter 1 except for sentences 3 and 4' of 2nd* pagagraph.
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Exemption to be changed accordingly.
.}
Gentlemen:
r
SUBJECT:
EXEMPTION RE00EST - FIRE PROTECTION RULE SCHEDULAR REQUIREMENTS OF 10 CFR 50.4B(c) - (Plant Name)
.d i
The Fire Protection Rule. (10 CFR 50.48) published on November 19,:1980, i
became effective on February 17, 1981, and required the results of certain tasks to be submitted to the Nuclear Regulatory Cc7 mission (NRC) by March 19, 1981.
By letter dated
, you applie'd for exemption f rom some of thes'e schedular requirements of 10 CFR 50.45(c).
The exemption requested i
related te the time allowed to complete a reassessment of the fire protection I
features at yeur plant for conforman:e to the specific requirrents of l
l Section I;1.G of Appendix R to 10 CFR 50; to evaluate the cifference l
determined for each area; and to design modific'attens to meet the require-ments or provide a PJstifiable basis by means of a fire ha:ards analysis for an exemption from sui;h requirements.
For reasons as stated in your exemption i
request, you request 4d additional time to cceplete the abeve reassessrents, evaluations and desi;ns.
(By letters dated you revised your request.)
The Cc. mission has granted your request as des'cribed'in the enciesed exemption.
The trem; tion is. conditional u;ct a requirement that the sut-ittal be complete, as cefir.ed in the exe ;;ien.
Sin:e the sutmittal cate gra-ted by this ext ption has already passed and your sub9ittal has already teen made, ycu are given a f
grace ;eriod cf 60 days af ter ycur receipt of ',nis exem;tien te c:9plete your sutnitial.
If tne Dire: tor of ',he Office cf Nuclet' Res;ter Regulatien sh;uld l
ceter-i e af ter the H cays has ela: sed that ytur sub9ittal is n:' cc ;1ete, y u will te f 0gnd in viclation Of 10 CFR 50.*E(:).
Su;n a violaticn mill l
te a ::ntinuin; cre fro-the cate grantes by ;"e eit ;tien and a civil penalty n!y be i ocsed for ea:n ety the vi0lati:n 0:n*,inues.
l A c;;y c f thi s e x t ';*,i c h is tein; filed with t*.e Of fict cf the Itdtral T. 3 p i s '.e '* f C r 7.l5 I i : a ti 0 n.
l S i nce rely l
I i
E rt.l c s u re E Jt ePp tic n I
l CC w/ enclosure:
$ee next paSe l
j
)'
Letter 4 p.
f Gentlemen:
FIRE PROTECTICN RULE 10 CFR 50.a!(c)(5) - ALT!b ATIVE SAFE J
5"!JEC7e SKUTOOWN - SECTION 111.G.3 0F APrENDlx R TO 10 ',FR 50 (Plant Name)
The Fire Pr.ctection Rule (10 CFR 50.48 and Appendix I to 10 CFR 50) became effective on February 17, 1951.
Piragra;h 50.4S(c)(5) requir,ed submittal design descriptiens of codifications needed to satisfy Section Ill.G.3 of,of l
1 A:pendix R to 10 CFR 50 by Marc.h 19, 1951.
By letter dated
, you submitted the design description of i
modifications requireo to meet section Ill.G.3 of Ap;endix R to 10 CFR 50 for (Plant Name)
We have reviewed yo r submittal and find that aeditional infor.Tation is required for us to ecTplete our review.
The l'
information required was originally requested from you by letter dated l
Feb rua ry 20, 1951.
The enclosure to this letter indicates what information l.'
you have not supplied.
Provide a ec piete response of items incicated in i
the enciesure within 60 days of receipt of this let,ter.
If.ycur response l
is not ec clete at that tiet, y cu will be fcund in viciation of 10 CFR
!;.a!(c)(!).
