ML20097F081

Forwards Rev 0 to Vols 1 & 2 of App R Compliance Assessment Rept

ML20097F081
Person / Time
Site:	Davis Besse
Issue date:	09/06/1984
From:	Crouse R TOLEDO EDISON CO.
To:	Stolz J Office of Nuclear Reactor Regulation
Shared Package
ML20097F083	List: ML20097F081
References
1076, TAC-56864, NUDOCS 8409180380
Download: ML20097F081 (14)

Text

.

Docket No. 50-346 7gtggo License No. NPF-3 Serial No. 1076 [cs[$cm rux-September 6, 1984 'a e Director of Nuclear Reactor Regulation Attention: Mr. John F. Stolz Operating Reactor Branch No. 4 Division of Operating Reactors United States Nuclear Regulatory Commission Washington, D. C. 20555

Dear Mr. Stolz:

On July 25-29, 1983, the Nuclear Regulatory Commission (NRC) conducted an audit of the Toledo Edison Company Davis-Besse Nuclear Power Station, Unit No. 1 (DB-1), with regard to the Station's compliance to Appendix R of Title

'10, Part 50, of the Code of Federal Regulations.

Subsequent to the audit exit meeting held on July 29, 1983, Toledo Edison identified twenty-nine (29) deficiencies around which it developed a pro-gram of short and long term actions intended to adequately respond to each deficiency. The developed Audit Response Program (ARP) was submitted to your staff on September 13, 1983 (Serial No. 986).

Of the actions identified in the ARP, the results of four tasks (1, 2, 3,

& 5)'were specifically requested to be submitted to Nuclear Reactor Regula-tion (NRR) for review. This request for submittal to NRR transpired in the Restart Safety-Evaluation issued on September 23, 1983 (Log No. 1375).

This letter formally transmits the Toledo Edison results achieved thus far for those four specific tasks. A restatement of the tasks as discussed in the referenced letter is included as Attachment 1. The methods utilized by Toledo Edison to accomplish the objectives of the tasks in Attachment I has deviated from the original task statement in some cases. The intent of ad-dressing the specific audit deficiency, however, has been met or has been exceeded. Several meetings were held with the NRC since the audit, in order to keep your staff informed of and to obtain concurrence with the methodology utilized to perform each task. Those tasks identified by numbers 1, 2, 3, and 5 are renumbered here 1, 2, 3, and 4, respectively. The status of all other tasks and activities identified in the ARP submittal will be detailed in the Toledo Edison response to the July 25-29, 1983 Inspection Report.

The Toledo Edison response to the referenced tasks 1, 2, and 4 is included as the two volume enclosure entitled the " Appendix R Compliance Assessment

-Report" (CAR).

. THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO. OHIO 43652 00 8409190380 040906 PDR ADOCK 05000346

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' D ckst No. 50-346 Llcense No. NPF-3

- Serial No. 1076

- September 6, 1984 Page 2 The CAR details the DB-1 compliance to the requirements of Sections III G.

J, L, and 0, of Appendix R to 10 CFR 50. Within the CAR, the level of com-pliance to the required sections of Appendix R is specified.

A table _ summarizing the compliance level of fire areas with Appendix R is in the CAR as Table 1-1, and included here as Attachment 2. Physical modi-

' fication alternatives and procedural modifications are identified to address specific noncompliances. In certain fire areas, it has been technically

. evaluated.that the existing fire protection features, while not meeting the letter of Appendix R, meet or exceed the intent of the specific requirement.

For these areas, exemptions are requested from the requirement of concern.

. Table 1-2 of the CAR summarizes the exemptions requested from the specific requirements of Appendix R,'and is included here as Attachment 3.

.On April 16, 1984, Toledo Edison cubmitted a revised schedule for completing the tasks in the Audit Response Program (Serial No. 1042). The September 1, 1984 commitment for the discussed tasks was identified in that letter. Ad-ditionally, in that letter Toledo Edison attempted to convey to the NRC, its concern over the potential impact on the ARP of performing the various tasks without the guidance that would normally be provided in an inspection report.

