ML20207H798
| ML20207H798 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 12/31/1986 |
| From: | Houston R Office of Nuclear Reactor Regulation |
| To: | PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| Shared Package | |
| ML20207H802 | List: |
| References | |
| NUDOCS 8701080124 | |
| Download: ML20207H798 (10) | |
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i a6 7590-01 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of Dockets Nos. 50-277 and 50-278 PHILADELPHIA ELECTRIC
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COMPANY
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Peach Bottom Atomic Power
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Station, Units 2 and 3
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EXEMPTION I.
The Philadelphia Electric Company (PEC0, the Licensee) is the holder of Facility Operating License No. DPR-44 which authorizes operation of Peach Bottom Atomic Power Station, Unit 2 and Facility Operating License No. DPR-56 which authorizes operation of Unit 3 These operating licenses provide, among other things, that the Peach Bottom Atomic Power Station is subject to all rules, regulations, and Orders of the Commission now or hereafter in effect.
The station comprises two boiling water reactors at the Licensee's site located in York County, Pennsylvania.
II.
On November 19, 1980, the Commission published a revised Section 50.48 and a new Appendix R to 10 CFR 50 regarding fire protection features of nuclear power plants. The revised Section 50.48 and Appendix R became effec-tive on February 17, 1981.Section III of Appendix R contains 15 subsections, lettered A through 0, each of which specified requirements for a particular aspect of the fire protection features at a nuclear power plant. One of these subsections, III.G, is the subject of the Licensee's exemption requests.
Subsection III.G.2 of Appendix R requires that one train of cables and equipment necessary to achieve and maintain safe shutdown be maintained free of fire damage by one of the following means:
8701090124 861231 PDR ADOCK 05000277 F
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Separation of cables and equipment and associated nonsafety circuits of redundant trains by a fire barrier having a 3-hour rating.
Structural steel forming a part of or supporting such fire barriers shall be protected to provide fire resistance equivalent to that required of the barrier, b.
Separation of cables and equipment and associated nonsafety circuits of redundant trains by a horizontal distance of more than 20 feet with no intervening combustibles or fire hazards.
In addition, fire detectors and an automatic fire suppression system shall be installed in the fire area.
Enclosure of cable and equipment and associated nonsafety circuits c.
of one redundant train in a fire barrier having a 1-hour rating.
In addition, fire detectors and an automatic fire suppression system shall be installed in the fire area.
Subsection III.G.3 of Appendix R requires that for areas where alterna-tive or dedicated shutdown is provided, fire detection and a fixed fire suppression system shall also be installed in the area, room, or zone under consideration.
III.
By letters dated September 17, 1984 and May 23 and September 24, 1985, the Licensee requested exemptions from Section III.G of Appendix R.
By letters dated March 29 and June 6, 1985 and March 7, 1986, the Licensee transmitted structural steel evaluations and delineated proposed modifications as well as requested exemptions from Section III.G.2.
The following list of exemption requests reflects the latest status:
1.
Radwaste Building HVAC Equipment Area (Room 292, Elevation 150 Feet).
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. An exemption was requested from the specific requirement of Section III.G.2.a to the extent that duct penetrations through the fire barrier are not provided with fire dampers.
2.
Turbine and Reactor Buildings (Fire Areas 8 and 50).
An exemption was requested from the specific requirements of Section III.G.2.b to the extent that automatic fire suppression systems are not installed throughout the fire areas at elevation 195 feet.
3.
o Units 2 and 3 Main Steam Pipe Tunnel, Elevation 135 Feet.
An exemption was requested from the specific requirements of Section III.G.2.a to the extent that fire dampers are not provided in duct penetrations at elevation 135 feet, o
Standby Gas Treatment System Penetrations.
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 Unit 2 Control Rod Drive Equipment Area, Elevation 135 Feet.
An exemption was requested from the specific requirements of Section III.G.2.a to the extent that fire dampers are not provided in duct penetrations.
o Unit 2 Switchgear Room Duct Chase, Elevations 135 and 165 Feet.
An exemption was requested from the specific requirements of Section III.G.2.a to the extent that fire dampers with a fire rating of less tLin 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 penetra-
- tions, 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 a fire
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n, 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 penetra-tions.
4.
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 an open vertical labyrinth do not provide 3-hour fire rated barriers.
5.
o Radwaste Building, Units 2 and 3 M-G Set Rooms, Elevation 135 Feet.
