ML20207L967

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Safety Evaluation Supporting Amend 123 to License DPR-35
ML20207L967
Person / Time
Site: Pilgrim
Issue date: 10/13/1988
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20207L965 List:
References
NUDOCS 8810180043
Download: ML20207L967 (3)


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of UNITED STATES NUCLEAR REGULATORY COMMISSION c

h W ASHINGTON, D. C. 20666 I

i SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION l

RELATED TO AMENDMENT NO. 123 TO FACILITY OPERATING LICENSE NO. DPR-35 j

BOSTON EDISON COMPANY PILGRIM NUCLEAR POWER STATION DOCKET NO. 50-293 i

INTRODUCTION The Safety Evaluation Report (SER) that accompanied Pilgrim Nuclear Power Station (PNPS) Technical Specification Amendment No. 35 documented PNPS compliance with Appendix A of Franch Technical Position (BTP) APCSB 9.5-1.

Section 4.13 of the SEP identified the fire barriers that provide 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> see, ration between redundant safety related systems, or separation of areas with significant fire hazards.

During refueling outage number seven, a reevaluation was conducted of fire barriers, including fire doors, fire darpers and penetration seals. This review determined that existing documentation would not support verification of a three hour rating for some of the barriers referenced in the SER, As a result, Fira Protection Engineering Evaluations (FPEEs) were performed to determine the adequacy of these fire barriers.

By letter dated August 6, 1988 (BECO 88-120), the licensee advised the NRC that FPEEs had been perfomed and requested that the NRC amend Section 3 F of Facility Operating License No. OPR-35. An amendment to the license is required because relief is sought from a previous amendment. No. 35.

This Safety Evaluation was undertaken to review the methodology and accuracy of FPEEs used to document the acceptability of selected PNPS fire barriers having a fire rating of less than three hours.

EVALUATION The licensee's process for conducting FPEEs provides a femal and consistent methodology for verifying and documenting the adequacy of specific fire protection systems or features. FPEEs have been used to document the acceptability of fire barriers having a fire rating of less than three hours.

FPEEs are compnsed of the following elements:

Area configuration and occupancy, 8810180043 SS1013

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i Combustible loading (in tenns of equivalent fire severity), extent and nature of combustibles, and continuity of combustibles.

Safe Shutdown Systems, potentially affected.

Consequences of a fire in an area.

(This section includes the fire hazards analysis, means of fire propagation, consequences and potential impact on safe shutdown capability).

i Other considerations.

(Other topics that may be included, where appropriate, are: fire protection features, ir.cluding detection and suppression; purpose of barrier; other factors that limit fire spread.

Review and approval by a Fire Protection Engineer.

1 The staff has previously reviewed and approved the concept of FPEEs to document the adequacy of fire protection measures at PNPS when the existing configuration was otherwise not in strict compliance of Appendix R requirements, For the 17 fire barriers that are the subject of this evaluation the licensee's analysis by FPEE finds that 15 have a rating that exceeds the fire hazard to which the barrier is exposed. That is, the combustible leading, extent and nature of combustibles and their continuity (all expressed in British Thermal Units) do not exceed the fire rating of the barrier being analyzed. The remaining two fire barriers separate a fuel oil day tank, and the turbine lube oil reservoir and storage areas from surrounding equipment.

The fire hazard for each of these locations exceeds even a 7.hree hour fire barrier because of their high combustible loading, l

however, each of these areas are provided with autouatic fire suppression and fire detection.

L TM se barriers do not fully satisfy the requirements of Section Ill.G 2.a of l

Appendix R to 10 CFR Part 50, in this case, however, the FPEEs have demon.

i strated that the barriers provide adequate protection aganist the fire hazards i

to which they are exposed, except for two instances where the areas are l

provided with automatic fire detection and suppression which provide the t

t required protection.

Therefore, the underlying purpose of the requirement for 3-hour fire barriers is satisfied ir these cases. Accordingly, the staff has determined that an exemption is required from the reautrement of Section l

Ill.G.2.a. to the extent that redundant safe shutdown :apability is supported j

by 3-hour fire rated barriers, q

ENVIRONMENTAL CONSIDERATIONS I

The NRC staff has detemined that these barriers do not fully satisfy the requirements of Section !!!.G.2.a of Appendix R to 10 CFR 50 in relation to l

3-hour rated fire barriers and a Notice of Environmental Assessment and Finding of No Significant Impact was published in the Federal Register on l

October 13, 1908 (53FR40146).

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i 3-CONCLUSION On the basis of the Evaluation presented above, the staff finds that the relief sought by the licensee for Section 3.F of the license should be granted and their license so amended, i

The staff has concluded, based on the considerations discussed above, that (1) there is reasonable assurance that the health and safety of the will not be endangered by operation in the pro >osed canner, and (2) public t

such activities will be conducted in compliance wit) the Commission's regulations, and the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public. Accordingly, we conclude that the proposed changes are acceptable.

PRlilCIPAL CONTRIBUTORS:

E. H. Trottier D. Mcdonald Dated:

October 13, 1988 f

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