Text

Forwards Revised,New & Temporary Exemptions from 10CFR50,app R,In Ref to NRC Ltr Re Meeting on 920528,to Discuss Results of New App R Analysis & Potential Exemptions Needed as Results of Analysis
	ML20101K871
Person / Time
Site:	FitzPatrick
Issue date:	06/26/1992
From:	Ralph Beedle; POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
	JPN-92-032, JPN-92-32, NUDOCS 9207060128
	Download: ML20101K871 (50)
	v • d • e

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123 Ma=n Street Wtute Plains. New York 10601

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June 26,19n2 JPN 92-032 U. S. Nuclear Regulatory Commission Attn.: Document Control Desk Mail Station P1 137 Washington, DC 20555

SUBJECT:

James A. FitzPatrick Nuclear Power Plant Docket No. 50 333 Revised, New or Temporary Exemptions From 10 CFR 50, Appendix R

REFERENCE:

1. NRC letter, R. A. Plasse to NYPA, dated Jur a 8,1992, regarding the meeting on May 28,1992 to discuss the results of the new Appendix R Analysis and the potential exemptions needed as a result of this analysis.

Dear Sir:

Authority and NHC staff members met on May 28,1992 to discuss draft exemption requests from the requirements of Appendix R to 10 CFR 50 (Reference 1). The exemption requests are in Attachment 1. These requests are a result of the recent reassessment of the Fire Protection Program at F!!zPatrick.

The Authority is requating a total of six exemptions. The exemptions have been divided into three exemption request categories: revised, new and temporary. The Yevised exemption requests ask that existing exemptions be modified to include additional fire areas or equipment.

For each revhed exemption request, the original exemption basis presentN in the associated NRC safety evaluation remalas. The new exemotion request has not been previously submitted to the NRC and results from the new 1992 Appenc,x R reanalysis for FitzPatrick. The temporary exemption requests are presented because modifications necessary to bring the plant into compliance with Appendix R cannot be completed prior to startup.

The hardship to the Authority if these exemptions are not granted is that the plant will have to remain shutdown until the modifications are complete. The total cost of the modifications tha, would be implemented if the revised and new exemption requests are denied is estimated to cost approximately $3,870,000. A!I the rva fications discussed in the exemptior requests would be conipleted prior to startup from the av d refueling outage which translates mio 20 months (i.e.,

18-month cycle plus 2-month refu6.g outage). This 20 months reflects the longest schedule if the temporary exemption requests are denied. At a cost of $12,000,000 per month in lost revenue (i.e., $400/)00 per day and 30 days per month) the estimated total lost revenue to the Authority is

$240,000,000 if FitzPatrick had to remain shutdown for an additional 20 months. This lost reveriue estimate only includes the loss of income from FitzPatrick generated power and does not include the cost of replacement power. Therefore,if all the enclosed exemption requests are denied, the estimated total cost to the Authority is $243,870,000. h

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9207060128 PDR 920626 Y ADOCK 05000333 i PDR

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These are only preliminary estimates of the time and cost it would take to complete the modifications if the exemptions are not granted. Detailed engineering, cost and schedule evaluations have not been prepared to support these estimates.

The Authority's fire protection staff are available to meet with your staff to further discuss these exemptions, if you have any questions regarding these exemption requests, please contact Mr. J. A. Gray, Jr.

Very truly ours, Ralph E. Beedle Executive Vice President

- Nuclear Generation ec: Regional Administrator U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Office of the Resident inspwtor U. S. Nuclear Regulatory Commission P. O. Box 136 Lycoming, NY 13093 Mr. Richard Plasse Project Directorate 11

- Division of Reactor Projects - 1/II U. S. Nuclear Regulatory Commission Mail Stop 14 B2 Washington, DC 20555 4

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! ATTACHMENT 1 TO JPN-92-032 1

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! REQUESTS FOR EXEMPTION FROM 10 CFR 50, APPENDIX R i

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3 JAMES A FITZPATRICK NUCLEAR POWER PLANT:

1 NEW YORK POWER AUTHORITY -

l- JUNE 26,1992 '

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ATTACHMENT 1 TO JPN 92-032 9

1.0 INTRODUCTION

The Authority is requesting the exemptions listed in this attachment as a result of the recent reassessment of the Fire Protection Frogram at the James A. FitzPatrick Nuclear Power Plant.

The exemption requests aro summarized in Se. tion 2.0 and are divided into three exemption request categories: revised, new and temporary. The revised oxomption requests are necessary to include additional fire areas and/or equipment. For each revised exemption roquest, the original exemption basis presented in the associated NRC safety evaluation remains unchanged.

The new exemption request has not been previously submitted to the NRC and results from the now 1992 Appendix R reanalyds for FitzPatrick. The temporary exemption requests are necessary to permit plant startup before modifications to bring the plant into Appendix R compliance can be completed. The revisod exemption roquests are in Section 3.0, the new exemption requests are in Section 4.0, and the temporary exemption requests are in Section 5.0.

The equipment descriptions reflect the configuration that the plant will be in when it starts up from the current refueling outage.

Table 1.0-1 lists the Fire Arcas and Firo Zones at FitzPatrick, t

Page 2 of 49 1

ATTACHMENT 1 TO JPN 92-032 Table 1.01 FitzPatrick Fire Arc.as/ Fire Zones FIRE AREA FIRE ZONE AREA DESCRIPTION lA AD-1 Administration Building el. 272' AD-2 Administration Building el. 272' AD-3 Administration Building el. 272' AD-4 Administration Building el 286' AD-5 Administration Building el. 286' AD-6 Administration Building el. 300' AS 1 Auxiliary Boller Room el. 272' MG1 Motor Generator Room el. 300' IB FP-1 West Diesel Fire Pump Room el.255' CR2 Radwaste Building Control Room el. 284' RW 1 Radwaste Building and Pipo Tunnel SH-13 Screenwell House IC CT 1 West Cable Tunnel el. 260' SW 1 Turbine Building Switchgear Room el. 272' ID CT 4 North Cable Tunnel el. 286' IE FP 2 Turbine Building Foam Room el. 272' TB 1 Turbine Building Basement el 252', Mezzanine el. 292', and Operating Floor el. 300*

OR1 Turbine Building Turbine Oil Storage Room el. 252' OR-2 Turbine Building Turbine Oil Storage Room el. 272' OR3 Turbine Building Miscellaneous Oil Storage Room el. 252' ll CT 2 East Cable Tunnel el. 260' SW 2 Turbine Building Switchgear Room el. 272' lil BR-1 Battery Room 1 el. 272' BR 2 Battery Room 2 el. 272' IV BR 3 Battery Room 3 el. 272' BR-4 Battery Room 4 el;272' V EG 1 A Emergency Diesel Generator Room el. 272'- .-

EG 2 C Emergency Diesel Generator Room el. 272' EG 5 Emergency Diesel Generator South Switchgear Room el. 272' t Page 3 of 49 q

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l ATTACHMENT 1 TO JPfl-92-032 t

Table 1.01 FitzPatrick Fire Areas / Fire Zones -

(continued)

FIRE AREA FIRE ZONE AREA DESCRIPTION VI EG 3 B Emergency Diesel Generator Room el. 272' EG 4 D Emergency Diesel Generator Room el. 272' EG-6 Emergency Diesel Generator North Switchgear Room el. 272' Vil CR1 Control Room el.300' RR-1 Relay Room el 284' CS-1 Cable Spreading Room el. 272' Vill RB 1C Reactor Building Northeast and Northwest Quadrants el. 300'-

IX SB-1 Standby Gas Filter Room el. 272' RB-1 A Reactor Building East Side el. 272', Southeast Quadrant el. 300', and Entire Floor on el. 326',

el. 344', and el. 369' .

l X RB 1B Reactor Building East Side al. 272' and Southwest Quadrant el. 300' XI CT 3 South Cable Tunnel el. 286' XII SP1 South Safety Related Pump Room el. 255' Xill SP 2 North Safety Related Pump Room el. 255' -

XIV PC-1 Primary Containment (Drywell)

XV SU 1 Torus Room -

XVI BR 5 Battery Room Corridor el. 272' XVil RB 1E Reactor Building East Crescent Area ol. 227' i XVill RB 1W Reactor Building West Crescent Area el. 227' YARD XR1 Transformer Area West of Turbine Building CAD-1 West End of Containment Air Dilution Building CAD-2 East End of Containment Air Dilution Building CST-V Condensate Storage Tank Concrete Vault MH-2 Manhoto No. 2 Located East of Reactor Building and South of Auxiliary Boiler Room Page4 of 49

ATTACHMENT 1 TO JPN-92-032 2.0

SUMMARY

OF EXEMPTION REQUESTS 2.1 . Revised

1. Revise an existing exemption from the requirements of 10 CFR 50, Appendix R, Sections lil.L1.b and Ill.L2.b so that the reactor coolant level be permitted to drop below the top of the core for BWRs during use of alternative safe shutdown procedures which includes the possibility of Control Room evacuation following a fire in any of five fire zones: (1) Control Room; (2) Relay Room; (3) Cable Spreading Room; (4) North Cable Tunnel; (5) Battery RNm Corridor.

2. Revise an existing exemption from the requirements of 10 CFR 50, Appendix R, Sections lll.G.?, Ill.G.3 and Ill.L with respect to the separation of redundant safe shutdown circuits in that they are not in accordance with Section Ill.G.2 and alternate shutdown capability has not been provided in accordance with Sections lil.G.3 and Ill.L in the Torus Room (Fire Area XV) and adjacent Fire Areas IX, X, XVil and XVill.

2.2 New

1. Grant a new exemption from the requirements of 10 CFR 50, Appendix R, Section lit.J that mandates permanently installed 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Appendix R W ng in -

outdoor areas. The requested exemption is to use general outdoor liv. . , outdoor security lights, vehicle headlights and/or flashlights for exterior access and egress routes not only for the Fire Areas listed in the exemption request, but for any Fire Area where exterior access and egress routes may be used.

2.3 Temporary

1. Grant a temporary exemption from the requirements of 10 CFR 50, Appendix R, Section Ill.G.1 with respect to the ventilation systems in the Emergency Service .

Water (ESW) and Residual Heat Removal Service Water (RHRSW) Pump Rooms _j (Fire Areas XII and Xill) being free of fire damage. The exemption is needed until .

the modifications can be completed to assure that one division of RHRSW and ESW and either the electric or diesel driven fire pump and the associated ventilation systems will be available in the event of a fire in Fire Areas IB or 11.-

Interim compensatory actions will be implemented until the modifications are completedJ See NYPA LER 91021-00, dated November 27,1991.

4 Page 5 of 49

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ATTACHMENT i TO JPN 92-032 8 4

2. Grant a temporary exemption from the requirements of 10 CFR 50, Appendix R, Sections Ill.G.2 and lit.G.3 with respect to a full area suppession system being required in the West Cable Tunnel (Fire Area IC) to protect rodundant circuits that are Installed in this area. The exemption is nesdod until modifications can be completed to provide fire supprossion adoquate for the hazards present. Interim compensatory actions will be implomonted until the modifications are completed.

In addition, a full area suppression system is being installod in the East Cablo Tunr'el (Fire Area ll). The inoperability of the existing suppression system is governed by the requirements of Branch Technical Position (BTP) 9.5-1, Appondix A. Therefore, the impact of a fire on the safe shutdown systems in the East Cable Tunnel is covered by the interim compensatory actions and permanent modifications discussed in the Pump Room Ventilation exemption request.

The inoperability of the existing suppression systems in both cable tunnels was discussed in NYPA LER 92-004-00, dated February 14,1992.