Toledo Edison received your August 30, 1984 letter (Log No. 1-1024) Inspection

_ Report No. 50-346/83-16(DE) regarding the July 25-29, 1983 audit of compliance to Appendix R on September 5, 1984. Toledo Edison has had insufficient time to review the inspection report prior to this submittal and our actions have been based upon our understanding of the audit findings as verbally transmitted during the audit exit meeting.

With regard to Task No. 3. Toledo Edison has determined that a review of the wricten audit findings against the task methodologv and results be performed prior to document submitcal. This determination was made to ensure that Toledo Edison is responding to the specific audit findings.

i The 'results of Task No. 3, therefore, will not be submitted at this time, however, they will be submitted in the Toledo Edison response to the audit inspection' report.

Task #5 described in Serial #986 was to perform a review of the Engineering Inspection Team (EIT) walkdown performed during 1975-1976. The results of this task were to have been used to assess Davis-Besse compliance with Ap-pendix R relative to associated circuits.

s However, a complete re-analysis of safe shutdown and associated circuit

-channel separation.was performed and is described in the attached CAR.

Toledo Edison believei that the extensive circuit tracking (both safe shutdown and associated circuits) performed for the CAR meets the intent of the previously proposed Task #5. Therefore, the intent of this task is considered to be addressed by the attached report.

D.-

D:ckSt No. 50-346 License No. NPF-3 Serial No. 1076 September 6,.1984 i Page.3

?

Scheduling Tol'edo Edison intends to implement.the fire protection modifications in acco'rdance with procedures for the Integrated Living Schedule Program (ILSP).

Toledo Edison has prepared a-preliminary Summary Level Planning Worksheet (SLPW) for 'the fire protection project. This SLPW was prepared consistent

- with the Toledo Edison Integrated-Living Schedule Program plan submitted on-July-16, 1984, in Toledo Edison letter, Serial No. 1043.

In a-parallel. effort, Toledo Edison is developing a Davis-Besse specific fire risk analysis. The fire risk analysis will be used to arrive at a prioritizied list (with respect to safety) of proposed fire related modi-fications. Toledo Edison intends to prioritize these modifications as a function'of their impact on risk reduction at Davis-Besse and resource requirements'(manpower and dollar).

In the first quarter- of 1985, Toledo Edison plans to prioritize the pro-posed modifications and revise the SLPW to show a realistic schedule for completing the proposed modifications. Due to the number and cost of modifications proposed, it is anticipated that it will take approximately three refueling cycles to complete necessary fire protection modifications.

- Thus, a completion date for modifications should be approximately at the end of'the 1989 refueling outage.

- Compensatory Measures Toledo Edison has taken specific steps to ensure that DB-1 can be operated in a manner to provide protection of plant equipment important to safe shutdown'and with no adverse effects to the health and safety of the pub--

lic. These steps are in addition to these taken in response to the audit findings as documented in the ARP submittal. NRC concurrence with the ade-quacy of those' compensatory measures was received-in the Restart Safety Evaluation dated September 23, 1983 (Log No. 1375). The additional mea-sures taken are discussed below:

, 1. Upon identification that Appendix R noncompliances existed for a particular fire area, an hourly fire patrol was estab-lished. Guidance was provided to ensure the maximum effec-4 tiveness of;the fire patrol's roving tours.

2. .Until proposed plant modifications can be completed, noncom-pliances to Sections.III.G and III.L of Appendix R, which currently exist at DB-1, will be addressed in plant safe shutdown procedures. Operator guidance necessary to address the potential fire damaged equipment for which' plant modifi-cations have not- yet been implemented will be incorporated into Item 4. The procedures may be revised removing such guidance upon implementation of each modification.

n

.y Docket No. 50-346 y  ; License No. NPF-3 Serial No. 1076 September 6, 1984.

