ML20087J750
| ML20087J750 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 03/14/1984 |
| From: | Murphy W VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| FVY-84-24, NUDOCS 8403230063 | |
| Download: ML20087J750 (20) | |
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VERMONT YANKEE NUCLEAR POWER CORPORATION RD 5. Box 169, Ferry Road, Brattlebore VT 05301
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ENGINEERING OFFICE Y
March 14, 1984 1671 WORCESTER ROAD FVY 84-24 FRAMINGHAM, MASSACHUSETTS 01701 TELEPHONE 617-872-8100 United States Nucir.ar Regulatory Commission Washington, D. C. 20555 i
Attiention:
Harold R. Denton, Director Office of Nuclear Reactor P.egulation
References:
(a) License No. DPR-28 (Docket No. 50-271)
CO) Letter, VYNPC to USNRC, FVY 83-92, dated August 16, 1983 (c) Letter, USNRC to VYNPC, Inspection Report 50-271/83-26, dated November 2, 1983 (d) Letter, USNRC to All Licensees and Applicants of Nuclear Power Reactors, Generic Letter 83-33, dated Oct0ber 19, 1983 (e) Letter, USNRC to All Licensees and Applicants of Nuclear Power Reactors, I&E Informatiota Notice 84-09, dated February 13, 1984 (f) Letter, VYNPC to USNR, WVY 77-8, daled January 31, 1977 (g) Letter, USNRC to VYNPC, Amendment No. 43 to Facility Operating License DPR-28, dated January 13, 1978
Subject:
Request for Exemption - 10CFR Part 50, Appendix R, Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979
Dear Sir:
In accordance with the provisions of 10CFR Part 50.12. Vermont Yankee Nuclear Power Corporation hereby requests eight exemptions from the requirements of 10CFR Part 50, Appendix R.
Specifically, we are seeking exemptions from the provisions of Appendix R,Section III.G.2, Fire Protection of Safe Shutdown capability. Approval of these exemption requests will subsequently negate the need to provide for alternate shutdown capability in accordance with Section III.G.3 of Appendia: R.
Our requests for exemption are provided as Enclosure 1 to this letter.
By Reference (b), we s.:bmitted an exemption request for our Reactor Building Northwest Corner Room (Elevation 232').
Exemption No. 1 to Enclosure 1 supersedes Reference (b) in its entirety. Reference (b) is hereby withdrawn, from concideration.
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~ United States Nuclear Result. tory Connaiss' ion March 14, 1984 Attention: Harold R. Denton, Director Page 2 The enclosed exemption requests reflect the results of our consideration
- of-the findings of I&E Inspection Report 50-271/83-26, as well as the NRC's subsequent issuance of clarification with respect to the requirements of 10CFR
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-Part 50, Appendix R, as detailed in References-(d) and (e).
It should be
.noted that a resurvey of our Reactor Building, initiated in response to the concerns expressed by the NRC in Meforence (c), is ongoing and acy result in the need for additional exemption requests.
We trust that our requests are deemed acceptable; however, should you have any questions on this matter, please contact us.
Very truly yours, VERMONT YANKEE UUCLEAR POWER CORPORATION W.
. Murph Vice President nd Manager of Operations Enclosures cc:. United States Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia', PA 19406 Attention: -Dr.1 Thomas E. Murley l
I STATE OF. VERMONT)
)ss WINDHAM COL'NTY )
Then personally appeared before me, W. P. Murphy,.who, being duly sworn, l.
did state that'he is a Vice President and Manager of Operations of Vermont
' Yankee Nuclear Power Corporation, that he is duly authorized to execute and
' file the focegoing request in the name and on the behalf of Vermont Yankee Nuclear Power Corporation and that the statements therein are true to the best of his knowledge and belief.
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D. M. McCue Notary Public
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ENCLOSURE 1 VERMONT YANYFE EXENPTION REQUESTS FROM
~100FR50. APPEN'.IX R 1.
Reactor Buildina. Northwest Corner Room. Elevation 232' - Shotos 22. 23 Vermont Yankee requests exemption from the requirements of Section f
III.G.2.b of Appendix R for the ncethwest corner room, Elevation 232'.
Specifically, exemption is requested from the requirement to have redundant trains of equipment separated by a horizontal distance of 20 feet with no intervening fire hazards or combustibles where fixed fire detection and suppression systems are installed.
l The technical basis for this exemption request follows here.
