ML20205Q454
| ML20205Q454 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 05/13/1986 |
| From: | Gears G Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8605280298 | |
| Download: ML20205Q454 (10) | |
Text
-
~
UNITED STATES g
NUCLEAR REGULATORY COMMISSION L
j WASHINGTON, D. C. 20556 May 13,1986 Docket No. 50-277/278 LICENSEE: Philadelphia Electric Company FACILITY: Peach Bottom Atomic Power Station, Units 2 and 3
SUBJECT:
May 6,1986 MEETING WITH THE PHILADELPHIA ELECTRIC COMPANY (PECo) TO DISCUSS THE SPECIAL CIRCUMSTANCES FOR THE LICENEEE'S FEQUESTED EXEMPTIONS TO APPENDIX R TO 10 CFR 50 On Tuesdav May 6, 1986, a meeting was held at the NRC headquarters in Bethesda, Maryland to discuss the special circumstances for the licensee's requested exemptions to Appendix R.
Fire Protection Frogram, to 10 CFR 50.
The licensee requested exemptions to Appendix R in letters dated May 27, 1983. September 16, 1983, September 17, 1984, May 23, 1985, and September 24, 1985.
The special circumstances are in the final rule revising the criteria in 10 CFR 50.12(a) for granting exemptions from the requirements in 10 CFR 50.
The final rule was published December 12, 1985 (50 FR. 50764) and was effective on January 13, 1986.
The revised criteria would authorize the Commission to grant exemptions which are authorized by law, will not present an undue risk to the public health and safety, are consistent with common defense and security, and are justified by "special circumstances".
i is the list of individuals that attended the meeting. is the proposed meeting' agenda offered by the licensee.
The following is a summary of the significant items discussed and the actions, if any, taken or proposed.
1.0 Special Circumstances for Exemptions To Appendix R to 10 CFR 50 By letters dated May 27, 1983, September 16, 1983, September 17, 1984, May 23, 1985 and September 24, 1985, the licensee requested the following list of exemptions requests:
ni!52gggteggg;7 S
F
p
-y-i) Penetration Seals Materials An exemption was requested from Section-III.M of Appendix R to 10 CFR 50 to the extent that it requires penetration seals which utilize only non-combustible materials.
ii) Radwaste Building HVAC Equipment Area (Room 292, Elevation 150)
An exemption was requested from the the specific-requirement of Section III.G.2.a to the extent that the duct penetrations through the fire barrier.are not
.ith fire dampers.
provided w
iii) Turbine Building and Reactor Building (Fire Areas 8 and 50)
An exemption was required from the specific requirements of Section III.G.2.b to the extent that automatic fire suppression systems are not_ installed throughout the fire area at elevation 195 feet.
iv) Five Areas Relating to Damper Installation or Modification o
Main Steam Pipe Tunnel-Unit 3, Elevation 135 Feet.
An exemption was requested from the specific requirement of Section III.G.2.a to the extent that duct penetrations through fire barriers are not provided with fire dampers.
o Standby Gas Treatment System Penetrations An exemption was requested from the the specific requirements of Section III.G.2.a to the extent that duct penetrations through fire barriers are not provided with fire dampers.
o Control Rod Drive Equipment Area-Unit 2, Elevation 135 Feet An exemption was requested from the specific requirements of Section III.G.2.a to the extent that duct penetrations through fire barriers are not
-provided with fire dampers.
o Switchgear Room Duct Chase-Unit 2, Elevation _135 and 165 Feet
n i
.-m..
c 3
- e An exemption ynis requested from the specific requirements of Section III.G.2.a to the extent that fire dampers with fire rating of less than 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> are provided in the duct penetrations.
o Spent Resin Tank Room-Elevation 91 Feet, 6 Inches An exemption was requested from the specific requirements of Section III.G.2.a to the extent that
' fire dampers with fire rating of less than 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> are provided in the duct penetrations.
v.
Outboard Main Steam Isolation Valve Rooms (Fire Areas 208 and 254)
An exemption was requested from the specific requirements of Section III.G.2.a to the extent that non-rated blowout panels and open vertical labyrinth do not provide 3-hour fire rated barriers.
vi. Emergency Cooling Tower Fire Detector An exemption was requested from the specific requirements of Section III.F to the extent that automatic fire detection in this area would not be provided.
In the licensee's letters of May 27, 1983, September 16, 1983, September 17, 1984, May 23, 1985 and September 24, 1985, a discussion of special circumstances for requesting exemptions to Appendix R based upon the final rule revising the criteria in 10 CFR 50.12(a) was not provided since these exemption requests preceded the effective date (January 13, 1986) of the final rule (50 FR 50764).
The licensee stated in this meetir.g, as special. circumstances, that the existing and proposed fire protection features at Peach Bottom would result in accomplishing the underlying purpose of the rule (Special Circumstance ii).
A more detailed analysis of the special circumstances is detailed below:
i) Penetration Seals The technical requirement of Section III.M of Appendix R would not be met because certain penetration seals are not entirely constr ucted of non-combustible materials.