Page 4 3 '. An effort will be initiated to evaluate the seriousness of

.noncompliances associated with each fire area.

~

This is being done independent of the fire risk analysis dis-

~

cussed under Scheduling, in order to evaluate the adequacy of the interim measures taken. Factors being utilized in the evaluation include:

combustible loading area (room)' fire protection features (i.e. suppression, detection) frequency of plant tours through areas extent of noncompliance interim measures taken impact of noncompliance on safe shutdown capability The results of this evaluation will determine if any additional compensatory measures are necessary for a specific fire area.

' Any such additional measures will be implemented as soon as possible.

4. sToledo Edison has. dedicated the resources necessary to develop and implement all procedural actions identified in this submit-tal. This will result in more areas achieving compliance with the requirements of Appendix R. With the completion of this efforr, a total of 21 areas will be in compliance with Section III G of Appendix R.- These procedures will be in place prior A

to completion of the 1984 refueling outage.

Toledo Edison continues to place a high priority on attaining full compli-ance to the requirements of Appendix R. Toward this end, +,he effort to implement the discussed modifications has been initiated. Additionally, other tasks not yet' completed, as. identified in our previous correspondence in response to the Appendix R audit, are receiving dedicated attention.

With regard to the CAR, a long term Appendix R compliance program is,evol-ving and is planned to be implemented in'1985. Upon implementation, a Revision 1s to this CAR is to be developed. The design documents utilized in the' development of this submittal are current through March 1, 1984. The

intent of the revision will be to ensure the performance of the Appendix R

. review on all implemented Facility Change Requests and drawing updates. This update of the Appendix R Compliance Assessment will automatically occur upon

~

implementation of the long term program. This revision is tentatively planned for 12-18 months from issuance of this submittal.

'As part of this revision process, the Fire Hazards Analysis will also be up-

-dated. All information concerning the description of fire areas, plant fire hazards, and fire protection features 'will be verified and consolidated into the FRAR. . All information with regard to Appendix R and specifically the

-systems required to meet the rule will remain in the CAR.

-Dn:ket N6. 50-346 License No..NPF-3

- ' - Serial No. 1076 September 6,'1984'

-Page:5 a

4 Through the development and performance of the Appendix R Compliance Assess-

. ment Program _ Toledo Edison's intent'has been to ensure the results of this

- review are accurate and'well defined. It is understood, however, that the specific method utilized to eliminate an Appendix R noncompliance may be

~ changed due.to.many different reasons. Toledo Edison will incorporate any

such changes'or final implementation decisions into Revision 1 to this re-port, which will be forwarded to your office.

Toledo Edison has determined that the nature of. the noncompliances, when reviewed considering the_-low probability of the fire, the fire protection

- features _ existing in the plant, and the compensatory measures instituted t or to be instituted, does not adversely effect the health and safety of the public.- Toledo Edison will continue its aggressive effort to resolve this issue.

Attached is a check for $4,350.00, for twenty-nine (29) exemptions at $150 per. exemption, per 10 CFR 170.12(c).

~

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- Very truly yours, gP hh

-RPC:JSH:nif-

- encl. (37 copies of CAR and check) cc: DB-1 NRC Resident Inspector Mr. Al DeAgazio,' NRR Project Manager (3 copies of CAR)

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.Dockat Ns. 50-346

. [ License.No.1NPF-3

' Serial No.:1076-

-4 Attachment 1:

~Page'l of 2-

.m TASKS TO BE SUBMITTED TO NRR'FOR REVIEW AND EVALUATION

. Task 1.. " Safe Shutdown Systems Identification Minimum systems,~ components, and circuits required for hot

-standby 'and for cold shutdown will be identified. Associ-ated' circuits whose. damage could affect shutdown capability as defined in Generic Letter 81-12 will be included.

- The systems,. components, and circuits identified will be located in the plant. " Fires will be postulated in each fire -

area / zone and the fire protection features for the systems, components, land circuits will be evaluated against the re-quirements of Appendix R,Section III.G.2.

