ML20044A130
| ML20044A130 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 06/25/1990 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20044A129 | List: |
| References | |
| NUDOCS 9006280106 | |
| Download: ML20044A130 (13) | |
Text
!
- [, O* C* 0%'b,,
.E UNITED STATES NUCLEAR REGULATORY COMMISSION h
WASHINGTON, D. C. 20655 N...../
O SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOP REGULATION REQUEST FOR EXEMPTIONS FROM SPECIFIC TECHNICAL REQUIREMENTS OF APPENDIX R TO 10 CFR PART 50 GPU NUCLEAR CORPORATION AND JERSEY CENTRAL-POWER & LIGHT COMPANY s
OYSTERCREEKNUCLEARGENERATINGSTATIOj!
l l
DOCKET NO. 50-219 1.0 Introduction By letter dated August 25, 1986, GPU Nuclear Corporation (the licensee) re-L quested exemptions with supporting justification from certain of the technical' l'
requirements of Section 111.0 of Appendix R to 10 CFR Part 50 for specific l
areas of the plant.
1.
The staff's evaluation of the requested exemptions based on its review of the supporting justification is given below:
1 2.0 F_ ire Zone RB-FZ-10, Elevation 51 Feet 2.1 Exemption Requested 1:
11 An exemption is reque:ted from the requirement of Section III.G.2 for j.
not providing area wide automatic fire suppression in the fire zone.
2.1.1 Evaluation 1
p Modifications provided to protect safe shutdown capability located in this fire zone include:
l,'
Relocating selected electrical circuits in conduit within the zone, Providing selected electrical circuits run in conduits with one-hour m
fire rated barriers.
[
Relocating selected electrical circuits outside this fire zone.
lA Assuring that all manual actions required for hot and cold shutdown due l
to fire in this zone will be accomplished from outside this zone and are not affected by a fire in this zone.
Installation of water curtain sprinklers and open heat deluge water spray systems to protect open hatch and stairway penetrations through floors.
[O[ $0bbk nf r
1:
i P In addition to the modifications listed above, several other mitigating factors are-available in this zone which preclude the need for area wide automatic fire suppression.in the zone.
These factors are:
Fire loading in the zone is low with approximately 12,500 BTU per square foot, consisting primarily of cable insulation, and corresponds to a fire severity of about 10 minutes as measured on the ASTM E-119 time / temperature curve.
Automatic fire' detection capability which alarms locally and in the control room and which covers approximately 90% of the zone with all combustibles (cable trays) protected.
Two automatic open-head water spray deluge systems are installed to protect the cable trays and the open equipment hatch and open stairwell.
Each system is controlled by its own cross-zoned automatic ionization fire detection system. Standpipe and hose station and portable extinguishers for manual fire fighting capability supplement the automatic fire suppression capability.
2.1.2 Conclusion Based on the above evaluation, we conclude that any fire in Fire Zone RB-FZ-1D, elevation 51 feet, will be promptly detected and extinguished, and that automatic fire sup)ression need not be expanded to provide coverage for the entire zone. We, t1erefore, conclude that this requested exemption should be granted.
3.0 Fire Zone RB FZ-1E, Elevation 23 Feet 3.1 Exemption Requested An exemption is requested from the requirement of Section III.G.2 for not providing area wide automatic fire suppression in this fire zone.
- 3.1.1 Evaluation Modifications provided for protection of safe shutdown capability, and other
' mitigating factors in this fire zone, are the same as-those described for Fire Zone RB-FZ-10, elevation 51 feet, in Section 2.1.1 above, except that the fire loadingL(while still low) is approximately 20,000 BTU per square foot and corresponds to a fire severity of about 15 minutes as measured on the ASTM E-119 time / temperature curve.
3.1.2 Conclusion For the same reason outlined in Section 2.1.2 above, we conclude that this requested exemption should be granted.
3.2 Exemption Requested for the Fire Zone RB-FZ-1E, elevation 23 feet, a second exemption is requested from the requirement of Section III.G.2 for not providing specific protection for the reactor scram system circuitry in this fire zone.
f 8
s I 3.2.1 Evaluation p
In addition to the modifications provided for protection of safe shutdown capability.for this fire zone, the following conditions apply specifically to the reactor scram system circuitry.
-1.
All reactor scram circuitry is contained in conduit except for the backup scram valve circuitry.
