ML20212A913

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Exemption from Requirements of 10CFR50,App R,Subsection Iii.G Re Fire Doors for 24 Fire Areas,Charging Pump Cubicles,Control Room,Main Steam Valve Room & Fire Dampers
ML20212A913
Person / Time
Site: Beaver Valley
Issue date: 12/04/1986
From: Novak T
Office of Nuclear Reactor Regulation
To:
DUQUESNE LIGHT CO.
Shared Package
ML20212A836 List:
References
NUDOCS 8612290080
Download: ML20212A913 (7)


Text

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7590-01 9

UNITED STATES OF AMEPICA NUCLEAR REGULAT0DY COMM!SSION In the Matter of i Docket No. 50-334

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DUO'JESPE LIr,4T C0wrANY )

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Beaver Valley Powcr )

Station Unit 1 i EXEMPTION I.

The Duquasne Light Company (DLC, the licensael is the holder of Opere'4ro License No. DPP-66 which authnrizes operation of the Reaver Va' ley Power Statior., Unit 1 The license provides, areng other things, that Peaver Valley Power Station, Unit 1 be subject to all rules, reculations, and Orders o' tFr Commission now or hereafter in effect.

The plant is a pressurized water reactor at the licensee's site located in Shippingport, Pennsylvania.

TI.

On November 19, 1980, the Commission published a revised Section 50.tR and a new Appendix R to 10 CFR Part 50 regarding fire protectio'n features of

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nuclear power plants. The revised Section 50.48 and Appendix R became effective on February 17, 1981.Section III of Appendix R contains 15 subsections, lettered A through 0, each of which specifies reouirements fer a particular aspect of the fire protection features at a nuclear power plant.

One of these subsections, III.G, is the sub.iect o# the licensee's exemption reouests.

Subsection III.G.? of Aopendix R requires that one train of cables and equipment necessary to achieve and maintain hot shutdown conditions be maintained free of fire damage by one of the following means:

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a. Separation of cables and equipment and asteciated nonsafety circuits of redurdant trairs by a fire barrier having a 3-hour rating.

Structural steel forming a part of or sopporting such fire barriers shall be protected to provide fire resistance eouivalent to that reauired of tha barrier,

b. Separatier of cables and equipment and associated nonsa'ety circuits of redundant trains by a horizontal distance of more than ?O feet with no intervening combustibles or fire bazards. In addition, fire detectors and an automatic fire suppressinn syster shall be installed in the fire area,
t. Enclosure of cable and equipment and associated nensafety circuits of ore redundant train in a fire barrier having a 1-hour ratino, in addition, fire detectors and an automatic fire suppression syster- ,

shall be installed in the # ire area.

Subsection III.G.3 of Apnendix R requires that whare Subsection III.r,p s cannot be met, alternative or dedicated shutdown capability should be provided. For areas where alternative or dedicated shutdown is provided, fire detection and a fixed fire suppression system shall also be installed in the area, room, or zone under consideration.

III.

By letter dated June 30, 1982, the licensee requested exemptions fron o

specific technical requirements o' Appendix R to 10 CFD 50. On March 14, 1983, the NRC cranted the requested exemptions. By letter dated Dececher 16, 1983, the licensee reauested additional exemptions for nine fire areas. t!ith the exception of the exemption concerning structural steel, these exemptions were granted on August 30, 1984, 2

4 By letter dated .1enuary 14, 1985 and supplemented by letters dated October 16, 1985, and October 28, 1986, the licensee requested five additinral exemptions. These additional exemption reauests concerned the fire doors, fire dampers, cherging pump cubicles, centrol room, and main steam valve ronm.

These additional exemption recuasts are the sub.iect of this evaluation.

The following list of exenption requests reflects the latest status:

1. Fire decrs for twenty-four fire areas.

Exemptions were requested from the technical requirements o# Section III.G.2.a to the extent that the fire door assemblies in the 3-hour fire-rated barriers that separate these areas are not UL-listed for 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.

Section III.G.2 of Appendix R to 10 CFR 50 contains requirenents for the protection of hot shutdnwn components located within the same fire area. It does not apply to fire area boundaries. Acceptable guidelines for establishment o' # ire area boundaries are set forth in Section D.I.(j) of Apoendix A to RTP APCSB 9.5-1. Therefore, the staff has reviewed the fire doors discussed in the Licensee's request for conformance with Appendix A guidelines.

2. Charging pump cubicles.

An exemption was requested from the technical requirements of Section III.G.2.b to the extent that the redundant charging pumps are not separated fron each other by at least 20 feet of horizontal distanra

  1. ree of intervening combustibles and to the extent that an automatic fire suporession systen is not provided.
3. Control Room (Fire Zones CR-1 and CR-?).

An exemption was reauested from the technical reouirements of Section III.G.P.b to tha extent that redundant trains of emergency diesel generator circuits and power cables are not separated from each other

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_4 by at least 20 feet of horizontal distance free of interveninc combustibles and to the extent that an autcrctic fire suppression systen is not installed.

4. Main Steam Valve Doom (Fire Area PS-li.

An exenotion was requested from the technical requirements o'Section III.G.?.a to the extent that redundant safe shutdown valves are not separated from each other by 3-hour rated fire barriers.

