ML20141D281
| ML20141D281 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 03/24/1986 |
| From: | Bernero R Office of Nuclear Reactor Regulation |
| To: | GENERAL PUBLIC UTILITIES CORP., JERSEY CENTRAL POWER & LIGHT CO. |
| Shared Package | |
| ML20141D284 | List: |
| References | |
| NUDOCS 8604070468 | |
| Download: ML20141D281 (20) | |
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7590-01 A
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION I
In the Matter of N
4 GPU NUCLEAR CORPORATION AND Docket No. 50-219 JERSEY CENTRAL POWER & LIGHT COMPANY Oystes Creek Nuclear Generating
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Station
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EXEMPTION I.
The GPU Nuclear Corporation (the licensee), et al., is the holder of Provisional Operating License No. OPR-16 which authorizes operation of the Oyster Creek Nuclear Generating Station. The license provides, among other things, that it is subject to all rules, regulations and Orders of the Commission now or hereafter in effect.
The Oyster Creek Station power source is a boiling water reactor located at the licensee's site in Ocean County, New Jersey.
II.
On November 19, 1980, the Commission published a revised Section 10 CFR 50.48 and a new Appendix R to 10 CFR Part 50 regarding fire protection features of nuclear power plants (45 FR 76602). The revised Section 50.48 and Appendix R became effective on February 17, 1981.Section III of Appendix R contains fifteen subsections, lettered A through 0, each of which specifies requirements for a particular aspect of the fire protection features at a nuclear power plant.
One of these fifteen subsections, III.G., is the s.ubject.of this exemption request. Specifically, Subsection III.G.2 requires that one train of' cables and equipment necessary to achieve and maintain safe shutdown be maintained free of fire damage by one of the following means:
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a.
Separation of cables and equipment and associated non-safety circuits of redundant trains by a fire barrier havin9 a 3-hour rating. Structural steel formino a part of or supporting such fire barriers shall be protected to nrovide fire resistance eauivalent to that required of the barrier; b.
Separation of cables and equipment and associated non-safety circuits or redundant trains by a horizontal distance of more than 20 feet with no intervening combustibles or fire hazards.
In addition, fire detectors and an automatic fire suporession systen shall he installed in the fire r.rea; or c.
Enclosure of cables and eouipment and associated non-safety circuits of one redundant train in a fire barrier having a 1-hour ratino.
In addition, fire detectors and an automatic fire suporession system shall be installed in the fire area.
III.
By letter dated April 3, 1985, as supplemented by letters dated July I?
and October 9,1985, the licensee reauested seven exemptions for thirteen fire areas from the requirements of Section III.G of Appendix R, to the extent that f
it requires physical separation and/or fire protection systems to protect redundant trains of safe shutdown related cable and eautoment. The April 3, 1985, submittal superseded the licensee's letters dated December 16, 1983, and February 13 and May 3, 1984.
In the meeting summary dated February 28, 1986, thelicenseep[8vided information relevant to the "special circumstances" findina required by revised 10 CFR 50.1?(a) (See 50 Fed. Req. 50764). The licensee stated that I
L 7590-01 3-existing and proposed fire protection features at Oyster Creek accomplish the underlying purpose of the rule.
Implementing additional modifications to provide additional suppression systems, detection systems, and fire barriers would require the expenditure of engineering and construction resources as well as the associated capital costs which would represent an unwarranted burden on the licensee's resources. The licensee stated that the costs to be incurred are as follows:
Engineering and installation of additional piping, sprinkler heads, and suppor ting structures.
Engineering and installation of fire barriers, supports, support protection, and ongoing maintenance.
Significant rerouting of high power cabling and associated ctaits, ducts, and supports.
Possible need to provide additional fire pumos and/or diesel generator capacity.
Increased surveillance on new or extended fire suppression and fire detection systems.
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Increased congestion in numerous plant locations complicating future plant modifications / operation.
The ifcensee stated that these costs are significantly in excess of those required to meet the underlying purpose of the rule. The. staff concludes that l
"special circumstances" exist for the licensee's requested exemptions'in that application of the regulation in these particular circumstanceh is not necessary to achieve the underlying purposes of Appendix R to'10 CFR Part 50.