2.
There are no external system circuits contained within the reactor scram conduits.
3.
Reactor scram circuits are normally energized until reactor scram is desired. At this time, power is interrupted and the scramdischargevolume(SDV)ventanddrainpilotvalves,the scram pilot air valves, and the backup scram pilot valves are deenergized to scram the reactor.
4 To achieve a reactor scram either the scram pilot air valves or the backup scram pilot valves are required to be deenergized.
5.
The effects of fire on the reactor scram circuits in conduit would be to interrupt power and initiate a scram.
3.2.2 Conclusion For all of the reasons given above, we conclude that additional protection is not required for the reactor scram system circuitry and that the requested exemption should be granted.
-3.3 Exemption Requested For the Fire Zone RB-FZ-1E, elevation 23 feet, a third exemption is requested from-the requirement of _Section III.G 2 for not providing either additional separation from'insitu combustibles or protection _for CRD Hydraulic System Bypass Valve,V-15-30.
3.3.1 ' Evaluation In addition to the modifications provided for the protection of safe shutdown capability for this zone, the following conditions apply specifically to the CRD Hydraulic System Bypass Valve V-15-30.
- Valve V-15-30 will be manually opened to provide a flow path for coolant makeup to the vessel with loss of offsite power. Makeup-to the vessel is not required until 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> 24 minutes after scram based on the vessel inventory analysis. Fusing of this valve as a result of a fire such that the valve cannot be operated is not considered a credible event because of the low fire loading in this zone, and the pipes connected to the valve being filled with water which provides ample heat. sink capability to protect the valves.
In addition, the principle combustible (cable insulation) is protected by automatic fixed water spray deluge system, and the valve is physically located
- within the spray area of the cable tray deluge system (approximately 6 feet below-the trays and 1 foot to the side).
3.3.2 Conclusion Since a fire in this fire zone would not be of significant magnitude, the duration of the fire will be short due to automatic extinguishment or extinguishment by the plant fire brigade. The valve is located within the spray area of a deluge system and the heat conduction to the water filled piping will provide cooling of the valve. The valve is not required to operate for almost 31 hours3.587963e-4 days <br />0.00861 hours <br />5.125661e-5 weeks <br />1.17955e-5 months <br /> after the fire. Therefore manual operation of the valv is considered to be achievable without the addition of any further L
protection.
We therefore conclude that this exemption should be granted.
3.4 Exemption Requested For the Fire Zone RB-FZ-1E, elevation 23 feet, a fourth exemption is requested from the requirement of Section III.G.2 for not providing a one-hour fire barrier for drywell penetration box P-13.
3.4.1 Evaluation In ad ition to the modifications provided for the protection of safe shutdown capability for this zone, the following conditions apply specifically to the drywell penetration box P-13.
1.
The only portion of the EMRV circuits located in this fire zone which could potentially be subjected to spurious operation due to a hot short is contained inside the penetration box.
(A short to ground will not cause spurious actuation). A fire cannot be initiated inside the penetration boxes as the result of electrical fault protective devices.
2.
The penetration box is located approximately five (5) feet.below the bottom of the fire zone ceiling. -Fire detection utilized to actuate the cable tray deluge water spray systems is located on the ceiling in the area of the penetration box (area-wide ionization detection is provided in the fire zone). Therefore, a fire in the zone will be detected and alarmed prior to any significant heat buildup at the elevation of the penetration box.
3.
The penetration box is effectively within the spray pattern of the existing automatic cable tray deluge water spray system. The water spray will provide cooling and prevent the propagation of fire from outside into the penetration box.
A fire in this zone would not be of significant magnitude, and the duration of the fire will be short due to self extinguishment, extinguishment by the deluge system, or extinguishment by the plant fire brigade. Consequently, the general heat buildup in the area due to the fire will be limited. The addition of fire barriers to the cables (not in conduit) could cause damage to the cables due to
t the inability to add adequate cable supports because of severe space limitations. The box is located within the spray area of the cable tray deluge system which will further limit any heat buildup inside l
the penetration box. Since a fire initiated inside the penetration box is not a credible event and since the effects on the penetration box due to an outside fire will'be limited by the low fire loading l
and water spray system, the addition of a fire barrier will not L
increase the level of fire protection safety above that provided by
~
existing fire protection features in order to achieve safe shutdown.