5. Fire Dampers.

Exemptions were requested fron Section III.G.2.a to the extent that it requires separation of cables and equipment and associated nonsafety circuits of redundant trains by a fire barrier having a 3-hour rating.

Section I!I.G.2 of Appendix P contains requirements for fire protection within fire breas. It does not apoly to fire area boundaries. Acceptable guidelines for the establishmert of fire area boundcries are set forth in Section D.I.(j) of Appendix A to BTP APCSB 9.5-1. Therefore, the staff has reviewed the affected # ire danpers for conformance with Appendix A guidelines.

In summary, the exemptions were requested from separating redundant trains by 3-bour fire barriers, or from separating redundant trains by 20 #eet of horizontal distance free of intervening combustibles and providing automatic fire suopression systems as required by Section IIT.G of Appendix P.,

Based on the review of the licensce's analysis, the sta#f ccrcludes tha+-

o The separation of redundant trains of charging pumps by more than pn feet o# horizontal distance free of intervening combustibles in the adjacent corridor and the installation of automatic fire suncression systems would not 'significantly increase the level of fire protection

e in the charoine pump cubicles. Therefore, the requested exemptine can be granted.

o The separation of redurdant trains of emergency diesel generator circuits in Fire Zones CR-1 and CR-2 by more than 20 feet of horizortal distarce free of intervening ennbustibles and the inrtalla-tion of automatic fire suppression systens would net significantly increase the level of fire protection in these fire zones. There-fore, the reauested exemptions can be granted.

o The separation of redundant valves in the main steam valve room by 3-hour fire-rated barriers would not significantly increase the level of fire protection in this araa. Therefore, the requested exemptinrs can be granted.

Ry letter dated October 28, 1986, the licensee provided in#orration relevant to the "r,pecial circumstances" finding reouired by revised 10 CFD 50.12(a) (see 50 FR 50764). The licensee stated that existion and proposed fire protection features at Beaver Valley Power Station Unit 1 accomplished the underlying purpose of the rule. Implementing additional modifications to provide additional suppression systems, detection systems, and fire barriers would recuire 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:

1. Fire doors, $757,000
2. Charging pumo cubicles, $7,770,000
3. Control room, $976,000
4. Main steam valve room, $1,268,000
5. Fire dampers, $1,723,000

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4 The licensee stated that these costs are sioni'icantly in excess o' those reovired to meet the urderiving ourpose o' the rule. The staf# concludrs that "special circumstances" exist 'or the licensee's reonested exemptions in tha+

aoplication of the reculation in these particular circumstances is no' necessary to achieve the underivino nurnoses n' Appendix R to in CFD Dart 60 See 10 CFD 50.1? fail?ilii).

IV.

Accordingly, the Commission has determined that pursuant to 10 CFD 50.12(a), (1) these exemptions as described in Section TT' are authorized tu law and will not present an undue risk to the public health and safetv and are consistent with corron defense and security, and (Oi special circumstances are Dresent #nr the exemptions in that application o' the regulation in these particular circumstances is not necessarv to achieve the under1ving puronsas of Apoendix R to 10 CFD Dart sn. There# ore, the Commission hereby arants the

'ollowino exenotions #or three items mentinned in Section III above # rom the requirements o' Section iTI.G of Aopendix R to 10 CCD Dart 50:

9 Charging Dumo Cubicles, to the extent that redundant Dumos are not separated by a horizontal distance n' more than 20 faet with ro interveninq combustibles or # ire hazards in the adiacent corridor and that automatic fire sunoression systems are not installed pursuant to ITT.G.9.b.

3. Control Room (Fira Zones CD-1 and CD 'l, to the extent that redundant trains of sa#e shutdown cables are not senarated by a horizontal distance n' more than 90 feet with on intervening combustibles or
  1. ire hazards and that autometic # ire suooression systems are not installed pursuant to TTT.G.9.b.

4 Main Steam Valve Room (Fire Area 95-11, to the extent that redundan+

trains o' equipment are not seoarated by 3-hour fire-rated barriers pursuart to III.G.?.a.

Pased on the evaluation, the staff 6150 concludes that item I is an acceptable deviation from the guidelines of Appendix A te BTP APCSR c,g_1:

1. Twenty-four fire arees, to the extent that fire door assemblies separating safe shutdown areas are not 3-hour-rated.

Item 5, fire damper design, is not an scceptable deviation; details may be found in the safety evaluation mentioned below.

Pursuant to 10 CFR 51.3?, the Commission has determined that the grantinc of these exemptions will have no significant impact on the environment (51 FR 43790, December 4,1986).

A copy of the safety evaluation dated November le86, related to this action is available for public inspection at the Commission's Public Document Room,1717 H Street, N.V., Washington, D.C. and at the local public docur.ent room located at B. J. Jones Mcmorial Library, M3 Franklin Avenue, Aliquippa, Pennsylvania 15001. A copy may be obtained upon written recuest addressed to the U.S. Nuclear Pegulatory Commission, Washinaton, D.C. 20555, Attention: Director, Division of PVR Licensing-A.

This Exemption is effecti.ve upon issuance.

l Dated at Bethesda, Maryland this 4th day of December,1986.

l FOR THE NUCLEAR REGULATORY COMMISSION Thomas M. Novak, Actino Director l Division of PWR Licensino-A l Office of Nuclear Reactor Regulation e

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