An exemption was requested from the specific requirements of Section III.G.2.a to the extent that certain structural steel members forming a part of or supporting fire barriers should be protected to provide fire resistance equivalent to that of the 1
barrier.
o Reactor Building, Units 2 and 3 HPCI Rooms, Elevation 88 Feet.
An exemption was requested from the specific requirements of Section III.G.2.a to the extent that certain structural steel members forming a part of or supporting fire barriers should be protected to provide fire resistance equivalent to that of the barrier.
o Turbine Building, Emergency Switchgear Rooms, Elevation 135 Feet.
An exemption was requested from the specific requirements of Section III.G.2.a to the extent that certain structural steel members forming a part of or supporting fire barriers should be protected to provide fire resistance equivalent to that of the barrier.
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' o Turbine Building, Battery Rooms, Elevation 135 Feet.
An exemptica was requested from the specific requirements of Section III.G.2.a to the extent that certain structural steel members forming a part of or supporting fire barriers should be protected to provide fire resistance equivalent to that of the barrier.
o Reactor Butiding, RHR Pump and HX Room, Elevation 91 Feet, 6 Inches.
An exemption was requested from the specific requirements of Section III.G.2.a to the extent that certain structural steel members forming a part of or supporting fire barriers should be protected to provide fire resistance equivalent to that of the barrier.
In summary, the exemptions were requested from separating cables and equipment and associated nonsafety circuits of redundant trains by a 3-hour rated fire barrier per the requirements of Section III.G.2.a of Appendix R, and from providing automatic fire suppression systems as a part of protection requirements of Section III.G.2.b of Appendix R.
In Fire Areas 8 and 50 and the radwaste building HVAC equipment area, redundant safe shutdown equipment is well separated with no intervening combustibles. Lack of intervening combustibles, the low combustible loading, and the provision of alternate shutdown capability independent of the remote shutdown panel area and the HVAC equipment area provide sufficient passive protection to ensure that one shutdown division would remain free of fire damage.
The staff also finds that there is reasonable assurance that a fire in the areas for which exemptions have been requested from the requirements of
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e,Section III.G.2.a (redundant safe shutdown systems not separated by a 3-hour barrier) would be of low magnitude, detected in its incipient stage, and extinguished by the fire brigade. The low combustible loading in each of such areas ensures that redundant safe shutdown equipment located in the adjoining areas will not be damaged before a fire is controlled.
Automatic fire suppression systems are provided in the areas in which certain members of structural steel supporting fire barriers are not protected. The staff finds that due to the provision of these systems and/or administrative procedures, there is reasonable assurance that a fire in these areas would not affect structural steel.
Based on the review of the Licensee's analysis, the staff also concludes that the installation of 3-hour rated fire dampers, 3-hour rated blowout panels, barriers between redundant trains, the installation of automatic fire suppression systems throughout affected fire areas, and the installation of i
fireproofing on structural steel forming part of or supporting fire barriers would not significantly increase the level of fire protection in these A more detailed evaluation concerning the exemption requests is areas.
contained in the Safety Evaluation issued concurrently.
I By letter dated March 7,1986 and in a meeting held with Philadelphia Electric Company personnel on May 6, 1986 (which was documented in the NRC's staff meeting summary dated May 13,1986), the Licensee provided information relevant to the "special circumstances" finding required by revised 10 CFR 50.12(a) (see 50 FR 50764).
In this correspondence, the licensee 1) stated how the criteria established in 10 CFR 50.12 are satisfied and that the activities to be authorized by the requested exemptions do not violate any other applicable laws or regulations, 2) discussed why the exemptions present
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7-no undue risk to the public health and safety because when consideration is given to the effects of alternative mitigative features, there is adequate fire resistance and protection without the minimal if any additional protection that would be provided if the licensee were required to implement modifications that met a literal, strict compliance with all aspects of Appendix R, 3) discussed how and why the cost of the overall fire protection program would be substantially increased if the exemptions are not granted without any demonstrable or corresponding increase in the level of improvement in fire
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protection and 4) discussed how the intent and equivalency criteria of Appendix R would be achieved by granting the exemption. The Licensee stated that existing and proposed fire protection features at Peach Bottom Units 2 and 3 accomplished the underlying purpose of the rule.
Implementing additional-redifications to provide additional suppression systems, detection systems, and fire barriers would require the expenditure of engineering and construction resources as well as the associated capital costs which would represent an unwarranted burden on the Licensee's resources. The Licensee stated that these i
costs are significantly in excess of those required to meet the underlying l
purpose of the rule.' The staff concludes that "special circumstances" exist for the Licensee's requested exemptions in that application of the regulation in these particular circumstances is not necessary to achieve the underlying purposes of Appendix R to 10 CFR 50.
