ML20217F739

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Requests Addl Info Re Peach Bottom Atomic Power Station Units 2 & 3 Appendix R Exemption Requests
ML20217F739
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 10/14/1999
From:
NRC (Affiliation Not Assigned)
To:
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
References
NUDOCS 9910210054
Download: ML20217F739 (2)


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\\D IW ATTACHMENT PLANT SYSTEMS BRANCH DIVISION OF SYSTEMS SAFETY AND ANALYSIS OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR ADDITIONAL INFORMATION -

PEACH BOTTOM ATOMIC POWER STATION UNITS 2 AND 3 APPENDIX R EXEMPTION REQUESTS 1.

The exemption request states that all cables within the fire areas that are the subject of this exemption request meet flame retardant standards that are "similar" to the flame retardant rating specified in the Institute of Electrical and Electronic Engineers (IEEE)

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Standard 3831974, "lEEE Standard for Type test of Class 1E Electrical Cables Field Splices and Connections for Nuclear Power Generating Stations," and therefore, (1) will not propagate a fire and are self extinguishing, and (2) will not ignite or contribute to fire growth without a flame source. Provide a detailed description of the fire resistive test (s) including the acceptance criteria and any deviations from the IEEE 383 standard, that were used to qualify the cables in the subject fire areas. Provide a technical basis for the conclusion that the subject cables will *not ignite or contribute to fire growth withcut a flame source " ~ this is not part of the testing criteria specified in IEEE 383, 2.

For the fire areas that are the subject of this exemption request that are provided or will be provided with automatic sprinkler protection, verify that sprinkler coverage is provided throughout the fire area and that the subject sprinkler systems are designed, installed and maintained k accordance with the applicable standards published by the National Fire Protection Assodation (NFPA). Provide a technical justification for any deviations from the applicable NFPA standards.

3.

For several fire zones that are iT subject of this request, credit ir., taken for smoke and or heat detection that !s provided in " adjacent areas." Provide a technical justification for the conclusion that the detection provided in " adjacent areas" would be effective at detecting an incipient fire in ther areas / zones that are the subject of this request.

j Provide information on the spacing of these detectors in comparison to the listing / approval for the devices and the ventilation paths that communicate with these

" adjacent areas."

4.

The cost estimate submitted with the request for providing automatic detection estimates a total cost to achieve compilance of $4.9 million. The cost breakdown for each fire arealzone range from approximately $35 to $50 per square foot. Based on Means Reoair and Remodelino Cost Data, typical costs for retrofitting automatic detection in industrial facilities range from $1 to $3 per square foot. Explain the method and assumptions used to prepare the cost estimates submitted with the exemption I)f request.

I 5.

' Perch Bottom Atomic Power Station (PBAPS) has been previously granted

' approximately 20 exemptions from the technical requirements specified in Appendix R to 10 CFR Part 50. Identify any fire areas or fire zones that are the subject of this request that have previously approved exemptions. For those areas / zones with previously 9910210054 9,91014 g &p

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'N approved exemptions, provide an assessmerit of the impact,if any, of the lack of automatic detection on the previously approved exemptions.

6.

The exemption reqtsst references the PBAPS Individual Plant Evaluation for Extemal Events (IPEEE), however the fire area and fire zone desig.1ations in the IPEEE are different than the fire area and fire zone designations used in the subject request.

Provide a cross reference document for the fire areas and fire zones in the iPEEE to those that are the subject of this exemption request to enable the staff to assess the risk i

significance of the request.

7.

For the safe shutdown (SSD) cables in each of the fire zones that are the subject of this request, provide a description of the system (s) associated with the SSD cable (s).

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