Review of the isolation of' circuits between the Auriliary Shutdown Panel and.thh control room / cable spreading room will be included in~this task.

Task 2.. ' Fire Hazards Analysis Report (FHAR) - Appendix R Review

' Revision'6 'of the DB-1 FHAR will be reviewed against the requirements of 10 CFR 50 Appendix R, Sections III.G, J, 0,

- and L.. Revisions resulting 'from Task I will be incorporated

in- the FHAR. _ Feedback will be .provided to upgrade 'the in-terim procedures when information affecting the procedures becomes available.-

A generic review of'the' instrumentation will be performed to identify the extent of conformance to the alternative shut-

, down "apability requirements of Appendix R,Section III.L.

~ Recommendations concerning modifications and/or exemptions will be made.

(

I Task 3. Fire Hazards Analysis Report - Compatibility Review

. A review will be performed to ensure commitment compatibility

-between the DB-1 Fire Hazards Analysis Report (including refer-

!~ enced documents). the National Fire Protection Association Code, the Updated Safety Analysis Report (USAR), and the DB-1 Technical Specifications.

L -

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it Dock;t Nr. 50-346 License No. NPF-3

- Serial No. 1076~

Attachment 1 Page 2 of 2 Task 4*. Associated Circuit Analysis

- A review will'be performed of the TED 1975-1976 engineering inspection of channel separation at DB-1 to determine con-

~ sistency with'the guidelines provided in Appendix R Sections III.G and L, Generic Letter 81-12, and the clarification letter to the Generic Letter. Existing Toledo Edison analyses will be upgraded, as necessary, to meet the aforementioned guidelines.

• Task 5 in September 13, 1983 Audit Response submittal.

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TABLE 1-1 o!'y[p n.o.

AREA COWLIANCE NUMERICAL SUMARY "w g.

i l Procedural Compliance Physical Exemptions Alternate Shutdown

~((

I Fire i Existing i Modifications i Upon Completion l Modifications I to I to l Capability l l Area l Compliance l Required I of Procedures l Required l III.G.2 I III.G.3 Required l I I I I I I l A I No I Yes l No I Yes l X l X l Yes l I I I I I I I I B l No I Yes l No I Yes l l l l l l l l 1 I I I I l C l Yes l l l l l l

I I I I I I l l D l No I Yes l No lWalkdown requiredl l l l 1 l l l l l l ,

l E l No I Yes l Yes l No l I I I I I I I I l l l l l F i No I Yes l No l Yes l l l 8

I I I I I I I I l G l No l Yes l No l Yes I l X l Yes i l i l i l l I i l H l No I Yes l No l Yes I X 1 1

, I I I I I I I I l

I J l No l Yes I Yes l No l I ,

I i l l I I I I I ,

I i l X l No l Yes I Yes l No l I l Yes I i I I I I I I I I i I L I Yes l I I l l l 1

1 I I I I I l l ;I M Yes 1 2 .

ll P I No l Yes I ' No l Yes l I X l Yes l I I I I I I I I I l l Q l No l Yes l No I Yes l l X 1 Yes I

1 1 I I I I I I I j l R l No l Yes l No I Yes l I X l Yes i

i I I I I I I i l S l Na l Yes I Yes l No i l l I

I I I I I I I I .

I 4

l T I No I Yes l No l Yes l

• Yes l l l l l l l l 1 1 I I I I *Previously approved ,,,

. . ~. n TABLE 1-1 - w 4 f-. f. #

.(continued) o j. g " g .

rt *- O

• AREA COWLIANCE NUMERICAL SLNMARY " w g *,, g l .