3. Grant a temporary exemption from the requirements of 10 CFR 50, Appendix R, Section Ill.G.2 with respect to three-hour rated fire barrier penetration seals. The exemption is needed until concerns associated with bondstrand, green . read and PVC (polyvinyl chloride) piping penetrations can be resolved and modifications can be completed to assure separation by a three-hour-rated fire barrier. Interim compensatory actions will be implemented until the modifications are completed.

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I A1TACHMENT 1 TO JPN 92-032 3.0 REVISED EXEMPTIONS 3.1 Alternate Shutdown With Control Room Evacuation Exemption Requested in accordance with the provisions of 10 CFR 50.12(a), the New York Power Authority 9 quests a reused exemption from the requirements of 10 CFR 50, Appendix R, Sections Ill.L1.b und Ill.L2.b as they apply to the James A. FitzPatrick Nuclear Power Plant so that the reactor coolant level be permitted to drop ovow the top of the core for BWRs during use of alternative safe shutdown procedures which includes the possibility of Control Room evacuation following a fire in any of five fire zones: (1) Control Room; (2) Relay Room; (3) Cable Spreading Room; (4) North Cable Tunnel; (5) Battery Room Corridor.

This exemption would extend the current exemption that allows the use of alternate shutdown with Control Room evacuation to two additional Fire Areas: 1) Fire Area ID (North Cable Tunnel) and 2)

Fire Area XVI (Battery Room Corridor). The result of this request is to treat a fire in these two areas in the same fashion as the current exemption treats a fire in Fire Area Vil (Control Room, Relay Room, Cable Spreading Room).

Fire Areas / Fire e o.- is Affected FIRE AREA FIRE ZONE AREA DESCRIPTION ID '.,T-4 North Cable Tunnel el. 286' Vil CR-1 Control Room ol. 300' RR1 Relay Room el 284' CS-1 Cable Spreading Room el. 272' XVI BR-5 Battery Room Corridor el. 272*

Technical Justification

Background

The NRC approved the use of Automatic Depressurization System (ADS) in conjunction with the Residual Heat Removal (RHR) system in the Low Pressure Coolant injection (l_PCI) mode of operation for achieving remote reactor shutdown for a fire in Fire Area Vll (Control Room, Relay Room, and Cable Spreading Room) in Reference 3.1-1.

9 in References 3.12 and 3.1-3, the Authority requested an exemption from the requirements of 10 CFR 50, Appendix R, Sections Ill.L1.b and Ill.L2.b so that the reactor coolant level be permitted to drop below the top of the core during the use of alternate safe shutdown following a postulated fire which renders the Cc /;:' ~ 'm uninhabitable. That exemption request was based on an analysis which determined the amount of time available for operator action before ADS initiation was necessary. Assum' e loss of all high pressure makeup coincident with reactor

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scram and isolation, this analysis K., - ed an increase in the operator response time from ten to thirty minutes. The NRC approved tne exemption in Reference 3.14.

Page 7 of 49

ATTACHMENT 1 TO JPN-92-032 Physical Artang ment .

Fire Areas ID and XVI associated with this revised exemption request are adjacent to Fire Area Vll which is assodated with the original exemption. Their arrangement supports a revised exemption -

L. becaitse they are not discontinuous. The two additional Fire Areas are immediately adjacent to the Control Room Complex (Control Room, Relay Room, Cable Spreading Room). The north wall -

of the Cable Spreading Room (el. 272') is the south wall of the Battery Room Corridor (el,272').-

The east wall of the North Cable l'unnel (01. 286') is part of the west wall of the Relay Room (el. 284').

Fire Protection Features The North Cable Tunnel (Fire Area ID) is bounded by thre& hour rated fire bartiers. There are no e significant fixed exposed combustibles in this area other thar$ Ne retardar t r: ables. Smoke

- detection and automatic carbon dioxide suppression systemb are provided throughout this area.

The Battery Room Corridor (Fire Area XVI) O bounded by three-hour rated fire walls. There tfe no significant fixed exposed combustibles in this area other than fire retardant cables. A smoki, detection system is provided throughout this area. In addition, a modification, that will be completed prior to startup from the current refueling outage, will provide an automatic w6 pipe e sprinkler system throughout this area.

Shutdown Systems Affected For Fire Area ID, a fire could potentially disable the following systems: RHR (Division A LPCI, Division A Suppression Pool Cooling, Division B - Suppression Pool Cooling), Core Spray -

(Division A and B), RCIC, HPCI, Control Room Ventilation (Division A and B) and Relay Room Ventilation (Division A and B), and capability to actuate the SRVs from the Control Room (capability to actuate the SRVs from the Alternate Shutdown Panel has been assured).

For Fire Area XVI, a fire could potentially disable the following systemsi RHR (Division A), Core -

Spray (Division A and B), RCIC, HPCI, Control Room Ventilation (Division A and B), and capability to actuate the SRVs from the Control Room (capability to actuate the SRVs from the Alternate Shutdown Pa..al has been assured). In addition, Control Room process monitoring and diagnostic instrumentation (Reactor Vessel level, Reactor Vessel oressure, Torus level, Torus prt.as ~e and RHR flow) may be lost due to loss of power supplies (i.e., due to the loss of Control Room untilation the power supplies overheat).

Prior Exemption Basis StillValid

. The Authority has reviewed its submittals and the NRC's transmittals (References 3.1 1 through 1 3.1-5) The basis of the Authority's analysis remains valid and is sufficiently conservative and -

st 3tes that the operator has up to thirty minutes to initiate manual actions outside the Control Room. This maximum operator action time of thirty minutes will not pose a threat to the fuel cladding integrity or compromise the attemate shutdown method proposed.- A thirty minute operator action time will not compromise the ability of the suppression pool to condense steam in a stable condition during steam discharge via safety / relief valves, or compromise the' integrity of the suppression pool.

Page 8 of 49 i

ATTACHMENT 1 TO JPN=92-032

, i The orsrator actions required to support tho use of ADS /LPCI from the Alternato Shutdown Panots, for a firo in Fire Arca ID or XVI, ato a subset of those required for a firo in Fire Arca Vll.

Thorofore, the oporator actions necessary to safoly shutdown the plant in the ovent of a fire in Firo Areas ID or XVI would be less challenging than a fire in Fire Arca Vll.

Many systems that are postulated to be lost due to a postulated fire in olther Fire Area ID or XVI, would be temporally available for use in the Control Room since their loss is not due to diroct fim damago, but rather due to a loss of Control Room ventilatlon. Thus shutdown would initially start in the Control Room and operators would be dispatched, por procedures if the Control Room heats up, from the Control Room to the local control panels. As Control Room control and/or indication is lost (i.e., due to loss of ventilation, the Control Room slowly heats up and equipment becomes inoperable), theso Nnctions would be transferred to the operators at the local control panels. Thorofore, safe shutdown scenarios (both opernor action and operator action time) for postulawd ':res in Fire Areas ID and XVI are enveloped by the safe shutdown scenarios for postulated firos in Fire Arca Vll.

Battery Room Corridor Suppression System Exemption The Authority had previously requested an exemption (References 3.15 and 3.1-6) from the requirements of 10 CFR 50, Appondix R, Section Ill.G.3 for the Battery Room Corridor. Attor the Authority committed to provide suppression in the Battery Room Corridor (Reference 3.17), the NRC granted the exemption (Reference 3.18). However, the exemption will no longer be required when the installation of a suppression system in this area is complete, The Authority has committed to complete tho installation of this new system prior to startup from the current refueling outage (Roterenco 3.17) and will abandon the exemption.

Hardship to the Authority The hardship to the Authority if this exemption is not granted is that the plant will have to remain shutdown until modifications are complete. The modifications that would be required are: provido a!! ornate power for various components in the HPCI and/or RCIC systems and relocate the transformer and associated equipmeni so that process instrumentation would be available in the Control Room. These modifications are estimated to cost approximately $420,000. The Authonty estimates that it will take approximately two months after the present refueling outage to design, install and test those modifications. At a cost of $12,000,000 por month in lost revenue (1.o.,

$400,000 per day and 30 days per month) the estimated total lost revenue to the Authority is

$24,000,000 if FitzPatrick had to romain shutdown for an additional two months. This lost revenue estimate only includes the loss of incomo from FitzPatrick generated power and does not include the cost of replacement power. Therefore, the estimated total cost to the Authority is

$24,420,000.

These are only preliminary estimates of the time and cost that it would take to complete the above modifications. Detailed engineering, cost and schedulo evaluations have not been prepared to support these estimates.

Page 9 of 49 l

ATTACHMENT 1 TO JPN 92-032 10 CFR 50.12 Criteria This request satisfios the critoria outlined in 10 CFR 50,12(a)(1) for granting an oxomption becauso (a) the exemption is authorized by law, (b) it will not present an undue risk to pub!ic health and safoty and (c) it is consistent with the common defense and security, 10 CFR 50.12(a)(2) states that the Commission will not considor granting an exemption request unless special circumstancos are present. Special circumstancos are present whenover:

(1) Application of the regulation in the particular circumstancos conflicts with other rules or requirements of the Commission; (ii) Application of the regulation in the particular circumstancos would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule; or (iii) Compliance would lasult in undue hardship or other costs that are significantly in excess of thoso contemplated when the regulation was adopted or that are significantly in excess of those incurrod by others similarly situatod; or (iv) Tho oxomption would result in bonofit to the public health and safety that compensates for any decrease in safety that may result from the grant of the exemption; or (v) The exemption would provide only temporary relief from the applicable regulation and the licensoo or a,.plicant has mado good faith efforts to comply with the rogulation; or (vi) There is present any other material circumstances not considered when the regulation was adopted for which it would be in the public interest to grant an exemption.

This exemption request satisfies critorion 10 CFR 50.12(a)(2)(ii) as follows:

a) That for fire scenarios where the Control Room is evacuated, alternate shutdown capability exists, and l b) The Authority demonstrated, in the analyses provided in Reference 3.13, that although there is a maximum time interval of 150 seconds during which the coolant ,

level would drop below the top of the coro, safo shutdown could be affected from the remote shutdown panels under a maximum operator action time of 30 minutos using approved alternate shutdown proceduros without fuel damage. l t

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ATTACHMENT 1 TO JPN 92-032 References 3.1 1 NRC Letter from D. B. Vassallo; to J. P. Bayne; dated April 26,1983; subject:

" Alternate Safe Shutdown Capability, Modifications and Exemptions to Meet Appendix R of 10 CFR 50 Fire Protection' 3.1 2 NYPA Letter JPN-85-49 from J. C. Brons; to D. B. Vassallo; dated June 14,1985; subject: ' Appendix R to 10 CFR 50, Section Ill.L Request for Exemption Regarding Alternate and Dedicated Shutdown Capability

3.1 3 NYPA Letter JPN-85-90 from J. C. Brons; to D. R. Muller; dated December 17, 1985; subject: ' Appendix R to 10 CFR 50, Section Ill.L Exemption Request Regarding Alternate and Dedicated Shutdown Capability" 3.1-4 NRC Letter from R. M. Bernero; to J. C. Brons; dated September 15,1986; subject:

" Exemption From Appendix R of 10 CFR 50 Concerning Core Uncovery During Alternate Safe Shutdown

3.1 5 NYPA Letter JAFP-91-0454 from R. J. Converse; to NRC Document Control Desk; dated July 31,1991; subject: "Ap sendix R to 10 CFR 50 Exemption Request for Area Wide Suppression in the Battery Room Corridor" 3.1-6 NYPA Letter JPN 91040 from R. E. Boedle; to NRC Document Control Desk; dated August 6,1991; subject: " Additional Information and Errata Regarding Two Appendix R of 10 CFR 50 Exemption Requests

3.1 7 NYPA Letter JPN 91-043 from R. E. Beedle; to NRC Document Control Desk; dated August 16,1991; subject: " Schedule for Short Term Fire Protection Actions" 3.1 8 NRC Letter from R. A. Capra; to R. E. Beedle; dated September 18,1991; subject:

" Issuance of a Technical Exemption from a Requirement of 10 CFR Part 50, Appendix R, for the James A. Fit 2 Patrick Nuclear Power Plant (TAC No. 81184)"

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. ATTACHMENT 1 TO JPN-92-032 s

3.2 Torus Room

' Exemption Requested in accordance with the provisions of 10 CFR 50.12(a), the New York Power Authority requests a . *

revised exemption from the requirements of 10 CFR 50, Appendix R, Sections lil.G.2, Ill.G.3 and -

lit.L with respect to the separation of redundant safe shutdown circuits in that they are not in i accordance with Section Ill.G2 and a!!emate shutdown capability has not been provided in 2

accordance with Sections Ill.G.3 and Ill.L in the Torus Room (Fire Area XV) and adjacent Fire -

) Areas IX, X, XVil and X\';ll, i

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This exemption would revise the current exemption to more accurately reflect the equipment in the Torus Room and adjacent areas, it would also provide a revised technical basis for the exemption to reflect the new area description. .