Such 4 violatien will be a centing:n; ene and a civil penalty may be ir;esed fer'each cay the violatien centinues.
1 (i nc e r ely,
1 l
l l
i I-:lesure:
i EldLtsk fCr ac,",iti0nal Informatien CC W/ enc 1Csure:
See next page e
i 9
c a
e e
Letter 5 - Same as Letter 1 except for new 2nd paragraph - must be incorporated into Exemption s
~
s Gentlemen:
SUBJECT:
EXEMPTION RE00EST - FIRE PROTECTION RULE SCHEbutAR REQUIREMENTS OF 10 CFR 50.4S(c) - (Plant Name)
.+
The Fire Protection Rule, (10 CFR 50,45)' published on November 19,19$0, became ef fective on February 17, 1981, and required the results of certain tasks to be submitted to the Nuclear Regulatory Ccqmission (NRC) by March 19, 1961.
5,y letter dated
, ycu applied for exemption from some of these schedular requirements of 10 CFR 50.4B(c).
The exemption requested; i
related to the time allewed to c.cmplete a reassessment of the fire protection features at your plant for conferman:e to the specific requirements of Section Ill.G of Appendix R to 10 CFR 50; to evaluate the difference determined. for each. areat and to design modifica'tions to meet the require.
i nents er provide a justifiable basis by means of a fire ha:ards analysis ter i
an esem;tien f rom such requirements.
For reasons as stated in your exemption i
request, ycu requested additional time to co plete the above reassessments, I
evaluations and designs.
(!y letters dated
, you revised your request.)
The Cc.-ission has granted your exe ; tion retuest.in part.
You requested that the date f0P submittal be extended until The Cc nissi:n has granted an extensi0n until July i.1952. Inis cate is talec u;0n the restense of all the licensees with regard to the time needed to cerform the reassess ent re;uired and the redesign of glar. features if necessary.
All but a few ii:ensees indi:4ted sub.ittal cates ;rier te July 1,1952, and any have alrea:y rede ineir sub-itta15.
On tnis basis, l
- e c a r. :t fi n: t%:t y:ur ;r:::sec s:recule exhibits ycur test'ef fort in l
-tetin; ine re;uire ents cf 10 ;rR 50.45(c) anc R;;encit R i: 10 CFR !O.
l intref:ra, in tne jue;-ent cf the :: mis sien, the tire ela;sec frem l
Neve.:er li,1950, when tne Fire Prete: tion Rule was pu listed, until luly 1,1952, albs acequate tire f er y0u te c ;1ete yeur W+=+r-t, f u b-i f fel.
'f y ur res::nse is not ec ;1ete en July 1,1952, ycu will de fcund in vitiati:- Of 10 CrR !O.45(:1(51.
Su:n a vi:1stien mill te.a centinuin;
- .e a-: : :ivil ;tralty may :e im: sec f r ta:h cay tre vi:lati:r. cea.tinues.
Si nc e rely,
i t
i Enc 1Csure:
Exemptien f
I CC h/en:lCsure:
See next page
[
.l
NUCLEAR REGULATORY COMIS$10N
(
In the Matter of
)
)
'I CAR 0'.IN A. POWER AND LIGHT
) Docket hos. 50-325 eM 50-324 CO.MPANY
)
(Brunswick Steam Electric Plant
)
Unit Nos.1 and 2)
)
EXEMPTION 1.
The Carolina Power and Lignt Ccmpany (the licensee) is the holder of Facility Operating License Nes. OPR-71 and DPR-62 which authorize operatien l
ef the Brunswick Steam Electric-Flant (ESEP), Unit Nes.1 and 2.
These l
licenses provide, among other things, that they are :Jbject to all rules, regulations and Orders of the Cc. mission now or hereaf ter in effect.
