ML20207B695

Forwards Request for Exemption from Requirements of 10CFR50.48(d)(3)(iii) Requiring Implementation of Fire Protection Features,Before Startup from Unplanned Outage That Lasts for 120 Days

ML20207B695
Person / Time
Site:	Pilgrim
Issue date:	07/14/1986
From:	Lydon J BOSTON EDISON CO.
To:	Zwolinski J Office of Nuclear Reactor Regulation
References
86-098, 86-98, NUDOCS 8607180170
Download: ML20207B695 (11)

Text

M e O BOSTONEDiSON Executive Offices 800 Boylston Street Boston, Massachusetts 02199 BECo Letter 86-098 James M. Lydon July 14, 1986 Chief operating Offrer Mr. John A. Zwolinski, Director BWR Project Directorate #1 Division of Licensing Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555 License DPR-35 Docket 50-293 Pilgrim Nuclear Power Station Request for Schedular Exemption from 10 CFR 50.48

Dear Sir:

On July 2, 1986, Boston Edison Company (BECo) notified the Staff of the potential for the current unplanned maintenance outage to extend beyond 120 days in duration. This potential was based on our expectation that completion of various testing and inspection procedures could require additional time.

Subsequent schedular analysis now confirms our previous expectation.

Consequently, BECo believes that the provisions of 10 CFR 50.48(d)(3)(111) will applj, requiring the expedited completion prior to startup of all modifications approved by the Staff in accordance with Appendix R of 10 CFR Part 50. This letter briefly summarizes our basis-for seeking an exemption from this schedular requirement and approval to complete Appendix R modifications in accordance with the provisions of 10 CFR 50.48(d)(3)(1).

BECo is presently completing the final modifications to bring Pilgrim Nuclear Power Station into conformance with the requirements of 10 CFR Part 50 Appendix R. This effort began almost six years ago and represents an expeditious response to the Commission's Appendix R requirements. As specified in both our July 2 letter and the attached formal request for schedular exemption, BECo has experienced a series of circumstances beyond our control which will extend the duration of the current unplanned outage beyond 120 days. Numerous planning and schedule alternatives have been considered in an attempt to improve this schedule, but these efforts have been unsuccessful.

! .t, M h +@+ 6 8607180170 860714 PDR ADOCK 0S000293 h d F PDR

BOSTON EDISON COMPANY Mr. John A. Zwolinski July 14,.1986 As you are aware, the Appendix R modifications have been scheduled to be completed during Refueling Outage #7 (RF0 #7) since the NRC approval of BECo's Long Term Program (LTP) in July of 1984. RF0 #7 is presently scheduled to commence during January 1987.

Such a schedule, however, requires the granti'ng of this exemption application. Should this application be denied, Pilgrim Station will remain shutdown and must begin the refueling outage early and without benefit of the additional four months of needed preparatory time. We are in the process of evaluating the effects which would result from a premature entry into the Refueling Outage. The planning and careful coordination of resources, materials, and tasks is a complex endeavor. An external intervention, such as beginning the outage much sooner than expected, could close windows for accomplishing planned modifications. Tasks previously planned to occur in particular sequences or in parallel with other activities during the outage may need to be rescheduled, possibly extending the duration of RF0 #7. The potential exists for the disruption to be significant with consequential ripple ef fects on our ability to efficiently execute the LTP-planned activities. For all the stated reasons, BEco believes that expeditious completion of Appendix R and other plant modifications would be best served by granting this exemption.

We will continue to maintain close contact with the Staff and will ensure that updated information is provided as it becomes available. Should you have any comments or questions concerning this issue, please do not hesitate to contact us. An application fee of $150 accompanies this submittal.

Ve truly yours, (Lm# M D Attachment i

)

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EXEMPTION REQUEST i

Pursuant to the provisions of 10 CFR 50.12, Boston Edison Company requests exemption from the requirements of 10 CFR 50.48(d)(3)(iii) which requires the implementation of those fire protection features, including alternate shutdown capability, involving installation of modifications requiring plant shutdown, before startup from an unplanned outage that lasts for at least 120 days.