Fire Areas / Fire Zones Affected e.

FIRE AREA FIRE ZOfJE AREA DESCRIPTION IX SB 1 Standby Gas Filter Room el. 272' 4 RB-1 A . Reactor Building East Side el. 272', Southeast

, Quadrant el. 300', and Eiitire Floor on el. 326',

. el. 344', and el. 369' X RB-1B Reactor Building East Side el. 272' and Southwest Quadrant el. 300*

XV SU 1 Torus Room XVil RB 1E Reactor Building East Crescent Area el. 227' XVill RB-1W Reactor Building West Crescent Area el. 227' Technical Justification Backaround in Reference 32-1, the NRC granted an exemption from the' requirements of 10 CFR 50,'

Appendix R, Sections Ill.G.2, Ill.G.3 and Ill.L which stated that neither separation, suppression, -

detection and/or protection of redundant shutdown divisions nor the installation of an alternate shutdown capability is required for the Torus Room. Page 4 of the NRC's Safety Evaluation -

includes a description of the Torus Room:

" the area contains only the suppression pool and is a controlled access area bounded on all sides by three-hour rated masonry construction; there are no combustible materials and no significant fire hazards in the area! and that :

shutdown related components in the area consist only of the RHR pump suction -

valves of both divisions. These valves are in an open position and all power cables to them have been disabled under a previously approved plant modification."

, Page 12 of 49

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ATTACHMENT 1 TO JPN-92-032 This poagraph does not accurately describe the Torus Room. However, the technical basis for the exemption remains valid.

Physical Arrangement The Torus Room (Fire Area XV) is located in the Reactor Building with its floor being at el. 227'.

This room is a controlled access area and is bounded on all sides by masonry construction.

The floor and more than half of the walls of the Torus Room are below grade (approximate!y el. 271'), adjacent to the exterior and thus not an issue sincc fire propagation from the exterior is not a concern. The wails that separate the Torus Room from the crescent areas (Fire Areas XVil and XVill) are three-foot thick reinforce 1 concrete. The unsealed penetrations in these walls are shown in Figures 3.21 and 3.2 2. The ceiling that separates the Torus Room from Reactor

. Building el. 272* (Fire Areas IX and X) is two-foot thick reinforced concrete. The unsealed penetrations in this ceiling are shown in Figure 3.2-3.

The Torus Room contains the torus, valves, pipes, non-combustible insulation, instrument tubes and cables installed in conduits. This area is essentially devoid of exposed combustible, Fire Protection Features The Torus Room has neither an automatic fire detection system nor an automatic fire suppression system. Due to the area configuration and the combustible loading, this area was exempted (Reference 3.2-1) from the requirements necessitating these systems. Manual sprays are available from hose stations located in Fire Area IX.

Adjacent to the Torus Room are the East and West Cres':ent Areas (Fire Areas XVil and XVill respectively). They are provided with automatic smoko detection systems. Water curtains are provided to separate the East and West Crescent Areas and to separate the East Crescent Area from Fire Area IX. Manual sprays are available from hose stations located in Fire Areas IX, X, XVil and XVill.

The RCIC enclosure, which is in the West Crescent Area, is constructed of three hour fire-rated walls and ceiling. Curbs are also provided to prevent the spread of oil. Finally the RCIC Turbine is protected with an automatic water spray system. Consequently a fire in this enclosure will neither affect the West Crescent Area nor the Torus Room.

The HPCI enclosure straddles the boundary between the East and West Crescent Areas and since the enclosure is open (i.e., it has no ceiling) it is split by the water curtain between the crescent areas. The enclosure consists of a seven-and-one-half foot high spray shield wall to limit the

, spread of spraying oil and a curb to limit the spread of leaking oilin the event of a HPCI system oil line break. Finally the HPCI turbine is protected with an automatic water spray and manual foam suppression system. Consequently, a tire in this enclosure is not likely to affect the crescent areas or the Torus Room.

Page 13 of 49

A'lTACHMENT 1 TO JPN-92-032 Frorn above, the Torus Room is bounded by Reactor Building el. 272' (Fire Areas IX and X). This area is provided with automatic smoke detection systems. Water curtains are provided to separato Fire Area IX from Fire Areas X and XVil and to separate Fire Area X from Fire Area IX.

Manual sprays are available from hose stations located in Fire Arcas IX and X.

Shutdown Systems Affected The Torus Room contains valves and components associated with the HPCI and RCIC systems.

Conservatively, these systems will be considered disabled for a postulated fire in the Torus Room.

This area also contains equipment and cables associated with the Containment Atmospharo Dilution (CAD) System, specifically the nitrogen supply for the ADS accumulators Although the CAD System is not required for Appendix R safe shutdown, a postulated failure (i.e., the spurious opening of a CAD valve) may divert the nitrogen supply and could, if not detected and corrected, affect the long term operability of the ADS valves. Manual actions will be taken per procedures to assure CAD operability.

In addition, the Torus Room contains Core Spray suction valves 14MOV 7A and 14MOV 7B. While no!ther of these valves are needed for a fire originating in the Torus Room,14MOV 7A needs to be available for a fire in the eastem portion of the HPCI enclosure while 14MOV-7B needs to be available for a fire in the western portion of the HPCI enclosure. See the discussion on the HPCi enclosure provided under

Fire Originating Within the Crescent Area (Fire Areas XV!! and XVill)*.

Finally the Torus Room contains valves 10MOV 151 A and 10MOV 151B (RHR suction valves) which are in the open position with all power cables to them disabled. Thus th!s flow path would be available for safe shutdown during a fire in this area. This valve configuration was accepted by the NRC in granting the Torus Room exemption (Referonce 3.21).

Shutdown Systems Available Either RHR- LPCl/ Suppression Pool Cooling (Division A) or RHR LPCt/ Suppression Pool Cooling (Division B) will be available for safe shutdown in the Torus Room. Control Room ADS actuation capability is available. In addition, for a fire originating in the HPCI enciesure either Core Spray (Division A) or Core Spray (Division B) will be available.

Fire Originating Within the Torus Room (Fire Area XV)

The required safe shutdown equipment which is located in the Torus Room and subject to fire-induced failures is limited to the following instrumentation: Torus level (23LT-202A and 23LT-202B) and Torus temperature (161TI-131 A and 161Ti-131B). As described above, al! RCIC and HPCI valves located in the Torus Room and 10MOV 151 A,10MOV 151B,14MOV 7A, and 14MOV-78 are assumed lost in the event of a torus fire.

Page 14 of 49 I

ATTACHMENT 1 TO JPNo92-032 Rodundant torus level sensors are separated by a distanco of greator than 110 foot on the opposite tido of the torus without intervening exposed combustibles (Boo Figure 3.2-4).

Considering the type, spacing and quantitics of fixed combustibles and the low probability of transient cornbustibles to be located within the Torus Room, it is not considorod possibio for a firo in the Torus Room to propagate the intervening distance. Any associated fire damage would be localized to the immediato vicinity of the fire. The 110 foot separation with the radiant shielding of the drywell is more than acequate to assure that both the redundant torus level sensors are not lost.

For torus temperature measuremont, the plant uses Resistance Temperaturo Detectors (RTDs).

There are 32 RTDs (16 per Division) installed in 16 thermowells uniformly spaced around tho torus.

. Each thermowell contains or'e Division A RTD and one D! vision B RTD. The 16 Division A RTDs enter the west side of the Torus Room frcm el. 272' of the reactor building. A portion of the RTDs are routed clockwise with the remainder routed countor clockwise. The 16 Division B RIDS entur the east sido of the Torus Room from the Eest Crescent Area, a portion of the RTDs are routed clockwise with the remainder routed counter-clockwiso (see Figure 3.2-4).

Each channel of torus temperatuto instrun entation averages the temperature from its associated division RTDs. This instrumentation has the capability to recognize and discard failed RTDs.

Consequently, the loss of multiple RTDs within a divisic,n does not disable an entire channel. In addition, the operator can survey the RTDs inciividually in the Relay Room.

Although considered incredible, if it is assumed that all the RTDs and associated cablir.g located within a 120 degree arc of the Torus Room is lost due to a fire, sufficient RTDs would be unaffected to assure the operability of at least one division of torus temperature sensors.

Since the Torus Room is essentially devold of exposed combustibles, there is no firo exposure hazard to equipment and/or cabling in the crescent areas or Reactor Building el 272'.

i Fire Originating Within the Crescent Area (Fire Areas XVil and XVili)

The wall separating the East and West Crescent Arcas from the Torus Room is three-foot thick reinforced concrete containing a number of unsealed openings (soo Figures 31-1 and 3.2-2).

A fire in either the East or West Crescent Area is not expected to damage circuits and/or equipment in the Torus Room via the unrated seals and/or unsealed openings based on the i following:

a) The crescent area has a floor to-colling height of approximetely 40 feet, this allows l vertical rise of the thermal plume, thus limiting its horizontal spread and decreasing its temperature due to mixing with air, b) The vast majority of exposed combustibles in this area are installed above the non fire rated flood control bulkhead penetrations into the Torus Room, thereby limiting the fire exposure to the bulkhead,

! c) Except for the flood control bulkhead, which is not near the HPCI enclosure (see Figures 3.2-1 and 3.2-2), the non-fire-rated seal assemblies and unsealed penetrations are small, Page 15 of 49

ATTACHMENT 1 TO JPN 92-032 6

d) The HPCI oil will be contained in the HPCI onclosure and the Torus Room circuitry and/or equipment will not be directly exposed to the oil, e) The suppression systems (water spray and foam) installed in the HPCI enclosure will limit the extont and severity of the fire, and f) Fire detection and manual fire fighting would limit the extent of fire damage in this area.

In the unlikely event that a fire in the East or West Crescent Area cau+od damage in the Torus Room, this damage would not cause loss of redundant safe shutdov q capability based on the following:

a) There are no exposed combustibles in the Imrn- vicinity of the unsealed openings, thorofore, fire spread cannot occur an< damage which does occur would be limited to the immediato vicinity of the ing, b) For a fire in the East Crescent Area, Division A systoms are relied upon for safe shutdown and Division A torus level and temperaturo indic.ation will not be lost even if it is assumed that all circuitry and/or equipment within the portion of the

< Torus Room adjacent to the East Crescent Area is lost, c) For a fire in the West Crescent Area, Division 8 systems are relied upon for safe shutdown and Division B torus level and temperature indication will not be lost even if it is assumed that all circuitry and/or equipment within the portion of the Torus Room adjacent to the West Crescent Area is lost, d) For a HPCI enclosure fire, circuitry associated with Coro Spray suctic valves 14MOV 7A and 14MOV 7B (the only equipment in the Torus Room required to support Core Spray operation) is located in excess of 60 feet from the HPCI enclosure, thus due to the lack of fixed intervening exposed combustibles, it is not credible to postulate that a HPCI enclosure firo can spread within the Torus Room in such a manner that the circuitry for olther Coro Spray suction valves would be rendered inoperable, e) Sensing lines associated with torus level sensors 23LT 202A and 23LT-202B are located in excess of 100 feet from the HPCI enclosure, therefore, for the same reasons stated in (d) above, it is not credible to assume that either torus level sensors would be rendered inoperable, and f) If all cabling and equipment associated with torus temperature sensors 161TI 131 A and 161TI 1318 located in a 120 degree arc of the torus adjacent to the HFG enclosure was assumed lost, both 161TI 131 A and 161TI 131B woud be available.