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,. The licensee's request for seven exemptions (thirteen fire areas) was reduced to four exemptions (eight fire areas) because the staff concluded that three exemptions (five areas) were not needed. The acceptability of the exemption requests for each of the eight fire areas is addressed below.
Details are contained in the NRC staff's related Safety Evaluation.
The fire areas related to the four exemptions addressed herein are:
(1) Reactor Building Elevation 51 feet (Fire Area RB-FZ-1D)
(2) Reactor Building Elevation 23 feet (Fire Area RB-FZ-1E) (1 of 2 exemptions)
(3) Reactor Building Elevation (-) 19 feet (Fire Area RB-FZ-1F)
(4) Turbine Building Lube Oil Area (Fire Area TB-FZ-11B)
(5) Turbine Building Basement Floor-South End (Fire Area TB-FZ-110)
(6) Turbine Building Condenser Bay (Fire Area TB-FZ-11E)
(7) Turbine Building Basement & Mezzanine (Fire Area TB-FZ-11H)
(8) Office Building - 480V Switchgear Room (Fire Area 08-FA-6B)
(1 of 2 exemptions)
Based on our evaluation, we concluded that the three exerr.ptions requested for the following areas are not needed:
(9) Reactor Building Elevation 23 feet (Fire Area RB-FZ-1E) (1 of 2 exemptions)
(10) Office Building - 480V Switchgear Room (Fire Area 0B-FA-6B) (1 of 2 exemptions)
(11) Office Building - Motor Generator Set Room (Fire Area 08-FA-8A)
. (12/13) Office Building - Battery & Electrical Tray Room (Fire Area dB-FZ-8C)
(2 exemptions)
1 7590-01 L Exemption 1 (Fire Areas RB-FZ-10, IE and 1F and Fire Area 08-FA-6B)
The licensee requested an exemption from the technical requirements of Section III.G of Appendix R in each of these areas to the extent that it requires the installation of an area-wide automatic fire suppression system.
Discussion (Fire Area RB-FZ-ID)
This area is bounded by walls, floor and ceiling of reinforced concrete.
However, this portion of the Reactor Building communicates, via unprotected openings, with other plant locations which the licensee has designated as separate fire areas. These penetrations are delineated in Appendix E of the licensee's April 3,1985 report.
This fire area contains electrical circuits for hot shutdown paths 1, 2, 3, and 4 and for cold shutdown paths 1, 2 and 3 as defined in the above-referenced report.
For a fire in this area, hot shutdown is achieved using systems from path 1 and cold shutdown is achieved using path 3.
All required hot sh.tdown path 1 systems that are located in this area are protected by a 1-hour fire-rated barrier. Cold shutdown path 3 systems in this area that would be damaged in a fire can either be repaired within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or an alternate means of achieving shutdown exists outside of this fire area via manual operation of certain valves.
The fire loading in this area has been calculated to be 12,500 BTU /sq.ft.
which corresponds to a fire severity of less than 10 minutes as determined by the ASTM E-119 time-temperature curve.
Existingfireprotectionincludesanarea-widefiredetectionsy$ tem;two fixed, water spray deluge systems which cover cables in trays;, portable fire extinguishers and manual hose stations. The licensee,has committed
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,. to reroute certain safe shutdown-related circuits outside of this fire area and to protect others in a 1-hour fire barrier as delineated in the April 3, 1985 fire hazards analysis report.
Discussion (Fire Area RB-FZ-1E)
This area is bounded by walls, floor and ceiling of reinforced concrete, which contain unprotected openings into adjoining plant locations, that the licensee has identified as separate fire areas, as delineated L. the April 3, 1985 report.
This fire area contains electrical circuits for hot shutdown paths 1, 2, 3 and 4 and for cold shutdown paths 1, 2 and 3 as defined in the above-referenced report. For a fire in this area, hot shutdown is achieved using shutdown path 1 and cold shutdown using path 3.