1.-
l The f acility comprises two boiling water reactors at the licensee's site Ic:ated in Srunswick County, North Carolina.
l l
11, l
On N:ve-te r 19. 1950, the Cc-.ission publishec a revised Se:tien 10 CFR 1
50.15 a*: a rea i;;en:ix E to 10 CFE 50 regarding fire ;r:*.e:tien features cf 1
- ,v:h a * ;;a t t ple".ts (?! F.R. Mf 02).
The revisec Se:tien 50.45 aat A;;encia R teta e ef fe:tise en Februt*y 17, 1951.
Se:tien E0.4E(c) estat11sted the schtcules fer satisfyin; tne previsiers of A;;entix E.
Se:ti:n 111 of A;;en:ix t :ta.taias fif teen,sutst:tiens, letterec a t*rew;% 0, ta:h ef nich s;e:ifies reautre ents fer e particular aste:t cf the fire ;rcte: tion features at a nuclear ;e er plant.
One of these fif teen subst:tiens 111.G., is the subje:t of this exer; tion request.
Ill.G. s;ecifies detailed require:ents for fire prote:tien ef the equi;. ant used for safe shutdewn by reaes of se;aration and barrie rs (!!1.G.2 ).
If the requirerents for,e:aratien and tarriers ceuld nct be ret in an area, alternative safe snutdein capability, ince;endent of that area and equi; ent in that area, was required (!!1.G.3.).
e o
l i
k
'Section 50.48(c) requircd completion of all modifications to.eeet the l
provisions of Appendix R within a specified time from the effective date of this 1
~ fire orotectio'n rule February 17, 19,81', except for modifications to provide l
alternative safe shutdown capability.
These latter modifications (!!!.G.3.)
1 require NRC review and approval.
Hence, Section 50.43(c) requires their completion' within a certain time af ter liRC approval.
The date for submittal cf design descriptions of any modiiications to previce alternative safe shutdown capability was specified as 'iarch 19, 1981.
l Sy letter cated l' arch 6,1981, as amended September 14, 1951, and January 18 j
1982, Carolina Power and 1.ight requested exemptions from 10 CFR 50.4S(c) with 1
respect to the requirements of Section !!!.G of A;pendix R as folleas:
(1)
Extend fec-Narch 19, 1951, te June 30, 1952, the date for submittal of
- lans anc schedules
- a:hieve ec ;11ance with !!!.G.2 recuired by
$fD.45(e)(5);
(2)
Extea: f r:913. arch 19,1911, to June 30, 1962, the cate.f0r filin* aceiticnal ese :tiens fre-5e:tien !!!.'S.
vesva*: to $$50.12(a) at: 50.:!(c)(6),
(3) l x *.e n f ec "ar;h 19, 1951, tc J ua,e 30, 1951,
+,*e cate f0r su:*ittal cf l
cesi;*. ces:ri;ti:ss cf alternative er cecicate: shutd0wn systems to ces:1y wi*h Se:tich Ill.G.3., if su n are nt:essaryi a*:
l i
(4)
E tte
- fr;"' FebrWar/ 17, 19M to Ju*e 30,1952, the date frc* whicn the i a l *, tilati0r 50tt0ules establiste if $!O. !(c)(2) ar.: 13) are :al:ulatec.
Ben this.~Tirt F r0'e:t.icn Rule eies a;;revec by the OC-3.issi0n, it, was l
unders'cC# tha* }he time rtquired for each licenset 10 i't tKa-int Dese r
I previously-approved configuratiens at its plant to detert",ine whet,her they meet l
the requirements of Se:tien Ill.G ef Ap;endix R to 10 CFR 50 was n:t well known and wouic vary dependin; d;:n the degree of confer ta:e.
Ter ta:h item of non.
i c0nfor an:e that was fcu'O. a fire ha:ards analysis had to be perfer ed to j
determine whether 'the existing configuraticIn ;r,'cVidec sufficient fire prctectien.
l If it did, a basis had to be for ulated for an ext ;tien recuest.
If it did act,
3
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. modifications to either meet the requirements of A'ppehdi1R,or to provide some other acceptable' configuration, that could be justified for an exemption, had.