The requested exemption is in conformance with 10 CFR 50.12(a)(1) in that it is not in conflict with other legal requirements, does not present undue risk to the public health and safety and is consistent with the common defense and security.  ;

In addition, the requested exemption conforms with ecial circumstances as described in 10 CFR 50.12(a)(2)(v) in that the exempt would provide only '

temporary relief f rom the applicable regulation and BECo has made good faith efforts to comply with the regulation.

The Exemption Would Provide Only Temporary Relief From The Applicable Regulation The exemption would only provide temporary schedule relief during the  ;

period of time beginning with the startup f rom our present unplanned outage until shutdown for Refueling Outage #7, a period of approximately four months. l BECo Had Made Good Faith Efforts To Comply With The Regulation BECo's good faith efforts to comply with the regulation is best demonstrated by addressing each of the additional four criteria for schedular exemption from 10 CFR 50.48 that is provided in NRC Generic Letter 86-10, dated April 24, 1986. Each of the four criteria and BEco's position relative to each is provided below.

i (1) BECO HAS. SINCE THE PROMULGATION OF APPENDIX R IN 1980. PROCEEDED EXPEDITIOUSLY TO MEET THE COMMISSIGN'S REQUIREMENTS ]

l BEco is presently completing the final modifications to bring Pilgrim Nuclear Power Station into conformance with the requirements of 10 CFR Part 50 Appendix R. This ef fort began almost 6 years ago, and is approximately 85% complete. Figure 1 provides the status of each of the Appendix R modifications. Figure 2 shows the relation of each modification to the total Appendix R work effort. Upon completion this will represent a total expenditure of almost $14,000,000.

Figure 3 shows the amount expended to date, the amount committed to date, and the amount authorized for the total project.

Pilgrim Station has a comprehensive program for preventing the occurrence of fires, promptly detecting their presence, and rapidly extinguishing fires prior to their threatening safe shutdown equipment. This fire protection strategy is further supported by an Page 1 of 5

l additional layer of protection through adequate separation of redundant divisions of safe shutdown equipment. Protection for the safe shutdown capability is provided through the use of rated fire barriers, physical space f ree of intervening combustibles, and automatic suppressions systems.

Since November 1980, Pilgrim Nuclear Power Station has been equipped with an alternate shutdown capability designed to shutdown the plant in the event of a fire in the Control Room or Cable Spreading Room.

The system complements the comprehensive fire protection program at Pilgrim Station and provides additional defense-in-depth to pister.t against the effects of fire in plant areas containing redundant divisions of safe shutdown equipment. The alternate shutdown system was installed in accordance with Staff guidelines contained in Branch Technical Position (BTP) 9.5-1 as described in the NRC safety evaluation report (SER) issued on December 21, 1978. The shutdown capability for these areas was subsequently recognized in the SER issued in November 1983 as satisfying the requirements of Appendix R.

In November 1980, contemporaneous with Pilgrim's alternate shutdown system becoming operational, the Commission enacted 10 CFR 50.48 and Appendix R to Part 50. The rule required licensees to review the adequacy of the BTP 9.5-1 fire protection programs to determine whether additional enhancements to the measures in place would be feasible. BEco's reanalysis identified a number of modifications which would further enhance the protection of the safe shutdown capability against the effects of fire. The important aspects of our proposed nodifications are in three areas: redefining the BTP 9.5-1 fire areas based on rated fire barriers, adding to our existing fire suppression systems, and rerouting certain electrical cables in other plant areas to conform with new Staff clarifications developed subsequent to the issuance of Appendix R.

The alternate shutdown system modifications include rerouting certain cables in a ductline around the perimeter of the plant. In addition, several other projects are encompassed in the program including:

(1) enhanced alternate shutdown capability for the emergency diesel generators; (2) adding torus water level and temperature instrumentation to the alternate shutdown capability; (3) implementing operator action for loss of component function due to a fire; and, (4) adding to the Reactor Building automatic suppression system.