With the exception of the reactor scram system circuitry, all required hot shutdown path 1 systems that would be damaged by a fire in this area are protected by a 1-hour fire barrier. Cold shutdown path 3 systems in this area that would be subject to fire damage can either be repaired within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or an alternate means of achieving safe shutdown exists outside of this fire area by manual operation of certain valves.
The fire loading in this area has been calculated to be 20,000 BTU /sq.ft.
which corresponds to a fire severity of less than 16 minutes as determined by the ASTM E-119 time-temperature curve.
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, Existing fire protection includes an area-wide fire detection system, two fixed, water spray deluge systems which cover cables in trays; portable fire extinguishers and manual hose stations. The licensee has committed to re-route certain safe-shutdown-related circuits outside of this fire area and to protect others in a 1-hour fire barrier as delineated in the April 3,1985 report.
Discussion (Fire Area RB-FZ-1F)
This area is bounded by walls, floor and ceiling of reinforced concrete which contain unprotected openings into an adjoining plant location that the licensee has identified as a separate fire area.
This fire area contains electrical circuits for hot shutdown paths 1, 2, 3, and 4 and for cold shutdown paths 1, 2, and 3 as defined in the April 3, 1985 report.
Fce a fire in this area, hot shutdown is achieved using shutdown path 1 and cold shutdown using path 1.
All required hot shutdown systems that would be damaged by a fire in this area are protected by a 1-hour fire barrier.
If cold shutdown path 3 systems were lost in a fire, an alternate i
means of achieving safe shutdown exists which is independent of this fire area.
The fire loading in this area has been calculated to be 1,500 BTU /sq. ft.
which corresponds to a fire severity of less than 2 minutes as determined by the ASTM E-119 time-temperature curve.
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4 Existing fire protection includes an automatic fire detection system; portable fire extinguishers and manual hose stations. The licensee has committed to reroute certain safe shutdown circuits outside of this fire area and to protect others in a 1-hour fire barrier as delineated in the April 3, 1985 report.
Discussion (Fire Area 08-FA-68)
This fire area is bounded by walls, floor and ceiling of 3-hour fire-rated construction except for the 1-hour rated wall common with adjacent fire area 08-FA-6A.
In the event of a fire in this location, hot and cold shutdown will be achieved using shutdown path 2.
The required shutdown-related cables are either protected by a 1-hour fire barrier or an alternate means for achieving safe-shutdown is available outside of this area.
The fire load has been calculated to be 71,000 BTU /sq. ft which represents a fire severity of less than 1-hour as determined by the ASTM E-119 time-temperature curve.
Existing fire protection includes an area-wide fire detection system; an automatic halon fire suppression system for the switchgear room portion of this fire area; portable fire extinguishers and manual hose stations.
In the April 3,1985 report, the licensee proposed to make structural, ventilation system and halon system modifications to isolate this fire area from adjacent plant locations; to reroute certain shutdown related cables and to protect others in a 1-hour fire-rated barrier.
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f 7590-01 l The licensee justified the exemptions in these four areas on the basis of the low fire loading, the existing fire protection and the proposed modifications.
Evaluation The technical requirements of Section III.G.2 are not met in these locations because of the absence of an area-wide automatic fire suppression system.
In addition,Section III.G.3 is not met because of the absence of an area-wide, fixed, fire suppression system in a location where an alternate shutdown capability has been provided.
Our principal concern was that in the event of a fire the absence of an area-wide automatic fire suppression system would result in loss of all shutdown capability. However, the fire load in these areas is low, with combustible material generally dispersed. Where concentrated quantities of combustible cable insulation exists, the cables are protected by a deluge system.
All of these areas are protected by a fire detection system.
If a fire should occur, the staff has determined that it will be detected in its incipient stages, before significant propagation occurred. The fire would then be put out by the plant fire brigade using the portable fire extinguishers and manual hose stations.
If rapid reon temperature rise occurred before the arrival of the brigade, existing fire suppression systems will actuate to limit fire spread, to protect the cables covered by the systems and to reduce, room temperature.
Until the arrival of the brigade and eventual fire suppression, the 1-hour fire
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.. barriers installed to protect one shutdown pathway provides sufficient passive fire protection to provide us with reasonable assurance that those systems would remain free of fire damage. For those redundant shutdown systems that are not similarly protected, the licensee has identified an alternate capability that is physically and electrically independent of these fire areas.
