ML20207L974
| ML20207L974 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 10/13/1988 |
| From: | Varga S Office of Nuclear Reactor Regulation |
| To: | BOSTON EDISON CO. |
| Shared Package | |
| ML20207L965 | List: |
| References | |
| NUDOCS 8810180045 | |
| Download: ML20207L974 (6) | |
Text
e 7590-01 UNITED STATES OF ANERICA NUCLEAR REGULATORY COMMISSION In the matter of BOSTON EDISON COMPANY Docket No. 50-293 (PilgrimNuclearPowerStaticn)
EXEMPTION The Boston Edison Company (BEco), the licensee, is the holder of Operating License No. DPR-35 whict. authorizes operation of Pilgrim Nuclear Pcwer Station. The license provides, among other things, that the Pilgrim Nuclear Power Station is subject to all rules, regulations, and Orders of the Cor.nission new or hereaf ter in effect.
The plant is a boiling water reactor at the licensee's site located in Plymouth County, Massachusetts.
On November 19, 1980, the Comission published a revised Section 50.48 and a new Appendix R to 10 CFR Part 50 regarding fire protection features of nuclearpowerplants(45FR76E02). The revised Section 50.48 and Appendix R became effective on February 17, 1981. Section 111 of Appendix R contains 15 subsections, lettered A through 0, each of which specifies requirements for a particular aspect of the fire protection features at a nuclear power plant.
One of thtse subsections, Ill.G.2.a. is the subject of the licensee's exemption request.
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2 Section !!!.G.2.a of Appendix R to 10 CFR Part 50, requires that separation of cables and equipment and associated non-safety trains by a fire barrier having a three 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.
III.
By letter dated August 6, 1988, BEco requested an amendment to revise the license to allow some fire barriers to have a rating of less than three hours as referenced in License Condition 3.F and supported by Fire Protection Engineering Evaluations (FPEE) perfomed by BECo. The NRC staff has determined that these barriers do not fully satisfy the requirements of Section
!!I.G.2.a of Appendix R to 10 CFR Part 50 in relation to three hour fire barriers and an exemption is required in addition to the requested amendment.
The Safety Evaluation Peport (SER) that accompanied Pilgrim Nuclear Power Station (PNPS) Technical Specification Amendment No. 35 documented PNPS compliance with Appendix A of Branch Technical Position (BTP) APCSB 9.5-1.
Section 4.13 of the SER identified the fire barriers that provide three hour separation between redundant safety related systems, or separation of areas with significant fire hazards.
During refueling outage number seven, a reevaluatiun was conducted of fire barriers, including fire doors, fire dampers and penetration seals. This review detemined that existing decumentation would not support verification of a three hour ratino for some of the barriers referenced in the SER. As a result, FPEEs were perfomed to detemine the adecuacy of these fire barriers.
The FPEEs consist of the following elements: area configuration
3 i
and occupancy; combustible loading; safe shutdown systems potentially affected; consequences of a fire in an affected area; other considerations (i.e., detection, suppression purpose of barrier, etc.) and; the review and approval of a fire protection engineer.
The staff has previously reviewed and approved the concept of FPEEs to document the adequacy of fire protection measures at PNPS when the existino configuration was otherwise not in strict compliance of Appendix R requirements. For all but two of the 17 fire barriers that are the subject of this exer.ption, the licensee's analysis by FPEEs find that they have a rating that exceeds the fire hazard to which the barriers are exposed.
That is, the combustible loading, extent and nature of combustibles, and their continuity (all expressed in British Thermal Units) do not exceed the fire rating of the j
barrier being analyzed and the existing fire barriers provide adequate protection. The reraining two fire harriers separate a fuel oil day tank, and i
the turbine lube oil reservoir cnd storage areas from surrounding equipment.
The fire hazard for each of these locations exceeds even a three hour fire barrier because of their high combustible loading. However, these two i
areas are provided with automatic fire suppression and fire detection which provide adequate protection for the areas.
Based on the above evaluation, the staff concludes that application of l
the regulation in these particular circumstances is not necessary to achieve the underlying purpose of Appendix R to 10 CFR Part 50. The licensee's existing fire protection configuration provides an equivalent level of j
protection to that achieved by compliance with Section !!!.G.2.a of Appendix R.
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4 Therefore, an exemption to the requirements of Section III.G.2.a of Appendix R in relation to the need for three hour fire rated barriers should be granted.
IV.
Accordingly, the Comission has detemined, pursuant to 10 CFR CO.12(a),
that (1) the exemption as described in Section !!! is authorized by law, will not present an undue risk to the public health and safety, and is consistent with the comen defense and security, and (2) in this case, special circumstances are present in that application of the regulation is not nicessary to achieve the underlying purpose of Appendix R to 10 CFR Part 50.
Therefore, the Comission hereby grants the exemption from the requirements of Section !!!.G.2.a of Appendix R to 10 CFR Part 50 regarding the separation of cables and equipment and associated non-safety trains by a fire barrier having a three hour ratine.
Pursuant to 10 CFR 51.3?, the Comission has detemined that the granting of this exemption will not result in any significant environmental impact (53 FR 40146). A copy of the licensee's submittal dated August 6,1988, is available 'or public inspection at the Comission's Public Document Room, 2170 L Street, N.W., Washington, D.C. and at the Plymouth Public Library,11 North Street, Plp outh, Massachusetts 02360. Copies may be obtained upon written reouest addressed to the U.S. Nuclear Regulatory Comission, Washington, D.C.
70555, Attention: Director, Division of Reactor Projects I/II.
. This Exemption is effective upon issuance.
I Datea at Rockville, Maryland this /3 % day of CC6*b
, 1988.
FOR TiiE NUCLEAR REG'JLATORY COPJtISS10ti
/S Steven A. Varga, Director Division of Reactor Projects 1/II Office of Nuclear Reactor Regulation p
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ThisExemptioniseffectiveuponissujg.
Dated at Rockville, Maryland this
~- day of 6&*
, 1988.
FOR THE NUCLEAR REGULATORY Com !SSION
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rec Division of Reactor Pr ts 1/11 i
Office of Nuclear Reac Regulation i
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