ML20205Q482
| ML20205Q482 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 04/12/1999 |
| From: | Hagan J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9904210254 | |
| Download: ML20205Q482 (2) | |
Text
Joesph J.Hagan Srnior %ce President - Nuclear Operations A
PECo Nuclear l
v 1
PECO NUCLEAR mcoen. c -
A Unit of PECO Energy
$5, p Na 6I ws 610 64 o 6100 l
l April 12,1999 I
i Docket Nos. 50-352 50-353 i
License Nos. NPF-39 NPF 85 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
Subject:
Limerick Generating Station, Units 1 and 2 Request for Change to Confirmatory Order
Reference:
Letter dated May 19,1998, B. C. Buckley (NRC) to G. D. Edwards (PECO),
" Confirmatory Order Modifying License Nos. NPF-39 and NPF-85 for Limerick Generating Station, Units 1 and 2" The purpose of this letter is to request a change to the Confirmatory Orde.:r which modified the Limerick Generating Station Units 1 and 2 licenses to incorporate our commitment to complete implementation of the Thermo-Lag 330-1 fire barrier corrective actions. The Confirmatory Order modifying License Nos. NPF-39 and NPF-85, dated May 19,1998, was consented to by PECO Energy Company in our letter dated April 27,1998. The stated commitment completion was scheduled for the end of the April 1999 refueling outage for Limerick Generating Station, Unit 2.
However, based on our rate of progress to complete this work, it is evident that this milestone will not be met. Therefore, we are requesting a modification of the original date.
The reason for the request is the inability to complete installation of certain Darmatt KM-1 electrical raceway fire barrier systems by the end of the April 1999 refueling outage. Darmatt KM-1 is the electrical raceway encapsulation material selected as an attemative to Thermo-Lag 330-1. We are requesting that the Confirmatory Order be modified to reflect that the Thermo-Lag 330-1 fire barrier corrective actions will be accomplished by September 30,1999.
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In a briefing provided to members of NRR and Regional staff on March 30,1999, we identified
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that we would complete the electrical and mechanical modifications and Thermo-Lag 330-1
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upgrade work by the end of the April 1999 refueling outage. That commitment remains i
unchanged. In addition, we plan to transition into our revised Fire Safe Shutdown Program by May 14,1999. These actions. along with certain Darmatt KM-1 installations, will complete the
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Thermo-Lag 330-1 fire barrier corrective actions for 130 of the 138 fire areas at Limerick Units 1 and 2 by the end of the April 1999 refueling outage. We indicated in the briefing that the staffing of the project has peaked at over 350 personnel and our cost estimates to complete the project have tripled from eariier projections provided to NRR. The majority of the manpower resources i
applied to the project have been working extended hours in an attempt to complete the project in i
the committed time frame. The possibility of not completing the Darmatt KM-1 fire barrier l
systems by the end of the outage was also discussed during this briefing.
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Darmatt KM-1 was selected in the first quarter of 1998 and Limerick configuration spec ~ Tic testing of the material was completed in August of 1998. Staffing for the individual fire barrier system
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design effort began as the test reports were being written. Additional challenges arose as we l
removed the existing Thermo-Lag 330-1 and started the Darmatt KM-1 designs. Over 250 interferences (thermal shorts, raceway supports, grounding, obstructions, etc.) were identified as requiring resolutions. Each interference requires engineering, planning and craft labor to be j
applied prior to the installation of the Darmatt KM-1. In some cases, significant structural 99042f0254 990412
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PDR ADOCK 05000352 P-PDR L
', e April 12,1999 Page 2 modifications have been required. These issues, along with other unforeseen impediments, led us to greatly underestimate the Darmatt KM-1 design / installation effort.
We utilized a risk informed strategy in developing the Darmatt KM-1 installation schedule. The j
Limerick Individual Plant Examination for Extemal Events (IPEEE) was used to establish the relative fire risk by individual fire area. Limerick's IPEEE fire risk analysis was performed utilizing the EPRI Fire Vulnerability Evaluation (FIVE) methodology. The NRC accepted the FIVE methodology for IPEEE use on July 26,1993. This analysis was filed with the NRC in response to Generic Letter 88-20, Supplement 4, on June 26,1995. The IPEEE concluded that there were no fire induced vulnerabilities to severe plant accidents at Limerick. Fire Area 02 (13kV Switchgear Room) is the only location with Darmatt KM-1 scope which exceeded the IPEEE -
FIVE Fire Compartment Screening Methodology threshold level. This evaluation of Fire Area 02 is supported by the 1983 Limerick Severe Accident Risk Assessment (SARA) and the 1989 Limerick Severe Accident Mitigation Design Attemativo (SAMDA) analyses. Realizing the relative risk of this area, enhanced compensatory measures were established prior to removing th : Thermo-Lag 330-1 to support the Darmatt KM 1 designfmstallation effort. All of the work in Fire Area 02, including the extensive Darmatt KM-1 scope, has been given high priority. Within Fire Area 02 we recently installed additional smoke detectors to cover each ceiling beam pocket, per NFPA 72 (1996), and will have also installed a new limited area pre action sprinkler system.
If the Darmatt KM-1 fire barrier systems are not completed by the end of the refueling outage, we will continue the enhanced compensatory measures until the last fire barrier system is complete.
There are seven other fire areas where we expect to be installing Darmatt KM-161 the end of the refueling outage. These fire areas were evaluated in the Limerick IPEEE assuming the electrical raceway encapsulation fire barrier systems were not in place. The resultant IPEEE - FIVE Compartment Screening risk values for these seven fire areas are below the established threshold of fire risk significance. The SARA and SAMDA analyses also supported these conclusions. Each Darmatt KM-1 fire barrier system will be made operable upon completion of i
work and documentation closure. Until each barrier system in a fire area is operable, the current compensatory measures will remain in effect. It is estimated that the final Darmatt KM-1 fire barrier system associated with the Thermo-Lag 330-1 fire barrier corrective actions will be i
completed by September 30,1999. We are planning on providing periodic status reports of our progress to complete the Darmatt KM-1 fire barrier systems to both the NRC Limerick Project Manager and Senior Resident inspector.
The Order states that the Director, Office of Nuclear Reactor Regulation, may relax or rescind, in writing, any provisions of this Confirmatory Order upon a showing by the Licensee of good cause.
It is our belief that we have made a good faith effort to complete all the required remediation within the constraints of the Order and that the work remaining is of minor fire risk significance to the safe operation and shutdown of the plant. Therefore, we request a modification to the Order extending the completion date.
We appreciate your assistance in this maaer. Should you need additional information or have any questions regarding the information contained in this letter please contact Mr. Garrett
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Edwards, of my staff, at (610) 640-6761.
Sincerely,
^
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1 Joseph J. Hagan Senior Vice President, Nuclear Operations cc:
H. J. Miller, Administrator, Region I, USNRC A. L. Burritt, USNRC Senior Resident inspector, LGS