Alternate -

Procedural Compliance l Physical Exemptions Shutdown

! I Fire l Existing l Modifications 1 Upon Completion l Modifications I to I to I Capability. 1-l Area l Compliance l Required I of Procedures l Required l III.G.2 l III.G.3 l Required I 1 I I I I I I I l l l U l No l Yes l No I Yes I. X l X l Yes I

I I I I I I I I I l V l No I Yes l No l Yes l X l l l

! I I I I I I I I I I W I Yes l l l l l l l I I I I I I I I I I

I X l No l Yes  ! Yes l No l l l 1 1 I I I I I I I 'l i Y I No I Yes I Yes i No l I I l I. I I I I I I I I l Z l Yes l l l l l l l l l l l l l l l l l AA I Yes l l l l l l l 2

I I I I l' I I I I i l AB I No l Yes l No l Yes l l l l 4

I I I I I I I I I I l AC l No I Yes I Yes l No I l l l i i 1 1 I I I I I I I I BB l Yes l I l l l l l i i i i i i l I i

! BD l Yes l l l l l l l 1 1 I I I I I I I i l BE I No l No N/A I Yes l I I i

i i l l l l l l l BF 1 No I No l N/A l Yes l l l l

{ l I i i l i l 1 1 1 II l Yes  ! I I I I I

! I I I I I I I I l-1 l CC I No l No l N/A l Yes l l l l

! I I I I I I I I I

! l DA l No I Yes l No l Yes I X l l l i l i i i l i I I I I I I I I I I

) 1 2 1

4

^ EN Yl C. ?

il 11 a R R-TABLE 1-1 " h 0 fji N (continued) Rgyp F AREA COWLIANCE NUMERICAL

SUMMARY

Ng g emw dK l i I - 1 I I I Alternate l l l l Procedural l Compliance I Physical l Exemptions l Shutdown l l Fire i Existing I Modifications l Upon Completion i Modifications I to I to I Capability i I Area l Compliance l Required I of Procedures l Required l III.G.2 I III.G.3 l Requirad 4 1 1 I I I I I I l l DB I No l Yes i No I Yes l l l l l l l l l 1 I I l l DC 1 Yes l l l l l l l 1 I I I I I I I I l DD l No l Yes l No I Yes l l l Yes l I I I I I I I .

I DE I No I Yes l Yes l No I I l l I  ! I I I I I I I l l DF l No l Yes l No l Yes I l X l Yes  !

1 I I I I I I I I l

l DG l Yes  ! I I l l l l 1 I I I I I I I 1

I DH I No I Yes i No I Yes l l l .

I I I I I I I I I DJ l No l Yes l No l Yes l l l Yes l I I I I I I I I I

I EE l No I Yes l No I Yes I l X l Yes l I I I I i i Yes

• Yes 1 FF l No l Yes l No l l 1 I i I I I I I I I I HA I Na l Yes l No l Yes l I I  !

I I I I I I I I I

l HH I No l Yes l No l Yes l I X l Yes I I I I I I I l

I UU l Yes l l l l l l l l l BM l No l Yes l No l Yes l l l l l 1 l l BN l No l Yes j Yes i No l I I I I i l I i i I I I I I I l I