Page 16 of 49

ATTACHMENT 1 TO JPN 92-032 Firo Origination on Reactor Building 01. 272' IFiro Arcas IX and X)

Fire Area IX is above the cast portion of the Torus Room and contains Divls:on B circuitry and equipment. Therefore, the plant relics on Division A circuitry and equipment for safe shutdown.

Fire Area X is above the west portion of the Torus Room and contains Division A circuitry and equipment. Thorofore, the plant relios on Division 8 circuitry and oquipment for safe shutdown.

The various unsealed mechanical ponotrationa (soo Figuro 3.2 3) that are in the fire barrior separating the Reactor Building el. 272' from the Torus Room are either sparos or contain pipes, conduits and/or tubing. In addition, there is a personnel access (ladder penetration RS 7) which is covered by grating. I Due to the configuration of these penettations and surrounoing combustibles, it is unlikely that any buming debris will f all into the Torus Room.

Further, buming debris from Fire Area IX, with the exception of the torus temperature indication, will only fall on Division 8 circuitry and/or equipment in the Torus Room. Since Fire Area IX contains Division B circuitry and equipment, the plant relios on Division A circuitry and equipment for safe shutdown due to a fire in Fire Area IX.

Similarly, burning debris from Fire Area X, with the exception of the torus temperaturo indication, will only fall on Division A ekcultry and/or equipment in the Torus Room. Since Fire Area X contains Division A circuitry and equipment, the plant relies on Division B circuitry and oculomont for safe shutdown due to a fire in Firo Area X.

The impact of any of this flaming debris on the Torus Room including the impact on the torus temperature indication is enveloped by the previous discussion provided under " Fire Originating Within the Torus Room (Fire Area XV)".

Hardship to the Authority The hardship to the Authority li this exemption is not granted is that the plant will have to remain shutdown until modifications are complete. The modifications that would be required are: provido full area suppression and detection, seal open penetrations in the fire barriers and provide additional one hour rated fire barriors and wraps. Theso modifications are estimated to cost approximately $3,350,000. The Authority estimates that it will take approximately two months after the present refueling outage to design, install and test those modifications. At a cost of

$12,000,000 per month in lost revenue (i.e., S400,000 per day and 30 days por month) the estimated total lost revenue to tr.1 Authority is $24,000,000 if FitzPatrick had to remain shutdown for an additional two months. This lost revenue estimato only includes the loss of incomo from FitzPatrick geurated power and does not include the cost of repiacement power. Therefore, the estimated total cost to the Authority is $27,350,000.

These are only preliminary estimates of the time and cost that it would take to complete the above modifications. Detailed engincoring, cost and schedule ovaluations have not been prepared to support these estimates.

Page 17 of 49

ATTACHMENT 1 TO JPN 92-032 10 CFR 50.12 Criteria This request satisfies the criteria outlined in 10 CFR 50.12(a)(1) for granting an exemption becauso (a) the exemption is authorized by law, (b) It will not present an undue risk to public health and safety and (c) it is consistent with the common defense and security.

10 CFR 50,12(a)(2) states that the Commission will not consider granting an exemption request unless special circumtances are present. Special circumstancos are present whenever:

(1) Application of the ,ogulation in the particular circumstances conflicts with other rules or requiremorsts of the Commission; (ii) Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achlove the underlying purpose of the rulo; or (iii) Compliance would result in undue hardship or other costs that are significantly in excess of thoso contemplated when the regulation wac adopted or that are significantly in excess of those incurrod by others similarly situatod; or (iv) The exemption would result in bonofit to the public health and safety that compensates for any decrease in safety thut may result from the grant of the exemption; or (v) The exemption would provido only temporary relief froin tha applicable regulation and the licensco or applicant has made good faith efforts to comply with the regulation; or (vi) There is present any other material circumstances not considered when the regulation was adc1ed for which it would be in the public interest to grant an exemption.

This exemption request satisfies critoria 10 CFR 50.12(a)(2)(ii) and (iii) as 1ollows:

a) The modifications required to achieve compliance with Sections Ill.G and Ill.L would not significantly enhance the level of fire safety above that provided by existing fire protection, and b) It would be costly to modify the Torus Room to comply with Sections Ill.G and Ill.L References 3.2 1 NRC Lotter from D. B. Vassallo; to J. P. Bayne; dated July 1,1983; subject:

" Exemption Roquests .10 CFR 50.48 Fire Protection and Appendu R to 10 CFR 60" Page 18 of 49

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ATTACHMENT 1 TO JPN 92-032

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ATTACHMENT 1 TO JPN-92-032 l

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4.0 NEW EXEMPTIONS l__ _ 4.1 ' Outdoor 8-Hour Appendix R Ughting Exemption Requested q I In accordance with the provisions of 10 CFR 50,12(a), the New York Power Authority requests an-

exemption from the requirements or 10 CFR 50, Appendix R, Section Ill.J as they apply to the -

James A. FitzPatrick Nuclear Power Plant that mandates permanently installed 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Appendix R I lighting in outdoor areas. The requested exemption is to use general outdoor lights, outdoor-security lights, vehicle headlights and/or flashlights for exter!or access and egress routes not only- l j for the Fire Areas listed in this exemption request, but for any Fire Area where exterior access and ,

egress routes may be used.

A fire in Fire Area ID, Vil, IX, X, XI, XV, XVil or XVill requires operator actions in the Containment -i

Atmosphere Dilution (CAD) Shack which is reached via exterior access and egress routes. _ A fire in Fire Area IV, V!! or XVI requires the transport of equipment from the warehouse to the plant.-

j Operator actions take place inside buildings or next to doors where interior 8-hour Appendix R '

i lighting is available.

Fire Areas / Fire Zones Affected FIRE AREA FIRE ZONE AREA DESCRIPTION ID CT-4 " North Cable Tunnel el.286'-

IV BR-3 Battery Room 3 el. 272'

! BR 4 Battery Room 4 el. 272' Vil CR-1 Control Room el. 300'

RR-1 Relay Room el. 284'

CS-1 Cable Spreading Room el.272*

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IX SB 1 Standby Gas Filter Room eli272' i- RB 1 A Reactor Building East Side el. 272', Southeast -

Quadrant el. 000', and Entire Floor on 01. 326', -

01,344', and el. 369' X RB 1B hactor BuW East Side el.272' and Southwest

.- Quadrari, . 300' XI CT-3 South C able Tunnel el. 286' XV SU 1 Torus Room XVI - BR 5 ' Battery Room Corridor el.-272* 1 XVil RB-1E Reactor Building East Crescent Area el. 227' -

N XVill - hB _1W . Reactor Building West Crescent Area el. 227':

t Page 23 of 49--

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ATTACHMENT 110 JPN 92-032 FIRE AREA F 'E ZONE AREA DESCRIPTION YARD CAD.1 West End of Containment Air Dilution Building CAD 2 Cast End of Containment Air Dilution Building CSTN Condensate Storago Tank Conesta Vault MH2 Manhole No. 2 Located East of Reactor Building and South of Auxiliary Boller Room Technical Justification Plant procedures for an Appendix R safe shutdown require various operator actions be performod at different aroas in the plant. However, a firo in Fire Areas ID, Vil, IX, X, XI, XV, XVil and XVill will require manual operator actions in the Containmont Atmosphore Dilution (CAD) Shack via access and egress routes outsido the buildings. A fire in Fire Areas IV, Vil and XVI will require personnel to transport specific components from the warehouse facility via access and ogress routes outsido the buildings. Figure 4.1 1 is a plot plan showing typical exterior access and ogress routes between the Administration Building and the CAD Shack and betwoon the Turbine Building and the warohouse.

For locations inside bull dings where access, egress and operator actions are required for Appendix R safe shutdown,8-hour Appendix R lighting has been installed or will be installed prior to startup from the current refueling outage. The exterior portions of the access and ogress routes to and from the CAD Shack and the warehouse are not provided with 8-hour Appendix R lighting.

The safe shutdown components (27AOV-128A,27AOV 1288 and 27 CAD 905) requiring operator actions are located in the CAD Shack and will bo illumir ated by 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Appendix R lighting in the event of loss of the plant's 115KV offsite supply. This 8-hour Appendix R lighting will be installed prior to startup from the current refueling outage.

A mobile dicsol generator, and it's associated hardware are stored in the warehouse and will be utilized to meet the portable ventilation requirements postulated in the FitzPatrick Appendix R Analysis. Inside the warehouse, both the storaga location and the access / ogress routes will be provided with 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Appendix R lighting. This 8-hour Appendix R lighting will be installed prior to startup from the current refueling outage.

Inside the plant 8-hour Appendix R lighting will be provided along the access / egress routes leading to exterior doors A-27213 and A 27214 of the Administration Building and exterior door E 272-1 of the Turbino Building. This 8-hour Appendix R lighting will be installed prior to startup from the curront refueling outage. Personnel could exit from door A-272-13 or A 272-14 when proceeding to the CAD Shack. Personnel retrioving the mobile diesel generator from the warehouse could exit from door E 272-1. A vehicle will be used to transport the mobile diesel

)

generator between the warehouse and the plant. The mobile diesel generator and it's associated equipment will be setup just outside of door E-272-1 where illumination from 8-hour Appendix R l lighting just insido door E 272-1 will be available.

During daylight hours outdoor lighting is not necessary and during nighttime hours the Authority I intends, via this exemption request, to use general outdoor lights, outdoor security lights. vehicle headlights and/or flashlights for exterior access and egress routes, i

Page 24 of 49

ATTACHMENT 1 TO JPN-92-032 The station perimotor fonce is illuminated by the station security lighting system which has backup power from the socurity diosol generator. This diesel generator is operated by automated circuitry and the diosol generator operability is monitored by security personnel. This assures that the security diosol generator will automatically start and pick up the security lighting circuits upon a loss of offsito power. The security diesel generator is designed to continuously supply power to the security lighting system in excess of eight hours. The security diesel generator is located in an area which is separated from those fire areas that contain safe shutdown components. The associated cables and conduits for the security perimotor lighting is not routed through any of the plant's internal fire areas.

Outdoor lighting is powered from the 13.2KV Lake Road System. This system is used only outside the plant and is independent of all internal plant electrical systems. Thoroforo, a loss of the 13.2KV Lake Road System is not considered credible during an intomal plant fire. Cable and conduit for the extorlor flood lights are not routed through any fire areas of the plant and thoroforo would not be affected by a fire insido the plant, in the unlikely event that the 13.2KV Lake Road System was unavailable, portable fylts wccid be adequate for providing illumination on the outside access / ogress routos. For personnel on foot, portable flashlights are storod in the emergency equipment lockers at various locations throughout the plant for use during omergencies. Flashlights are also stored in the Abnormal Operating Procedure equipment cabinets (Control Room ol. 300', Relay Room of. 284'), Remote Shutdown Panol (Roactor Building ol. 300'), Alternate Shutdown Panol 1 (Reactor Building el. 272'), Altomate Shutdown Panel 2 (Roactor Building East Crescent 01. 227') and Alternate Shutdown Panel 3 (Emorgency Diesel Generator North Switchgoar Room 01. 272'). There are also two additional large portable hand lights in the Control Room that are constantly trickle charged in order to assure their availability during emergencies. In addition, twenty-two hydrant stations around the plant are equipped with portable flashlights. Storage locations are inventorlod periodically por the plant procedures which assures that the correct number of flashlights are present and that they are operable.