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Many of the new features can be installed while the plant is operating; however, final termination and preoperational testing of the alternate shutdown system modifications requires the plant to be in a shutdown condition.

Figure (1) provides a detailed depiction of the status of each line item in the Appendix R SER (the line items in the BTP 9.5-1 SER have all been completed). BECo submits that the record supports the.  :

expeditious resolution of fire protection issues at Pilgrim Station.

(2) THE DELAY IS CAUSED BY CIRCUMSTANCES BEYOND BEco's CONTROL l l

On April 12 of this year, BECo shutdown Pilgrim Station to investigate identified leakage in the residual heat removal (RHR) i system. During and subsequent to this shutdown additional equipment problems arose involving the reactor mode switch and main steam isolation valves (MSIV's). While in a shutdown condition, BEco was advised in IE Information Notice 86-39 of the potential for intergranular stress corrosion cracking (IGSCC) of impeller wear rings for the RHR pumps.

These pumps are important to providing core cooling in the event of an accident. The importance of these pumps to safe operation was an important consideration to BECo's decision to open and inspect each of the RHR pumps. Coincident with this decision, BECo identified the need to leak test the containment isolation valves. Pilgrim's voluntary decision to inspect the RHR pumps will result in extending the unplanned outage beyond 120 days.

, In addition to the equipment issues outlined above, a labor dispute arose on May 1,1986 involving one of the contractor trade unions.

This dispute resulted in a work stoppage which affected all '

contractor trade unions on site, including those installing the Appendix R modifications. As of the date of this letter the work stoppage continues. Boston Edison Company union employees' contract expired on May 15, 1986. The subsequent work stoppage was the i longest experienced by BEco in over a decade and continued until . lune  ;

23, 7986. The net effect of both job actions slowed modifications  ;

and cepairs at Pilgrim Station and required the reallocation of '

preoutage preparation resources.

It has only been in the last three weeks when it has become apparent l that the station would not return to service until late August, l several weeks after the 120 day deadline is activated. The critical path activities for startup are the RHR pump inspection to resolve the IGSCC concerns and integrated containment leakage testing.

BEco believes that the above chronology of events constitutes an adequate demonstration of circumstances beyond its control.

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(3) THE PROPOSED SCHEDULE FOR COMPLETION REPRESENTS A 8EST EFFORT UNDER THE CIRCUMSTANCES BEco has examined whether the plant could be restored to service before the current outage extends to 120 days. The focus of this review fell upon the feasibility of providing additional resources to the RHR pump inspection for IESCC and integrated containment leakage testing. This review concluded that such action would be neither practical nor possible. The IESCC and integrated containment testing issues are resolvable but each requires specific time and the resource allocation has been optimized, and, therefore, the resolution schedule cannot be accelerated.

BECo has also evaluated the possibility of completing the required Appendix R modifications on an expedited basis. The construction schedule requires extensive work prior to the final terminations and testing.

The remaining Appendix R preoutage construction work will take approximately 14 weeks to complete, predicated upon a 6 day a week, 20 hour2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> a day work schedule. These activities have been directly impacted by the contractor trade union labor dispute and the 14 week effort will consence upon the return of the contractor labor force.

BEco has assessed the use of an alternative work force during the interim period but has concluded that this approach is not a viable option. The engineering support aspects of the Appendix R work have continued unabated. The final termination and testing portion of the Appendix R work can only be performed when the plant is shutdown and is now scheduled for RF0 #7. It is estimated that the " shutdown specific" work will require an additional 10 weeks and cannot begin until the preoutage construction work has been completed.

The accelerated schedule would increase costs significantly, reduce work efficiency, and increase radiation exposure.

It is important to note that since the incorporation of the Pilgrim Long Term Program (LTP) an amendment to the Pilgrim Station Operating License in July of 1984, the Appendix R modifications have been planned and scheduled to be completed during RF0 #7.