Power cables for both safety trains are in this room. These are for
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redundant safety equipment but are not required for hot shutdown. The i
cables are XI?/PVC, and they enter the corner room in heavy wall conduit six feet from the ceiling with a separation of approximately three feet.
These conduits then quickly diverge (See Sketch SK-FP-1, Attachment A).
When the conduits are approximately 26 feet from each other, the cables enter tray. The trays then exit the corner room with a separation of approximately 30 feet. The cables :r.:pply power to the Core Spray Pumps A and B; RHR Pumps A through D; and RHR Service Water Pumps A throtsh D.
Ncte that none of this equipment is assumed in our an31ysis as being necessary to achieve hot shutdown. The RHR and RHR service water pumps i
are necessary to reach a cold shutdown condition.
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This elevation contains racks and cabinets. The ceiling height is approximately 18 feet. The lower level (213' elevation) contains the steam-driven reactor core isolation coolant pump and related switchgear.._
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.e' There is an open stairway between the two elevations. The combined
-combustibles of both elevations consist of lubricants and cable insulation and are calculated to be 12.330 BTU /ft. sq., a low combustible level.
Fire suppression in the area is presently provided by portable wall-mounted extinguishers, and hose statior.s on the 252' level and in the torus area. Smoke detectors are installed at the 213' and 232' N.
elevations of this corner room.
It should also be noted that this corner co m la a restricted area.
Controlled access from above is through a locked steel structure; and
-from below via the torus, through a locked, touvered steel door, These conditions minimi::e general travel in the area and greatly reduce the probability of the introduction of transient. combustibles.
We will install an area pre-4ction water suppression system to cover the northwest corner room Elevation 232', using the existing detectors to r
. activate the system.
We believe that the limited access t.o the area, the low combustible
-loading, the detection systam, the abseace of intervening combustibles, and the pre-action water suppression system will provide protection for 4'
~the public health and safety in a fashion equivalent to that resultin6 from compliance with the specific technical requirements of Section III.G.2.b of Appendix R for 20 foot. horizontal separation with no intervenin, fire hazards or combustibles. Therefore, we request an exsaption from.the requirements of Section III.G.2.b of Appendix R for this corner room.
2.
Reactor BuildinK. Torus Ares
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Vermont Yankee requests exemption from the requirements of Section III.G.2.b of Appendix R for the Reactor Building Torus Area.
f-Specifically, exception is requested from the III.G.2 requirement to have L
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E runandant trains of equipment separated by a horizontal distance of more than 20 feet with no intervening combustibles or fire hazards, and with an autcmatic suppression system installed in the area.
The technical basis for this exemption request follows here.
. Redundant power and control cables for the Core Spray, RHR, and RHR service water pumps enter the torus area in the northwest corner. These pumps are not needed for hot shutdown. The cables are separated by approximately 30 feet. They then run in a cab 11 tray in opposite directions around the perimeter of the torus approximately 30 feet off the float until they reach the northeast and southeast corner rooms.
Where they either enter the corner rooms or a splice box mounted in the torus wall. This configuration is shown on Sketch SK-FP-1 (Attachment A).
Up to this point, they are no closer than the 30 feet I
where they entered the torus.
Rach RHR corner room contains two RHR pumps. Within each corner room, one RHR pump is powered from one power system (SI), and one is powered from another power system (SII). To provide the power to these pumps, a set of cables for one RHR pump from each safety train continues in
. conduit from the splice boxes at each corner room along the east wall of the torus and into the opposite corner room-(See drsving SK-FP -1, Attachment A).
These cables run beside each other and are redundant to each other. A fire near these conduits could remove power from one RHR pump in each train. However, because each safety train has two redundant RHR pumps (one in one corner room, one in the other corner room), one pump would be left in each train. A fire outside either corner room could remove power from three RHR pumps, two from one train and one it.
the other train. However, the second pump in one train would be left to operate. l 1
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The Torus Area is a large octagonal area, 140 feet across with a very low combustible loading. The ceiling is approximately 37 feet high. The Primary Containment and the torus itself fill a large volume of the area and preclude a fire from moving across the area. In addition, this area is equipped with numerouc smoke detectors and fire extinguishers. Manual hose stations are also available within this crea. Although trantient combustibles-(in the form of clothing, plastic, and wood) could be present in the torus area to support maintenance activities, such combustibles will not be admitted unless an evaluation of the area is performed and appropriate compencatory fire protection measures are institutoa. These compensatory measures could include one or more of the following actions:
(1) control of the maximum amount of clothing and plastic allowed into the area; (2) additional fire extinguishers; (3) use of non-combustible storage bins; and/or, (4) a continuous f3re watch in the area. The inherent separation within this area, coupled with the very low combustible loadings and existing fire protection measures, insure that a fire in one particulac section of th6 torus area will not progress'.to other sections.