3.4.2 conclusion For all of the reasons cited in the evaluation above, we conclude that this exemption should be granted.
4.0 Fire Zone RB-FMF,. Elevation.(-);19, Feet 4.1 gempyjodeguested An exemption is requested from the requiretrent of Section III.G.2 for not providing area wide automatic suppression in this fire zone.
l-4.1.1 Eyaluation The fire loading in this zone is negligible, consisting primarily of cable insulation, at about 1500 BTU per square foot. This corresponds to a fire severity of about two minutes as measured on the ASTM E-119 time / temperature curve. Automatic fire detection capability, which alarms locally and in the control room, is located in this fire zone. Portable extinguishers and hose stations are provide for manual fire fighting operations.
A fire in.this zone would not be of significant size or duration and would not corrpromise the one-hour fire rated barriers provided for protection of the safe shutdown ccmponents.
In addition, the autmatic fire detection available in this fire zone is expected to alert the fire brigade to the onset of fire in the zone so that prompt manual suppression of any fire in the zone can be accomplished.
4.1.2 Conclusion For all of the reasons listed in the evaluation above, we conclude that automatic fire suppression throughcut this lone is not required and therefore, this requested exemption should be granted.
4.2 Exemption Requested For the Fire Zone RB-FZ-1F, elevation (-19) feet, a second exemption is requested from the requirement of Section III.G.2 for not providing either additional separation from insitu combustibles or protection for core spray
-system valve V-20-1.
- 4.2.1 Evaluation In addition to the conditions described above in Section 4.1.1 for this fire zone, the following conditions apply specifically to valve V-20-1 in th's core spray system.
Manual action required for hot and cold shutdown for a fire in inis zone will be accomplished outside of the fire zone except for opening valve V-20-1.
This valve, located in Room RB-FZ-1F3 (North-West corner of room in the same fire zone) must be opened following a fire in RB-FZ-1F3 but only within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> 24 minutes after scram to complete the alignment of the condensate storage tank to the core spray pump NZ018. Other manual actions will not be affected by a fire in this zone.
Fusing of this valve by heat from a fire in this zone resultin becoming inoperable is considered not credible because of (1) g in the valve the low fuel loading in the zone, (2) the provision of automatic fire detection and manual fire suppression capability, and (3) the heat sink capability of the water filled piping connected to the valve.
4.2.2 Conclusion Based on the above evaluation, we conclude that the provision of additional protection for this valve will not significantly enhance fire protection in this zone and, therefore, we recommend that this requested exemption be granted.
5.0 Fire Zone TF-FZ-118 - Turbine Lube Oil Storage, Pumping and Purification Areas 5.1 Exemption Requested An exemption is requested from the requirement of Section III.G.2 for not providing a 3-hour rated fire barrier for the portion of circuit 14-25 that is located in this fire zone.
5.2 Evaluation A pull pit beneath the floor of a corridor in the turbine building contains circuit 14-25. The floor and walls of this pull pit are of sand, and all electrical cables routed through the pit are run in conduits. Physical separation of the pit, and-therefore circuit 14-25, from TB-FZ-118, consists of (1) an aluminum cover plate bolted in place near the bottom of the floor and (penetration, (2) six inch minimum depth RTV foam floor penetration seal,3) slab slab.
m
, Based on the separation of this pull pit from the remainder of the Fire Zone
.TB-FZ-11B by the minimum 6-inches of RTV foam; the lack of combustibles in the pit; all cables routed in conduits; negligible fuel loading in the area above the pit; limited access to the pit because of high radiation levels and consequent low probability for an exposure fire due to transient combustibles; and the fact that all conduits enter and leave the pit through the sand walls
- fire is considered not to be a credible event in this pull pit. Therefore, i
further fire protection modifications or additional protection for circuit 14-25 in the pull pit is not required.
5.3 Conclusion Based upon the above evaluation, we conclude that further fire protection modifications or additional protection for circuit 14-25 in the pull pit in Fire Zone TB-FZ-11B is not required and this requested exemption should be granted.
6.0 Fire Zone TB-FZ-11D 6.1 Exemption Requested An exemption is requested from the requirements of Section III.G.2 and III.G.3 for not providing automatic fire detection in this zone.