The above stated provisions assure that plant personnel will have adequate illumination for" exterior access and ogress in the ovent of an Appendix R fire and a toss of the p' ant's 115KV offsito power.

Hardship to the Authority The hardship to the Authortly if this exemption is not granted is that the plant will have to remain shutdown until modifications are complote. The modifications that would be required are:

providing weatherproof lighting for the access and egross routes betwoon the plant and the CAD l Shack and the warehouse. These modifications are estimated to cost approximately $100,000.

l The Authority estimates that it will tako approximately two months after the present refueling outage to design, install and tost these modifications. At a cost of $12,000,000 por month in lost .

revenue (i.e., $400,000 por day and 30 days per month) the estimated total lost revenue to the Authority is $24,000,000 if FitzPatrick had to remain shutdown for an additional two months. This lost revenue estimate only includes the loss of incorne from FitzPatrick generated power and does not include the cost of replacement power. Thorofore, the estimated total cost to the Authority is

$24,100,000.

Page 25 of 49

ATTACHWiNT 1 TO JPN-92-032 Those are only preliminary estimates of the timo and cost that it would take to compicto the above modifications. Detailed engincoring, coat and schedule ovaluations have not boon prepared to support those estimates.

10 CFR 50.12 Cmeria This request satisfies the criteria outlined in 10 CFR 50.12(a)(1) for granting an exemption becauso (a) the exemption is authorized by law, (b) it will not present an unduo risk to public health and safety and (c) it is consistent with the common defense and security.

10 CFR 50.12(a)(2) states that the Commission will not considor granting an exemption request unless special circumstanc6s are present. Spoc!al circumstances are present whenever:

(i) Application of the regulation in the particular circumstances conflicts with other rulos or requiremonts of the Commission; (ii) Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule; or (iii) Compliance would result in indue hardship or other costs that are significantly in excess of those contemplated when h, regulation was adopted or that are significantly in excess of those incuirM by others st dlarly situatod; or (iv) The exemption would result in benefit to the public health and safety that compensates for any decrease in safety that may result from the grant of the exemption; or (v) The exemption would provide only tempor9ry relief from the applicable regulation and the licensee or epplicant has made good faith efforts to comply with the regulation; or (vi) There is present any other material circumstances not considered when the regulatior was adopted for which it would be in the public interest to grant an exemption.

This exemption request satisfies critoria 10 CFR 50.12(a)(2)(ii) and (iii) as follows:

a) The use c' the exterior security lighting with backup power from the security diesel, the exterior plant lighting supplied by the 13.2KV l.ake Road System, the use of vehicle headlights and/or the use of flashlights for outsido access / egress routes will provide the necessary illumination and satisfy the intent of Section Ill.J,

b) Such an exemption has been granted to other applicants (e.g., !ndlan Point 3, North Anna Units 1 and 2 and Trojan Nuclear Plant), and c) The modifications required to achiove compliaue with Section Ill.J would not significantly enhance the level of safety for exterior access and ogress routes illuminated by the existing lighting systems.

l l

l Page 26 of 49 l

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ATTACHMENT 1 T@JPN:92-032 5.0 TEMPORARY EXEMPTIONS 5.1 Pump Room Ventilation l Exemption Requested in accordance with the provisions of 10 CFR 50.12(a), the New York Power Authority requests a temporary exemption from the requirements of 10 CFR 50, Appendix R, Section Ill.G.1 as they apply to the James A. FitzPatrick Nuclear Power Plant with respect to the ventilation systems in the Emergency Service Water (ESW) and Residual Heat Removal Service Water (RHRSW) Pump Rooms (Fire Areas Xil and Xlll) being free of fire damage. The exemption is needed until the modifications can be completed to assure that one division of RHRSW and ESW pumps and olther the electric drivon fire pump or diesel driven fire pump and their associated ventilation i systems will be available in the event of a fire in Fire Areas IB or ll. The modifications are scheduled to be completed prior to startup from the Reload 11/ Cycle 12 refueling outage which is curtontly scheduled to begin in October 1993. Interim compensatory actions will be implemented until the modifications are completed.

The RHRSW A Pump and C Pump, the ESW A Pump and the Electric Fire Pump are located in the North Safoty Related Pump Room (Fire Area Xill). The RHRSW D Pump and D Pump as well as the ESW B Pump are located in the South Safety Related Pump Room (Fire Area Xil). The Diesel Fire Pump is located in the West Diosol Fire Pump Room (Fire Area IB). Those rooms are separate compartments in the Scroonwell House (Figure 5.1 1). Air to cool these compartments is drawn from and exhausted to the Scroonwell House. Contici Panels for the exhaust fans serving thoso compartmonts are located in tho Scroonwell House.

A fire in the Scroonwell House (Fire Area IB/ Fire Zone SH 13) could damsge the Control Panels which could doenergize the exhaust fans. Additionally, the fire could close the dampers in the rcom air intakes. A firo in the East Cable Tunnel (Fire Area ll/ Fire Zone CT 2) could damage -

cables which could doonergizo the exhaust fans. The loss of cooling to these cc mpartments when the pumps are operating could cause the pumps to overheat and fail. See NYPA LER 9102100 (Reforonce 5.1 1).

i l The Authority is in the process of developing modifications that will assure that ventilation is -

E available to one division of RHRSW and ESW and olther the electric or diosol driven fire pump in the event of a firo in the Scroonwell House or in the East Cable tunnel. However, it is anticipated - '

that the modifications will be extensivo and, due to the procurement of long lead timo equipment, will require approximately eighteen months to complete. Therefore, the Authority proposes interim compensatory actions until the modifications are complete.

Fire Areas / Fire Zones Affected FIRE AREA FIRE ZONE AREA DESCRIPT!ON IB FP 1 West Diesel Fire Pump Room 01. 255' CR2 - _ Radwaste Building Control Room el 284' RW1 Radwaste Building and Pipo Tunnel SH 13 Serconwell House l

ll CT 2 East Cable Tunnel el. 260' SW2 Turbine Building Switchgear Room el. 272' Page 23 of 49

ATTACHMENT 1 TO JPN 92 032 l

FIRE AREA FIRE 2ONE AREA DESCRIPTION X11 SP 1 South Safety Related Pump Room el. 255' Xill SP 2 North Safety Related Pump Room el. 255' Technical Justification

Background

l Tho ventilation systems in tho Safety Related Pump Room 'ine West Diesel Fire Pump Room wore modified in 1979 as a ret uit of the Authority's Branc' .,cnnical Position (BTP) 9 5.1, Appendix A fire protection work. These modifications are covered by the Ucense Condition issued as part of Amendment 47 to the FitzPatrick Operation Ucense (References 5.12 and 5.13).

The ventilation systems were interlocked with the fire detection system and a separate source of ventilation intake alt from the East Cable Tunnel was a:,sumed in the event of a fire in the Scroonwell House. The concerns associated with the ventilation systems were identified after a roview of firo scenarios indicated that ventilation would be inadequate if the fire detection system actuated or if the respective control panels were lost. The resulting inadequate ventilation could rendst the pumps in the room inoporablo. ;

Physical Arrangement ,

As shown in Figuro 5.1 1, the RHRSW A Pump and C Pump, the ESW A Pump ano the Electric Firo Pump are located in the North Safoty Rotated Pump Room (Fire Area Xill). The RHRSW B Pump and D Pump as well as tho ESW B Pump are located in the South Safety Rotated Pump Room (Fire Area Xll). The Diesel Fire Pump is located in the West Diesel Fire Pump Room (Fire Area 18). These rooms are separate compartments in the Screenwell House. AHo ventilate those compartments is drawn through openings at el. 255' and exhatJod through openings at el. 272' of the Scroonwoll Houso. Control Panels for the exhaust fans serving these compartments are located in the Screenwell House at ol 272' appraximately 10 feet apart. !

Existing Firo Protection Features Threo hour barriers surround the North and South Safety Related Pump Rooms as well as the West Diosol Firo Pump Room, except for the ventilation exhaust fan openings, nine pump

, supports, two unprotected steel plate assemblies, and a 30 by 30 steel access plate, three hour-rated penotration seals have been installed in these barriers. The exhaust fan openings were exempted from having fire dampers as discussed in References 5.14 and 5.15. Penetration seals l are not installod where vertical turbine pumps penetrate the room floor. The steel plate

! assemblies consist of caps welded to spare sleeved penetrations. The access cover is . ,

constructed of diamond plate steel and covers an access hole to the intake area below the room.-

lonization type smoke detectors are provided in both the Safety Related Pump Rooms and the-West Diesel Fire Pump Room. These annunciate in the Control Roomc Thermal fire detectors are also located in the Safety Related Pump Rooms, the West Diesel Firo Pump Room and at the room alt intakes. Those detectors annunciato an alarm in the Control Rcom and activate thelt associated ETLs (electro thermal links) when the temperature exceeds 135 degrces F. Thoso ETLs will be disabbd as part of the interim compensatory actions.

= Page 29 of 49

ATTACHMENT 1 TO JPN 92-032 High area temperaturo detectors aro installod in the Safety Related Pump Rooms. Thoso detectors also annunciato a trouble alarm in the Control Room if the area temperature exceeds 104 degroos F.

The firo dampers in the Safety Rolated Pump Room vontilation system air intakes are equipped with ETLs which activate by thormal firo detoction actuation or when tho temperature of the ETL excoods 165 degroos F.

Manual fire supprossion (hoso stations and portable extinguishors) ero louted throughout the Scroonwell House area and in the Safety Related Pump Rooms.

Arca detect!on and supprossion have not boon installod in the Scroonwell Houso because of the noncombustible construction of the building and the low combustible loading. The Scroonwell House is en open area of approximatoly 19,000 4f with a roof at ol. 301' 8*.

1 ScroonwolMjouso Firo The safo shutdown components and circuitry rolled for sale shutdown in the ovont of a firo in tho Scroonwell Houso (Firo Area IB/Firo Zono SH 13) consists of Control Panol 73HV 11B and firo i dampors 73FD 1 A and 73FD 18.

Given the negligiblo quantitles of exposed combustibles in the immodiato area of the control panels or the dampors, the possibility of a firo starting in or propagating to those areas is considorod unlikely. However, if a fire is postulated which could damago panel 73HV 11B, the damago would bo isolated to within the panol and/or be limitod to the area around the panel given the negligiblo amount of exposed comtvistibles. Thorofore, a postulated fire which could damago both 73HV 11B, redundant panel 73HV 11 A and their associated circuitry before the fire is detected and extinguishod, is also unlikely. In a similar manner, a postulated fire that would closo fire dampers 73FD-1 A and 73FD 1B would bo unlikely to affect fire dampers 73FD-1C and 73FD-1 D.

As previously stated, thoro are negligiblo intervening exposed combustibles in the immediato vicinity of Controf Panol 73HV 11B. Rodundant division Controf Pano! 73HV 11 A is approximately ton foot away on the samo elevation. Exposed combustibles in the vicinity of the panels consist of a firo hose which is located betwoon tho two panols. Thirtoon rodundant Division A safo shutdown cables are routed above the panol are located approximately six foot away and other non safo shutdown circuitry is routed adjacent to panol 73HV 11B. Cables and circuitry within twenty foot of panel 73HV 11B are routed in noncombustible enclosures (l.c. junction boxes or metal conduit) and, thorofore, are not considorod intervening exposed combustibles. Thoro are no other pctontial scurces of ignition or combustibles within twenty foot of panel 73HV 118.