I to be designed.
Where fire protection features alone could not ensure pro-tection.cf safe shutdown capability l' alternative safe shutd wn capability had to be designed as required by 'Section III.G.3'. of Appendix R.
Depending upon
~
the extensiyeness and number of the areas involved, "the time required for this re-examination, reanalysis and redesign could vary from a fed months to a' year or more. The Commission d'ecided, however, to require one, short-term date for all licensees in the interest of ensuring a best-effort, expedited completion of compliance with the Fire Protection Rule, recognizing that there would be a number of licensees who could not meet these time restraints but who could then
~
request appropriate relief through the exemption pr,0 cess. Licensees for 44 of the 72 plants to which Appendir. R applies (plants wi+.h an operating license issued prior to January 1,1979) have requested such schedular relief.
The licensees for the remaining 28 plants made submittals to neet the, schedular recuirements of 50.4S(c).
All of these submittals, however, were deficient in some respects.
In general, mucn of the information requested a
in a generic letter (81-12) dated February 20, 1981, to the licensees of all 72 olahts, was not creviced.
Tnerefore, adcitienal time is being used to t
complete those submittals also.
3 III.
)
Prior to the issuance of Appendix R, the Brunswick Units had been reviewed against the crit'eria of Appendix A to the Branch Technical Fosition 9.5-1 (BTP 9.5-1).. The BTP 9.5-1 was developed to resolve the lessons learned from the fire at Browns Ferry Nuclear 11 ant, itisbroaderinscopethan j
Appendix R, formed the nucleus of the' criteria developed further in Appen' dix R It
s 5
4 e
and in its present, revis'ed form constitutes the 'section of the Standa'rd Review' I
Plan used "fur the review of applications for construc' tion.pemits and operating licenses of new plants. The. review was compieted by the NRC staff and its fire protection cons.ultants and a Fire Prote.ction Safety Evaluation (FPSER) w'as issued.
~
A few itgms remained unresolved.
Further discourse between the licensee and the NRC staff resulted in resolution of these items as documented in'two supplements to the FPSER._ The FPSER and its supplements support'e'd the issuance of amendments to the operating licenses of the Brunswick UnitsEwhich requir'ed modifications' to be made to plant physical. features, systems, ar}d administrative controls to meet the criEeria of Appendix A to BTP 9.5-1.
All of these modifications have 1
been c'ompleted.
Therefore, the' Brunswick Units have have upgraded to a.,high degree of fire protection already and the extensive reassessment involved in this request for additional time is to quantify, *in, detail, the differences betwee'n what was re'contly approved and the specific requirements of Section III.G to Appendix R of 10 CFR 50.
The licensee also stated in the request for exemption that all other sub-sections of Appendix R would be met on the schedules required by 10 CFR 50.4S(c)'.
As mentioned earlier there are 14 other subsections which contain criteria for other aspects of fire protection features.
One of these,Section III.L., provides the criteria fcr Alternative Safe Shutdown capability anc thus affects the final
. reassessment and redesign, if necessary, of this feature at the Brunswick Ur.its.
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Nevertheless, this means that compliance with thh remaining app)icable sections of Appendix R have been or will be completed on or before the implementation dates required by the Fire Protection Rule.
1/
- Brunswick Unit 1 - Operating License DPR-71 Amendment 11 supported by FPSER issued November 22, 1977 Amendment 23 supported by Supplement l',to F.PSER is; sued April 6,1979 Amendment 28 supported by Supplement 2 to FPSER issued June 11, 1980 Brunswick Unit 2 - Operating License DPR-62 Amendment 37 supported by FPSER issued November 22, 1977 Amendment 47 supported by FPSER issued April 6,1979
Base'd on the above considerations, we find'that;,the licensee has completed a substantial part of the fire protection features at Brunswick Units 1 and 2 in conformance with the requirements of the Fire Protection Rule and is applying signific, ant effort to complete the r.eas;essment of any remaGing modifications which 'might be necessary for strict conformance with Section III.G. We find l
that because of the already-completed upgrading of these facilities, there is no undue risk to the health and safety of the public involved with cont.inued operation until the comp 1'etion o'f this reassesment on June 30, 1982.
