ML20214D068
| ML20214D068 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 11/14/1986 |
| From: | Houston R Office of Nuclear Reactor Regulation |
| To: | PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| Shared Package | |
| ML20214D069 | List: |
| References | |
| NUDOCS 8611210343 | |
| Download: ML20214D068 (6) | |
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7590-01 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter PHILADELPHIA ELECTRIC Dockets Nos. 50-277/278 COMPANY
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Peach Bottom Atomic Power Station, Units 2 and 3 EXEMPTION I.
The Philadelphia Electric Company (the licensee) is the holder of Facility Operating License No. DPR-44 which authorizes operation of the Peach Bottom Atomic Power Station, Unit 2 and Facility Operating License No. DPR-56 which authorizes operation of Peach Bottom Atomic Power Station, 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 Part 50 regarding fire protection features of nuclear power plants. The revised Section 50.48 and Appendix R became effective 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.
Two of these subsections, III.F and III.M, are the subject of the licensee's exemption request.
8611210343 861114 DR ADOCK 05000 7
.Section III.F requires that for areas where alternative 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.
Subsection III.M of Appendix R requires that penetration seals utilize only noncombustible materials.
III.
By letter dated May 27, 1983, the licensee requested an exemption from Section III.M of Appendix R to 10 CFR 50 to the extent that Section III.M requires penetration seals which utilize only noncombustible materials. By letters dated July 22, 1983, September 16, 1983, December 2, 1983, February 10, 1984, September 17, 1984, January 16, 1985 and September 24, 1985,'the licensee provided additional information to support the exemption request.
By letter dated September 16, 1983, the licensee also requested an exemption from the requirements of Section III.F of Appendix R.
Section III.F of Appendix R requires the installation of automatic fire detection systems in all areas of the plant that contain or present an exposure fire hazard to safe shutdown or safety-related systems or components.
In the NRC's staff meeting summary dated May 13, 1986, the licensee l
provided information relevant to the "special circumstances" finding required by revised 10 CFR 50.12(a) (see 50 FR 50764). The licensee's information is l
suninarized as follow:
l l
i)
Penetration Seals The technical requirement of Section III.M of Appendix R would not be mot because certain penetration seals are not entirely constructed of noncombustible materials.
However, the licensee states that they have l
l
[
.' committed to refurbishing all subject seals used in fire rated barriers in accordance with the staff accepted ASTM tests. Therefore, it is the licensee's position that the modified seals will provide adequate performance under fire conditions and provide an equivalent level of protection to that required by Section III.M. Thus, the application of the regulation in this particular circumstance is not necessary to achieve the underlying purpose of the rule (see 10 CFR 50.12(a)(2)(ii)). Additionally, compliance with Section III.M concerning the subject seals would result in costs that are significantly in excess of those contemplated when the regulation was adopted since it would result in the complete removal and total replacement of all seals in question.
ii) Emergency Cooling Tower Fire Detectors The licensee stated that although safety-related cables in conduits are located in this area (stairwell), no other fixed combustibles are present and access is controlled by security personnel. This area is not used for storage and current administrative controls on combustibles preclude the presence of a fire hazard. Therefore, application of the regulation (Section III.F of Appendix R) in this particular circumstance is not necessary to achieve the underlying purpose of the rule (safe shutdown).
The staff concludes that "special circumstances" exist for the licensee's requested exemptions in that the application of the regulation in these particular circumstances is not necessary to achieve the underlying purposes of Appendix R to 10 CFR 50.12(a)(2)(ii).
The following list of exemption requests, therefore, reflects the latest status:
i)
Penetration Seals r
. The technical requirement of Section III.M of Appendix R would not be met because certain penetration seals are not entirely constructed of non-combustible materials.
ii) Emergency Cooling Tower Fire Detector An exemption was requested from the specific require;ments of Section III.F to the extent that automatic fire detection in this area would not be provided.
The acceptability of these exemption requests is addressed below.
Details are contained in the NRC staff's concurrently issued Safety Evaluations.
DISCUSSION In response to the new fire protection rule Appendix R to 10 CFR Part 50, the licensee committed to upgrade all penetration seals in barriers used to separate redundant safe shutdown equipment which the staff had previously questioned. Upon further investigation of this open item the licensee determined that approximately 6,250 seals in 341 fire barriers needed to be upgraded, and in some cases, the licensee further concluded that certain penetration seals would require removal and replacement with fire rated seals. By letter dated May 27, 1983, the licensee indicated that instead of replacing penetration seals in accordance with III.M of Appendix R in some cases, existing seals which contain combustible materials would be modified and the modified seal would be tested in accordance with appropriate ASTM testing requirements. By letter dated September 24, 1985, the licensee stated that the redesigned penetration seals used in fire rated barriers will be refurbished with modified penetration seals which have been successfully tested and approved under appropriate ASTM standards.
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. Based on the licensee's commitments and the tests conducted on the redesigned penetration seals, we find the modified seals which contain combustible material will provide adequate performance under fire conditions and will provide an equivalent level of protection to that required by Section III.M of Appendix R.
The technical requirements of Section III.F are not met in the Emergency Cooling Tower Stairwell because automatic fire detection systems have not been installed. The combustible loading in the stairwell is negligible. Consequently, a fire of any significant magnitude or duration is not expected. Therefore, the safety-related cabling in the stairwell would not be prone to fire damage.
Therefore, we find that installation of automatic fire detection systems would not significantly increase the level of fire protection in these areas.
IV.
Accordingly, the Commission has determined that, pursuant to 10 CFR 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 application of the regulation in these particular circumstances is not necessary to achieve the underlying purpose of Appendix R to 10 CFR Part 50. Therefore, the Commission hereby grants the following exemptions from the requirements of Section III.M and III.F of Appendix R to 10 CFR Part 50:
i)
Penetration Seals
o
. An exemption to the technical requirement of Section III.M of Appendix R to have penetration seals entirely constructed of noncombustible materials.
- 11) Emergency Cooling Tower Fire Detectors An exemption from the specific requirements of Section III.F to the extent that automatic fire detection in the emergency copling tower does not have to be provided.
Pursuant to 10 CFR 51.32, the Commission has determined that the granting of these exemptions will have no significant impact on the environment
( 51 FR 41450 ).
This Exemption is effective upon issuance.
FOR THE NUCLEAR REGULATORY COMMISSION GA O
yne Housf.
Deputy Director Division of BWR Licensing Dated at Bethesda, Maryland this 14th day of November,1986
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