BEco, therefore, believes that the proposed schedule for completion represents a best effort under the unique circumstances of the current outage and justifies not requiring the completion of Appendix R modifications on an earlier schedule from that planned for almost three years.

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(4) ADEQUATE INTERIM COMPENSATORY MEASURES WILL BE TAKEN UNTIL COMPLIANCE IS ACHIEVED BECo has currently deployed an extensive contingent of fire watches, a staff of individuals specifically trained to identify incipient fire conditions and hazards, and provide immediate warning for early suppression. A fire watch staff is on continuous duty in the plant areas where the alternate shutdown capability will be p*ovided upon completion of the RF0 #7.

In addition to fire watches, the plant areas containing redundant safe shutdown equipment affected by this application are, except for the torus compartment, already equipped with detection systems.

These systems provide early detection and suppression of incipient fire conditions, and provide time for the fire brigade to arrive and extinguish the fire. Such measures provide reasonable assurance that the safe shutdown capability will be protected from the effects of fire. The combustible loading of the torus compartment is in the lowest fire severity category. The NRC has recognized this as evidenced by granting Boston Edison an exemption from detection and suppression in this area.

Details of the Appendix R work .emaining to be completed, the effected areas of the plant and the related compensatory measures applied are presented in Figure 4.

BECo has reviewed the circumstances of this application. Beyond the continued presence of the fire watch staff and automatic suppression and detection systems, we have yet to identify other compensatory measures of an interim nature which could substantially enhance the level of safety pending completion of remaining work. He will, nevertheless, continue to review this situation and consult with your Staff, as appropriate, to identify any additional protective features which would be beneficial.

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BOSTON EDISON COMPANY FIRE PROTECTION / APPENDIX R MODIFICATION STATUS 1982 1983 1984 1985 1986 1987 I

RFO#7 REFUELING OUTAGE # 7 e

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I PDC 83-61 A 3-HR FIRE RATING 4160 "A" SWITCHGEAR ROOM I

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BOSTON EDISON COMPANY APPENDIX R MODIFICATIONS RELATIVE LEVEL OF EFFORT l

PDC 84-03D PDC 84-03F PDC 85-41 PDC 84-03B PDC 85-498 PDC 85-49A X PDC 83-61 A PDC 83-61B PDC 86-31 PDC 83-05 PDC 84-03A PDC 86-XX i

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Boston Edison Company Compensatory Measures for Ongoing Appendix R Plant Modifications -

PDC # Description Plant Locations Affected Compensatory Measures PDC 84-03D ADS Modifications Reactor Bldg, Elev 23' E Detection; Fire Watch (Roving 20-Min)

PDC 84-03E Cable Installation Reactor Bldg, 23' & 51' E & W Detection; Fire Watch (Roving 20-Min)

RBCCW "B" Area PDC 84-03F Diesel Generator Mods Reactor Bldg, 23' E Detection; Fire Watch (Roving 20-Min)

PDC 85-41 Torus Water Level Mods Torus Compartment Fire Watch (Roving 20-Min)

PDC 85-49B Sprinkler Modifications Reactor Bldg, 23'N, 51'N,51'S Detection; Fire Watch (Roving 20-Min)

PDC 85-49A Sprinkler Stub-outs & Reactor Bldg, 23'N,51'N,51'S, Detection; Fire Watch (Roving 20-Min)

Drains Torus Compartment North Side '

PDC 83-61 A 3 Hr Fire Rating - 4160 Switchgear Rm "A" Control Detection; Fire Watch (Roving 20-Min)

"A" Switchgear Room Bldg El 23' 4

PDC 86-31 Fire Dampers Switchgear Room Cable Detection; Fire Watch (Roving 20-Min)

Spreading Rm Contro! Room RBCCW PDC 86-XX Emergency Lights Various Hand Held Lights Available Figure 4

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