• Prsviously approved 1 3

Docht No. 346 Licenen No. NPF-3

.Ssrial No. 1076 Attachment 3 TABLE 1-2 Page 1 of 4 LIST OF EXEMPTION REQUESTS Section Appendix R l Reference l Exemption Statement I Reference l l l- 1 I l 2.5.1 ISecurity modifications to Fire Doors 320, 321, 1 III.G.2 l l 1322, 323, 332, 427, 428 and 605 l l l l l l l 2.5.2 lNon Fire Rated Doors 601 and 602 l III.G 2 I I I I 2.5.3 lNon-rated openings with no fire dampers in the i III.G.2 l l l Auxiliary Feedwater (AFW) Pump Rooms l l l l(237 and 238, FireAreas E and F). l l l l l l l 2.5.4 IInterconnected opening between Fire Area G l III.G.2 l l(Passage 227) and Fire Area H (Corridor 209 l l land Passage above Fuel Transfer Tubes). l l l l l l l 2.5.5 1,Non-rated barrier in Corridor 304 located in l III.G.2 l l l Fire Area V separating Corridor 209, Fire Area HI l l (non fire-rated hatchway located in floor slab).I I I I I I I 2.5.6 l Redundant passive components (Decay Heat L III.G.2 l l Coolers) in Decay Heat Cooler Room 113 are not l l l l separated by a 3-hour fire-rated barrier. l l l l Non-rated openings in Passageway 227, Fire III.G.2 l 2.5.7 l l l Area G separating Passageway 110A in Fire 1 l l l Area A (non fire-rated steel plates and l l l Igrating located in passageway to provide l l l lequipment removal and facilitate ventilation). l l 1 1 I I I 2.5.8 INon-rated barrier in Clean Waste Receiver Tank l III.G.2 l l Room 123, located in Fire Area A separating the l l l Boric Acid Addition Tank Room 240, Demineral- l l l lizer Room 233, and the Boric Acid Evaporator I l l IRoom 234, which are located in Fire Area G. I I I I I I l 2.5.9 lNon-rated hatch in Room 428, Fire Area / Zone X-1 l III.G.2 l l l communicates with Room 322, Fire Area / Zone P-1 l l l llocated in the Elevation 603' floor slab. l l l 1 1 I l' 2.5.10 lNon-rated openings in the South wall of the l III.G.2 l I l Auxiliary Feedwater Pump Rooms, which interface l l l lwith Clean Waste Receiver Tank Rocm 124. l l l l 1 I I I I I 1-2-1

,Docket No. 50-346~-

License No. NPF-3 Serial No. 1076

. Attachment 3 TABLE 1-2 Page 2. of - 4 (continued)

.c LIST OF EXEMPTION REQUESTS I l Section l Appendix R l Reference l Exemption Statement l Reference l I i l I.. .2.5.11 INon-rated opening where the Emergency Ventila- l III.G.2 l l Ition System (EVS) and its associated duct l l l l work pass through 3-hour fire-rated floor slabs l l l ;and ceilings, not containing 3-hour rated fire l I l  : dampers. I I l l I I 2.5.12 ;Non-rated openings where the Containment Purge l III.G.2 l l l Exhaust System ducts pass through 3-hour fire- l l l Irated floor slabs and ceilings, not containing l l

'- l 13-hour rated fire dampers. I l l l l 4.2.3 -I An exemption is requested from the requirement l III.G.2 l Ito have a three hour barrier separating l l

. Iredundant trains for all embedded conduit. l l

I I I 4.6.1 lExemption is requested from the requirement to l III.G.2 1 4

l(Fire Area A)lhave full (in lieu of partial) area suppression,I I l l' zonal suppression exists over required ll

, I l components / circuits when accrediting 20 feet l separation with suppression, detection and low l

I lintervening combustibles. l I l l I 1 4

l l Exemption is requested from 20 feet separation l III.G.2 l l l l(16 feet horizontal separation exists) require- l ' l l Iment for Cable Trays 2 CEC, 2CEE, and 2CEF in  ; i 1 room 124 , I l .

l l l l Exemption is requested from the requirement to l III.G.3 l have full area suppression and detection in the l l area of consideration for the alternative l l l lshutdown capability utilizing the mechanical SG l l l l l l l pressure gauges. l l l 4.6.7 l Exemption is requested from the requirement to l III.G.3 I j l(Fire Area G)lhave full area automatic suppression and l l l l detection in the area of consideration due to l l 1 l lthe alternative shutdown actions for manually l l l l positioning valve MS107 (not located in this l l I l fire area). 1 l l l l l

.I l l l t

1-2-2

Dockst No. 50-346 License No. NPF-3 S rial No. 1076 '

