ML20207M990
| ML20207M990 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 01/08/1987 |
| From: | Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Kane W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8701130371 | |
| Download: ML20207M990 (5) | |
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PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET F'.O. BOX 8699 PHILADELPHIA PA.19101 (215)8414000 January 8, 1987 Docket Nos. 50-277 50-278 Mr. William F. Kane, Director Division of Reactor Projects Region I U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406
SUBJECT:
10 CFR 50, Appendix R, Fire Protection Program Peach Bottom Atomic Power Station
REFERENCE:
(1)
Compensatory Measures for Conditions of Non-Compliance with Appendix R, dated October 24, 1986, from S. L. Daltroff, PECo, to William F.
Kane, NRC (2)
Special Report: Conditions of Non-Compliance with Appendix R, dated October 31, 1986 from J. S. Kemper, PECo, to T. E. Murley, NRC (3)
Justification for Continued Operation of Peach Bottom, dated November 28, 1986, from S. J. Kowalski, PECo, to William F. Kane, NRC
Dear Mr. Kane:
This letter requests several minor revisions in the schedule and compensatory measures associated with establishing full compliance with the provisions of the Fire Protection Rule, 10 CFR 50, Appendix R, at Peach Bottom Atomic Power Station Unit Nos. 2 and 3.
These revisions involve:
(1) the schedule for completing Unit 3 and common equipment modifications that impact full compliance on Unit 2, (2) fire watch personnel requirements, and (3) conditions under which the compensatory measures may be terminated.
Members of our Engineering and Licensing staffs discussed these revisions with C. J. Anderson, NRC, Region I during a December 15, 1986 telecon and these revisions are being submitted in accordance with his recommendation.
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Mr.' William F. Kane January 8, 1987 Page'2 The letter also describes the resolution of two conditions of non-conformance with Appendix R in a manner different-from the methods previously described in references (2) and (3).
Additionally, alternatives to other methods previously described may become necessary for resolution of the associated conditions of non-conformance.
Accordingly, it is our request that the schedule in the planned Confirmatory Action Letter be based on " resolution of conditions:of non-conformance" and not-on implementation of specific modifications or procedures.
The NRC will be notified of any revisions in the methods previously described for resolving conditions of non-conformance.
Unit 3 and Common Equipment Modification Schedule The Reference (2) letter states that Philadelphia Electric Company (PECo) will bring Unit 2 into full compliance with Appendix R prior to startup after the Spring 1987 refuel outage.
Since submittal of the referenced letter, we have determined that there are two modifications required on Unit 3 and common equipment which could impact the capability to achieve safe shutdown (Appendix R, III.G.2) on Unit 2-since the current assessment is that both a Unit 2 and a Unit 3 outage is necessary for their implementation.
Therefore, the following revision to the schedule is provided.
It is our plan to complete all other Unit 2 Appendix R modifications prior to startup after the Spring 1987 refuel outage.
The two Unit 3 and common equipment modifications required for Unit 2 to achieve full compliance will be completed 4
during the first Unit 3 outage of sufficient length to complete the modifications following both the shutdown of Unit 2 for the Spring 1987 refueling outage and the availability of the-new equipment.
The equipment needed to complete the modifications is f
currently anticipated to be available by March 1987.
The duration of the outage necessary to perform the modifications is expected to be less than 5 days.
The first modification involves encapsulating a large junction box containing-cables described in Item I.A.2 of the j
reports enclosed with the Referenced (2) and (3) letters.
The second modification involves replacing magnetic-only circuit breakers associated with two Unit 3 battery chargers as described i
in Item IV.B of the reports enclosed with the referenced (2) and (3) letters.
The descriptions of items I.A.2 and IV.B in Reference (3), explain the conditions of non-conformance and justifications for continued operation.
The analyses in Reference (3) provided for the first condition (I.A.2) concluded that an overload that trips the circuit breaker is not probable based on the absence of electrical motor loads on the circuits in question.