Page 30 of 49

ATTACHMENT 1 TO JPN>92-032 Similarly, thero is negligible Intervening exposed combustibles in the immediate vicinity of Fire Dampers 73FD 1 A and 73FD 18. The redundant dampers 73FD 10 and 73FD 1E are located appr',ximately 5 feet and 20 feet respectively from damper 73FD-18. Exposed combustibles in the vicinity consist of a traveling screen motor, gearbox and clutch are located above and approximately two foot away from Fire Damper 73FD 1 A. These contain small amounts of lubricants and gear oil. The gears and chain are covered by a metal guard which would shield the motor and gearbox from the fire damper. A one-half Inch PVC (polyvinyl chloride) pipe is also routed above the dampers. This PVC pipo is a chemical sample line which carries a sodium hypochlorito solution. Cables and circuits in the area are routed in noncombustible enclosures and therefore are not considered intervening combustibles. However, there are cable trays routed through the Scroonwell House whose closest approach to either of the fire damoers is approximate twenty foet. A temporary diked area is located east of the North Safety Related Pump Room and contains approximately 000 gallons of chemicals (see Figure 5.12). The chemicals are utilized in the cleaning of the Service Water System. Discussions with the manufacturer indicate that they are of limited combustibility, Class lilB. In addition, the chemicals are contalned in thrne steel supported plastic tanks. The Authority has diked the area and is in the process of taking fury.or measuros to assure adequate protection of the fire dampers from the minimal fire hazard associated with these chemicals and their storage and delivery system. Thoro' are no other potential sources of Ignition or combustibles within 20 feet of either fire damper. No redundant division safo shutdown circuits aro located within 20 feet of either fire damper.

Three cables associated with the Division A EDG ventilation system are located south of the pump rooms, approximately fifty foot from panel 73HV 118 and fire dampers 73FD 1 A and 73FD-18.

Rodundant cables associated with the Division B EDG ventilation system will be rerouted from the area to assure divisional separation prior to startup from the current refueling outage. In both casos those cablos are associated with the CO 2 suppression system and subsequent closure of the CO2activated dampers in the EDG Switchgoar Room.

The romalning cables associated with Division A and B Safety Related Pump Room ventilation systems that are routed through the Screenwell House will bo disabled by interim compensatory actions (c) and (d). For th4 reason, their loss will not affect olther ventilation system.

Cable Tunnel Fire in the event of a fire in the East Cable Tunnel (Fire Area ll/ Fire Zone CT 2), the Division A Safety Related Pump Room Ventilation System is relied upon for safe shutdown. The East Cable Tunnel .

runs behind the west wall of both Safety Related Pump Rooms. A significant quantity of combustible material (primarily electrical cables associated with both safe and normal shutdown) exists in the cable tunnel. The East Cable Tunnel is equipped with lonization type smoke detectors that annunciate in the Control Room and will also be protected by the interim compensatory actions that are discussed in the Cable Tunnel Suppression Systems exemption roquest.

Two cables (ISWVARK003 and ISWVARC115) required to support the operation of fan 73FN 3A are loctthd in the East Cable Tunnet.. Cable ISWVARK003 is protected by a one hour wrap while Cable (ISWVARC115) is unprotectod. Loss of either of these cables could result in the loss of the Division A Safety Related Pump Room ventilation systemc This will not cause loss of the ESW or RHRSW pumps because portable ventilation will be provided to assure cooling.

Page 31 of 49 j

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ATTACHMENT 1 TO JPN 92-032 Interim r yfgylory Actions The / J.fwA y propoA %)plement the following interim compensatory measures until trWwtv can 60 coroMed to assure that one division or train and the associated ventilation

.ge.fe# wW tevMabM h t+ went of a fire in the Screenwell House or in the East Cable Tunnel:

r~

6 in d6 ors 76FDR SP 255 2 and 76FDR SP 255-4 to assure separation

& acon the North and South Safety Related Pump Rooms and the East Cable

,nol.

b) Closo fire damper 73FD 1F to assure separation between the North Safety _Related Pump Room and the West Diesel Fire Pump Room, c) ETLs associated with four fire dampers (73-FD 1 A,73-FD-1B,73-FD 10, and 73 FD 1D) will be replaced with 165 degree F fusible links (closure of the dampers is annunciated in the Control Room).

4 d) Modify the fire detection circuitry to assure that two fans (73FN 3A and 73FN 38) will not stop in the event of detection activation. The existing logic circuitry tums those fans off if the associated thermal detector in the area is activated.

e) Combustible frce zones will be established around Control Panels 73HV 118 and 73HV 11 A and around fire dampers 73FD 1 A,73FD 18,73FD-1C and 73FD-1D.

f) Portable smoke ejectors will be readily availab!e to ventilate the North Safety Related Pump Room in the unlike!y event of a fire. Two, two-stage, portable smoko ejectors, rated at 9500 CFM or greater, clearly labeled "For Fire Protection Uso Only" will be placed inside the West Diesel Fire Pump Room. The operations staff and the plant firo b*lgade will be instructed on the purpose of these fans, g) Establish a ono hour roving fire watch who will be instructed to assure that the combustibio froe zort.es are maintained.

Please note, that in the East Cable Tunnel, a continuous fire watch has been posted until the modifications astociated with the suppression system are complete (see the Cable Tunnel Suppression Systems exemption request).

Bases for Interim Compensatory Actions

The actions described above will provide an equivalent lovel of protection. Early detection is

! assured oy thermal detection, area smoke detection, fire watches, and high area temperature detection all of which alarm in the Control Room, l-in the event of a fire in the East Cable Tunnel, ventilation of the North Safety Related Pump Room is assured by dedicated portable ventilation fans.

Page 32 of 49

__ _ _ . . _ . _ _ . _ _ _ - - __ ___ .____ _ __ ~_. _ ___ _.._..____ _.__ _

ATTACHMENT 1 TO JPN 92-032 4 ,

s Hardship to the Authority l The hardship to the Authority if this exemption is not granted is that the plant will have to remain j

shutdown until the modifications are completo. As previously stated the modifications would be <

4 completed prior to startup from the next refueling outage which translates into 20 months (i.e.,

18 month cycle plus 2 month refueling outage). At a cost of $12,000,000 per month in lost revenue (i.e., $400,000 per day and 30 days per month) the estimated total lost revenue to the Authority is $240,000,000 if FitzPatrick had to remain shutdown for an additional twenty months.

This lost revenue estimate only includes the loss of income from FitzPatrick generated power and j does not include the cost of replacement power.

10 CFR 50.12 Criteria i

3 This request satisfies the criteria outlined in 10 CFR 50.12(a)(1) for granting an exemption because (a) the exemption is authorized by law, (b) it will not present an undue risk to public health and safety and (c) It is consistent with the common defense and security.

10 CFR 50.12(a)(2) states that the Commission will not consider granting an exemption request

. unless special circumstances are present. Special circumstances are present whenever:

(i) Application of the regulation in the particular circumstances conflicts with other rules or requirements of the Commission; (ii) Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achleve the underlying 4

purpose of the rule; or (iii) Compliance would result In undue hardship or other costs that are significantly in excess of those contemplated when the regulation was adopted or that are significantly in excess of those incurred by others slmllarly situated; or (iv) The exemption would result in benefit to the pubile health and safety that compensates for any decrease in safety that may result from the grant of the exemption; or (v) The exemption would provide only temporary relief from the applicable regulation and the licensee or applicant has made good faith efforts to comply with the regulation; or (vi) There is present any other material circumstances not considered when the regulation was adopted for which it would be in the public Interest to grant an exemption.

This exemption request satisfies criteria 10 CFR 50.12(a)(2)(iii) and (v) as follows:

a) The interim compensatory actions described above provide an eq'uivalent level of protection, b) The exemption would provide temporary relief until the ventilation system is modified to be in compilance with Appendix R, and

! c) To remain shutdown until the modification is complete would result in significant replacement power costs to the public with no incremental benefit to the public 4 health and safety.

/

i l: Page 33 of 49 L

ATTACHMENT 1 TO JPN 92-032 References 511 LER 9102100; dated November 27,1991; subject: ' Residual Heat Removal, Emergency Diesel Generators, and Fire Pumps Potentially Made Inoperable Due to inadequate Modification installation Activities *; transmitted by NYPA Letter JAFP-910786 from R. J. Converse; to NRC Document Control Desk; dated November 27,1991; subject: "Uconsee Event Report: 9102100 RHRSW/ESW Pump Room Fire Dampers' 5.1 2 NRC Letter from T. A. Ippolito; to G. T. Berry; dated August 1,1979; regarding:

Amendment No. 47 to the FitzPatrick Operating Ucense and the Supporting Safety Evaluation Report 5.13 NRC Letter from T. A. Ippolito; to G. T. Berry; dated October 3,1980; subject:

' Review of Fire Protection Safety Evaluation Supplement items" 5.14 NYPA Letter JPN 85 28 from J. P. Bayne; to D. B. Vassallo; dated April 12,1985; subject: " Appendix R to 10 CFR 50 Exemption Request for Fire Dampers Not Required to Enhance Fire Protection

5.1 5 NRC Letter from R. M. Bernero; to J. C. Brons; dated April 30,1986; subject:

' Exemption From Appendix R to 10 CFR 50 Concerning Installation of Fire Dampers" Page 34 of 49

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ATTACHMENT 1 TO JPN 92-032 l 5.2 Cable Tunnel Suppression Systems Exemption Requested in accordance with the provisions of 10 CFR 50.12(a), the Now York Power Authority toquests a temporary exemption from the requirements of 10 CFR 50, Appendix R, Soctions Ill.G.2 and Ill.G.3 as they apply to the James A. FitzPatrick Nuclear Power Plant with respect to a full area supprossion system boing requirod in the West Cable Tunnol (Firo Area IC) to protect redundant circuits that aro Installod in this arca. The exemption is noodod until modifications can be completed to provido firo supprossion adequato for the hazards present. Intorim componsatory actions will bo implomonted until the modifications are complotod.

In addition, a full aroa suppression system is boing installod in the East Cablo Tunnel (Firo Area ll).

The Inoperability of the existing supprossion systom is governod by the requiremonts of Branch Technical Position (BTP) 9.51, Appondix A and the Technical Specifications. Thoroforo, the impact of a fire on the safe shutdown systems in the East Cablo Tunnel is covered by the interim componsatory actions and permanont modifications discussed in the Pump Room Vontilation exemption request.

The Inoporability of the existing supprossion systems in both cable tunnels was discussed in NYPA LER 92 004-00 (Reforenco 5.21).

The Authority has developed modifications to the cable tunnel supprossion systems. The domolition and installation of the now systems will be dono in series so that at least one tunnel has an available supprossion system. Although the existing systems havo boon declared inoperablo, they aro still availablo and will provido a lovel of protoction. The schodulo for the Installation of this now system is longthonod by this two-phase demolition / construction approach. Tho modifications are extensivo and will be completod no lator than July 31,1993. 'horofore, tho Authority proposos interim compensatory actions until tho modifications are empleto.

In addition, the submittal of this exemption request and tho implomer:tation of the interim componsatory actions discussed in tho exemption request fulfill the requiremonts of tho l

FitzPatrick Technical Specification Sections 3.12.B.1.b,3.12.B.2 and 6.9.B.2.

Fire Areas / Fire Zones Affected FIRE AREA FlRE ZONE AREA DESCRIPTION IC CT1 West Cable Tunnel ol. 200' SW 1 Turbino Building Switchgear Room 01. 272' il CT 2 East Cablo Tunnel ol. 260' SW2 Turbino Building Switchgoar Room of. 272' Pago 37 of 49

ATTACHMENT 1 TO JPN 92432 Technical Justification

Background

The automatic fire suppression systems in the East and West Cablo Tunnols woro doclared inoporable on January 15,1992 (Reference 5.21). The systems woro declared inoperable aftor a review of the hydraulle design calculations inuicated that the spray systems did not provido adoquato coverago.

