ML20041D901
| ML20041D901 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 03/05/1982 |
| From: | Garrity J Maine Yankee |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| GL-81-12, MN-82-42, NUDOCS 8203090490 | |
| Download: ML20041D901 (2) | |
Text
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(207) 623-3521 g_gg March 5, 1982 q
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9,gygg MAR 091982" h6 thited States tJuclear Regulatory Commission Washington, D. C. 20555 ugu gy l
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Attention:
Mr. Darrell G. Eisenhut, Director Division of Licensing h,
g Re ferences:
(a) License No. DPR-36, (Docket No. 50-309)
(b) USNRC Letter to Maine Yankee Atomic Power Co., dated February 20, 1982 (Generic Letter 81-12)
Subject:
Request for Exemption
Dear Sir:
This letter requests two exemptions from the requirements of Appendix R to 10CFR50, dealing with fire protection.
The first requests an exemption from Section III.G.3.b, last sentence, as applied to the control room. We interpret this sentence to require installation of both detection and suppression in the control room even though we have the capability to shut down the plant from outside the control room.
We do not feel it is prudent or necessary to install a fixed suppression system in the control room, and request an exemption from that requirement.
Our bases for such an exemption follows here:
The control room is a continually manned area, thus aiding in the o
quick detection of any fire.
Smoke detectors are provided throughout the room and inside control o
cabinets.
The walls, floor and ceiling of the control room are constructed of o
reinforced concrete, providing a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire barrier from surrounding areas.
o All electrical penetrations into the room are sealed.
Fire dampers have been provided on ventilation lines.
o The fire loading in the control room is low.
o There is strict control over the use of any flammable materials.
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There is little problem with transient combustibles because there is no need for them to go through the control room.
Portable extinguishers within the control room provide sufficient capability to handle any incipient fire.
Fire hoses are available outside the control room and can be o
utilized in the control room if needed.
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b 8203090490 020305 PDR ADOCK 05000309 L
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M AINE Y ANKEE ATOMIC POWER COMP ANY United States tbclear Regulatory Commission March 5,1982 Attention:
Mr. Darrell G. Eisenhut, Director Page Two In addition, we feel that the installation of a fixed suppression system could decrease overall safety rather than increase it.
Inadvertent operation of any known suppressant could cause either equipment damage (e.g. water); or make it necessary for personnel to evacuate the room, (e.g. CO2 and Halon).
The second exemption requested is from the requirements of Sections III.G.2 and 3 as applied to the Cable Vault. The Cable Vault is below grade and houses only cables.
It is not a part of the Cable Spreading Room, which is located above the control room, but serves as a tunnel to carry cables from the Control Building to other plant areas.
We do not feel it should be necessary to bring this area into conformance with Section III.G 2 and 3 of Appendix R, and request an exemption from that reouirement. Our basis for such an exemption folbws here.
The Maine Yankee Cable Vault is a below grade vault containing only O
cables.
The room is approximately 47'L x ll'W x 9'H with limited ventilation o
to support combustion.
The only access to the vault is from above through a normally locked o
hatch.
The key to the hatch is closely controlled by the Shift Supervisor.
The area currently has installed smoke detectors; an automatic CO2 suppression system, and a manually operated sprinkler system.
Maine Yankee has strict administrative controls established to o
define and limit the use of flammable solvents at the plant.
Flammable solvents are prohibited from the Cable Vault.
The Cable Vault's inherent design, fire detection and suppression systems, and the administrative controls described above combine to provide a high degree of protection to safety systems from fire damage.
This protection meets the intent of Appendix R and warrants an exemption to the separation / barrier requirements of Section III.G.2 and 3.
We believe the above information provides an adequate basis for our request for exemptions, proving that the existing fire protection features in the Control Room and the Cable Vault meet the intent of Appendix R, and trust that you will grant the exemption.
If you have any further questions or comments, please contact us.
Very truly yours, MAINE YANKEE ATOMIC POWER COMPANY S
John H. Garrity, Senior Director Nuclear Engineering and Licensing JHC/bjp
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