ML18102B339

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Requests That NRC Consider Detailed Clarifications Submitted & Issue Exemption Request from Requirements of 10CFR50 App R,Section III.G.2 for Fire Area FA-EP-100G & FA-PP-100H
ML18102B339
Person / Time
Site: Salem  
Issue date: 05/23/1997
From: Eric Simpson
Public Service Enterprise Group
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LR-N97337, NUDOCS 9706020148
Download: ML18102B339 (3)


Text

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Public Service Electric and Gas Company E. C. Simpson Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 Senior Vice President - Nuclear Engineering MAY 2 3 1997 LR-N97337 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 10 CFR 50, Appendix R, Section III.G.2 Exemption Request Fire Areas 1, 2 FA-EP-lOOG and 1, 2 FA-PP-lOOH Salem Generating Station Unit Nos. 1 and 2 Facility Operating Licenses DPR-70 and DPR-75 Docket Nos. 50-272 and 50-311 Gentlemen:

On July 15, 1988, PSE&G requested an exemption from the requirements of 10 CFR 50, Appendix R, Section III.G.2 for fire areas FA-EP-lOOG and FA-PP-lOOH, the Upper Electrical Penetration Area and the Inner Piping Penetration Area respectively.

Specifically, PSE&G requested an exemption from the requirement that automatic detection and suppression be installed in areas where a minimum 20 foot separation between cables and equipment is utilized as the means of ensuring one redundant train of equipment is free of fire damage.

On July 20, 1989, the NRC denied the above noted exemption request.

This denial was based on concerns. with the operability of the Emergency Control Air Compressor (ECAC).

On January 4, 1991, PSE&G requested that the NRC reconsider their previous denial of this request.

On April 28, 1992, PSE&G provided additional information on the ECAC operability concerns.

The NRC responded, on June 29, 1992, that the staff had no further questions regarding the availability of the ECAC, and that the exemption request was being reviewed.

In a January 25, 1996 letter, the NRC agreed with the conclusions of a November 1995 Technical Evaluation Report (TER) that the exemption request for Fire Area FA-EP-lOOG and FA-PP-lOOH should be granted.

Recently, the NRC has expressed reservations about approving this exemption request.

The NRC concern is with the use of 3M E-50 to encapsulate cables in Fire Area 1(2)FA-EP-100G.

PSE&G

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.J~R-N97 337 continues to believe this exemption request is appropriate, and would like to clarify the technical merits of our request.

As identified in the exemption request evaluation, fire area FA-EP-lOOG contains redundant safe shut down equipment separated by approximately 35 feet.

Within this 35 feet, there is negligible intervening combustibles, and PSE&G adequately controls the introduction of transient combustibles into all areas of the plant.

While no automatic suppression is present in the area, local detection is installed above the limited fire hazards in the area, and manual fire suppression equipment is available for each area.

PSE&G has determined that the use of E-50 is not required to support the exemption request.

A modification to re-route the cables was implemented.

The modification relocated the cables so that approximately 35 feet of spatial separation exists between the redundant trains of equipment; however, the cables are still in FA-EP-lOOG.

The E-50 material was not removed from the cables, but it is not required to support the exemption request.

The existing fire protection features in fire area 1(2)FA-EP-100G and 1(2) FA-PP-lOOH are adequate to ensure that Salem is capable of achieving and maintaining safe shut down.

Accordingly, we request that the NRC consider the clarifications detailed in this letter, and issue the exemption request from the requirements of 10 CFR 50 Appendix R, Section III.G.2 for fire area FA-EP-lOOG and FA-PP-lOOH.

If you have any questions please contact us.

Sincerely, 95-4933

I Document Control~sk LR-N97337 C

Mr. Hubert J. Miller, Administrator -

Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. L. N. Olshan, Licensing Project Manager -

Salem U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 14E21 Rockville, MD 20852 Mr. C. Marschall -

Salem (S09)

USNRC Senior Resident Inspector Mr. K. Tosch, Manager, IV NJ Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625

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