Based upon the above analysis, we believe that the public health and safety will be protected in a fashion equivalent to that resulting from compliance with the specific technical requirements of Section III.G.2.b for installation of automatic fire suppression and twenty foot separation throughout the Torus Area. Therefore, we request an exemption from the l.
requirements of Section III.G.2.b of. Appendix R for this area.
-3.
Reactor Buildinst. Northeast and Southeast Corner Rooms - photos 11.18.
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Vermont Yankee requests exemptions from the requirements of Section III.G.2.b of Appendix R for both the northeast and southeast corner rooms. Two exemptions are requested. First, an exemption is requested for the Reactor Building area, Elevntion 252', between the stairs down to f
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the two RHR corner rooms from the requirement to have installed detection
.and automatic fire suppression between redundant trains of equipment with more than 20 feet.of separation. Second, an exemption is requested within each room from the III.G.2.b requirement to have redundant trains of equipment separated by a horizontal distance cf 20 feet with no intervening fire hazards or combustibles and with an autor.mtic suppression system installed in the area.
The technical ~ basis for thest. exemption requests follo.as here.
.With respect to the first exes.ption request, each of these RHR corner rooms contains a core spray pump, two RHR pumps, and two RHR service water pumps. These redundant corner rooms are separated by approximately 100 feet within the Reactor Building. The equipment in these rooms is i
not needed to achieve hot shutdown.
If a fire occurred in one of the cornce rooms, the other room is unaffected.
To commun!.cate between these rooms, a fire must either propagate thcough the Torus Area, through two (2) fireproofed, watettight doors; or.nove up and out the steel stairway to Elevation 252', across the 100 feet
-separating it from the other room, then down the steel stairway into the other room. The path through the Torus Area was previously addressed in Exemption Request Number 2.
There are no intervening combustibles between these two corner rooms at either klevation 252' or in the Torus Area. In addition, fire detection is provided in each corner room as well as in the Torus Area. Manual hose stations and fire extinguishers are also available throughout this area. Although transient combustibles (in'the form of clothing, plastic, and wood) could be present in the torus area to support maintenance activities,-such combustibles will not be admitted unless an evaluation of the area is performed and appropriate compensatory fire protection measures are instituted. These compensatory measures could include one _ - _ - - - _ _ _ _ - _ _ - - _
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or more of the following actions:
(1)-control of the maximum amount of-L
' clothing and plastic allowed into the area; (2) additional fire
- extinguishers; (3) use of non-combustible storage bins; and/or, (4) a s.
continuous fire watch in the area.
Based'upon the above analysis, we believe.that the existing: separation.
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, within the Reactor Building and the absence of intervening combustibles
' provide protection for the public health and safety in a fashion equivalent to that resulting from compliance with the specific technical requirements of Section III.G.2.b to Appcsdix R for installed detection
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and automatic fire suppression between redundant trains of equipment with more than 20 feet of separation.- Therefore, we request an exemption from 1
that requirements of II.G.2.b of Appendix R for this area.
.With' respect to the second exemption request, each of these corner rooms contains redundant equipment, as described above. Certain equipment could be lost to a single fire in one corner, room; however, as addressed-above, this' loss would not prevent cold shutdown because redundant equipment exists in the opposite corner room. In addition. fire t
deteellon is provided within both rooms. As discussed above, we believe the~exlIting separation within the Reactor Buildir.g and the absence of L
. intervening combustibles between the two rooms provide protection for the i
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c public health and,srfety'in a fashion equivalent to that resulting from compliaise with the specific technical-requirements of Section III.G.2.b of Appendix R'for 20 foot separation and the installation of suppression
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. requirements ot III.G.2.b of-Appandix R for this area.
. Reactor Buildina. dievation 25'2'. Northwest Corner - photos 5. 6. 7. 8. 9 s ',
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.x 2 Vemont;Yan)ree requests two ' exemptions from the requirements of Section i
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III.G.2 of Appendix _R for the'ncethwest corner, Rievation 252', of the Reactor Buildi'ng". Specifically, the first exemption is requested from theIII.Gi2Yeduidmentgohaverdhundant'trainsofequipmentseparated t
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.by a. horizontal distance of 20 feet with no intervening combustibles or firA asards.