For certain cold shutdown systems that might be lost in a fire, the licensee has repair procedures with materials on site, that will enable these systems to be restored to operable condition within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Therefore, the absence of area-wide fire suppression systems is not necessary to provide reasonable assurance that safe-shutdown conditions can be achieved and maintained.
Based on our evaluation, we conclude that the licensee's alternate fire protection configuration with the proposed modifications, will achieve an acceptable level of fire protection equivalent to that required by Sections III.G.2 and III.G.3. Therefore, the licensee's request for exemption from an area-wide fire suppression system in the following areas should be granted:
Reactor Building Elevation 51 feet (Fire Area RB-FZ-1D)
Reactor Building Elevation 23 feet (Fire Area RB-FZ-1E)
Reactor Building Elevation (-) 19 feet (Fire Area RB-FZ-1F)
Office Building-480V Switchgear Room (Fire Area 0B-FA-6B) 4
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7590-01
. Exemption 2 (Fire Areas TB-FZ-11B and TB-FZ-11H)
The licensee requested an exemption from the technical requirement of Section III.G.2 of Appendix R in these two areas to the extent that it requires that redundant shutdown circuits in a pit area be separated by a 3-hour fire barrier.
Discussion (Fire Area TB-FZ-11B)
This area is bounded by masonry walls, floor and ceiling. However, this portion of the Turbine Building communicates, via unprotected openings, with other plant areas that the licensee has identified as separate fire creas. These penetrations are delineated in Appendix E of the licensee's April 3,1985 report.
This fire area contains electrical circuits for hot shutdown paths 1, 2, 3, and 4 and cold shutdown paths 1, 2, and 3 as defined in the April 3, 1985 report.
For a fire in this area, hot shutdown is achieved using hot shutdown path 1, with isolation condenser system "A" instead of "B".
Cold shutdown is achieved using path 1.
Redundant shutdown-related circuits are located in a pit area where separation per the requirements of Section III.G.2 is not achieved.
The fire load in this area has been calculated to be approximately 586,000 BTU /sq. ft., which represents a fire severity of approximately 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> as determined by the ASTM E-119 time-temperature curve. The principal combustible material consists of turbine lube oil and cable insulation; 9
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. Existing fire protection includes a fire detection system, an automatic sprinkler system over cable trays; water spray systems for the lube oil storage tank; a sprinkler system for the bearing lift pumps; portable fire extinguishers and manual hose stations.
In the April 3, 1985 report, the licensee committed to reroute certain safe shutdown circuits outside of this fire area. The licensee also committed to fill the pit area where vulnerable shutdown-related cables are located with sand or with a fire-rated silicon foam.
Discussion (TB-FZ-11H)
This area is bounded by reinforced concrete walls, floor and ceiling.
However, this portion of the Turbine Building communicates, via unprotected openings, with other plant locations that the licensee has identified as separate fire areas.
This fire area contains electrical circuits for hot shutdown paths 1, 2, 3, and 4 and cold shutdown paths 1, 2, and 3 as defined in the April 3, 1985 report. For a fire in this area, hot and cold shutdown will be achieved using shutdown path 2.
Shutdown path 2 circuits are located in a pit area where separation per the requirements of Section III.G.2 is not achieved.
There are no in-situ fire hazards in this location. The fire load as calculated by the licensee is negligible.
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. l Existing fire protection includes portable fire extinguishers and manual hose stations. The licensee connitted to fill the pit area where vulnerable shutdown cables are located with sand or with a fire-rated silicon foam.
The licensee justified the exemptions in these locations on the basis that the fire hazard-in the pits is negligible.
Also, the fire hazard in the area around the pit is either negligible or mitigated by fire suppression systems. The licensee also justified these exemptions on the ability of the sand or silicon foam to prevent fire damage to redundant cables where they are vulnerable.
Evaluation The technical requirements of Section III.G.2 are not met in this area because redundant shutdown-related cables are not separated by a 3-heur barrier within the pit area.