6.2 Evaluation Selected "B" train safe shutdown circuits have been relocated and/or protected by one-hour rated fire barriers. Manual actions required for hot and cold-shutdown due to a fire in this zone will be accomplished outside of-this zona and will not be affected by any fire in this zone.
In addition the
~ f
'oading in this zone is low (about 22,000 BTU per square foot),and corresponds to a fire severity of about 16 minutes as measured on the ASTM E-119 time / temperature' curve.
This low fuel loading consists primarily of cable insulation, lubricating and hydrogen seal oil, and transient combustibles.
Fire protection provided in this fire zone consists of an area wide automatic sprinkler system and a localized automatic sprinkler system installed to protect the hydrogen seal oil units. Both of these sprinkler systems alarm in the control room and thus function also as a fire alarm system, although not as an early warning detection system.
6.3 Conclusion
- Based upon.the above evaluation, we conclude that any fire that might occur will= not be of significant magnitude or duration, and that it will be promptly extinguished by one of the two automatic sprinkler systems installed in this fire zone.
In addition, when the sprinklers operate, an alarm will sound in the control room, promptly alerting the fire brigade who will respond for any manual fire fighting or salvage operations that remain.
For the above reasons we conclude.that the addition of a zone wide fire detection system will not provide significantly more fire protection than what is already available, and therefore, the requested exemption should be granted.
~
7.0 Fire Zone.TB-FZ-11E-7.1 Exemption Requested An exemption is requested from the requirement of Section Ill G.3 for not l
providing autcmatic fire detection in this zone.
7.2 Evaluation The fire loading in this zone consists of electrical cable insulation in trays and minor amounts of lubrication oil in pumps. The fire loading is low (approximately 8,000 BTU per square foot) and corresponds to a fire severity of about 7 minutes as measured on the ASTM E-119 time / temperature curve.
In addition, an automatic closed head sprinkler system protects all areas west of columns Line F and includes all cable trays. Operation of the sprinkler system alarms in the control room which serves the function of an automatic detection system. Such alarm will promptly alert the fire brigade for performing any residual fire fighting operations.
7.3 conclusion Based upon the above evaluation, we conclude that any fire that might occur i
will not be of significant magnitude or duration. Also, any such fire will be I
promptly extinguished by operation of the automatic sprinkler systems.
If for some reason, the automatic sprinklers are able only to control the fire but not achieve extinguishment, the fire brigade, having been alerted es a result of alarm in the control room from the sprinkler system, will be able to achieve prompt extinguishment. Therefore, we conclude that the addition of zone wide fire detection capability will not provide significantly more fire protection than what has already been provided and, therefore, the requested exemption L
should be~ granted.
l 8.0 Fire Zone.TB.FZ-114 Basement.and.Mezzanina Soup east,Q d 8.1 gemp}tionJequested,
(
An exemption is requested from the requirement of Section III.G.2 for not providing a 3-hour fire rated barrier for Train "A" electrical power system l
circuit 14-22.
8.2 Evalution l
The Train "A" electrical power system circuit 14-22 cables in this fire zone are located in a pull pit located beneath the basement floor.
It is similar to the pit described in-Section 5 above. All of the cables in the pull pit are routed in electrical conduit. The pit has been filled with sand to provide the conduits with a minimum cover of six-inches. Thus, there are no exposed combustibles in the pull pit. A steel plate flush with the zone floor covers the entrance to the pull pit.
A 8.3 Conclusion i
i We conclude from the above evaluation that the lack of exposed combustibles in -
the pull pit, the fact that the electrical cables for the Train "A" electrical power system circuit 14-22 are routed in conduits, and the fact that these condelts have a minimum cover of 6-inches of sand and the steel plate cover to the pull pit, proside protection at least equivalent to a three-hour fire rated barrier. Therefore, the provision of a 3-hour rated fire barrier between the cables in the pull pit and the remainder of Fire Zone TB-FZ-11H would not provide significantly more fire protection than what is already available. Therefore, this requested exemption should be granted.
9.0 Fire Area 08,FA 480 Volt Switchgear. Room 9.1 Emption Requestg An exemption has been requested frcm the requirement of Section III.G.2 for not providing automatic fire suppression for the corridor areh of new Fire Zone OB-FZ-68, which has been created out of the Fire Area OB-FA-6.
9.1.1 Evaluation This requested exemption has already been accepted by the staff.
It was discussed and evaluated in Section 2.0-2.4 of our safety evaluation that was transmitted to the licensee by NRC letter dated Merch 24, 1986.