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The technical basis for this first exemption request follows here.
Control and instrumentation cables associated with both trains and selected power cables are routed from the Control Building into the Reactor Building through the northwest corner at Elevation 252'.
This area is of particular interest in that s very heavy concentration of cables of both trains are located there. In addition, several cables associated with our alternate shutdown design are routed in conduit in this vicinity, switch controllers are located on a column between the trays, and two valve contactors for HPCI and RCIC are located ten feet apart on the steam tunnel walls. The fire loading near these contactors is very low, with no intervening combustibles. The two trains are separated by approximately 20 feet; smoke detection has been provided in the area, and a pre-action automatic sprinkler system is installed beneath the lowest level of cable trays. It has been determined that a fire originating outside the area covered by the sprinkler system could spread horizontally to the area containing redundant cables at a level above the sprinkler system. Therefore, we will make the following changes in the area.
We will expand the pre-action system to cover the floor area in this corner as far as the steam tunnel wall. We will also add a second level of sprinkler heads at the ceiling over the same floor area. This system will promptly suppress any fire in this area, including those that might result from a fire in other parts of the Reactor Building, and insure that redundant safety systems are preserved.
l We believe that these modifications will preclude a fire in this area, as well as one in other parts of the Reactor Building, from preventing the plant reaching hot shutdown and will provide protection for the public health.and safety in a fashion equivalent to that resulting from compliance with the specific technical requirements of Section III.G.2.b
.of Appendix R to have redundant trains of equipment separated by a horizontal distance of 20 feet with no intervening combustibles or fire hazards. Therefore, we request an exemption from the requirements of III.G.2.b for this area.,
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The second exemption is requested from the III.G.2.c requirement to have redundant trains of equipment separated by a one-hour fire barrier with detection and suppression in the area.
The technical bases for this second exemption request follows here.
The floor area at Elevation 252' is separated from the rooms below by a steel enclosure and a steel plate covered hatch.
4 Both the hatch and the enclosure are constructed of heavy steel plate and sit on the 252' Elevation (See Photo 5).
Incide the enclosure, the steel stairway descends to the room at Elevation 232'.
This room is discussed in detail in Exemption Request No. 1 of this enclosure. We are planning to install a pre-action sprinkler system in this room. Additionally, as discussed above, we plan to expand the pre-action sprinkler on Elevation 252' in this area. Therefore, we will have a heavy steel enclosure and a hatch plate with a pre-action sprinkler on either side of it.
We believe this will provide protection for the public health and safety in a_ fashion equivalent to that resulting from the specific technical requirements of Section III.G.2.c of Appendix R for provision of a one-hour rated barrier. Therefore, we request an exemption from the requirements of III.G.2.c of Appendix R for these areas.
- 5.
Reactor Buildina. Elevation 280'. East Side. Instrument Racks -
Photos 2. 3 i
Vermont Yankee requests an exemption from the requirements of Section III.G.2.b of Appendix R for the east side of the Reactor Building.
Elevation 280', by Instrument Racks 25-5 and 25-6.
Specifically, 4
exemption is requested from the III.G.2.b requirement to have detection and automatic suppression installed between redundant trains of equipment separated by a horisontal distance of 20 feet with no intervening combustibles or fire hazards.
l The technical basis for this exemption request follows here.
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Level and pressure transmitters are located on the Elevation 280' instrument racks. Redundant level indication is available from two racks located on Elevation 252'.
Redundant pressure indication is available from two racks located on Elevation 213'.
Therefore, more than adequate redundant indications are provided throughout the Reactor Building.
These racks on Elevation 280' are separated by approximately 30 feet, sad their cables in conduit pass in close proximity to each other. There are no intervening combustibles. Additionally, redundant instrumentation exists on Elevation 252', 28 feet below and in another quadrant of the building, and on Elevation 213', 67 feet below and in another quadrant cf the Rasetor Building. A fire in either of these rack areas will not affact the others.