- However, the licensee states that they have committed to refurbishing 1
all subject seals used in fire rated barriers in accordance with the staff accepted ASTM tests.
Therefore, it is the
.m
__._.-.__.,m.
..w.e
-q-licensee's position that the modified seals will provide adequate performance under fire conditions and provide an equivalent level of protection to that required by Section III.
M.
Thus, the application of the regulation in this particular circumstance is not necessary to achieve the underlying purpose of the rule (Special Circumstance 11-50 FR 50764).
Additionally, compliance with Section III. M concerning the subject seals would result in costs that are significantly in excess of those contemplated when the regulation was adopted since it would result in the complete removal and total replacement of all seals in question.
ii) Autom.atic Fixed Suppression System (Elevation 195 )
Implementing automatic fire suppression systems would require the expenditure of engineering and construction resources as well as associated capital costs which would represent an unwarranted burden on the licensee's resources (special Circumstance iii). The costs which would be incurred are as follows:
o Engineering and installation of additional piping, sprinkler headers, and supporting structures, o Increased surveillance on new fire suppression systems.
The licensee also states that the combustible loadings in these areas are low.
In addition, there is separation between safe shutdown equipment in excess of 100 feet with no intervening combustible and numerous intermediate barriers including floor slabs.
Thus, the application of the rule in this particular circumstance is not necessary to achieve the underlying purpose of the rule (Special Circumstance ii).
iii)
Dampers in the Radwaste Building Installing 3-hour rated fire dampers would require that this ventilation system would have to be taken out-of-service while installing fire dampers.
In order to prevent the migration of contaminated gas and particulates to non-contaiminated areas elaborate temporary air filtration systems would be needed or costly decontamination operations would result.
In either case, the costs which would incur include:
o Engineering and installation costs of a temporary air filtration system
n.
-..-...a
..u......
._._a.
. o The costs involved in the need for special ALARA procedures during the installation process The licensee states that these costs would result in undue hardship significantly in excess of those contemplated when the regulation was adopted. In addition, the existing and proposed fire protection features (including line heat detectors and alarms in the control room), the lack of intervening combustibles, and spatial separation taken together accomplish the underlying purpose of the rule (one shutdown division remaining free of fire).
iv)
Dampers in Five Areas For dampers in these five areas, the licensee indicates that compliance in this particular circumstance is not necessary to achieve the underlying purpose of the rule since the combustible loadings in areas adjacent to each penetration is low and the existing ducts are of substantial steel construction to reduce the possibility of fire propagation.
Also smoke detectors are provided on at least one side with alarms in the control room which would permit quick dispatch of fire brigades for manual suppression.
Until the fire is extinguished, separation and intermediate barriers between safe shutdown systems, the steel construction of the duct, and low combustible loadings would provide sufficient protection to achieve the underlying purpose of the rule (i.e.,
one safe shutdown division will remain free of fire).
As an alternative, new sections of duct could be installed at each barrier penetration location which would parallel the existing duct work and serve as a by-pass in the event of damper failure.
The licensee states that the cost and time associated with this approach is extremely high and represents costs in excess of those contemplated when the regulation was adopted.
v) Blowout Panels (MSIV VALVE ROOMS)
Blowout panels and open labyrinth do not provide 3-hour fire rated barriers.
The equipment required inside the MSIV rooms are needed early in shutdown.
In addition, the licensee states that the equipment cannot be caused to operate spuriously from the MSIV room.
It is the licensee's position that the combustible loadings in these rooms and adjacent areas are low and since there is an inability of spurious operation, required compliance to Section III.G.2.a is not necessary to achieve the underlying purpose of the rule (safe shutdown). In addition, required compliance would result in the following excessive associated costs:
1 m
p.u z_._..
o Engineering.and installation of fire barriers, supports, support protection and ongoing maintenance o Engineering of a new system to permit bypassing of steam venting in the event of a high energy line break (the function of the existing blowout panels)
These costs would be significantly in excess of those contemplated when the the regulation was adopted.
vi) Emergency Cooling ~ Tower Fire Detectors The licensee stated that although safety-related cables in conduits are located in this area (stairwell), no other fixed combustibles are present and access is controlled by security personnel.
This. area is not used for storage and current administrative controls on combustibles preclude the presence of a fire hazard.
Therefore, application of the regulation (Section III.F of Appendix R) in this particular circumstance is not necessary to achieve the underlying purpose of the rule (safe shutdown).
The staff stated that the licensee has provided the additional information relevant to the need for the requested exemptions.
2.0 Fire Protection Evaluation Report (FPER) Format i
The licensee and the staff discussed the proposed FPER ieport concerning the Appendix R review at Peach Bottom.
The general discussion included the use of the Perry FPER as model, need for exemption information in the FPER, and the referencing of surveillance and operability requirement in the FPER.
In addition, both staff and licensee discussed the recently issued Generic Letter on Appendix R (Generic
)
Letter 86-10. April 24, 1986).
)
3.0 App "A"
versus App.