9.2 E,x,gption. Requested t
An exemption has been requested from the requirement of Section III.G.2 for not providing that at least one safe shutdcwn path needed to raintain hot shutdown is free of fire damage without any repair. The exemption is requested.to allow minor repairs outside of this zone to provide the required-hot shutdown capability for the new Fire Zone OB-FZ-6A created out of Fire Area 08-FA-6.
9.2.1 Evaluation The licensee stated that the 480V switchgear room, Fire Area OB FA-6, will be modified to create two separate Fire Zones, OB-FZ-6A and 6-B.
Fire Zone 08-FZ-6A and 6B will contain the Bus 480V USS 1A2 and the redundant Bus 480V USS 182 respectively. For a fire in Fire Zone OB-FZ-6A, the licensee will use hot shutdown path I which, in turn, requires the Bus USS IB2 to power the needed equipment for the hot shutdown path. The proposed design incorporates a cable tie between the buses. Consequently a fire induced fault in the bus cable tie in Fire Zone OB-FZ-6A can result in loss of the Bus USS 182 and, therefore, comprise the hot shutdown capability for the Fire Zone OB-FZ-6A.
1 Therefore, the licensee has proposed the following operator actions in the sequence described below outside the Fire Zone OB-FZ-6A to restore the Bus USS IB2 and thereby ensure hot shutdown capability for the Fire Zone OB-FZ-6A.
, (1). Deenergize the Bus USS 1B2 locally in the Fire Zone OB-FZ-6B.
(2)
In the control room, trip the feeder breaker at 4160 switchgear 10 feeding the Bus USS 1A2.
(3) Disconnect the cable bus tie which is directly bolted to the bus bars in USS IB2 in the Fire Zone OB-FZ-68.
(4) Reenergize the Bus USS IB2.
q in their telephone conversations with us on February 16 and 20,1989, the licensee stated that the above manual actions will require 20 minutes to complete and that they will be performed immediately after a fire in Fire Zone i
OB-FZ-6A. The licensee further stated that the plant areas where the manual actions have to be performed will be easily accessible and will not involve any transient through the affected Fire Zone OB-FZ-6A.
In their submittal, the licensee examined the impact of temporary unavailability of hot shutdown equipment in Fire Zone OB-FZ-6A resulting from short term loss of the Bus USS 1B2 which powers these equipment. These are "B" 480V switchgear HVAC supply and exhaust fans, reactor coolant makeup CRD pump NC08B, A/B battery room exhaust fan and static charger and MG set B.
The licensee determined that reactor coolant makeup (because of available vessel water inventory) and the battery room exhaust fan will nct be needed for at least 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> after scram by which time the Bus USS 182 would have been-restored and the above components powered by the bus; and the static charger and MG set B will not be needed for quite some time after scram since the DC loads supplied by the 125 VDC Distribution Center B can be powered from the station batteries alone for a time period well in excess of the time required-to restore the Bus USS 1B2. The licensee further determined that since the majority of the electrical' loads in the Zone OB-FZ-6B are powered by the Bus USS 182,,the loss of the bus will result in significant reduction in heat output in the zone and consequently the need for the 480V switchgear supply and exhaust fans will not arise for a time period well in excess of the time required to resto're the Bus USS 1B2 and power the fans.
9.2.2 Conclusion Based on the above, we find that the identified operator actions (1) involve only one minor hot shutdown repair, namely, disconnecting the cable bus tie, (2) can be completed well before an unrecoverable reactor. condition occurs, (3) do not involve any transit through the fire affected zone, and (4) do not require any offsite components or tools. For the above reasons, we have determined that with the completion of all the identified operator actions including the minor repair in a timely manner, there is reasonable assurance that hot: shutdown can be achieved and maintained following a fire in Fire Zone 08-FZ-6A. Therefore, the requested exemption for performing the identified hot shutdown repair should be granted.
4
. 10.0 fire Zone.08-FZ.8A...Hotor. Generator Set Room 10.1 Exemption Requested An exemption has been requested from the requirements of Section III.G.2 for not providing automatic fire detection in this fire zone.
10.1.1 Evaluation The zone is protected by an automatic fire suppression system (autcratic sprinkler) which also serves as an automatic fire detection system (althcugh not providing an early warning), since actuation of the system alarms in the control room. Such system actuation and automatic alarm will result in promptly alerting the plant fire brigade for performing any required fire fighting actions.