The'relativa proximity of the racks on Flevation 280' to the Recirculation NG set area was addressed in the Fire Hazard Survey submitted in January 1977 [ Reference (f)], and in the NRC's Safety Evaluation Report [ Reference (g)], dated January 1978. As a result of this evaluation, smoke and thermal detection was installed over the nearby MG sets, the berm around the MG set was raised, and an automatic e
foam suppression system was inatailed. Manual hose stations and fire extinguishers are also provided in the area. Although transient l
combustibles (in the form of clothing, plastic, and wood) could be I
present in the torus crea to support maintenance activities, such combustibles will not be admitted unless an evaluation of the area is performed and appropriate compensatory fire protection measures are instituted. These compensatory measures could include one or more of the following actions:
(1) control of the maximum amount of clothing and plastic allowed into the area; (2) additional fire extinguishers; (3) use of non-combustible storage bins; and/or (4) a continuous fire watch in the area.
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Based-upon the above analysis, we bell' eve that the separation between the racks, the availability of redundant instrumentation in other parts of
-the~ Reactor Building, and the fire protection measures prescatly installed in the vicinity of these instrument racks, provide protection I
for the public health and safety in a fashion equivalent to that resulting from' compliance with the specific technical requirements of Section III.G.2.b of Appendix R to have detection and automatic suppression installed between redundant trains of equipment separated by a horizontal distance of 20 feet with no intervening combustibles or fire
. hazards. Therefore, we request an exemption from the requirements of
.III.G.2.b of Appendix R for this arsa.
6.
Reactor Building. Elevation 252'. Northeast Corner. Vital MCCs - photo 10 Vermont Yankee requests an exemption from the requirements of Section III.G.2.b of Appendix R for the northeast corner of Elevatica 252' of the Reactor Building, in the vicinity of vital MCCg.
Specifically, exemption is requested from the requirement to have redundant trains J equipment separated by a horizontal distance of 20 feet with no intervening fire hazards or combustibles, with fire detection and an automatic suppression system installed in the area.
h basis for this exemption request follows here.
These McCs contain control and power feeds for redundant ac mator-operated valves, some of which are located inside the inerted L
containment. There is approximately an 18-foot separation between the vital MCCs in question. The ceiling is approximately 27 feet high.
There are two cable trays approximately 18 feet off the floor which run part of the way between the MCCs. The cables then enter conduit for the balance of the distance. There are no other in situ combustibles in the area, as addressed in the Fire Hazard Survey subali.ted in Janr.ary 1977 (Reference (f)].
l To decrease the probability of fire damaging these NCC's, we intend to install the following modifications:
We will seal the conduits running between the MCCs to insure that a cable fire will not propagate through the conduits. We will also i
Install s radiant heat shield between MCC 89A acd 89B.
This shield will extend up approximately 14 feet and at lease four feet out from the wall.
Little or no in situ conhustibles are located in the area.
In addition, manual hose stations and extinguishers are available in the area. If a i
fire does etart in one MCC, the shield will prevent the radiant heat from reaching the second MCC.
Although transient combustibles (in the form of clothing, plastic, and wood) could be present in the torus area to support maintenance activities, such combustibles will not be admitted unless an evaluation r.
of the area is performed and appropriate compensatory fire protcction
' measures are instituted. These compensatory measures could include one or more of.the following actions:
(1) control of the maximum amount of I
clothing and plastic allowed into the area; (2) additior.a1 fire l
extinguishers; (3) use cf non-combustible storage bins; and/or, (4) a continuous fire watch in the area.
Based on the modifications discussed above, coupled with lack of l
l combustibics and existing fire protection features located in this area, we believe a fire in this area will not prevent the plant from achieving I
safe shutdown. In addition,'we believe these measures provide protection l-for the public health sad safety in a fashion equivalent to that resalting from compliance with the specific technical requirements of Section III.G.2.b of Appendix R to have redundant trains of equipment i
separated by a horizontal distance of 20 feet with no intervening combustibles or fire hazards, with fire detection and automatic fire l
suppression installed in the area. Therefore, we request an exemption i-ufrom the requirements of III.G.2.b of Appendix R for this area.
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power Cables in personnel Corridor - photos 16. 17 Vermont Yamkee requests an exemption from the requirenw.ts of Section III.G.2.c for the personnel corridor leading to the Reactor Building.
Specifically, exemption is requested from the III.G.2.c requirements to install fire detectors and an automatic suppression system where redundant trains of equipment are Japarated by a one-hour fire barrier.
4 The technical bases for this exemption request follow here.
Redundant power cables in conduit pass through the corridor, separated by approximately 19 feet. Although no detection or automatic suppression in this area, there are no in situ combustibles in the corridor. In
. addition, manual hose stations are available in this area.
To decrease the probability of a fire, we intend to wrap both sets of condaits with an accepted one-hour fire wrap. With this change, we believe that a fire in the corridor will not prev 0nt the plant from' reaching safe shutdown.