Our concern was that because of the lack of adequate physical separation, the cables in these pits would be vulnerable to fire damage.
However, because the pits are located in the floor and because products of combustion rise in a fire, we do not expect a fire outside the pit to have any significant affect on the cables within the pit. Also, because the pit area will be filled with sand or a fire-rated silicon foam, we have reasonable assurance that a fire will not originate within it or that a possible flammable liquid spill would affect the cables.
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. Based on our evaluation, we conclude that the licensee's alternate fire protection configuration with the proposed modifications will achieve an acceptable level of fire protection equivalent to that provided by Section III.G.2. Therefore, the licensee's request for exemption from a 3-hour fire barrier in the following locations should be granted:
Turbine Building Lube Oil Area (Fire Area TB-FZ-118)
Turbine Building Basement & Mezzanine (Fire Area TB-FZ-11H)
Exemption 3 (Fire Area TB-FZ-11D)
The licensee requested an exemption from the technical requirements of Section III.G.2 of Appendix R to the extent that it requires an area-wide automatic fire detection and suppression system.
Discussion This area is bounded by walls, floor and ceiling of reinforced concrete.
However, this portion of the Turbine Building communicates,'through unprotected openings, with adjoining plant locations that the licensee has identified as separate fire areas. These penetrations are delineated in the licensee's April 3, 1985 report.
This fire area contains electrical circuits for hot shutdown paths 1, 2, 3, and 4 and for cold shutdown paths 1, 2, and 3 as described in the above-referenced report.
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. For a fire in this area both hot and cold shutdown is achieved using shutdown path 1.
All required path 1 shutdown-related circuits are either protected by a 1-hour fire-rated barrier or the licensee has identified an alternate means which is independent of this area to safely shut down the plant.
The fire load in this location has been calculated to be 12,400 BTU /sq.ft.,
which represents a fire severity of less than 10 minutes.
Existing fire protection includes an automatic sprinkler system which protects cables in trays; a water spray system which covers the hydrogen seal oil unit; portable fire extinguishers and manual hose stations.
In the April 3,1985_ report, the licensee committed to relocate certain shutdown-related cables and to protect others in a 1-hour fire-rated barrier.
The licensee justifies this exemption on the basis of the low fire loading, i
existing fire protection and proposed modifications.
Evaluation l
The technical requirements of Section III.G. are not net in this area because l
of the absence of area-wide fire detection and suppression systems.Section III.G.3 is not met because a fixed fire detection and suppression system has not been provided for circuits for which an alternate shutdown capability l
has been provided.
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n We were concerned that because this area was not protected by an area-wide fire detection and suppression system a fire would damage redunda.it shutdown systems. However, the fire load is low with combustible materials generally dispersed. Where concentrated quantities of combustible materials exist, such as in cable trays and_the hydrogen seal oil unit, these combustibles are protected by an automatic fire suppression system. Where no concentrated combustibles exist, we expect a fire in those locations to be of initially limited magnitude and extent. Upon discovery by plant operators, the fire brigade would be dispatched and would put out the fire using existing manual fire fighting equipment.
If the fire occurred in the cable trays or in the seal oil unit, we expect the fire stporession systems to actuate and control fire spread. Until the arrival of the fire brigade and eventual fire extin-guishment, those required shutdown systems that are vulnerable to fire damage in this area are protected by a 1-hour fire barrier. Therefore, an area-wide fire detection and suppression system is not necessary to provide reasonable assurance that safe shutdown could be achieved and maintained.
Based en our evaluation, we conclude that the licensee's alternate fire l
protection configuration with the proposed modifications will achieve l
an acceptable level 6f fire protection equivalent to that required by Sections III.G.2 and III.G.3. Therefore, the licensee's request for exemption from an area-wide fire detection and suppression system in the Turbine Building l
Basement Floor-South End (Fire Area TB-FZ-11D) should be granted.
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' Exemption 4 (Fire Area TB-FZ-11E)
The licensee requested an exemption from the technical requirements of Section III.G.3 of Appendix R to the extent that it requires a fixed fire detection system in an area for which an alternate shutdown capability has been provided.