See10CFR50.12(a)(2)(ii).
IV.
l Accordingly, the Connission has determined that, pursuant to 10 CFR j
50.12(a), (1) the exemptions as described in Section III are authorized by law and will not present an undue risk to the public health and safety and are consistent with common defense and security and, (2) special circumstances are present for the exemptions in that appl! cation of the regulation in these
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e particular circumstances is not necessary to achieve the underlying purposes of Appendix R to 10 CFR 50. Therefore, the Commission hereby grants the following exemptions from the requirements of Section III.G of Appendix R to 10 CFR 50:
1.
Radwaste Building HVAC Equipment Area (Room 292, Elevation 150 Feet) to the extent that redundant safe shutdown cables and equipment are not separated by a 3-hour rated fire barrier pursuant to Section III.G.2.a.
2.
Turbine and Reactor Buildings (Fire Areas 8 and 50) to the extent that automatic fire suppression systems are not installed throughout the fire areas pursuant to Section III.G.2.b.
3.
o Units 2 and 3 Main Steam Pipe Tunnel, Elevation 135 Feet to the extent that redundant safe shutdown cables and equipment are not separated by a 3-hour rated fire barrier pursuant to Section III.G.2.a.
o Standby Gas Treatment System Penetrations to the extent that safe shutdown cables and equipment are not separated by a 3-hour rated fire barrier pursuant to Section III.G.2.a.
o Unit 2 Control Rod Drive Equipment Area, Elevation 135 Feet to the extent that safe shutdown cables and equipment are not separated by a 3-hour rated fire barrier pursuant to Section III.G.2.a.
o Unit 2 Switchgear Room Duct Chase, Elevations 135 and 165 Feet to the extent that safe shutdown cables and equipment are not separated by a 3-hour rated fire barrier pursuant to Section III.G.2.a.
e th Spent Resin Tank Room, Elevation 91 Feet, 6 Inches to the o
extent that redundant safe shutdown cables and equipment are not separated by a 3-hour rated fire barrier pursuant to Section III.G.2.a.
4.
Outboard Main Steam Isolation Valve Rooms (Fire Areas 208 and 254) to the extent that redundant safe shutdown cables and equipment are not separated by a 3-hour rated fire barrier pursuant to Section III.G.2.a.
5.
o Radwaste Building, Units 2 and 3 M-G Set Rooms, Elevation 135 Feet to the extent that certain structural steel members forming a part of or supporting fire barriers are not protected to provide fire resistance equivalent to that of the barrier pursuant to Section III.G.2.a.
Reactor Building, Units 2 and 3 HPCI rooms, Elevation 88 Feet o
to the extent that certain structural steel members forming a part of or supporting fire barriers are not protected to provide fire resistance equivalent to that of the barrier pursuant to Section III.G.2.a.
o Turbine Building, Emergency Switchgear Rooms, Elevation 135 Feet to the extent that certain structural steel members forming a part of or supporting fire barriers are not protected to provide fire resistance equivalent to that of the barrier pursuant to Section III.G.2.a.
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m o Turbine Buf1 ding, Battery Rooms, Elevation 135 Feet to.the extent that certain structural steel members forming a part of or supporting fire barriers are not protected to provide fire resistance equivalent to that of the barrier pursuant to Section III.G.2.a.
Reactor Buf1 ding, RHR Pump and HX Room Elevation 91 Feet, 6 o
Inches to the extent that certain structural steel members forming a part of or supporting fire barriers are not protected to provide fire resistance equivalent to that of the barrier pursuant to Section III.G.2.a.
Pursuant to 10 CFR 51.32, the Commission has detemined that the granting of these exemptions will have no significant impact on the environment (51 FR 47324)
A copy of the concurrently issued Safety Evaluation related to this l
action is available for public inspection at the Commission's Public Document Room, 1717 H Street, N.W., Washington, D.C. and at the local public document room located at the Government Publication Section, State Library of Pennsylvania, Education Building, Commonwealth and Walnut Streets, Harrisburg, Pennsylvania, 17126.
A copy may be obtained upon written request addressed to the U.S. Nuclear Regulatory Commission, Washington, D.C.
20555, Attention:
Director, Division of BWR Licensing.
This Exemption is effective upon issuance.
FOR THE NUCLEAR REGULATOR 7 COMMISSION j
i lhM
. Wayne Hous@n, Acting Director Division of BWR Licensing t
Office of Nuclear Reactor Regulation Dated at Bethesda, Maryland this 31st day of December 1986.
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