ML19347E627
| ML19347E627 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 05/05/1981 |
| From: | Withers B PORTLAND GENERAL ELECTRIC CO. |
| To: | Clark R Office of Nuclear Reactor Regulation |
| References | |
| TAC-46735, NUDOCS 8105130150 | |
| Download: ML19347E627 (2) | |
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May 5, 1981 M
Trojan huclear Plant Docket 50-344 License NPF-1 1
Director of Nuclear Reactor Regulation ATTN:
Mr. Robert A. Clark, Chief Operating Reactors Branch No. 3 Division of Licensing U. S. Nuclear Regulatory Commission Washington, DC 20555
Dear Sir:
By letter dated March 19, 1981 P'JE identified certain areas of the Trojan Nuclear Plant where alternative fire protection designs are utilized which do not meet all the requirements of 10 CFR 50, Appendix R.
Although the requirements are not met literally, the intent of Appendix R is satisfied and the following exemption requests are thereby justified.
Specific areas in which Appendix R,Section III.G.2 criteria are not met in all cases are the intake structure (El. 23 f t), Fuel Building (El. 45 ft), Auxiliary Building (El. 45 ft), Turbine Building (El. 45 ft),"
and the cable penetration area outside Containment. Fire protection for chese areas includes various combinations of fire barriera, detectors, physical separation, and fire suppression systems, as described in detail in the response to Staff Position P.F.8 in Sections C and G of Topical Report PCE-1012, " Trojan Nuclear Plant Fire Protection Review". The Fire Protection designs in these areas will ensure that one of the redundant trains required for safe shutdown will be free from damage in the event of a fire. Indeed, the NRC has concluded in Section 3.2.3 of its amended Safety Evaluation Report dated March 25, 1980, that " adequate protection will be provided in areas containing redundant safe shutdown cabling".
Since additional modifications will not significantly improve fire protection safety, an exemption from the requirements of Section III.G.2 of 10 CFR 50, Appendix R is hereby requested for the Trojan Nuclear Plant for the areas identified above.
The PGE letter dated March 19, 1981 also identified an alternative to the requirements of Section III.J of 10 CFR 50, Appendix R, with regards to emergency lighting. A total of seven areas requiring manual safe shutdown operations have now been identified as having emergency Jighting that is A
f powered from Class 1E a-c buses instead of being powered from batteries
//004 per Section III.J. The emergency lights can be powered off of either S
train of emergency power via transfer switches in the event that one
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train is unavailable. In addition, the alternative design will provide
//D lighting for a period of time longer than the 8-hour requirement of 8105 2 a o /5D g
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Portland General SectricCortinny Director of Nuclear Reactor Regulation May 5, 1981 Page two l
Section III.J.
Since replacement with battery powered lights will not enhance fire protection safety at Trojan, exemption from the 10 CFR 50, Appendix R, Section III.J, requirement for battery powered emergency lighting is hereby requested for the Trojan Nuclear Plant.
The requested exemptions will not endanger life or property or the common defense and security; adequate fire protection is provided and maintained by the present design. The alternatives proposed will not give rise to a significant adverse impact on the environment. Granting of the requested exemptions will minimize costs to the licensee and the consumers, and will be in the public interest since no additional modifications will be required.
Sincerely, a
(
Bart D. Withers Vice President Nuclear c:
Mr. Lynn Frank, Director State of Oregon Department of Energy
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