ML20214U238

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Forwards Rev 0 to Evaluation of Shutdown Capability in Event of Fire, Per NRC Request to Justify Continued Operation in Light of Identified Nonconformances W/App R
ML20214U238
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 11/28/1986
From: Kowalski S
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To: Kane W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20214U242 List:
References
CAL-86-07, CAL-86-7, NUDOCS 8612090196
Download: ML20214U238 (2)


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PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101 1215)841 4000 ENGINEERING AND RESEARCH OEPARTMENT Novenber 28, 1986 Docket Nos. 50-277 50-278 Mr. William F. Kane, Director Division of Reactor Projects Region I U.S. Nuclear Regulatory Conmission 631 Park Avenue King of Prussia, PA 19406 "..

SUBJECT:

Justification for Continued Operation of Peach Bottom Units 2 and 3 with Conditions of Non-Conformance with 10CFR50, Appendix R

Dear Mr.,

Kane:

NRC Confirmatory Action Letter 86-07, dated April 11, 1986, required Philadelphia Electric Company (PECo) to ccuplete its ongoing Peach Bottom Appendix R re-review (confirmatory program) and submit a report whenever a condition of non-conformance with Appendix R, Sections III.G or III.J, was identified. Three special reports dated May 22, 1986, Septenber 17, 1986, and October 31, 1986 describing all of the identified conditions of non-conformance have been submitted and the Appendix R re-review has been completed.

In an October 22, 1986 telecon, the NRC Region I requested that PECo submit a letter by October 24, 1986 describing carpensatory measures for each condition identified and submit a letter by Novenber 28, 1986, to justify continued operation in light of the identified conditions of non-conformance with Appendix R.

Ccmpensatory measures were the subject of the October 24, 1986 letter from S. L. Daltroff, PECo, to W. F. Kane, NRC, Region I.

These convensatory measures have been inplemented; the roving fire watch patrols have been increased to eight per shift and the personnel have conpleted enhanced training. Several plant inspections to improve control of ccnbustibles have been performed by the plant fire protection group supplementing the routine inspections required by Administrative Procedure A-30.

Supplemental Inspections will continue to be performed at least once a week until the Individual conditions of non-conformance are corrected.

8612090196 861128 p,I PDR ADOCK 05000277 F

PDR I

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The attachment to this letter provides the licensee's bases for concluding that continued operation of Peach Bottom Units 2 and 3 is justified while the conditions of non-conformance are being permanently corr.ected. The attachment justifies continued operation by dermnstrating that, for each condition of non-conformance, there is either no irtpact.on the ability to achieve safe shutdown following a fire in any fire area or the impact is negilgible. Each demonstration considers Peach Bottom-specific features, interim hardware changes, and the use of assunptions more realistic than those specified in Appendix R.

Of course, the conservative Appendix R assunptions will be utilized in all cases for the design and Implementation of the final modifications required to correct the identified conditions of non-conformance.

If you have any questions or require additional information, please do not hesitate to contact us.

Very truly yours,

/

S. J. Kowalski Vice President JTR/cb/11258601

Attachment:

" Evaluation of Shutdown Capability in the Event of a Fire" Copy to:

D. R. Muller, Director, BWR Project Directorate 162, Division of BWR Licensing, NRC T. P. Johnson, NRC Resident Site Inspector R. J. Clark, NRC Project Manager i