"R" Barriers i
This issue was discussed in connection with the guidance provided by the staff in Generic Letter 86-10.
j
. 4.0 Structural Steel Review The NRC staff discussed the timing of the Peach Bottom Structural Steel review with the licensee.
Further discussions on this issue may be forthcoming based upon the staff's analysis which is scheduled to be completed and transmitted to the licensee in June.
5.0 Continued Need for "Tri yearly" Status Reports The NRR staff indicated that the Pegion 1 Confirmatory Action Letter (CAL 86-07. April 11.
1986) and its reporting actions could replace the licensee *s voluntary tri yearly status report.
The NRR staff indicated that it still intends to maintain close contact with the licensee's staff in order to follow the progress of the Appendix R modifications.
6.0 Present Overall Program Status As a result of the Region 1 audit of the Peach Bottom Appendix R progress, the licensee has indicated the steps have been taken to assure that the all completion dates will be met.
These completion dates are outlined in the Region 1 Confirmatory Action Letter cited above.
The NRR staff indicated that its current Appendix R reviews are on schedule and that it awaits the submittal of the Appendix R FPER scheduled for September 30, 1986.
Original signed by/
Geralo E.
Gears. Project Manager SWR Project Directorate M2 Division of BWR Licensing
,. D151819WI100 c_DocketJfilel Enc l o sur es.
NRC PDR 1.
List of Attendees for Meeting Local PDR 2.
The Licensee's Proposed Meeting Agenda NRC Participants PDH2 Reading GGears cc w/ enclosures DMuller See next page EJordan OELD DBI M2 DBL PDM 2 ACRS(10)
G SN ris BGrimes 05-86 05/18/86
- 2. w...
.....~
..~. - =. - - -
- - -. ~. =
6 k
Mr. E. G. Bauer, Jr.
Peach Bottom Atomic Power Station, Philadelphia Electric Company Units 2 and 3 CC:
Mr. Eugene J. Bradley Mr. R. A. Heiss, Coordinator Assistant General Counsel Pennsylvania State Clearinghouse Philadelphia Electric Company Governor's Office of State Planning 2301 Market Street and Development Philadelphia, Pennsylvania 19101 P.O. Box 1323 Harrisburg, Pennsylvania 17120 Troy B. Conner, Jr., Esq.
1747. Pennsylvania Avenue, N.tl.
Mr. Thomas M. Gerusky, Director Washington, D.C.
20006 Bureau of Radiation Protection Pennsylvania Department of Thomas A. Deming, Esq.
Environmental Resources Assistant Attorney General P.O. Box 2063 Department of Natural Resources Harrisburg, Pennsylvania 17120 Annapolis, Maryland 21401 Mr. Albert R. Steel, Chairman Philadelphia Electric Company Board of Supervisors ATTN:
Mr. R. Fleishmann Peach Bottom Township Peach Bottom Atomic R. D. #1 Power Station Delta, Pennsylvania 17314 Delta, Pennsylvania 17314 Mr. M. J. Cooney, Superintendent Generation Division - Nuclear Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101 Mr. Anthony J. Pietrofitta, General Manager Power Production Engineering Atlantic Electric P. O. Box 1500 1199 Black Horse Pike Pleasantville, New Jersey 08232 Resident Inspector U.S. Nuclear Regulatory Commission Peach Bottom Atomic Power Station j
P.O. Box 399 Delta, Pennsylvania 17314 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, Pennsylvania 19406 1
p. __.
i C
i 4
I ATTACHMENT 1 i
List of Meeting Attendees May 6, 1986-P i
Name:
Organization:
Philadelphia Electric G. Morley.
Philadelphia Electric i
G. Reed C. Gerdis Philadelphia Electric W.
Birely Philadelphia Electric J.
Stang NRC/ DBL /PD#1 G. Gears NRC/ DBL /PD#2.
f P
e b
b
?
T I
b k
f P
s 1
I h
pg,,n r> Li.o., H*
, pg gg dd CO.2 NN 1
- )[dl h /ddi'( 'rW
/dC -
irm! Gholic !%ed PEc o
fwaiv fton%v drenad 0< qfl9C men is &,M g
Y' 5%fUdtU bM3D - ff8.//#6~ f)$$/7)ggi MJggj nWahe "wetwc ascawmoccisic speiyg,c> m e
o
';WS OW N l N0'$lO//A/Mf/$ /72ing,_ ___ ____ ___
l-
)* ffl$
? MQ
~h/3CsdSS.'
?
o).h & Ar,4 exey la /aIweM4 v
s) AdA%4 of acbonsGesoc<a6/wM wsky M4 spcs r &v nmoed.) 16 iemed' 56
.fref4 h C ef t*
r?n$kr?Ob 5S f M ' h Y,.
f 9
.go erad i a, is notir(aod as r s& M phn)ih%f sta6n c i%-
"ne4
%stk t
0 l
b 5
hY k s+J,J ssdnb A,9-ysschkya :~
s c. L J iu d /w % p s,d d i Lc a p 6
~
" eda i
mdid Ar rgeh9 mee mm
- 4. AntaarJtpyer J,6 cywi+
..