ML20212M775

Forwards Addl Info Supporting Exemption Requests 7-10 & 12-14 from Requirements of 10CFR50,App R.Strict Compliance W/App R Would Impose Unwarranted Expenditure W/O Increase in Plant Safety

ML20212M775
Person / Time
Site:	Yankee Rowe
Issue date:	08/22/1986
From:	Papanic G YANKEE ATOMIC ELECTRIC CO.
To:	Mckenna E Office of Nuclear Reactor Regulation
References
DCC-86-117, FYR-86-077, FYR-86-77, NUDOCS 8608270143
Download: ML20212M775 (4)

Text

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August 22, 1986 FYR 86-077 United' States Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Eileen M. McKenna, Project Manager PWR Project Directorate No. 1 Division of PWR Licensing-A

References:

(a) License No. DPR-3 (Docket No. 50-29)

(b) Letter, YAEC to USNRC dated December 28, 1984 (c) Letter, YAEC to USNRC dated April 30, 1985 (d) Letter, YAEC to USNRC dated November 7, 1985

Subject:

Appendix R Exemptions

Dear Ms. McKenna:

Yankee submitted in Reference (d) its revised list of exemptions to Appendix R for Yankee Nuclear Power Station. Attached to this letter is information that supplements our exemption requests to address the changes to 10CFR50.12(a)(2), special circumstances. The attachment identifies that all of Yankee's exemption requests involve situations in which our present design meets the underlying purpose of Appendix R. Thus, strict compliance with Appendix R would require the expenditure of engineering and construction resources as well as the associated capital costs which would represent an unwarranted burden on our resources without a corresponding significant increase in plant safety.

We trust that you will find this information satisfactory, however, should you have any questions regarding this matter, please contact us.

Very truly yours, YANKEE ATOMIC ELECTRIC COMPANY Georg Japanic, .

Senior Project Engineer - Licensing GP/kmc

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. ATTACletENT The following information is provided to supplement the exemption requests to Appendix R of 10CFR50 submitted by Yankee in letters, dated December 28, 1984, April 30, 1985, and November 7, 1985. This information is being provided to show special circumstances per 10CFR50.12(a)(2)(ii). Each exemption request will be discussed separately. Note that the exemption request numbers apply only to those remaining. All others have been deleted.

Exemption Request No. 7: Exemption to 10CFR50 Appendix R Section III.G.3 for Fixed Fire Suppression in the Diesel Generator Building.

The installation of fixed fire suppression throughout the Diesel Generator Building is not necessary to achieve the underlying purpose of the rule.

Section III.G.3 requires fixed fire suppression in the area to minimize fire damage to equipment required for hot shutdown due to fire spreading throughout the area. The section of the building that is not protected by a fixed suppression system has a fire loading that is just above that which is classified as a low-fire loading. The combustibles are also distributed such that a fire in one section will not propagate throughout the area. Therefore, fixed fire suppression is not required to prevent the spread of fire throughout the area.

Exemption Request No. 8: Exemption to 10CFR50 Appendix R Section III.G.2.d for Separation Between the Power Operated Relief Valve and Block Valve.

Horizontal separation of 20 feet without intervening combustibles between the electrical blisters containing the power cables to the power operated relief valve and its motor-operated block valve is not necessary to achieve the underlying purpose of the rule.Section III.G.2.d requires 20 feet of horizontal separation without intervening combustibles to prevent damage to redundant circuits from a single fire. These blisters are totally enclosed heavy gage metal boxes welded onto the inside of the vapor container steel shell. They are separated by a horizontal distance of 12 feet, and are not connected. The area between them contains no combustible material.

Therefore, a 20-foot separation is not needed to prevent damage to both cables from a single fire.

Exemption Request No. 9: Exemption to 10CFR50 Appendix R Section III.G.2.d for Separation Between the Power Operated Relief Valve and Block Valve.

Horizontal separation of 20 feet without intervening combustibles between the cables to the power operated relief valve and its motor-operated block valve inside the pressurizer cubicle is not necessary to achieve the underlying l purpose of the rule.Section III.G.2.d requires 20 feet of horizontal separation without intervening combustibles to prevent damage to redundant circuits from a single fire. The combustible loading in this area is not sufficient to support a fire capable of damaging both cables. Therefore, a 20-foot separation is not needed to prevent damage to both cables from a f single fire.

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. ATTACHMENT (Continued)

Exemption Request No. 10: Exemption to 10CFR50 Appendix R Section III.C.2.d for Separation Between Pressurizer Level Transmitters.

Horizontal _ separation of 20 feet without intervening combustibles between the

. two pressurizer level transmitters at the bottom of the pressurizer cubicle is i not necessary to achieve the underlying purpose of the rule.Section III.G.2.d requires 20 feet of horizontal separation without intervening combustibles to prevent damage to redundant circuits from a single fire. The combustible loading in this area is not sufficient to support a fire capable of damaging both cables. Therefore, a 20-foot separation is not needed to prevent damage to both cables from a single fire.

Exemption Request No. 12: Exemption to 10CFR50 Appendix R Section III.G.3 for Fixed Fire Suppression and Fire Detection in the Primary Auxiliary Building.

The installation of fixed fire suppression and fire detection throughout the Primary Auxiliary Building is not necessary to achieve the underlying purpose

> of the rule.Section III.G.3 requires fixed fire suppression and fire j- detection in the area to minimize fire damage to equipment required for hot shutdown due to fire spreading throughout the area. The Primary Auxiliary

, Building has a very low combustible loading. The few areas where combustible  !

materials are concentrated, such that they may support combustion, have fire detection provided. Therefore, fixed fire suppression and fire detection are not required throughout the Primary Auxiliary Building to prevent the spread 3

of fire.

1 Exemption Request No. 13: Exemption to 10CFR50 Appendix R Section III.G.3 for Fixed Fire Suppression and Fire Detection in the Turbine Building.

i l Ihe' installation of fixed fire suppression and fire detection throughout the Turbine Building is not necessary to achieve the underlying purpose of the rule.Section III.G.3 requires fixed fire suppression and fire detection in the area to_ minimize fire damage to equipment required for hot shutdown due to fire spreading throughout the area. The turbine operating floor and the Water Treatment Room are the only areas without fixed fire suppression and detection throughout. These areas are situated such that a fire in either area cannot impact any area in the Turbine Building containing hot shutdown equipment.

All areas of the Turbine Building containing hot shutdown equipment are protected by fixed fire suppression and fire detection via system flow alarms. Therefore, fixed fire suppression and fire detection are not needed in these areas to prevent the spread of fire to hot shutdown equipment in the Turbine Building.

Exemption Request No. 14: Exemption to 10CFR50 Appendix R Section III.G.2.c for one-hour Fire Barrier Between the Diesel Generator Building and Manhole i No. 3.

The installation of a one-hour fire barrier material over the manhole cover into Manhole No. 3 is not necessary to achieve the underlying purpose of the rule.Section III.G.2.c requires a one-hour fire barrier between redundant circuits to prevent fire damage to these circuits from a single fire. Manhole No. 3 is approximately two feet below the Diesel Generator Building floor.

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.. ATTACHMENT (Continued)

The 1/2" thick steel plate cover over the entrance is raised about 10 inches above the top of the manhole. Approximately 14 inches over the cover is a 3/8 inch thick solid steel plate which forms part of the Diesel Generator Building floor. This configuration provides an equivalent level of protection to prevent the spread of fire between the Diesel Generator Building and Manhole No. 3. Therefore, a one-hour fire barrier is not required to prevent the spread of fire between the two areas.

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