Firo Protection Features The West Cablo Tunnel is bounded by throo hour rated fire barriors and by throo-hour rated firo barrior ponottations with the exception of the piping ponotrations discussed in the Piping Ponotrations exemption request and two ponotrations (S 1378 and S 1379) which extend from the floor of the tunnot to the roof of a main stcam tunnel below. Radiation monitors aro inserted into thoto accessways to measuro radiation lovels insido the main steam tunnol. They are covered by stool platos.

Tho East Cable Tunnelis boundod by throo hour rated fire barriors and by throo-hour rated fire barrior ponotrations with the exception of the piping ponotrations discussed in the Piping Ponotrations exemption request.

Shutdown Systems Affected A fire in the West Cablo Tunnel could render inoporable the following systems: Coro Spray (Division A), RCIC, RHR LPCI (Division A) and Emorgency Diosol Generators (Division A).

A fire in the East Cablo Tunnot could ronder inoperable the following systems: HPCI, RHR LPCI (Division B) and Coro Spray (Division B).

Ghutdown Systems Available For a firo in the West Cable Tunnel the following systems are available for safe shutdown:

RHR Supprossion Pool Cooling (Division B), RHR LPCI (Division B), Core Spray (Division B),

ADS Valves, HPCI, Emergoney Diosol Gonorators (Division B) and Emergency Servico Water (Division B). The Control Room instrumentation available for this fire is: RV lovel (02-3U 85B and 02 3LR 98), RV pressuro (OGPI 61B and OGPl 908), Torus temperature (161TI 1318) and Torus lovof (23U 202B).

For a fire in the East Cablo Tunnot the following systoms are availablo for safe shutdown:

RHR Supprossion Pool Cooling (Division A), RHR LPCI (Division A), Coro Spray (Division A),

ADS Valvos, RCIC, Emergency Diosel Generators (Division A) and Emergency Service Water (Division A). The Control Room instrumentation available for this fire is: RV level (02-3U 85A, 02 3LI 91 ar:d 02-3LI 92), RV pressure (06PI 61 A,06PI 62 and 06PI 90C), Torus temperature (161TI 131 A) and Torus level (23U 202A).

l l

Page 38 of 49

ApACHMENT 1 TO JPN 92-032 Redundant ChWJits The only circuits roquired for safe shutdown in the West Cable Tunnel are: the power food to the Division B Load Center L 16 (Cablo 1HOEBBH001) and the circuitry associated with Division B Battery Room Vontilation (Cablo 1 ABVBBK055). In the ovont cablo 1 ABVBBK055 is damaged due to fire, AOP 58 (Abnormal ON,ating Proceduro) could assuro cooling of the Division B Battory Room and Charger Room vor. 'lation. For this reason, tbs potential loss of this cable is not a concern.

Cablo 1 ABVBBK055 is protected with a one hour rated fire barrior that has boon qualified by testing. Cable 1HOEBBH001 is currently protocted with a rated firo barrior. However, the qualification test included soveral test anomalios of cloctrical conductor temperatures at the conclusion of the one hour fire exposure. The Authority has roviewod test results from other vendors of similar configurations and fire wrap matorihis in which the test results concluded that those raceway protectivo systems woro qualified one-hour rated fire barriors. Based on those reviews, the Authority concludes that the cable raceway protective systom of cablo 1HOEBBH001 is qualified as a one hour rated fire barrior.

The only redundant circuits in tho East Cablo Tunnel are thoso associated with the Safety Related Pump Room Vontilation. Cablo 1SWVARK003 is provided with a one-hour rated firo barrior, whilo cable 1SWVARC115 is not provided with a barrior. The intorim compensatory actions and tho modifications that are discussed in the Pump Room Vontilation exemption request preclude the nood to ensure that those circuits are froe of fire damage.

Intcrim Componsatory Actions The Authority proposes to implomont the following two interim componsatory actions until firo suppression systems capable of providing coverago adoquato for the East and West Cablo Tunnels can bo installed:

a) A continuous fire watch will bo posted in each tunnel.

b) Daily walkdowns will be conducted to assure that transient combustibles in each tunnel aro hold to an absoluto minimum.

Bases for Interim Compensatory Actions The actions described abovo will provido an equivalent level of protection. Early detection and supprossion are assured by:

a) Backup manual fire supprossion will be availabio with installed hoso stations throughout the cach tunnel as well as hose stations in adjacent areas, b) Portable carbon dioxido fire extinguishers are Installed throughout each tunnel, and c) The existing automatic isnization smoko detection system will provido early indication of a fire in either tunnel to operators in the Contrc! Room.

l Pago 39 of 49

ATTACHMENT 1 TO JPN 92-032 Hardship to the Authority j The hardship to the Authority if this exemption is not granted is that the plant will have to romain shutdown until the modifications ato complete. AP previously stated the modifications would be l

completed by July 31,1993 which translates into 12 months (i.e., August 1992 through July 1993).

At a cost of $12,000,000 por month in lost revenuo (1.0., $400,000 por day and 30 days por month) tho estimated total lost revonuo to the Authority is $144,000,000 if FitzPatrick had to remain shutdown for an additional twolvo months. This lost revonuo estimato only includes the loss of income from FitzPatrick generated power and doos not include the cost of replacomont power, 10 CFR 50.12 Criteria This request satisfies the critoria outlined in 10 CFR 50.12(a)(1) for granting an exemption becauso (a) the exemption is authorized by law, (b) It will not present an undue risk to public I calth and safety and (c) it is consistent with the common defonso and security.

10 CFR 50.12(a)(2) states that the Commission will not considor granting an exemption request unless special circumstances are present. Special circumstancos are present whenovor:

(i) Application of the regulation in the particular circumstances conflicts with other rules or requirements of the Commission; (ii) Application of the regulation ir' the particular circumstancos would not servo the underlying purpose of the ru!o or is not nocessary to achiovo the underlying purpose of the rule; or (iii) Compilance would result in unduo hardship or other costs that aro l significantly in excess of thoso contemplated whon the regulation was adopted or that aro

! significantly in excess of those incurred by others similarly situatod; or (iv) The exemption would result in bonofit to the public health and safety that compensatos for any decreaso in safety that may result from the grant of the exemption; or (v) The exemption would provido only temporary relief from the applicablo regulation and the licensoo or applicant has mado good faith offorts to comply with the regulation; or (vi) Thore is prosont any other material circumstances not considorod when the regulation was adopted for which it would bo in the public Interest to grant an exemption.

. This exemption request satisfios critoria 10 CFR 50.12(a)(2)(iii) and (v) as follows:

l a) The interim compensatory actions described above provido an equivalent level of protection, l

b) The exemption would provido temporary relief until the suppression systems are modified to be in compliance with Appendix R, and c) To remain shutdown until the modification is complete would result in significant replacement power costs to the public with no incromontal bonofit to the public health and safety.

l l

Page 40 of 49

ATTACHMENT 1 TO JPN 92-032 References 5.2 1 LER 91-004-00; dated February 14,1992; subject: " Automatic Fire Suppression Systems in Safoly Related Cable Tunnels Doclared Inoporable Due to inadequato Design and Review for Appendix R Requiremonts"; transmitted by NYPA Lotter ,

JAFP 92 0154 from R. J. Converse; to NRC Document Control Desk; dated February 14,1992; subject: "Uconsoo Event Report: 926-00 Cable Tunnel Firo ,

Suppression Sprays Inoperable Duo to inadoquate Design and Appendix R i Review" l l

1 l

l I

l l

I Page 41 of 49

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(

A1TACHMENT 1 T3 JPN 92-032 5.3 Piping Penetrations Exemption Roquested in accordance with the provisions of 10 CFR 50.12(a), the Now York Power Authority roquests a temporary exomption from the requiremonts of 10 CFR 50, Appendix R, Soctions Ill.G.2 as they apply to the James A. FitzPatrick Nuclear Power Plant with respect to throo hour rated firo barrier penetration seals. The exemption is needed until concoms associated with bondstrand, groonthread and PVC (polyvinyl chlorido) piping ponotrations can be resolved and modifications can be completed to hsturo sepvation by a throo hour rated fire barrior. Interim compensatory actions will be implemented unt . .ho modifications are completed. The modifications are scheduled to be completed by November 30,1992.

l The Authority has developed or is in the process of developing modifications that will address the concerns associated with bondstrand, groonthread and PVC piping penetrations. However, tho modifications aro extensivo. Thorofore, the Authority proposes interim compensatory actions until the modifications are complotod.

Fire Areas / Fire Zones Affected FIRE AREA FIRE ZONE AREA DESCRIPTION IA AD-1 Administration Building ol. 272' AD2 Administration Building of. 272' AD3 Administration Building 01. 272' AD-4 Administration Building 01. 286' AD-5 Adtninistration Building 01. 286' AD-6 Administration Building ol. 300*

AS 1 Auxiliary Bollor Room o!. 272' MG1 Motor Gonorator Room ol. 300' IB FP 1 West Diosol Firo Pump Room 01. 255' CR2 Radwasto Building Control Room 01. 284' RW.1 Radwaste Building and Pipo Tunnel SH 13 Serconwell House IC CT 1 West Cablo Tunnel 01. 260' SW1 Turbino Building Switchgoar Room 01. 272' IE FP 2 Turbino Building Foam Room 01,272' TB 1 Turbine Building Basomont ol. 252', Mozzanino

01. 292', and Operating Floor 01. 300' OR1 Turbino Building Turbino Oil Storago Room 01. 252' OR2 Turbino Building Turbino Oil Storago Room 01. 272' OR3 Turbine Building Miscellaneous Oil Storago Room el. 252' l

ll CT 2 East Cable Tunnel ol. 260' l SW 2 Turbino Building Switchgoar Room 01. 272' I

Pago 42 of 49

ATTACHMENT 1 TO JPN 92 032 FIRE AREA FIRE ZONE AREA DESCRIPTION Vil CR1 Control Room el.300' RR 1 Relay Room el. 264' CS1 Cable Spreading Hoom ol. 272' Vill RB 1C Reactor Building Northeast and Northwest Quadrants ol. 300' IX SB 1 Standby Gas Filter Roorn el. 272' RB 1 A Reactor Building East Side el 272', Southeast Quadrant el. 300' and Entire Floor on el. 326',

el. 344', and ol. 309' X RB 1B Reactor Building East Side el. 272' and Southwest Quadrant al. 300' Technical Justification,

Background

As a result of the recent fire barrier penetration seal baseline inspection, the Authority identified several fire barrier penetrations that have penetrating items of bondstranci,-greenthread or PVC piping. In accordance with the requirements of Technical Specification Section 3.12.F " Fire Barrier Penetration Seals," the Authority declared the penetrations inoperable because of a lack of qualifying tests and the potential of the piping to degrade the existing three-hour rated fire barrier penetration seals. Subsequently, the Authority has identified additional bondstrand, groenthread and PVC piping penetrations and declared them inoperable.

Walkdowns of bondstrand, greenthread and PVC piping legan in February 1992 to identify the affected fire barrier penetration seals Preliminary testing of typical bondstrand, groenthread and PVC piping penetration configurations began about this time also. The preliminary testing revealed that the ability of penetration seals of closed (or non-vented) piping systems meeting the requiremants for a three hour rated fire barrier penetration sealis highly probable. However, the ability of penetration seals of open (or vented) piping systems meeting the requ!rements for a three-hour rated fire barrier penetration seat is questionable.

For the purpose of this issue, a closed (or non vented) piping system is one in which the piping is continuous. An open (or vented) piping cystem is one that freely communicates with the atmosphere, as in vont and drain lines.