. Attachment 3 TABLE 1-2

.Page 3 of 4 (continued)_

LIST OF EXEMPTION REQUESTS Section Appendix R l Reference l Exemption Statement l Reference I I I I I l 4.6.8 IExemption is requested from the requirement to l III.G.2 l l(Fire Area H)lhave full area suppression and detection in the 1 l l area covering Conduit 27671C (Circuit 1CBE1157J)l l l .which will be wrapped with a one-hour barrier. I I I I I I l 4.6.13 l Exemption is requested from the requirement to l III.G.3 l l(Fire Area P)lhave full area automatic suppression and l l l l detection in the area of consideration due to l l l Ithe alternative shutdown actions for manually l l l l positioning damper MV5314 (not located in this l l 4

l Ifire area). l l 1 1 I I III.G.3 l 4.6.14 IExemption is requested from the requirement to l(Fire Area Q)lhave full area automatic suppression and l l detection in the area of consideration due to l l l Ithe alternative shutdown actions for manually l l l lpositionin I l l

Ifire area)g damper MV5597 (not located in this

. l l l l l l 4.6.15 l Exemption is requested from the requirement to III.G.3 l

, l(Fire Area R)lhave full area suppression and detection in the l l l larea of consideration for the alternative i l l lshutdown capability utilizing the mechanical SG l l l l pressure gauges. l l l 1 1 I l 4.6.18 lExemption is requested from the requirement to l III.G.2 l l(Fire Area U)lhave full (in lieu of partial) area suppression i l l l(zonal suppression exists over circuits and/or l l l Icomponents requiring protection) with a one-hourl l l l wrap on the required trays and zonal detection l I l l(instead of full area detection). l l l l l l III.G.3 ll l Exemption is requested from the requirement to l L lhave full area automatic suppression and l l detection in the area of consideration due to l l ll Ithe alternative shutdown actions for providing l l

[ Iguidelines to install temporary ventilation l l l land perform damper positioning as necessary in l l l lthe CCW Pump Room. I l 1 I I I I l l l 1-2-3

Doclet No. 50-346 License No. NPF-3

.Sarigl No. 1076

• Attachment 3 TABLE 1-2 Page 4 of 4 (continued)

LIST OF EXEMPTION REQUESTS s Section Appendix R Reference l Exemption Statement i Reference l I I l l ~ 4.6.19 l Exemption is requested from the' requirement to l III.G.2 I l(Fire Area V)lhave full (in lieu of partial) area suppression l l l l(zonal suppression exists over circuits and/or l l l l components requiring protection) with a one-hourl l l  ; wrap on the required trays and zonal detection. l l l l An exemption for spatial separation less than l l l 120 feet for one circuit is also included. l I I I I I 4.6.33 Exemption is requested from the requirement to l III.G.2 l (Fire Area DA) ihave automatic suppression in this fire area l l lldue to in excess of 100 feet of horizontal l I lseparation with no intervening combustibles. l l l l l 1 4.6.38 l Exemption is requested from the requirement to l III.G.3 l l (Fire Area DF)lhave full area suppression in the area of I l l l consideration for the alternative shutdown l l l l guidelines to manually de-energize and position l l l l valve MS106 (MS106 is not located in this l l l area).

I 4.6.42 l Exemption is requested from the requirement to III.G.3 (Fire Area EE)lhave full area autcmatic suppression and idetection in the area of consideration due to l l l Ithe alternative shutdown actions for manually l l l l l l l

l positioning valve MS106. l l l 4.6.45 l Exemption is requested from the requirement to l III.G.3 l l(Fire Area HH)lhave area suppression in the area of considera- l l l ltion due to the alternative shutdown actions forl I l ll alternative temporary ventilation installation. l l l 1 1 I l 6.5 l Exemption is sought from the requirement to relyl III.J l l l solely upon eight-hour battery powered emergencyl l l 111ghting units in all areas needed for operationl l l lof safe shutdown equipment and in access and l l legress routes thereto, based upon the existence I land availability of the AC and DC essential l l

l 11ighting. l l l l l l 1 I I 4

4 1-2-4

-. . .-.- ._ - _,.-_-- - -.- -_.. - .---. - -. - -