Discussion The area is bounded by reinforced concrete walls, floor and ceiling.
However, this portion of the Turbine Building communicates, through unprotected openings, with other plant locations that the licensee has identified as separate fire areas.
This fire area contains electrical circuits for hot shutdown paths 1, 2, 3 and 4 and for cold shutdown paths 1, 2, and 3 as defined in the licensee's April 3, 1985 report.
For a fire in this area, hot and cold shutdown is achieved using shutdown path 1.
For those required shutdown path I systems that are located in this area and may be damaged by a fire, the licensee has provided an alternate capability that is physically and electrically independent of this fire area.
The fire load in this location has been calculated to be 8,100 BTV/sq. ft.,
which represents a fire severity of less than 7 minutes.
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Existing fire protection includes an automatic sprinkler system located throughout the condenser bay; portable fire extinguishers and manual hose stations.
In the April 3, 1985 report, the licensee committed to reroute certain shutdown-related circuits outside of this fire area.
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. The licensee justified the exemption on the bases of the low fire load, the existing fire protection, the proposed modifications and the ability to safely shut down the plant if a fire should occur in this area.
Evals: tion The technical requirements of Section III.G.3 are not met in this area because of the absence of a fire detection systems.
We were concerned that if a fire shculd occur, products of combustion would spread into adjoining fire areas and damage systems that would be necessary to safely shut down the plant. However, the fire load in this location is low. Combustible materialc are dispersed throughout the area. We, therefore, expect a potential fire to develop slowly with initially low heat buildup and smcke generation. Upon discover;y of the fire, the plant fire brigade would respond and extinguish it using manual fire fighting equipment, If the fire increased in intensity prior to the arrival of the brigade, we expect the autcmatic sprinkler system to actuate to control the fire, to liinit room temperature rise and to protect the thutdown systems that may be threatened.
If redundant shutdown systems were damaged within this location, an alternate shutdown capability exists that is outside this fire ares, Recause some of the walls and the ceiling contain unprotected openings we ev.pect some smoke to propagate into adjoining fire areas. But because of the automatic sprinkler
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_ 19 system in this area and the low fire loadino, we conclude that the annunt of smoke would not represent a significant threat to shutdown systems in the adjoining fire area. We, therefore, conclude that the absence of a smoke detector system in this area has no safety sinnificance.
Based on nur evaluation, we conclude that the licensee's alternate fire protection configuration with the proposed modifications, will achieve an acceptable level of fire protection equivalent to that required by Sections III.G.2 and III.G.3.
Therefore, the licensee's request for exemotion from a fire detection system in the Turbine Buildina Condenser Ray (Fire Area TR-FZ-11E) should be granted.
IV.
Accordingly, the Comission has determined pursuant to 10 CFR 50.12(a),
that (1) these exemptions as described in Section III are authorized by law, will not present an undue risk to the public health and safety, and are consistent with the comon defense and security, and (2) special circumstances are present for these exemptions in that application of the reculation in these particular circumstances is not necessary to achieve the underlyino purposes of Appendix R to 10 CFR Part 50. Therefore, the Commission hereby grants the exemption requests identified in Section III above.
Pursuant to 10 CFR 51.32 the Commission has determined that the grantino of these exemptions will not result in any significant environmental impact (50 FR 49633, December 3, 1985).
The Safety Evaluation dated March
, 1986, related to this action andtheabovereferencedsubmittalsbythelicenseeareavailablef[rpublic inspection at the Commission's Public Document Room,1717 H Street, N.W.,
Washington, D.C.
20555, and at the Ocean County Library,,101 Washinaton Street, Toms Rivers, New Jersey 08753.
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. A copy of the Safety Evaluation may be obtained upon written request to the U.S. Nuclear Regulatory Commission, Washington, D.C.
20555, Attention:
Director, Division of BWR Licensing.
These exemotions are effective upon issuance.
Dated at Bethesda, Maryland this24th day of March 1986.
FOR THE NUCLEAR REGULATORY COMMISSION 6
obert M. Bernero, Director Division of BWR Licensing Office of Nuclear Reactor Regulation l
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