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Mr. William F. Kane January 8, 1987 Page 3 As discussed in Reference (3), the second condition assumes the largest credible high impedance fault, following an Appendix R fire on the power cables to the battery chargers for the batteries which provide control power to the diesel generators.
Interim procedures have been implemented until the modification is complete.
These procedures require the shedding of unnecessary. loads in order to extend the time duration before the batteries are depleted, and the installation of temporary power feeds to the battery chargers.
As stated earlier in this letter, the remaining modifications required to comply with Appendix R will be implemented on Unit 2 and Unit 3 during their respective 1987 refuel outages.
This schedule is based on the anticipated approval of safe shutdown methods as described in the Fire Protection Plan (FPP) submitted to the NRC in September 1986.
Fire Watch Personnel Requirements In accordance with the provisions of the compensatory measures described in Reference (1), the number of fire watch patrols was increased from 2 to 8.
We have subsequently assessed the effectiveness of this program and concluded that the motivation and attention level of fire watch personnel to their assigned tasks could be improved by increasing the time required to perform each roving patrol.
Currently the time required to walk each of the 8 patrols is estimated to be:
1.
45 minutes 5.
15 minutes 2.
15 minutes 6.
20 minutes 3.
15 minutes 7.
45 minutes 4.
40 minutes 8.
45 minutes This demonstrates that four of the eight patrols take 20 minutes or less to perform, allowing for too much idle time between patrols.
Therefore, we propose, with NRC approval, to reduce the eight fire watches to six.
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We have drafted written instructions for these six new proposed patrols and have estimated how long it would take to walk these patrols.
The times are listed below:
1.
45 minutes 2.
50 minutes 3.
50 minutes 4.
50 minutes 5.
45 minutes 6.
55 minutes
Mr. William F. Kane January 8, 1987 Page 4 Further, we propose to. reduce the number of fire watches below six as conditions of non-conformance are resolved provided comparable monitoring of the remaining areas with unresolved conditions of non-conformance is maintained.
Termination of Compensatory Measures Reference (1) identified the compensatory measures implemented in response to the Appendix R conditions of non-conformance.
With regard to the fire watch provisions of the compensatory program, it is proposed that the fire watches remain in effect in a fire area, regardless of plant power status, until the conditions of non-conformance in the area are resolved.
The weekly plant inspections required under the provision of the compensatory measures would also continue, regardless of plant power status, far any area containing Appendix R conditions of non-conformance.
Resolution of Conditions of Non-Conformance We also take this opportunity to clarify two items related to the report enclosed with the Reference (2) letter.
The first concerns Item III.E.
The Justification for Continued Operation (JCO) for this item stated that a modification of a Motor Control Center (MCC) load breaker on MCC 30B59 had been completed by installing a 480-volt breaker that was coordinated over the trip range required.
However, the existing calibration settings were reviewed, and it was determined that, due to calibration tolerance, the "as left" settings from the previous calibration were within the tolerance for the new setting required to assure coordination over the trip range.
Thus, because replacement was determined not to be required, the breaker was not replaced.
The modification will now consist of revising the appropriate tabulation drawings to reflect the new setting.
No additional field work is required.
The status of a second Justification for Continued Operation (JCO) item can be updated.
Item I.F indicated a potential high drywell temperature due to the potential for both reactor head vent valves opening when the guidance of Generic Letter 81-12 is considered.
The JCO (Reference 3) stated that the leads for a head vent valve were disconnected at the primary containment penetration until a complete review of the condition was completed.
The review has been completed, and the results show that drywell temperature is limited to an acceptable level in the event both valves open.
Therefore, based on the analytical resolution, this item does not require a plant modification and the leads can be permanently reconnected.
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Mr. WilliEm F..Kane Ja'1uary 8, 1987 Page 5 Should you have any_ questions regarding this request, please do not hesitate to contact us.
Very truly yoars,
. W. Gallagher Vice President Nuclear Operations Attachments cc:
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P.
Johnson, Resident Site Inspector j
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