In addition, the combustible fuel loading in the area is low and corresponds to a fire severity of about 35 minutes as measured on the ASTM E-119 time / temperature curve. Also, the licensee has rerouted some circuits within this fire zone in conduits and has rerouted other circuits out of the zone to assure that at least one train of safe shutdown circuits within the zone will not be damaged by any fire that may occur in this zone.
10.1.2 Copelusion p
Based on the above evaluation, we conclude that any fire which might occur in Fire Zone OB-FZ-8A will be relatively small and will be controlled by the automatic sprinkler system.
Since operation of the sprinkler system will alarm in the control room, we expect prompt notification of, and response by, the fire brigade for any required manual fire fighting activities. Therefore, the installation of a separate automatic fire detection system would not provide a significant increase in fire protection for this fire zone and the requested exemption should be granted.
10.2 Exemption. Requested For the Fire Zone OB-FZ-8A, a second exemption is requested from the requirement of Section III.G.2 for not providing specific protection for the reactor recirculation valve circuits. contained in this fire zone.
10.2.1 Evaluation In addition to the information given above in Section 10.1.1 for this fire I
zone, the following information addresses the issue of protecting the reactor recirculation valve circuits.
A.
.There are a total of five (5) recirculation loops located in two firezones(08-FZ-8AandOB-FZ-8C). All five loops are open during normal power operation.
B.
The Oyster Creek Technical Specifications require four (4) loops to be open during normal power operation.
f J
j f
L C.
Two (2) recirculation loops are required to be open to provide natural circulation through the core for safe shutdown.
D.
Assuming fire damage to the valve for one recirculation loop, three (3) loops will remain open to provide natural circulation cooling of the core for safe shutdown.
10.2.2 Lone _lusion Based on the evaluations in Sections 10.1.1 and 10.2.1 above, we conclude that any fire which might occur in Fire Zone OB-FZ-8A will not damage more than one reactor recirculation loop valve circuit. Since the remaining three open recirculation loops provide sufficient natural coolant circulation tnrough the core to achieve and maintain safe shutdown, the requested exemption should be granted.
11.0 Fire Zone OB-EZ.8C... Battery,R gohnnej;anMjecgjc613ay; Room
- h. Elevation 11.1 Exemption Regu3sted An exemption is requested from the requirements of Section III.G.2 for not' providing specific protection to reactor scram circuits located in this fire zone.
11.1.1 Evaluation The licensee has identified the battery room ventilation system modifications,
. instrument modifications and electrical modifications to assure safe shutdown capability for this zone. The licensee further stated that all manual actions for hot and cold shutdown will be accomplished from outside of this fire zone and will not be affected by a fire in this zone. Additionally, the licensee provided the following justification to support this exemption request:
A.
All reactor scram circuitry is contained in conduit except for the backup scram valve circuitry.
B.
There are-no external system circuits contained within the reactor scram conduits.
C.
Reactor scram circuits are normally er.ergized until a reactor scram is desired. At this time, pcwer is interrupted and the scram discharge volume (SDV) vent and drain pilot valves, scram pilot air valves and the backup scram pilot valves are deenergized to scram the reactor.
D.
To' achieve a reactor scram either the scram pilot air valves or the backup scram pilot valves are required to be deenergized.
E.
The effects of fire on the reactor scram circuits in conduit would be to interrupt power and initiate a scram.
I
- l l l 11.1.2 Conclusion Based on the above evaluation we conclude that the licensee's justification for this requested exemption is valid and that it should be granted.
11.2 Exemption Requested
~
For the Fire Zone OB-FZ-80, a second exemption is requested from the provisions of Section III.G.2 for not providing specific protection to the reactor recirculation valve circuits contained in this fire zone.
3 11.2.1 Evaluation I
The situation for the reactor recirculation valve circuits located in this zone is similar to that described in Section 10.2.1 for the reactor recirculation valve circuits located in Fire Zone OB-FZ-8A and the same i
technical reasons which support that exemption request apply here also, i
11.2.2 Conclusion Based on the above, we conclude that this requested exemption should be i
granted.
I Dated: ' June 25, 1990 Principal Contributor:
D. Notley 4
l
)
i
\\