ML20100M212

Forwards Fire Damper Evaluation for App R Compliance & List of Dampers Not Required to Enhance Fire Protection. Requests Exemption from Requirements of Section III.G.2 of App R to 10CFR50

ML20100M212
Person / Time
Site:	FitzPatrick
Issue date:	04/12/1985
From:	Bayne J POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:	Vassallo D Office of Nuclear Reactor Regulation
Shared Package
ML20100M215	List: ML20100M212
References
JPN-85-28, NUDOCS 8504170358
Download: ML20100M212 (3)

Text

e- 123 Main Stmet White Plains, New Wrk 10601

- 914 681.6800 M Of $s"t@cutTvice president

& Authority " o "o" o"*'

April 12, 1985 JPN-85-28 Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Mr. Domenic B. Vassallo Operating Reactors Branch No. 2 Division of Licensing

Subject:

James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 Appendix R to 10 CPR 50 Exemption Request for Fire Dampers Not '

Required to Enhance Fire Protection

Dear Sir:

As a part of the Authority's program to implement the requirements of Appendix R to 10 CFR 50 we have conducted many analyses and evaluations of both existing and new fire protection measures at the FitzPatrick plant. The Authority also retained a fire protection consultant to conduct an independent review and assessment of our plans to implement the requirements of Appendix R.

As a result of these efforts, the Authority has recently identified

~

seventeen dampers that are not required because they will not enhance fire protection at FitzPatrick. A list of theae dampers and their locations is included as Attachment No. 1.

The Authority has prepared a report (Attachment No. 2) to justify the elimination of these dampers. This report was prepared by a qualified fire protection' engineer.

The basis for not requiring these dampers can be categorized as one or more of the following: (1) the damper would be installed in a fire-rated wall or barrier which has been derated based upon low combustible floor loading and resulting low fire severity; (2) fire dampers are not required in one hour barriers: (Tests have shown that sheetmetal ductwork penetrating a one hour barrier is effective in preventing the spread of fire.): or, (3) fire rated barriers >

separating fire areas that contain components of the same division are not required, h

F Df ' )CD

\ \

l

The Authority has carefully reviewed the requirements of Appendix R as they relate to these seventeen dampers. Fifteen of the seventeen dampers would be necessary to conform to the requirements of Appendix R without the approval of this exemption request these dampers are marked with an asterisk on Attachment No. 1. The remaining two dampers are not required to comply with Appendix R.

Based upon these analyses, the Authority hereby requests an exemption from the requirements of Section III.G.2 of Appendix R to 10 CFR 50 in accordance with the provisions of 10 CFR 50.12, to the extent that these fifteen dampers are required.

The Authority will develop administrative controls to limit the installation of permanent combustibles and the storage of transient combustibles to the amounts assumed in these analyses.

In accordance with 10 CFR 170, a check in the amount of $150.00 is included with this exemption request as the application fee. The Authority pays the fee under protest pending a final determination of the legality of the fee schedule.

If you have any questions regarding this exemption request or the associated evaluations, please contact Mr. J. A. Gray, Jr. of my staff.

Very truly yourn,

,[ T E J. P. Bayne I First Executive Vipe President Chief Operations Officer cc: U.S. Nuclear Regulatory Commission Office of the Resident Inspector P.O. Box 136 Lycoming New York 13093 l

4 ATTACHMENT NO. 1 TO JPN-8 5-2 8 New York Power Authority James A. FitzPatrick Nuclear Power Plant Danders Not Required to Enhance Fire Protection Damper Identifi-Item No. cation No. (Note 2) Location (Note 1)

1. 67FD-1 Between fire zones SW-1 and CT-1.

2. 67FD-4

• Between fire zones SW-1 and TB-1.

3. 67FD-5

• Between fire zones SW-1 and TB-1.

4. 67FD-6

• Betweer. fire zones SW-1 and TB-1.

5. 67FD-7

• Between fire zones SW-1 and TB-1.

6. 67FD-8

• Between fire zones SW-1 and TB-1.

7. 67FD-9 Between fire zones SW-2 and CT-2.

8. 67FD-12

• Between fire zones SW-2 and TB-1.

9. 67FD-13

• Between fire zones SW-2 and TB-1.

10. 67FD-14

• Between fire zones SW-1 and SW-2.

11. 72FD-3

• Between fire zones BR-1 and BR-4.

12. 72FD-4

• Between fire zones BR-1 and BR-4.

13. 72FD-5

• Between fire zones BR-4 and BR-5.

14. 72FD-6

• Between fire zones BR-1 and BR-4.

15. 73FD-1

• Between fire zones SP-1 and SH-1, 16, 73FD-2

• Between fire zones SP-2 and SH-1.

17. 73FD-3

• Between fire zones SP-2 and SH-1.

Notes: 1. Fire Zones are defined in Figures 4.1 through 4.11 of

"A Reassessment of the James A. FitzPatrick Nuclear Power

Plant for Conformance to.the requirements of Appendix R to 10 CFR 50", dated July 13, 1982, as amended. Attached to NYPA letter, J.P. Bayne to H.R. Denton, (JPN-82-61) dated July 13, 1982.

2. Fire dampers that would be required for conformance with

Appendix R if this exemption request is not approved have 4

been marked with an asterisk (*).

t

!