ML18089A486

Requests Exemption from 10CFR50,App R Requirements Re Definition of Fire Areas & Suppression Sys (Per Generic Ltr 83-33).Detailed Justification Will Be Submitted by 840131

ML18089A486
Person / Time
Site:	Salem
Issue date:	12/28/1983
From:	Liden E Public Service Enterprise Group
To:	Varga S Office of Nuclear Reactor Regulation
References
GL-83-33, NUDOCS 8401110153
Download: ML18089A486 (4)

Text

• -, . . . e

• ops~G Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, New Jersey 08038 Nuclear Department December 28, 1983 Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission

..---\. 79*20 Norfolk Avenue Bethesda, MD 20014 Attention: Mr. Steven Varga, Chief Operating Reactors Branch 1 Division of Licensing Gentlemen:

REQUEST FOR EXEMPTIONS FROM 10 CFR 50, APPENDIX R NO. 1 AND 2 UNITS SALEM GENERATING ST~TION DOCKET NOS. 50-272 AND 50-311 Generic Letter 83-33 provided NRC staff interpretations of certain 10 CFR 50 Appendix R requirements. During our review of this letter, Public Service Electric & Gas (PSE&G) identified several areas of concern related to "NRC Staff Position" which represent significant redefinition of Appendix R criteria.

Specifically, the staff's definition of fire areas and suppression system coverage is a significant deviation from the definitions used by PSE&G in evaluating Salem Generating Station, Units No. 1 and 2, for compliance to Appendix R. Our interpretations of these criteria were well documented in various reports and submittals which were reviewed by the NRC staff and, since no comments or objections were raised during the review we believed our interpretations to be acceptable.

As a result of the positions detailed jn Generic Letter 83-33 and subsequent discussions with the staff, PSE&G is requesting the attached exemptions from Appendix R. All of these exemptions are in areas covered by previously approved exemptions except numbers 1 and 5 which are new as a result of the new NRC interpretations, and number 7 which was previously requested but detailed supporting data has not been supplied.

Generic Letter 83-33 specifically details staff positions on "Automatic Suppression" and "Fire Areas" that differ from interpretations originally used by PSE&G. Fire areas in the Salem Generating Station are defined in PSE&G's "Safe Shutdown and Interaction Analyses" submitted to the NRC in September 1981 and subsequent exemption requests. These fire areas were not "separated from other areas by boundary fire barriers" as set forth in Generic Letter 83-33. Additionally, because of this difference in defined fire areas, fire suppression systems do

~------

not provide "suppression throughout the fire area."

8401110153 831228 PDR ADOCK 05000272 F . PDR The Energy fJeople 95-21 68 (80 Ml 11-82

u. s. Nuclear Regulatory Commission -2 12/28/83 By adopting Generic Letter 83-33 positions for the Salem fire protection program, PSE&G is confronted with the need for additional modifications and for exemptions from Appendix R.

Accordingly, pursuant to 10CFRS0.12, PSE&G hereby requests exemptions from 10CFR50 Appendix R as identified in the attached summary. Detailed justifications and descriptions were provided for the majority of these exemptions in previous submittals.

Appropriate references and/or detailed justification will be submitted by January 31, 1984.

PSE&G believes that for each area where an exemption is being requested, existing fire protection capabilities ensure that in the event of a fire, the Salem Units can be safely shutdown.

The types of exemptions requested are similar to those previously granted for Salem and other licensees; and thus, are not considered to represent a degradation of the Salem fire protection program.

Sincerely, E. A. Liden Manager - Nuclear Licensing and Regulation cc: Mr. Donald C. Fischer Licensing Project Manager Mr. James Linville Senior Resident Inspector

ATTACHMENT SALEM GENERATING STATION, UNITS NO. 1 & 2 REQUESTS FOR EXEMPTION FROM 10CFR50 APPENDIX R

1. Upper Elec. Pen. (El. 100)

An exemption is requested from the explicit requirements of 10CFRSO Appendix R Section III.G.2.c to the extent that no area-wide fixed suppression system is installed in this area.

2. Aux. Bldg. (El. 100) - Fire Area PlH/P2H An exemption is requested from the explicit requirements of 10CFRSO Appendix R Section III G.2.a to the extent that the equipment hatch, elevator enclosure and stairway walls do not constitute a rated 3-hour barrier.

3. Aux. Bldg. (El. 100) - Fire Area PlH/P2H An exemption is requested from the explicit requirements of 10CFRSO Appendix R Section III G.2.c to the extent that the area does not contain an area-wide automatic suppression and detection system.

4. Aux. Bidg. (El. 84) - Fire Area PlF/P2F An exemption is requested from the explicit requirements of 10CFRSO Appendix R Section III G.2.c to the extent that the installed fixed suppression/detection system is not "area wide".

5. Aux. Bldg. (El. 84) - Fire Area PlF/P2F An exemption is requested from the explicit requirements of 10CFR50 Appendix R Section III G.2.c to the extent that the Auxiliary Feedwater Pump Bay Area does not have complete 1-hour rated barriers for all equipment.

6. Aux. Bldg. (El. 84) - Fire Area PlF/P2F An exemption is requested from the explicit requirements of 10CFR50 Appendix R Section III G.2.a to the extent that the equipment hatches, elevator enclosure, and stairway walls do not constitute a rated 3-hour barrier.

EXEMPTIONS REQUESTS (Continued)

7. Aux. Bldg. (El. 84) - Fire Area PlL/P2L An exemption is requested from the explicit requirements of 10CFR50 Appendix R Section III G.2.c to the extent that the fire suppression system installed in this area is a manually actuated system.

8. Aux. Bldg. (El. 64) - Fire Area PlC/P2C An exemption is requested from the explicit requirements of 10CFR50 Appendix R Section III G.2.c to the extent that the installed fire detection and suppression system is not "area wide".

9. Aux. Bldg. (El. 64) - Fire Area PlC/P2C An exemption is requested from the explicit requirements of 10CFR50 Appendix R Section III G.2.a to the extent that the elevator enclosure, equipment hatch and the stairway walls do not constitute 3-hour rated barriers.

10. Aux. Bldg. (El. 64) - Fire Area PlB/P2B An exemption is requested from the explicit requirements of 10CFR50 Appendix R, Section III G.2.a to the extent that the elevator enclosure and stairway walls do not constitute 3-hour rated barriers.

11. Aux. Bldg. (El. 55) - Fire Area PlA/P2A An exemption is requested from the explicit requirements of 10CFR50 Appendix R Section III G.2.a to the extent that the equipment hatches and the stairway walls do not constitute a rated 3-hour barrier.

12. Aux. Bldg. (El. 122)

An exemption is requested from the explicit requirements of 10CFR50 Appendix R Section III G.2.a to the extent that the equipment hatches, elevator enclosure, and stairway walls do not constitute a rated 3-hour barrier.

JMV:jab/tap GK9 1-2