We believe that wrapping both cable, coupled with the lack of in situ combustibles during operation will provide protection for the public health and safety in a fashion equivalent to that resulting from compliance with the specific technical requirements of Section III.G.2.c of Appendix R to install fire detection and automatic fire suppression when redundant trains of equipment are separated by a one-hoar fire barrier. Therefore, we resuest an exemption from the requirements of j.
III.G.2.c of Appendix R for this ares.
8.
Reactor Buildina - photos 1. 4. 9. 10. 11. 12. 13. 14. 15 Vermont Yankee requests an exemption from the requirements of Section III.G.2 for the Reactor Building. Specifically, we are requesting an I
exemption from the general criterion of III.G.2 which states that whece l
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p cables or equipment of redundant trains of systems necessary to achieve
- and maintain safe shutdown era located within the same fire area, the
" licensee must meet the specific separation criteria of III.G.2.a. b, or c.
The technical basis for the request follows here.
l The preceding exemption requests address specific areas within the Reactor Building where we do not meet the strict separation criteria of
.Section III.G.2 of Appendix R.
However, as discussed in our 1977 Fire Hasards Survey [ Reference (f)], we onsider the Reactor Building to be technically one large firo area, separated into zones by floors, walls, and inherent spatial separation. Our subsequent fire protection program i
was based on this consideration. Numerous modifications and fire protection measures were implemented to insure that a fire in one particular area of the Reactor Building could not spread to other areas.
i The scope of our-program is documented in the 1977 Fire. Hazards Analysis
[ Reference (f)] and also in the NRC's 1978 Fire Protection Safety Evaluation Report [ Reference (g)], which was issued after the NRC's inspection of our overall Fire Protection Program. In addition, we have
' implement 2d various procedures to reduce the likelihood of a fire in any area of our facility and have established a five-man fire brigade to further insure that any fire is contained within a. local area, t
Our compliance to Sections III.G,-III.L. and III.O of_ Appendix R was reviewed as part of the NRC's most recent fire protection inspection and is documented in Reference (c). The inspection team concluded that although we'do not meet the strict separation criterion of III.G.2; "A review of the physical layout of redundant trains of equipment in the Reactor Building indicated that an inherent general separation exists due to the
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trains being located on cpposite sides of the primary containment. The combustible loading throughout the l
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i building appeared low overall, and the general layout of equipment is such that the building is not congested, and typically has numerous areas on each
. elevation where little or no combustible material is present. The team concluded that, although, the Licensee had failed to provide the specific fire protection features required by Appendix R Section III.G., the general configuration of equipment within the Reactor Building tends to minimize the not safety effect of the lack of the specific protection required by the Rule."
We believe that the fire protection modifications and measures implemented to date, coupled with the additional modifications being proposed for specific areas within the Reactor Building (as detailed in
'Rxemption Requests one through seven), meet the intent of Section III.G.2 separation criteria and provide protection equivalent to that provided by the establishment of physically bounded fire areas within the Reactor Building.
Given the existing' Reactor Building configuration, any local fire will be-contained within a smal1~ area by the actuation of fire suppression systems or the lack of intervening combustibles necessary to support the spread of the fire throughout any singis elevation or from one elevation to another.
In addition, manual hose stations and numerous fire l
extinguishers are available throughout the-Reactor Building.
.Although transient combustibles (in the form of clothing, plastic, and I
wood) could be present in an area of the Reactor Building to support I
maintenance activities, such combustibles will not be admitted within a particular area unless an evaluation of that area is performed and
. appropriate compensatory fire protection measures are instituted. These compensatory measures could include one or more of the following actions:
(1) control of the msximum amount of clothing and plastic 1-allowed into the area; (2) additional fire extinguishers; (3) use of non-combustible storage bins; (4) control of tho exact placement of worker change stations; and/or (5) a continuous fire watch in the area.
We believe that the inherent separation, low combustibic loading throughout the Reactor Building, the existing fire protection modifications and measures, and the additional fire protection modifications we have proposed in those specific areas where safe shutdown cculd have been affected by a fire, pecvides protection for the public hesith and safety in a fashion equivalent to that resulting from compliance with the technical requirements of Section III.G.2 of Appendix R.
Therefore, we request an exemption from the requirements of Section III.G.2 of Appendix R with respect to the installation of additional fire barriers, detection, and fixed suppression throughout the building.
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