Therefore, an exemption should 'be granted to allow such time for completion.
However,.
because we have found that most submittals of this reanalysis to date from other licensees have not been complete; that is, not all of the informat' ion requested by' Generic Letter 81-12 dated February 20, 1981, was provided, we are adding a condition to this exemption that recuires all such information to be submitted-by the date granted.
IV.
Accordingly, the Commission has determined that, pursuant to 10 CFR 50.12.,
an exemption is authorized by law and will not endanger life or preperty or the common defense and security and is otherwise in the public ipterest and hereby grants the following exemptiens with respect to the requirements of Section 1
111.G. of Appendix R to 10 CFR 50:
(1)
The date, March 19, 1981, for submittal of plans and schedJ1es to achieve compliance as required by $50.48(c)(5) is extended to June 30, 1982; i
(2)
The date, March 19, 'i981 for filing exemption requests pursuant to
$50.48(c)(6) which includes a telling provisi.on is extended to June 30, 1982; (3). The date, March 19, 1981, for submittal of design descriptions of alternative or dedicated shutdewn systems to comply wi,th Section Ill.G.3, as required by i
$50.48(c)(5) is extended to June 30, 1982; and (4)
The date, February 17, 1981, from which the, installation sch'dules established in $50.48(c)(2) and (3) are calculated, is extended to June 30, 1982;
a n
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' Provided the following conditions are met:
1).
Requests f'or exemption pursuant to $50.48(c)(6) must include:
a) 'kconcisestatementofth'eextentoftheexemption; b)
A concise description of the' proposed alternative design features
~
related to assuring post-fire shutdown capability; and c) a sound technical basis that justifies'the proposed alternative in terms of protection afforded to post-fire shutdown capability.
degree of enhancemerit in fire safety by: full compliance with' 111.G requirements,'or the detriment to plant safety incurred by
__ full compliance with III.G.fA simple statement that.the feature m
. for which the exemptlon is requested was previously approved by N
-the staff is not sufficient.
A simple assertion that in the licensee's judgment the feature for which the exemption is requested is adequate fire protection is not sufficient.
2).
The design descriptions of alternative or decidated shutdown s/ stems to comply with Section III.G.3., as required by $50.48(c)(5) shall include a point-by-point response to each. item in.Section 8 of inclosure i to generic letter 81-12 dated February 20, 1981, and-to
(
each item in Enclosure 2 to. Generic t.etter 51-12, dated February 20, 1981.
if the licensee does not meet the above conditions, the licensee will be found in violation of 10 CFR 50.48(c) even though the sub.ittal'may be made within the time limit granted by the exemption.
If such a violation occurs, imposition of a civil penalty will be considered under Section 234 of the Atcmic Energy Act, as amenced.
Such' a violation will be a continuing one
,begin'ning with' the date set in the exemption for submittal and termi: 'ing
. when all inadequecies are corrected.
A delay in the determination of inadequacy by the staff, daused by the work-load associated with reviewing all of the submittalt falling cue near the same timte, will not relieve the lice'nsee of the responsibility for completeness of the submit-
)
tal, nor will such delay cause any penalty that may be impesed to be mitigated.
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7-The NRC staff has determined that the granting of this exemption will not result in any significant environmental impact and that pursuant to 10 CFR 51.5(d)(4) an environmental impact statement or negative dec.laration'and. environ-mental
- impact appraisal..need not be repared in connection with this action.
FOR THE NUCLEAR. REGULTORY COM'4ISSION Harolci R. Denton, Director Office of Nuclear Reactor Regulation Dated at Bethesda, tiaryland this i
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