Ptge 43 of 49

ATTACHMENT 1 TO JPN 92-032 During thoso proliminary tests, the Authority observed that as piping of an open piping system (l.o., a 'U' shapod drain configuration) was subjected to an exposure fire, gases roloased from the I insido surfaces of the boatod pipe woro exhausted through one open ond of the pipo and air was I I

drawn into the cther open end. This circular flow continued for approximatoly ton minutos during the initial stages of the throo hour fire enduranco test whon the oxhaust flow self Ignited. This i ignition is bolleved to be the result of oxygen boing introduced into the system. This phenomena j was confirmod, whon during a test, the exLaust flow of a closed piping system did not exhibit this 1 self-Ignition. The flame that developed on the unexposed sido of the open piping system was approximately 0 inches above the ond of the pipo and tho quantity of smoke which was i considorod excessivo.

A formal test is currently schodulod for July 1992, in this tost, typical bondstrand, groenthroad and PVC piping ponotration configurulons will bo ovaluated por the requirements of ASTM E 119 and ASTM E 8 i4. Both opon and closed piping systoms will be tostod. It is expected that the closed piping system penotration configurations will moet the requiromonts of a throo hour rated fire barrior ponotration seal, it is also expected that the resulting tost data from the open piping system ponotration configurations will enablo the Authority to instituto the appropriato modifications which will addross the concom.

Tablo 5.31 prcvidos a location listing of the bondstrand, groonthread and PVC open piping systems that ponotlato threo hour rated firo barriors (both Appendix R fire barriors and Branch Technical Position (BTP) 9.51, Appendix A firo barriors). Tablo 5.3 2 providos a location listing of the bondstrand and groonthroad closed piping systems that ponotrate throo hour rated firo barriors (both Appendix R fire barriors and BTP 9.51, Appendix A firo barriors).

Interim Compensatory Actions The Authority proposes to implomont hourly firo watch patrols in each of the Firo Area whero bondstrand, groenthread or PVC piping syst6ms ponotrato throo-hour rated firo barriors.

Basis For Interim Compensatory Actions The action described above in conjunction with other existing fire protoction foatures will provido I an oqulvalent lovel of protection and assure that a fire in the vicinity cf an inoperablo fire barrior j penotration seal will be promptly detected and extinguishod. Those features inc:udo: l a) Automatic suppreesbo and/or detoction systoms, b) Manual hose stations and portablo firo extinguishors, and c) The on sito trainod firo brigado.

Tho Authority also believes that tho establishmont of an hourly fire watch patrol will be consistent with ALARA practicos while the establishment of a continuous firo watch may be in conflict with those practicos.

Page 44 of 49

l ATTACHMEN_T 1..T.O JPN 92-032 1

e Hardship to the Authority The hardship to the Authority if this exemption is not granted is that the plant will have to romain shutdown until the modifications are complete. As previously stated the modifications would be completed by November 30,1992 which translatos into four months (i.e., August 1992 thiough November 1992) At a cost of $12,000,000 por month in lost rovonuo (l.o., $400.000 por day and 30 days por month) the estimatod totallost revenue to the Authority is $48,000M11f FitzPatrick had to remain shutdown for an additional four months. This lost revonuo estimato only includos the loss of incomo from FitzPatrick gonorated power and does not include the cost of replacomont power, 10 CFR 50.12 Criteria This request satisilos the critoria outlined in 10 CFR 50.12(a)(1) for granting an exemption because (a) the oxomption is authorized by law, (b) it will not prosent an unduo risk to public health and safety and (c) It is consistent with the common defonso and security, 10 CFR 50.12(a)(2) states that the Commission will not considor granting an exemption ioquest unless special circumstancos are present. Special circumstancos aro prosent whenover:

(i) Application of the rogulation in the particular circumstancos conflicts with other ruios or requirements of the Commission; (11) Appilcation of the regulation in the particular circumstances would not Forve the undorlying purposo of the rule or is not necessary to achlove the undorlying purpose of the rulo; or (ill) Complianco would result in unduo hardship or other costs that are significantly in excess of those contomplated when the regulation was adoptod or that are significantly in excess of those incurred by others similarly situatod; or (iv) The exemption would iosult in bonofit to the public healli and safety that compensates for any docrease in safoty that may result from the grant of tho exemption; or (v) Tho exomption would provido only temporary relief from the applicablo regulation and the licensco or applicant has mado good faith efforts to comply with the regulation; or (vi) Thoro is prosent any other matorial circumstancos not considered when the regulation was adopted for which it would be In the public interest to grant an exemption.

This exemption request satisfios critoria 10 CFR 50.12(a)(2)(lil) and (iv) as follows:

a) The Authority intends to assuro that the subject ponotrations aro qualified as and/or modified to becomo throo hour rated fire barriors, b) Interim componsatory actions will bo implomonted until the subject ponotrations are considered three-hour rated fire harrlars, c) The interim r.ompensatory actions provido a levol of protection that moots or exceeds the Appendix R requirements, and d) To romain shuid0wn until the qualifications and modifications are complete would rosuit in significant replacement power costs to the public with no incromoatal bonofit to the public health and safety.

Page 45 of 49

ATTACHMENT 1 TO JPN 92-032 Table 5.31 Location of Open Piping Penetrations F

PENGTRATION SIDE 1 SIDE 2 ;

'NURGEh-

~

KFiffhESCRIPTION XREEDESCRIPTION~ l iTiioTea/ Fire Zono)~ (Fire Arsa/ Fire Zone)

'l Drain Turblne Bullding Hpe Tunnel Unos (IE/T31) (IB/RW 1) 3 Draln West Cobb tunnel Chemistry Laboratory Unos (IC/CT.1) (IA/AD-3)

S 144 Weet Oable Tunnel Chemistry Laboratory l

-(IC/CT.1) (IA/AD 3)

S 145 Wo;t Cable Tunnot Chemistry Labcratory :

OC/OT 1) (IA/AD 3)

S 150 West Cable TUMel Rad Decon, Are ;

(IC/CT 1) (IA/AD4)

S 202 West Cab le Tunnel Rad. Issuo Office . t (IC/CT 1) (IA/AD-3) i S 206 West Cable Tunnel Chemistry Laboratory (C/CT.1) (IA/AD-3)

S207 West Cable Tunnel Chemistry Laboratory '

(IC/CT.1) . (IA/AD-3) 8 208 West Cable Tunnel Chemistry Laboratory I

(IC/CT.1) (IA/AD-3)

! S 210 West Cable Tunnel Rad. lssue Office (IC/CT.1) (IA/AD 3)

S 211 West Cable Tunnel Chemistry Laboratory ;

(IC/CT 1) (IA/AD-3)

Page 46 of 49

) ATTACNMENT 1 T4 JPN 926 Table 5.31 Location of Open Piping Penetrations (continued)

PENETRATION~~

SIDE 1 SIDE 2

RUMBER XhKDESCRIPTION KREKbESCRIPTION (Firo Area /Firo Zono) (Fire Atea/ Fire Zone)

S 329 Reactor Building Pipe Tunnel (IX/RB 1 A) (IB/RW 1)

S-G20 Reactor Building Reactor Building (IX/RB 1 A) (Vill /RB 1C)

S-G21 Reactor Building Reactor Building (IX/RB 1 A) (Vill /RB 1C)

S-865 Reactor Building Hoactor Building (IX/RB 1A) (X/RB 18)

S 1366 Turtun6 bullobg Chernistry Laboratory (IE/TB 1) (IA/AD 3)

S 1387 West Cable Tunnel Pipe Tunnel (IC/CT 1) (IB/RW 1)

S-1391 West Cablo Tunnel Pipe Tunnel (IC/CT 1) (IB/RW 1)

S-4013 West Cablo Tunnel EasiCable Tunnel ,

(IC/CT 1) (ll/CT 2)

S-4024 Roactor Building Roactor Building (IX/RB 1 A) (Vill /RB IC)

Page 47 of 49

l ATTACHMENT 1 TOJ,,PN 92 032 4

Tbbie 5.3 2

Location of Closed Piping Penetrations I

- PENETRATION SIDE 1 GIDE 2 i NUMBER AREAbESCRIPTION XKDESCRIPTION ~

] (Firo Area / Fire Zone) (Fire Area /Hre Zene) j S 33 Auxillary Bollor Room Cable Spread!ng Room j ('A/AS-1) (Vil/CS 1) i i S-47 Administiation Building Cable Spreading Room j (IA/AD-3) (Vil/CS 1) l S-48 Administrat'in Building Cable Spreading Room (IA/AD 3) (Vil/CS 1) j_ S 212 West Cable Tunnel Telephone Room j (IC/CT 1) .l*./AD 1) l S 370 Reactor Building Pipo Tunnel (IX/RB 1 A) (IB/RW 1) i i S-371 Reactor Building Pipo Tunnel >

(lX/RB 1 A) (IB/RW 1)

S 372 Reactor Building Pipo Tunnel (IX/RB 1 A) (IB/RW 1)

S 374 Roactor Building Pipe Tunnel

, (IX/RB 1 A) (IB/RW 1) i S 557 Motor Gonorator Room Reactor Building .

(!A/MG 1) (IX/RB 1 A)

I S-559 Motor Generator Room Reactor Building (IA/MG 'l) (Vill /RB 1C) i ,

S-790 Reactor Building Auylliary Boller Room (IX/RB 1 A) (IA/AS 1)

S-801 Roactor Building - Reactor Building i

(IX/RB 1 A) (X/RB 1B)

Pago 48 of 49

)

g ., y e--n ,,...,n-- , ,- . , . , y- -

r --y-,,,, ,-,_,,.,,y, , , . ,,,,A.-w- ..,,l_,. ,,,.n-,, , - c p-, -,s, - - , , -, ,,,,-w,g,-r,,,*

ATTACHMENT 1 TG JPN-92 032

. <

s

, 4 4 ll Table 5.3 2 Location of Closed Piping Penetrations i (continued) ;

PENETRATION SIDE 1 SIDE 2 RUEBER XREI'bESCRIPTION XREEbESCRIPTION (Fire Area / Fire Zone) (Fire Atea/ Fire Zone) f S 1384 West Cab's Tunnel East Cable Tunnel (IC/CT 1) (ll/CT2) l S 1386 Turbine Building East Cable Tunnel (IE/TB 1) (ll/CT 2) :

S 1679 Turbine Building Screenwell House (IE/TB 1) (IB/SH 13)

S 1814 Screenwell House East Cable Tunnel ,

(IB/SH 13). (ll/CT 2)-

S 1815 Screonwell House East Cable Tunnel (IB/SH 13) (ll/CT 2)

S 2001 West Cable Tunnel East Cable Tunnel (IC/CT 1) (ll/CT 2)

S-2002 West Cab le Tunnel East Cable Tunnel (IC/CT 1) (II/CT 2) ~

S 2100. Auxiliary Boller Room Pipe Tunnel (IA/AS 1) (IB/RW 1) '

WS-50 ~ Turbine Building Radwaste Building .

(IE/TB 1) (IB/RW 1)

WS-60 Turbine Building Radwaste Building (IE/TB 1) (IB/RW 1)

WS-41i Radwaste Building Screenwell House (IB/RW 1) (IB/SH 13)

.l

)

Page 49 of 49.

_ _ . -_ . _ . . . . . _ . _ _ _ _ . . , _ _ . - - . _ . _ _ ..,_ .. - _ _ _ . _ .. _ .-_ _ . _ __, _;

JPN-92-032, Forwards Revised,New & Temporary Exemptions from 10CFR50,app R,In Ref to NRC Ltr Re Meeting on 920528,to Discuss Results of New App R Analysis & Potential Exemptions Needed as Results of Analysis

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JPN-92-032, Forwards Revised,New & Temporary Exemptions from 10CFR50,app R,In Ref to NRC Ltr Re Meeting on 920528,to Discuss Results of New App R Analysis & Potential Exemptions Needed as Results of Analysis

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Dear Sir:

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